San Mateo City Council
January 24, 2023

CITY OF SAN MATEO
City Council Special Meeting
January 24, 2023
6:00 PM
City Hall Council Chamber
Entrance is on O’Farrell Street

COUNCIL MEMBERS
Amourence Lee, Mayor
Lisa Diaz Nash, Deputy Mayor
Rich Hedges
Adam Loraine
Rob Newsom Jr.

AGENDA
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January 24, 2023
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CALL TO ORDER
Roll Call

CEREMONIAL

1. Human Trafficking Prevention Month – Proclamation

NEW BUSINESS
The public will have an opportunity to comment during the consideration of these items.

2. General Plan Amendment to Adopt the City of San Mateo's Housing Element for 2023-2031 Adopt a Resolution to approve a General Plan Amendment to update the Housing Element for the Sixth Housing Cycle (2023-2031) that is compliant with State law, provides a plan for at least 7,015 new housing units and affirmatively furthers fair housing, and determine that adoption of the Housing Element is exempt from review under the California Environmental Quality Act, based on the listed findings included in Attachment 3.

ADJOURNMENT
----------------------------------------------------------------------------------------------------------------------------- AGENDAS:

Agendas and material are posted on the City’s website on the Friday preceding each Council Meeting and can be viewed on the City's website at
www.cityofsanmateo.org
. Any supplemental material distributed to the Council after the posting of the agenda will be made part of the official record.

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PUBLIC COMMENTS/REQUEST TO SPEAK
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CITY OF SAN MATEO
Agenda Report
City Hall
330 W. 20th Avenue
San Mateo CA 94403
www.cityofsanmateo.org
Agenda Number: 2 Section Name: NEW BUSINESS Account Number: 25-3112 File ID: 23-7124 TO: City Council
FROM: Drew Corbett, City Manager
PREPARED BY: Community Development Department
MEETING DATE: January 24, 2023
SUBJECT:

General Plan Amendment to Adopt the City of San Mateo's Housing Element for 2023-2031 RECOMMENDATION:

Adopt a Resolution to approve a General Plan Amendment to update the Housing Element for the Sixth Housing Cycle (2023-2031) that is compliant with State law, provides a plan for at least 7,015 new housing units and affirmatively furthers fair housing, and determine that adoption of the Housing Element is exempt from review under the California Environmental Quality Act, based on the listed findings included in Attachment 3.

BACKGROUND:

The City of San Mateo (City) has prepared a draft update to the Housing Element of the General Plan to affirmatively further fair housing and accommodate the City’s 7,015-unit Regional Housing Needs Allocation (RHNA) for the 2023-2031 Housing Element cycle. The content of the draft 2023-2031 Housing Element is structured for consistency with the requirements set forth in State law. In addition to responding to requirements of State law, the Housing Element also demonstrates the City’s strategy to meeting its housing needs as determined by local growth projections through identification of sites as well as policies and programs that promote housing development in the City. Public review and input have been a critical component of this Sixth Cycle Housing Element Update, as further described in the Public Outreach Summary section below.

This staff report provides a summary of the Housing Element requirements, an overview of the status of the City of San Mateo’s draft Housing Element, the comments provided to the City by the California Department of Housing and Community Development (HCD) on the first 90-day review of the draft, and how the City has responded to HCD’s comments, as well as how the draft element substantially complies with the Housing Element law (Government Code sections 65580 – 65589.11) for purposes of adoption.

Since 1969, California has required that all local governments (cities and counties) adequately plan to meet the housing needs of their community. California’s local governments meet this requirement by adopting housing elements, which are generally updated every eight years. The housing element is a "chapter” of a city’s General Plan, which is also required by State law. However, it is the only element of the General Plan subject to specific requirements for content, and it must be certified by HCD. State funding programs for transportation, infrastructure, and housing often require or consider a local jurisdiction’s compliance with housing element law. In addition, non-compliance with housing element requirements and targets could potentially affect a local jurisdiction’s ability to impose local zoning and land use controls over housing development and receive certain types of State funding and grants.

For the upcoming eight-year housing cycle (2023-2031), HCD has identified the nine-county Bay Area region’s housing need to be 441,176 units, with this number broken down into four income categories, from very low-income households (which includes extremely low) to market rate housing. This Regional Housing Needs Determination (RHND) is based on

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population projections produced by the California Department of Finance (DOF) as well as adjustments that incorporate the region’s existing housing need. The City of San Mateo’s Regional Housing Needs Allocation (RHNA) for this housing cycle is 7,015 new housing units distributed across the four income groups as outlined in Table 1.

Table 1: San Mateo RHNA Targets Summary
Income Category Very Low
50% AMI
Low
80% AMI
Moderate
120% AMI
Above
Market Rate Total
2023-31 Allocation 1,777 1,023 1,175 3,040 7,015
Table Source: Housing Element Cycle 6 RHNA Allocation

The City’s draft Housing Element identifies how the City can accommodate its RHNA of 7,015 new units over the next eight years, and establishes goals, policies and programs to help address the City’s current and future housing needs. A proposed resolution for the City Council to adopt a General Plan Amendment to update the Housing Element for the Sixth Housing Cycle (2023-2031) is included as Attachment 1. The resolution concludes that the proposed Housing Element is compliant with State law, provides a plan for at least 7,015 new housing units and affirmatively furthers fair housing, and determines that it is exempt from review under the California Environmental Quality Act, based on the listed findings. The resolution that memorializes the Planning Commission’s recommendation to the City Council is included as Attachment 2.

The Planning Commission’s resolution is attached in draft form, pending formal approval at a future Planning Commission meeting.

The revised draft Housing Element (Attachment 5) includes the following sections:

1.Introduction and Background - Includes the history of San Mateo, the legislative framework for housing, consistency and relationship with other General Plan Elements, and a discussion on water/sewer capacity.

2.Housing Needs and Sites Inventory - Describes the City’s housing needs summary, RHNA allocation, sites inventory methodology, an overview of the adequate sites list and focused discussions on various areas that will support increased housing production (i.e. Accessory Dwelling Units, City Properties and Projects, the General Plan Update and Missing Middle Housing). A capacity of up to 9,934 housing units could be accommodated on the properties listed in the Sites Inventory under the City’s existing land use and zoning designations.

3.Other Required Housing Element Components - Provides an overview of the City’s governmental and non- governmental constraints to meet its housing goals, summarizes existing and potential housing resources, and describes the climate change context and energy conservation requirements for new housing developments.

4. Public Participation - Summarizes the City’s efforts to engage with the community, including under-represented groups, key accomplishments of the outreach efforts over the past 18 months, critical take-aways from the community input, and how this input was incorporated into the Housing Element’s goals, policies and programs.

5.Affirmatively Furthering Fair Housing (AFFH) Assessment - Provides an overview of AFFH requirements, a history of segregation in the region, and an assessment of the San Mateo’s AFFH issues with primary findings, contributing factors, and the AFFH action plan.

6.Housing Plan - Describes the policies, programs, implementing actions, and timelines associated with the City’s five goals for production and preservation of housing, protection of its residents, promotion of education and outreach, and affirmatively furthering fair housing.

7.Quantified Objectives - Includes an estimate of actual housing units that could be achieved via preservation and production given available resources as well as projected pipeline projects anticipated for completion over the eight-year housing cycle.

8.Review of Prior Housing Element - Highlights key accomplishments of, as well as challenges and opportunities learned from, the previous Housing Element and housing cycle (2015-2022).

The Housing Element also includes seven technical appendices (Attachments 6 to 12) that include detailed analysis and information that support the findings and conclusions in the main document.

Goals, Policies and Programs

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Housing needs in the City are significant, especially for very low-, low-, and moderate-income households. These needs affect the entire community, but disproportionately impact underrepresented, special needs, and ethnically diverse populations. Therefore, the Housing Element specifically focuses on the need to affirmatively further access to housing and promote fair housing policies and programs. Over the past two years, staff conducted extensive community outreach, including 19 public meetings, four surveys, and numerous pop-up events, to inform the approach for addressing these needs in the Housing Element.

Based on the City’s RHNA allocation, constraints analysis, AFFH issues, and input from the community, consultant team, and decisionmakers, the Housing Element articulates five goals to shape policies and programs over the next eight years as follows:

Goal 1 – Production. Facilitate and support the production of new housing at all income levels, but especially affordable housing. Twenty-one policies and 37 implementing actions have been identified to support this goal. Goal 2 – Preservation. Preserve existing housing that is affordable to lower- and middle-income residents. Six policies with 10 implementing actions have been identified to support this goal. Goal 3 – Protection. Protect current residents to prevent displacement. Seven policies with 16 implementing actions have been identified to support this goal.
Goal 4 – Promotion. Promote social resilience through public education and community outreach to make information more available and accessible. Five policies with 10 implementing actions have been identified to support this goal.
Goal 5 – Affirmatively Furthering Fair Housing. Address the issues of fair housing, equity and access while reinforcing the objective that affirmatively furthering fair housing is both a stand-alone priority and decisively inseparable from achieving the Housing Element’s other goals. Fourteen policies with 16 quantified objectives have been identified to support this goal.

To support attainment of the five goals, each policy identifies the lead department, funding source if known, target work plan or program measure, implementation action(s), and a timeline, to provide an adequate level of specificity and accountability. Individual action items associated with some of these policies and programs account for City priorities and resources over the eight-year cycle and will be considered independently for adoption by Council through appropriate community engagement and environmental review.

Sites Inventory and RHNA Strategy
The purpose of the adequate sites list (Sites Inventory) is to evaluate whether there are sufficient sites with appropriate zoning capacity (density) to meet the City’s RHNA goal. The Sites Inventory analysis was established based on development trends in the City over the last 5-10 years of consolidation and redevelopment of under-utilized sites, expressed interest or applications from developers and letters from property owners. However, it does not dictate where residential development will actually occur or what owners must do with their property.

The City used a conservative methodology to estimate the development potential of each property included on the Sites Inventory based on the criteria established by State law, development/redevelopment feasibility, site constraints, zoned capacity versus real capacity, prior project history, and developer/owner interest. The Sites Inventory in Appendix C of the Housing Element (Attachment 8) was updated to create site specific data sheets for some of the larger sites to adequately demonstrate their suitability for housing development and to provide additional information and analysis to support inclusion on the Sites Inventory. Based on this analysis, the City has capacity for potential development of up to 9,934 housing units, or 142% of the City’s RHNA. Table 2, on the following page, provides a summary breakdown of the properties included on the Sites Inventory by income category and opportunity area.

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Table 2 - San Mateo Sites Inventory Breakdown
Housing Opportunity
Areas Total Units Very Low Low Moderate Above Mod. Pipeline Bridgepointe 1,105 220 168 162 555 -
Hillsdale Station South 2,593 627 379 407 1,180 18
101/92 Interchange 2,452 455 221 248 1,528 961
Other Sites 3,784 570 473 500 2,012 1,936
ADUs 440 22 132 220 66 -
Totals 9,934 1,894 1,373 1,317 5,350 2,915
RHNA 7,015 1,777 1,023 1,175 3,040 -
Buffer 2,919
(42%)
177
(7%)
350
(34%)
142
(12%)
2,310
(76%) -
Note: The pipeline project numbers are based on information as of December 30, 2022. Number of pipeline units may change over time based on project applications.

Most of the properties listed on the Sites Inventory are located within one of the ten General Plan Study Areas that are being evaluated for change and increased density as part of the City’s General Plan Update process. The draft land use map increases land use densities within the Study Areas from 35-50 units per acre to 50-200 units per acre and adds capacity for up to 21,900 new housing units. Adoption of the updated General Plan, which is targeted for the end of 2023, would increase density on most of the housing sites and significantly increase development capacity and the City’s RHNA buffer.

Affirmatively Furthering Fair Housing
Affirmatively Furthering Fair Housing, or AFFH, means taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and fosters inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. California law, as established by AB 686, requires all public agencies to “administer programs and activities relating to housing and community development in a manner that affirmatively furthers fair housing, and take no action inconsistent with this obligation.” The law also requires housing elements to include an analysis of fair housing outreach and capacity, integration and segregation, access to opportunity, disparate housing needs, and current fair housing practices.

For the City of San Mateo, a Fair Housing Assessment prepared by 21 Elements, a countywide jurisdictional collaborative, describes fair housing enforcement and outreach capacity, integration and segregation, access to opportunity and disparate housing needs as contributing factors that needed to be addressed in the City’s fair housing action plan. In response to this analysis, as well as community input, an Affirmatively Furthering Fair Housing Action Plan, which details how the City proposes to respond to the factors contributing to the fair housing challenges identified in this analysis, was developed. The Action Plan is included in Appendix D of the Housing Element (Attachment 9) and the policies and programs to implement the Action Plan are included in the Housing Plan under Goal 5.

The updated draft of the Housing Element released on December 30, 2022 includes an extensive new narrative on a variety of topics in response to HCD comments, including more information on the history of the City’s development; the prioritization of contributing factors; detail on fair housing legal cases and inquiries; data on changes in racial composition in the City; enhanced discussion of special needs groups; and greater analysis of Racially/Ethnically Concentrated Area of Poverty (R/ECAPs) and Racially Concentrated Areas of Affluence (RCAAs). The additional analysis confirmed the conclusions of the original fair housing analysis and did not present new information that would trigger additional AFFH

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programs.

Public Outreach Summary
To support the preparation of the Draft Housing Element, a robust and inclusive community outreach and engagement process was initiated in the summer of 2021 and has been ongoing for the past 18 months. During this time, the City has conducted 19 public and community meetings and workshops, five intercept/pop-up events, four surveys, and conducted additional community engagement through partnership with 21 Elements. This is in addition to the many General Plan Update related public outreach activities during this period that have also included significant discussions around housing related topics. The outreach efforts have included an emphasis on connecting with community members for whom English was not spoken at home, renters, those under 45 years of age, low-income and very low-income households, people with disabilities, seniors, single female heads of household, people experiencing homelessness, and those from under- represented neighborhoods. Themes that were incorporated into the Housing Plan included production of more missing middle housing, more outreach and education to tenants and landlords, streamlining and simplifying development review and permitting processes, establishing programs to address fair housing and equity, and ensuring that new housing is sustainable and addresses climate change. All public comments and input received as part of the Housing Element outreach and engagement activities are included in Appendix F – Public Participation (Attachment 11).

Summary of Public Comments Received
Since the publication of the Revised Draft Housing Element on December 30, 2022, the City has received 18 written comments from individuals and organizations, including the Housing Action Coalition and the Sierra Club Loma Prieta Chapter. The comments expressed concerns about the feasibility of the properties on the sites inventory, concerns about too much housing being allowed as well as concerns about the location of new housing construction. In addition, several comments expressed support for the adoption of the Housing Element. During the January 12, 2023 Planning Commission public hearing, nine speakers provided comments. Speakers included representatives from One San Mateo, the Housing Action Coalition and the Carpenters Union. Comments expressed included concerns about the timing to implement Policies H3.4 and H5.4.1 to expand tenant protections, adding a policy about hiring local union labor and the need to identify more properties for the sites inventory. Written public comments are included as Appendix G – Public Review Period Comments (Attachment 12).

Revisions in Response to Public Comments
In response to the public comments received, staff is recommending that the Housing Element be updated to address some of the issues identified and to provide further clarification. The recommended revisions are as follows:
Update Policy H1.2 (Utilize Public Funding and Properties for New Affordable Housing) to include two new programs:
oSupport new affordable housing on the City owned parking lot at 4th and Railroad as part of the public- private partnership (Bespoke project)
oSupport affordable housing development on the City owned property at 4142 El Camino Real (0.32 acres) Update Policy H1.7 (Update Zoning Code Development Standards) to include a new program:
oAmend the Zoning Code to make residential uses allowed in C2, C3, E1 and E2 for non-R Overlay areas without a special use permit as currently required
Add a supplemental table in Appendix C to clarify and consolidate evidence to support development feasibility and realistic capacity (density) of each site in the Sites Inventory

It should also be noted that the City owned parking lot at 5th and B (adjacent to Ravioli House) is not on the Sites Inventory and not anticipated for development this cycle.

Planning Commission Review and Recommendation
During the January 12, 2023 Planning Commission public hearing, the Commission provided input on the Revised Draft Housing Element. The Commission expressed concerns about the sites inventory and methodology, including that the realistic capacity was not calculated in accordance with HCD guidance and that substantial evidence does not support housing development feasibility. In addition, the Commission expressed concerns that the Goals, Policies and Programs have not been adequately revised to address HCD’s comments, do not provide a significant commitment for

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implementation and do not fully meet AFFH requirements. The Commission voted 3-0 (with two commissioners absent) to recommend that the City Council not adopt the Revised Draft Housing Element for the Sixth Housing Cycle (2023-2031) based on the concerns outlined above and as further described in the Planning Commission Resolution, which is included as Attachment 2.

HCD Comments and Housing Element Revisions
Preparation of the City’s Housing Element initially started in 2020, with the community engagement process starting in the summer of 2021. The draft Housing Element was published at the beginning of April 2022, with the 30-day Public Comment Period between April 6, 2022 and May 6, 2022. The draft was reviewed by the Planning Commission at public meetings on April 26, 2022 and May 3, 2022, with City Council review and direction provided at a public meeting on May 23, 2022.

Staff revised the draft Housing Element based on Council’s direction and on July 1, 2022, the draft 2023-2031 Housing Element was submitted to HCD for its first review (90-day review period). HCD completed its review and provided a first review letter with their feedback and comments on September 28, 2022 (Attachment 4).

On November 7, 2022, the City Council held a study session to review and discuss HCD’s comments on the draft Housing Element and provide staff with direction. HCD provided several comments which had the potential to result in significant changes to the goals, policies and programs that Council has previously reviewed and provided feedback. Council directed staff to take the necessary steps to strengthen the language in the Housing Element to address HCD’s comments. Staff responded to HCD’s comments and published a revised Housing Element on December 30, 2022, for a 10-day public review period, while only seven days are statutorily required.

The summary below highlights some of edits by topic area that were requested by HCD as part of their review and a description of the updates made to the Housing Element to address these comments.

1. Affirmatively Furthering Fair Housing:
a. Appendix D of the Housing Element has been updated as follows:
i. Includes more information on the history of the City’s development and the prioritization of contributing factors.
ii. Provides more detail on fair housing legal cases and inquiries. iii. Expands on data on changes in racial composition in the City. iv. Includes an enhanced discussion of special needs groups. v. Provides a greater analysis of R/ECAPs and RCAAs.

2. Other Housing Needs:
a. Appendix A of the Housing Element includes more information regarding extremely low-income households, overpaying households and housing costs
b. A section was added to highlight the need for missing middle housing and identifies the various policies and program measures that address this issue.

3. Housing Sites Inventory:
a. Includes more detail on pipeline projects that are under review, approved, or being constructed. b. Developed a more detailed narrative by explaining each site individually and outlines basis for the realistic capacity calculation.
c. Added information regarding affordable housing projects in the pipeline and proposed on City land through a public private partnership effort.
d. Updated narrative and methodology section for development on nonvacant sites and added background information on age/size of building demolished for recently entitled development, existing versus allowable floor area, etc.
e. As noted above, the Sites Inventory has been updated to remove three sites (development feasibility during this cycle), add two new sites (pipeline projects) and adjusted the realistic capacity of two sites (Hillsdale Mall and Borel Square) and ADU production during this cycle. As a result, the Sites Inventory now has identified sites with a capacity to develop up to 9,934 new units, or 142% of the City’s RHNA.

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f. Updated the Sites Inventory with additional detailed descriptions of existing uses and maximum redevelopment potential, including referencing developer/owner interest and potential expanded capacity through the General Plan Update process, expected to be completed in 2024. g. Added a new policy for outreach to owners of properties on the Sites Inventory.

4. Zoning:
a. Reviewed existing requirements and constraints analysis against State law based on HCD’s comments. b. Added AB 139 discussion and program to address emergency shelter parking requirements. c. Policy H3.7 was updated to allow Low Barrier Navigation Centers in areas consistent with Government Code section 65660.
d. Reviewed existing Zoning requirements for Single Room Occupancy (SRO) units, Manufactured Housing, and Accessory Dwelling Units (ADUs), and updated draft program language where appropriate.

5. Constraints Analysis:
a. Updated Appendix B to add more information on the City’s land use controls and how they do or do not impact housing development to tie them to the proposed programs. b. Updated the constraints analysis to evaluate open space requirements in the R-3 zone and design review constraints and amended policies H1.8 and H1.13 accordingly. c. Added additional information about the General Plan Update (GPU) and how Measure Y will be addressed as part of the GPU adoption process in 2023/24.

6. Goals, Policies and Programs:
a. Updated and clarified timelines for various programs. b. Implementation timelines were revised for various programs per HCD’s comments, with many of the implementation timelines moved up to the front end of the Housing Cycle. c. Added two new policies to Goal H1 (Production) and one new policy to Goal H4 (Promotion). Many of the policies and program measures under all five goals were revised to provide additional clarity and to address constraints.

The draft resolution for the City Council’s adoption of the Housing Element (Attachment 1) demonstrates how the Housing Element conforms with State law. Specifically, Exhibit A shows how the Housing Element conforms with each applicable provision in the State’s housing element statutes, and Exhibit B provides a response to each of HCD’s comments.

Findings for Adoption
The following section outlines the required findings for adoption of the updated Housing Element and HCD’s required changes, including information on the City’s response. As required by California Government Code 65354 and Municipal Code Section 27.06.040(b), the Planning Commission shall make a recommendation to the City Council for all General Plan Amendments. As described above, the Planning Commission made a recommendation for the City Council to not adopt the Housing Element. Staff recommends that the City Council adopt the 2023-2031 Housing Element based on the following key findings and as further expanded upon in the proposed City Council resolution. Under Government Code 65356, a recommendation for approval must be made by a majority of the total membership of the City Council (three votes).

1. The 2023-2031 Housing Element, as updated, is internally consistent with the City’s 2030 General Plan.

2. State Law (Government Code Sections 65580-65589.11) – To be in substantial compliance with State law, a housing element must contain all of the elements mandated by State housing element law (See Fonseca v. City of Gilroy (2007) 148 Cal.App.4th 1174, 1191-92). Exhibit A in the proposed City Council resolution, Conformance of Housing Element with State Law Requirements, demonstrates that the City of San Mateo’s 2023-2031 Housing Element contains each of the elements mandated by State law.

3. HCD Review Letter – Outstanding Comments – Pursuant to Government Code Section 65585(b), HCD reviewed the draft Housing Element and reported the results of its review. HCD’s comment letter requested additional background information and further analysis in several areas of the Housing Element, including the feasibility of future housing sites, fair housing policy, housing goals, policies, and programs and removing constraints to building housing. HCD’s comments and the City’s responses to each comment are included in Exhibit B of the proposed City Council resolution.

NEXT STEPS:

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The following summarizes the next steps and anticipated timeline for approval and certification of the Housing Element:

January 24, 2023 City Council review and adoption of Housing Element January 31, 2023 Submit adopted Housing Element to HCD for certification

Following City Council adoption, the Housing Element will be submitted to HCD for final certification. Housing elements are required to comply with current State housing element law for the sixth housing cycle (2023-2031) on the established due date, which is January 31, 2023 for the Bay Area region. If a sixth cycle housing element has not been locally adopted by this deadline, the housing element would likely be deemed out of compliance with State law by HCD. Until recently, it was a widely held assumption across the state that the 120-day grace period outlined in State law would apply to housing elements still being reviewed by HCD or being updated by local jurisdictions in response to HCD comments. However, HCD has recently taken the position that the grace period does not apply beyond the January 31, 2023 deadline, and any jurisdiction without an adopted sixth cycle housing element would be deemed out of compliance.

It should be noted that in some circumstances, HCD certification is not required for a housing element to be found substantially compliant with State law. If HCD determines that a housing element does not substantially comply with State law, a jurisdiction must either revise the document to implement HCD requirements or adopt its own findings explaining why it complies with the statute despite HCD’s comments. 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. City staff believes that the revised draft Housing Element implements all changes requested by HCD and is consistent with State law, as extensively documented in the proposed City Council resolution.

In the Sixth Housing Element cycle, jurisdictions face a number of new consequences for not having a certified Housing Element. Under legislation enacted in recent years, if a city does not comply with State housing law, HCD may refer the city to the Attorney General. Significant fines may be imposed if a city does not comply with a court order for one year. A court finding a housing element inadequate may limit local land use decision-making authority until the jurisdiction brings its housing element into compliance, or local governments may lose the right to deny certain projects due to the “Builder’s Remedy” provision in the Housing Accountability Act (HAA). According to the HAA, if a jurisdiction has a noncompliant housing element, the city or county must approve any housing development project, regardless of the local General Plan and Zoning requirements.

Conversely, an HCD-certified housing element makes cities eligible for, or with higher priority for, numerous sources of funding, such as the Permanent Local Housing Allocation, Affordable Housing and Sustainable Communities Grants, SB 1 Planning Grants, CalHOME Program Grants, Infill Infrastructure Grants, Pro-Housing Design funding, Local Housing Trust Funds, and Regional Transportation Funds (such as MTC’s OneBayArea Grants).

As such, staff recommends that the City Council adopt the Housing Element in January, which can then be submitted to HCD by January 31, 2023. After the Planning Commission made their recommendation, there was a required 10-day public noticing period between the Planning Commission public hearing and the City Council public hearing, which further added to the Housing Element adoption timeline. Therefore, staff recommends that the Council adopt the resolution (Attachment 1) regarding the adoption of the Housing Element at the January 24, 2023 public hearing.

BUDGET IMPACT:

Although there are no direct budgetary impacts to taking this action, the preparation of the 2023-2031 Housing Element document has involved a significant amount of City staff time and the use of consultants. The preparation of the Housing Element is primarily funded by the City’s Advanced Planning Fund (Fund 25, through a fee collected with each building permit), with some State grants funds also being used for outreach and environmental review. To implement the Housing Element, a funding source is identified with each policy, and the Community Development Department will identify and allocate appropriate staff and budgetary resources to complete each effort.

ENVIRONMENTAL DETERMINATION:

As described in Attachment 3, this Housing Element is not a project subject to CEQA, because it can be seen with certainty

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that it will not cause a physical change in the environment, as there are no rezonings proposed (Public Resources Code Section 21065). The proposed adoption of the 2023-2031 Housing Element is considered exempt under the “common sense” exemption under state CEQA Guidelines Section 15061(b)(3) because the project involves policies, programs, and actions to meet the City’s RHNA and AFFH goals that would not have any potential for causing a significant effect on the environment, and identifying programs and actions that could remove constraints and promote affordable housing development. Because the City does not have to rezone any sites or make any physical improvements to adopt the Housing Element, it can be seen with certainty that there is no possibility that the Housing Element would have a significant effect on the environment. Thus, the General Plan Amendment to update the Housing Element for the Sixth Housing Cycle (2023-2031) is exempt from CEQA under the common sense exemption. Preparation of documentation to support this CEQA determination has been provided (Attachment 3) for consideration of the Housing Element by the Planning Commission and City Council for adoption.

NOTICE PROVIDED
All meeting noticing requirements were met. A public hearing notice for consideration of the Draft Housing Element at the January 12, 2022 Planning Commission special meeting was published in the San Mateo Daily Journal on December 30, 2022, January 4, 2023 and January 9, 2023. In addition, a public hearing notice for consideration of adoption of the 2023- 2031 Housing Element at the January 24, 2023 City Council special meeting was published in the San Mateo Daily Journal on January 14, 2023. Notice of updated Housing Element availability was displayed on the home page of the City’s website, posted to the City’s Housing Element website and a physical copy was made available at City Hall and the Main Library.

Notice of updated Housing Element publication was also included in the City’s E-Newsletter and sent out to various email distribution lists, including the Housing Policy, Housing Element and General Plan Update email distribution lists.

PUBLIC COMMENTS:

Appendix F in the Housing Element (Attachment 11) includes community feedback, communications and documentation that support the Housing Element preparation. All public comments submitted since the publication of the Revised Draft Housing Element on December 30, 2022 are included in Appendix G (Attachment 12), which also includes all comments received during the initial 30-day public review period (April 6, 2022 to May 6, 2022). Public comments submitted after the publication of the January 24, 2023 meeting agenda packet are posted to this item on the City’s Public Meeting Portal as “Post Packet Public Comments.”

ATTACHMENTS
Att 1 – Proposed Resolution
Exhibit A – Compliance with Statutory Provisions
Exhibit B – Revisions in Response to HCD Comment Letter Att 2 – Draft Planning Commission Resolution
Att 3 – Housing Element CEQA Determination
Att 4 – HCD First Review Comment Letter
Att 5 – 2023-2031 San Mateo Housing Element (Updated)
Att 6 – Appendix A - Needs Analysis
Att 7 – Appendix B - Constraints Analysis
Att 8 – Appendix C - Housing Resources and Sites Inventory Att 9 – Appendix D - Affirmatively Furthering Fair Housing Att 10 – Appendix E - Review of Prior Housing Element
Att 11 – Appendix F - Public Participation
Att 12 – Appendix G - Public Review Period Comments
Att 13 - Supplemental Table HCD Sites Inventory List ADDED 2:05PM ON 1/24/2023

STAFF CONTACT
Eloiza Murillo-Garcia, Housing Manager
[email protected]
(650) 522-7223

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CITY OF SAN MATEO
RESOLUTION NO. ____ (2023)

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN MATEO, ADOPTING A GENERAL PLAN AMENDMENT TO REPEAL THE 2015-2022 HOUSING ELEMENT AND ADOPT THE HOUSING ELEMENT OF THE GENERAL PLAN FOR THE PERIOD OF 2023-2031, IN ORDER TO AFFIRMATIVELY FURTHER FAIR HOUSING AND TO COMPLY

WITH THE STATE HOUSING ELEMENT LAW
WHEREAS, the legislature has found that, “California has a housing supply and affordability crisis of historic proportions. The consequences of failing to effectively and aggressively confront this crisis are hurting millions of Californians, robbing future generations of the chance to call California home, stifling economic opportunities for workers and businesses, worsening poverty and homelessness, and undermining the state’s environmental and climate objectives.” (Gov. Code Section 65589.5.); and WHEREAS, the legislature has further found that, “Among the consequences of those actions are discrimination against low-income and minority households, lack of housing to support employment growth, imbalance in jobs and housing, reduced mobility, urban sprawl, excessive commuting, and air quality deterioration.” (Gov. Code Section 65589.5.); and
WHEREAS, the legislature adopted the Housing Crisis Act of 2019 (SB 330) which states, “In 2018, California ranked 49th out of the 50 states in housing units per capita… California needs an estimated 180,000 additional homes annually to keep up with population growth, and the Governor has called for 3.5 million new homes to be built over 7 years;” and
WHEREAS, the State Housing Element Law (Government Code Sections 65580 et seq.) requires that the City Council adopt a Housing Element for the eight-year period 2023-2031 to accommodate the City of San Mateo (City) regional housing need allocation (RHNA) of 7,015 housing units, comprised of 1,777 very low- income units, 1,023 low-income units, 1,175 moderate-income units, and 3,040 above moderate-income units; and
WHEREAS, the City has prepared Housing Element 2023-2031 (“Housing Element”) in compliance with the State Housing Element Law and has identified sites that can accommodate housing units to meet the City’s RHNA; and
WHEREAS, as provided in Government Code Section 65350 et seq., adoption of this Housing Element Update 2023-2031 constitutes a General Plan Amendment; and WHEREAS, as provided in Government Code Sections 65352 – 65352.4 on April 22, 2022, the City mailed a public notice to all California Native American tribes provided by the Native American Heritage Commission and other entities listed; and
WHEREAS, no California Native American tribe requested consultation; and WHEREAS, the City has conducted extensive community outreach over the last two years, including six public meetings before the Planning Commission and the City Council; and WHEREAS, in accordance with Government Code Section 65585(b), on April 6, 2022, the City published the Draft Housing Element and requested public comment for a 30-day review period, and on July 1, 2022, after responding to public comments, the City submitted the Draft Housing Element to the State Department of Housing and Community Development (HCD) for its review; and

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WHEREAS, on September 28, 2022, the City received a letter from HCD providing its comments regarding the Draft Housing Element; and
WHEREAS, on December 30, 2022, the City published a Revised Draft Housing Element responding to HCD’s comments, and made the Draft available for public review through January 9, 2023; and WHEREAS, on January 12, 2023, the Planning Commission held a duly and properly noticed public hearing, reviewed the Revised Draft Housing Element and all pertinent maps, documents and exhibits, including HCD’s comments, the City’s response to HCD’s comments, the agenda report and all attachments, and oral and written public comments, and voted 3-0, with two commissioners absent, to adopt a resolution recommending that the City Council decline to adopt the Revised Draft Housing Element based on the findings listed in its resolution, which is attached to the accompanying staff report; and WHEREAS, the Revised Draft Housing Element was reviewed for conformance with the California Environmental Quality Act and was found to be exempt under Sections 15061(b)(3) as it can be seen with certainty that the proposed adoption of the Housing Element (which proposes no rezonings or intensification of land use) would not have a significant effect on the environment; and WHEREAS, on January 24, 2023, the City Council conducted a duly and properly noticed public hearing to take public testimony and consider this Resolution regarding the Housing Element, reviewed the Housing Element and all pertinent maps, documents and exhibits, including HCD’s comments, the City’s response to HCD’s comments, the agenda report and all attachments, the Planning Commission recommendation and oral and written public comments.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF SAN MATEO, CALIFORNIA, HEREBY finds and determines that, based on substantial evidence in the record, that:

1. The foregoing recitals are true and correct and are incorporated by reference into this action.

2. In accordance with Government Code Section 65300.5(a), the Housing Element is internally consistent with the City’s 2030 General Plan; and as required by state law and San Mateo Municipal Code Section 27.06.040(b), the Planning Commission has reviewed and provided a recommendation to the City Council on this General Plan Amendment.

3. The Housing Element substantially complies with Housing Element Law, as provided in Government Code 65580 et seq., and contains all provisions required by State Housing Element Law, as shown in Exhibit A to this Resolution, incorporated herein by this reference.

4. Based on substantial evidence in the record, the existing uses on the non-vacant sites identified in the Site Inventory to accommodate the City’s RHNA are likely to be discontinued during the planning period and therefore do not constitute an impediment to planned residential development on the site during the planning period. Section 65583.2(g)(2) of the Government Code requires that any jurisdiction relying on non-vacant sites to meet more than 50 percent of the RHNA for lower-income households must make findings based on substantial evidence that the existing use on the non- vacant site is not an impediment to residential development during the planning period. In the City of San Mateo, 99.2 percent of the RHNA for lower-income unit capacity is on non-vacant sites (183 of 189 sites are non-vacant). The City has provided such substantial evidence in Appendix C of the Housing Element that the existing uses will be discontinued and/or will not be an impediment to residential development during the planning period based on the physical characteristics, existing uses, redevelopment potential (including improvement to land value ratio, floor area ratio, and known developer/owner interest), location and context, local knowledge, and environmental and infrastructure constraints. Specifically, Table A in the Appendix C of the Housing Element demonstrates that six of the largest non-vacant sites in the Sites Inventory have owners that have

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expressed interest in residential or mixed-use development during this planning period; with the remaining sites having the ability to accommodate new housing without displacing existing uses (i.e. large parking lots or vacant areas, have under-utilized buildings or long-standing vacancies, or have conceptual proposals, development applications or planning approvals).

5. As required by Government Code Section 65585(e), the City Council has considered the comments made by HCD, including those in HCD’s letter to the City of San Mateo dated September 28, 2022, consistent with Government Code Section 65585(f), and as described in Exhibit B to this resolution, incorporated herein by this reference, and updated the Housing Element in response to the comments to substantially comply with the requirements of State Housing Element Law as interpreted by HCD.

6. The 2015-2022 Housing Element is repealed in its entirety.

7. This Resolution shall become effective upon adoption by the City Council.

8. The City Manager or their designee is hereby directed to file all necessary materials with HCD for HCD to find that the Housing Element is in conformance with State Housing Element Law and is further directed and authorized to make all non-substantive changes to the Housing Element to make it internally consistent or to address any non-substantive changes or amendments requested by HCD to achieve certification.

9. The Community Development Department Director or designee is hereby directed to distribute copies of the Housing Element in the manner provided in Government Code Sections 65357 and 65589.7.

BE IT FURTHER RESOLVED, that the City Council hereby adopts the 2023-2031 Housing Element in its current form, which has been found to be in substantial compliance with all applicable state statutes and HCD requirements.

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Exhibit A
Compliance with Statutory Provisions
Column 1 lists the sections of the California Government Code that are applicable to certification of the City’s 2023-2031 Housing Element and Column 2 identifies how the Housing Element is in compliance with that section.

GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
Section 65583
The housing element shall consist of an identification and analysis of existing and projected housing needs and a statement of goals, policies, quantified objectives, financial resources, and scheduled programs for the preservation, improvement, and development of housing.

See below for details.

The housing element shall identify adequate sites for housing, including rental housing, factory-built housing, mobilehomes, and emergency shelters, and shall make adequate provision for the existing and projected needs of all economic segments of the community.

See below for details
The element shall contain all of the following:
(a) An assessment of housing needs and an inventory of resources and constraints relevant to the meeting of these needs. The assessment and inventory shall include all of the following:

Housing needs – see Appendix A, Needs
Analysis
Resources – see Appendix C, Housing
Resources
Constraints – see Appendix B, Constraints
(a)(1) An analysis of population and employment trends and documentation of projections Appendix A, pp H-A-9 through H-A-22 (a)(1) A quantification of the locality’s existing and projected housing needs for all income levels, including extremely low income households, as defined in subdivision (b) of Section 50105 and Section 50106 of the Health and Safety Code. These existing and projected needs shall include the locality’s share of the regional housing need in accordance with Section 65584. Local agencies shall calculate the subset of very low income households allotted under Section 65584 that qualify as extremely low income households. The local agency may either use available census data to calculate the percentage of very low income households that qualify as extremely low income households or presume that 50 percent of the very low income households qualify as extremely low income households. The number of extremely low income households and very low income Appendix A, pp H-A-9 through H-A-22; for ELI
data, see H-A-22 et seq.

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
households shall equal the jurisdiction’s allocation of very low income households pursuant to Section 65584.
(a)(2) An analysis and documentation of household characteristics, including level of payment compared to ability to pay,
Appendix A, H-A-23 through H-A-31; for
overpayment see H-A-43 et seq.
(a)(2) housing characteristics, including overcrowding, and Appendix A, H-A-43 et seq. (a)(2) housing stock condition. Appendix A, H-A-36 et seq. (a)(3) An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites, and an analysis of the relationship of the sites identified in the land inventory to the jurisdiction’s duty to affirmatively further fair housing. Note: Please see Section 65583.2 regarding the land inventory.

See base document (2023-231 City of San
Mateo Draft Housing Element) for detailed
methodology of inventory (H-27 et seq.)
For detail on individual sites, nonvacant site
analysis and relationship to constraints, etc.,
see Appendix C, pp H-C-12 et seq.

For AFFH analysis of inventory, see Appendix D,
H-D-72 et seq.
[Note that AB 2339 (Chapter 654, Statutes of 2022) amended Section 65583(a)(4). It does not apply to ABAG-area housing elements unless the first draft of the housing element is submitted to ABAG after January 31, 2023 or a draft is submitted after April 1, 2023. Therefore the sections below include the statutory provisions of Section 65583(a)(4) effective in 2022. Jurisdictions adopting their housing element after January 1, 2023 should describe why AB 2339 is not applicable to them.] (a)(4)(A) The identification of a zone or zones where emergency shelters are allowed as a permitted use without a conditional use or other discretionary permit. The identified zone or zones shall include sufficient capacity to accommodate the need for emergency shelter identified in paragraph (7), except that each local government shall identify a zone or zones that can accommodate at least one year-round emergency shelter.

Appendix B, H-B-39 through H-B-42; see also
base document Policy H3.7, page H-80
(a)(4)(A) If the local government cannot identify a zone or zones with sufficient capacity, the local government shall include a program to amend its zoning ordinance to meet the requirements of this paragraph within one year of the adoption of the housing element. The local government may identify additional zones where emergency shelters are permitted with a conditional use permit.

Appendix B, H-B-39 through H-B-42; see also
base document Policy H3.7, page H-80

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(a)(4)(A) The local government shall also demonstrate that existing or proposed permit processing, development, and management standards are objective and encourage and facilitate the development of, or conversion to, emergency shelters.

Appendix B, H-B-39 through H-B-42; see also
base document Policy H3.7, page H-80
(a)(4)(A) Emergency shelters may only be subject to those development and management standards that apply to residential or commercial development within the same zone except that a local government may apply written, objective standards that include all of the following:
(i) The maximum number of beds or persons permitted to be served nightly by the facility. (ii) Sufficient parking to accommodate all staff working in the emergency shelter, provided that the standards do not require more parking for emergency shelters than other residential or commercial uses within the same zone.
(iii) The size and location of exterior and interior onsite waiting and client intake areas. (iv) The provision of onsite management.
(v) The proximity to other emergency shelters, provided that emergency shelters are not required to be more than 300 feet apart.
(vi) The length of stay.
(vii) Lighting.
(viii) Security during hours that the emergency shelter is in operation.

Appendix B, H-B-39 through H-B-42; see also
base document Policy H3.7, page H-80
(a)(4)(B) The permit processing, development, and management standards applied under this paragraph shall not be deemed to be discretionary acts within the meaning of the California Environmental Quality Act (Division 13 (commencing with Section 21000) of the Public Resources Code).

Appendix B, H-B-39 through H-B-42; see also
base document Policy H3.7, page H-80
(a)(4)(C) A local government that can demonstrate to the satisfaction of the department the existence of one or more emergency shelters either within its jurisdiction or pursuant to a multijurisdictional agreement that can accommodate that jurisdiction’s need for emergency shelter identified in paragraph (7) may comply with the zoning requirements of subparagraph (A) by identifying a zone or zones where new emergency shelters are allowed with a conditional use permit.

Appendix B, H-B-39 through H-B-42; see also
base document Policy H3.7, page H-80
(a)(4)(D) A local government with an existing ordinance or ordinances that comply with this paragraph shall not be required to take additional action to identify zones for emergency shelters. The housing element must only describe how existing ordinances, policies, and standards are consistent with the requirements of this paragraph.

Appendix B, H-B-39 through H-B-42; see also
base document Policy H3.7, page H-80
(a)(5) An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of See Constraints, Appendix B. For detail, see
below

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
subdivision (c), and [Note: The types of housing identified in Section 65583(c)(1) include multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing.] (a)(5) for persons with disabilities as identified in the analysis pursuant to paragraph (7), Appendix B, H-B-37 et seq. (a)(5) including land use controls, Appendix B, H-B-5 through H-B-11 (a)(5) building codes and their enforcement, Appendix B, H-B-15 through H-B-16 (a)(5) site improvements, Appendix B, H-B-18 through H-B-19 (a)(5) fees and other exactions required of developers, Appendix B, H-B-31 though H-B-36 (a)(5) local processing and permit procedures, Appendix B, H-B-20 through H-B-31 (a)(5) and any locally adopted ordinances that directly impact the cost and supply of residential development.

Appendix B, H-B-15 and H-B-12
(a)(5) The analysis shall also demonstrate local efforts to remove governmental constraints that hinder the locality from meeting its share of the regional housing need in accordance with Section 65584 Base document Policies H1.1 through H1.21,
especially Policies H1.3, H1.4, H1.6, H1.7,
H1.13, H1.18
(a)(5) and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters identified pursuant to paragraph (7).

Appendix B, H-B-38, and base document
policies H1.14, H4.3, H4.4 H5.1.1, H5.1.2,
H5.2.1, H5.2.2, H5.2.3, H5.4.1, H5.4.2, H5.4.3,
and H5.4.4
(a)(6) An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the availability of financing, Appendix B, H-B-46 through H-B-56
(a)(6) the price of land, Appendix B, H-B-46 through H-B-47 (a)(6) the cost of construction, Appendix B, H-B-47 through H-B-50

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(a)(6) the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Section 65583.2,
Appendix B, H-B-51
(a)(6) and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Section 65584.

Appendix B, H-B-51
(a)(6) The analysis shall also demonstrate local efforts to remove nongovernmental constraints that create a gap between the locality’s planning for the development of housing for all income levels and the construction of that housing.

Appendix B, H-B-46 through H-B-55, and base
document policies H1.9, H1.10 and H1.21
(a)(7) An analysis of any special housing needs, such as those of the (a)(7) elderly; Appendix A, H-A-23 et seq. and H-A-55 et seq. (a)(7) persons with disabilities, including a developmental disability, as defined in Section 4512 of the Welfare and Institutions Code;
Appendix A, H-A-56 through H-A-59
(a)(7) large families; Appendix A, H-A-53 et seq.
(a)(7) farmworkers; Appendix A, H-A-66 et seq.
(a)(7) families with female heads of households; Appendix A, H-A-54 et seq. (a)(7) and families and persons in need of emergency shelter. Appendix A, H-A-59 through H-A-65 (a)(7) The need for emergency shelter shall be assessed based on the capacity necessary to accommodate the most recent homeless point-in-time count conducted before the start of the planning period, the need for emergency shelter based on number of beds available on a year-round and seasonal basis, the number of shelter beds that go unused on an average monthly basis within a one-year period, and the percentage of those in emergency shelters that move to permanent housing solutions.

Appendix A, H-A-59 through H-A-65; see also
Appendix B, H-B-39 through H-B-42
(a)(7) The need for emergency shelter may be reduced by the number of supportive housing units that are identified in an adopted 10-year plan to end chronic homelessness and that are either vacant or for which funding has been identified to allow construction during the planning period.

Appendix A, H-A-59 through H-A-65; see also
Appendix B, H-B-39 through H-B-42

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(a)(7) An analysis of special housing needs by a city or county may include an analysis of the need for frequent user coordinated care housing services.

N/A
(a)(8) An analysis of opportunities for energy conservation with respect to residential development. Cities and counties are encouraged to include weatherization and energy efficiency improvements as part of publicly subsidized housing rehabilitation projects. This may include energy efficiency measures that encompass the building envelope, its heating and cooling systems, and its electrical system.

Base document, H-48 and H-49, and policy H2.3
(a)(9) An analysis of existing assisted housing developments that are eligible to change from low-income housing uses during the next 10 years due to termination of subsidy contracts, mortgage prepayment, or expiration of restrictions on use. “Assisted housing developments,” for the purpose of this section, shall mean multifamily rental housing that receives governmental assistance under federal programs listed in subdivision (a) of Section 65863.10, state and local multifamily revenue bond programs, local redevelopment programs, the federal Community Development Block Grant Program, or local in-lieu fees. “Assisted housing developments” shall also include multifamily rental units that were developed pursuant to a local inclusionary housing program or used to qualify for a density bonus pursuant to Section 65916.

Base document, H-24 through H-27; complete
list of developments is in Appendix A,
Attachment 2
(a)(9)(A) The analysis shall include a listing of each development by project name and address, the type of governmental assistance received, the earliest possible date of change from low-income use, and the total number of elderly and nonelderly units that could be lost from the locality’s low-income housing stock in each year during the 10-year period. For purposes of state and federally funded projects, the analysis required by this subparagraph need only contain information available on a statewide basis.

Appendix A, Attachment 2
(a)(9)(B) The analysis shall estimate the total cost of producing new rental housing that is comparable in size and rent levels, to replace the units that could change from low-income use, and an estimated cost of preserving the assisted housing developments. This cost analysis for replacement housing may be done aggregately for each five-year period and does not have to contain a project-by-project cost estimate.

Base document, H-24 through H-27
(a)(9)(C) The analysis shall identify public and private nonprofit corporations known to the local government that have legal and managerial capacity to acquire and manage these housing developments.

Base document, H-24 through H-27
(a)(9)(D) The analysis shall identify and consider the use of all federal, state, and local financing and subsidy programs that can be used to preserve, for lower income households, the assisted housing developments, identified in this paragraph, including, but not limited to, federal Community Development Block Grant Program funds, tax increment funds received by a redevelopment agency of the community, and administrative fees received by a housing authority operating within the community. In considering the use Base document, H-24 through H-27

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
of these financing and subsidy programs, the analysis shall identify the amounts of funds under each available program that have not been legally obligated for other purposes and that could be available for use in preserving assisted housing developments.
(b) (1) A statement of the community’s goals, quantified objectives, and policies relative to affirmatively furthering fair housing and to the maintenance, preservation, improvement, and development of housing.

Base document Goals, Policies and Programs,
including AFFH, H-71 through H-87
Quantified objectives: base document, H-88
through H-91
(2) It is recognized that the total housing needs identified pursuant to subdivision (a) may exceed available resources and the community’s ability to satisfy this need within the content of the general plan requirements outlined in Article 5 (commencing with Section 65300). Under these circumstances, the quantified objectives need not be identical to the total housing needs. The quantified objectives shall establish the maximum number of housing units by income category, including extremely low income, that can be constructed, rehabilitated, and conserved over a five-year time period.

Quantified objectives: base document, H-88
through H-91
(c) A program that sets forth a schedule of actions during the planning period, each with a timeline for implementation, that may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the housing element Base document Goals, Policies and Programs,
including AFFH: base document, H-71 through
H-87
(c) through the administration of land use and development controls, Base document Policies H1.1 through H1.21 (c) the provision of regulatory concessions and incentives, Base document Policies H1.3, H1.4, H1.6, H1.7, H1.13, H1.18, and others
(c) the utilization of appropriate federal and state financing and subsidy programs when available, Base document Policy H1.2 and H2.1 (c) and the utilization of moneys in a low- and moderate-income housing fund of an agency if the locality has established a redevelopment project area pursuant to the Community Redevelopment Law (Division 24 (commencing with Section 33000) of the Health and Safety Code).

Base document Policy H1.2 and H2.1
In order to make adequate provision for the housing needs of all economic segments of the community, the program shall do all of the following:

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(c)(1) Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Section 65584.09.

No sites need to be rezoned in order to
accommodate the RHNA allocation
(c)(1) Sites shall be identified as needed to affirmatively further fair housing For AFFH analysis of inventory, see Appendix D, H-D-72 et seq.
(c)(1) and to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing,
See base document programs, H-71 through H-
87; see also discussion in Constraints Analysis,
Appendix B, beginning on H-B-5
(c)(1) factory-built housing, Appendix B, H-B-44
(c)(1) mobilehomes, Appendix B, H-B-44
(c)(1) housing for agricultural employees, Appendix B, H-B-43 (c)(1) supportive housing, Appendix B, H-B-42
(c)(1) single-room occupancy units, Appendix B, H-B-45; and base document H-44 (c)(1) emergency shelters, Appendix B, H-B-39 et seq.
(c)(1) and transitional housing. Appendix B, H-B-42
(c)(1)(A) Where the inventory of sites, pursuant to paragraph (3) of subdivision (a), does not identify adequate sites to accommodate the need for groups of all household income levels pursuant to Section 65584, rezoning of those sites, including adoption of minimum density and development standards, for jurisdictions with an eight-year housing element planning period pursuant to Section 65588, shall be completed no later than three years after either the date the housing element is adopted pursuant to subdivision (f) of Section 65585 or the date that is 90 days after receipt of comments from the department pursuant to subdivision (b) of Section 65585, whichever is earlier, unless the deadline is extended pursuant to subdivision (f). Notwithstanding the foregoing, for a local government that fails to adopt a housing element that the department has found to be in substantial compliance with this article within 120 days of No sites need to be rezoned in order to
accommodate the RHNA allocation

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
the statutory deadline in Section 65588 for adoption of the housing element, rezoning of those sites, including adoption of minimum density and development standards, shall be completed no later than one year from the statutory deadline in Section 65588 for adoption of the housing element. (c)(1)(B) Where the inventory of sites, pursuant to paragraph (3) of subdivision (a), does not identify adequate sites to accommodate the need for groups of all household income levels pursuant to Section 65584, the program shall identify sites that can be developed for housing within the planning period pursuant to subdivision (h) of Section 65583.2. The identification of sites shall include all components specified in Section 65583.2. Note: Please see Section 65583.2 regarding the land inventory and conformance with subdivision (h).

No sites need to be rezoned in order to
accommodate the RHNA allocation
(c)(1)(C) Where the inventory of sites pursuant to paragraph (3) of subdivision (a) does not identify adequate sites to accommodate the need for farmworker housing, the program shall provide for sufficient sites to meet the need with zoning that permits farmworker housing use by right, including density and development standards that could accommodate and facilitate the feasibility of the development of farmworker housing for low- and very low income households.

Base document implementation plan, Policy
H1.17
(c)(2) Assist in the development of adequate housing to meet the needs of extremely low, very low, low-, and moderate-income households.

Base document Policies H1.1 through H1.21
(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
Base document Policies H1.1 through H1.21,
especially Policies H1.3, H1.4, H1.6, H1.7,
H1.13, H1.18
(c)(3) and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities.

Appendix B, H-B-38, and base document
policies H1.14, H4.3, H4.4 H5.1.1, H5.1.2,
H5.2.1, H5.2.2, H5.2.3, H5.4.1, H5.4.2, H5.4.3,
and H5.4.4
(c)(3) Transitional housing and supportive housing shall be considered a residential use of property and shall be subject only to those restrictions that apply to other residential dwellings of the same type in the same zone.

Appendix B, H-B-42 and base document policy
H1.15
(c)(3)Supportive housing, as defined in Section 65650, shall be a use by right in all zones where multifamily and mixed uses are permitted, as provided in Article 11 (commencing with Section 65650).

Appendix B, H-B-42 and base document policy
H1.15

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(c)(4) Conserve and improve the condition of the existing affordable housing stock, which may include addressing ways to mitigate the loss of dwelling units demolished by public or private action.

Base document Policies H2.1, H2.2, H2.4, H2.6
(c)(5) Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law.

AFFH policies in base document, H5.1.1
through H5.4.5
(c)(6) Preserve for lower income households the assisted housing developments identified pursuant to paragraph (9) of subdivision (a).

Base document policy H2.2
(c)(6) The program for preservation of the assisted housing developments shall utilize, to the extent necessary, all available federal, state, and local financing and subsidy programs identified in paragraph (9) of subdivision (a), except where a community has other urgent needs for which alternative funding sources are not available.

Base document, H-24 through H-27 and policy
H2.2
(c)(6) The program may include strategies that involve local regulation and technical assistance. Base document, H-24 through H-27 and policy H2.2
(c)(7) Develop a plan that incentivizes and promotes the creation of accessory dwelling units that can be offered at affordable rent, as defined in Section 50053 of the Health and Safety Code, for very low, low-, or moderate-income households. For purposes of this paragraph, “accessory dwelling units” has the same meaning as “accessory dwelling unit” as defined in paragraph (4) of subdivision (i) of Section 65852.2.

Base document policies H1.4 and H5.1.3
(c)(8) Include an identification of the agencies and officials responsible for the implementation of the various actions and the means by which consistency will be achieved with other general plan elements and community goals.

For responsible parties, including AFFH: base
document, pages H-71 through H-87
Consistency with the general plan: base
document, page H-19
(c)(9) Include a diligent effort by the local government to achieve public participation of all economic segments of the community in the development of the housing element, and the program shall describe this effort.

See Appendix F in its entirety, and the base
document for a summary (H-50 through H-60)

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(c)(10)(A) Affirmatively further fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2. The program shall include an assessment of fair housing in the jurisdiction that shall include all of the following components:

Appendix D in its entirety
(c)(10)(A)(i) A summary of fair housing issues in the jurisdiction Appendix D, H-D-10 through H-D-15 (c)(10)(A)(i) and an assessment of the jurisdiction’s fair housing enforcement and fair housing outreach capacity.

Appendix D, H-D-16 through H-D-23
(c)(10)(A)(ii) An analysis of available federal, state, and local data and knowledge to identify integration and segregation patterns and trends,
Appendix D, H-D-24 through H-D-49
(c)(10)(A)(ii)racially or ethnically concentrated areas of poverty and affluence, Appendix D, H-D-41 through H-D-49 (c)(10)(A)(ii) disparities in access to opportunity, Appendix D, H-D-50 through H-D-56 (c)(10)(A)(ii) and disproportionate housing needs, Appendix D, H-D-57 though H-D-71 (c)(10)(A)(ii) including displacement risk. Appendix D, H-D-67 through H-D-71 (c)(10)(A)(ii) The analysis shall identify and examine such patterns, trends, areas, disparities, and needs, both within the jurisdiction.

Appendix D in its entirety, as this information is
woven throughout
(c)(10)(A)(ii) and comparing the jurisdiction to the region in which it is located, based on race and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2) and Section 65008.

Appendix D in its entirety, as this information is
woven throughout
(c)(10)(A)(iii) An assessment of the contributing factors, including the local and regional historical origins Appendix D, H-D-6 through H-D-15 (c)(10)(A)(iii) and current policies and practices, for the fair housing issues identified under clauses (i) and (ii). Appendix D, H-D-16 through H-D-23 (c)(10)(A)(iv) An identification of the jurisdiction’s fair housing priorities and goals, giving highest priority to those factors identified in clause (iii) that limit or deny fair housing choice or access to opportunity, or negatively impact fair housing or civil rights compliance, Appendix D, H-D-14 et seq.

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(c)(10)(A)(iv) and identifying the metrics and milestones for determining what fair housing results will be achieved.

AFFH policies are located in the base
document, policies H5.1.1 through H5.4.5
(c)(10)(A)(v) Strategies and actions to implement those priorities and goals, which may include, but are not limited to, enhancing mobility strategies
AFFH policies H5.1.1 through H5.1.3
(c)(10)(A)(v) and encouraging development of new affordable housing in areas of opportunity, AFFH policies H5.2.1 through H5.2.3 (c)(10)(A)(v) as well as place-based strategies to encourage community revitalization, including preservation of existing affordable housing,
AFFH policies H5.3.1 through H5.3.3
(c)(10)(A)(v) and protecting existing residents from displacement. AFFH policies H5.4.1 through H5.4.5 (c)(10)(B) A jurisdiction that completes or revises an assessment of fair housing pursuant to Subpart A (commencing with Section 5.150) of Part 5 of Subtitle A of Title 24 of the Code of Federal Regulations, as published in Volume 80 of the Federal Register, Number 136, page 42272, dated July 16, 2015, or an analysis of impediments to fair housing choice in accordance with the requirements of Section 91.225 of Title 24 of the Code of Federal Regulations in effect before August 17, 2015, may incorporate relevant portions of that assessment or revised assessment of fair housing or analysis or revised analysis of impediments to fair housing into its housing element.

N/A
(c)(10)(C) The requirements of this paragraph shall apply to housing elements due to be revised pursuant to Section 65588 on or after January 1, 2021.

See above
(d)(1) A local government may satisfy all or part of its requirement to identify a zone or zones suitable for the development of emergency shelters pursuant to paragraph (4) of subdivision (a) by adopting and implementing a multijurisdictional agreement, with a maximum of two other adjacent communities, that requires the participating jurisdictions to develop at least one year-round emergency shelter within two years of the beginning of the planning period.

N/A
(d)(2) The agreement shall allocate a portion of the new shelter capacity to each jurisdiction as credit toward its emergency shelter need, and each jurisdiction shall describe how the capacity was allocated as part of its housing element.

N/A

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(d)(3) Each member jurisdiction of a multijurisdictional agreement shall describe in its housing element all of the following:

N/A
(d)(3)(A) How the joint facility will meet the jurisdiction’s emergency shelter need. (d)(3)(B) The jurisdiction’s contribution to the facility for both the development and ongoing operation and management of the facility.
(d)(3)(C) The amount and source of the funding that the jurisdiction contributes to the facility.

N/A
(d)(4) The aggregate capacity claimed by the participating jurisdictions in their housing elements shall not exceed the actual capacity of the shelter.

N/A
(e) Except as otherwise provided in this article, amendments to this article that alter the required content of a housing element shall apply to both of the following: [Note that this provision is applicable to AB 2339 (Chapter 654, Statutes of 2022), which amended Section 65583(a)(4). Jurisdictions adopting their housing element after January 1, 2023 should describe why this amendment is not applicable to them.] N/A
(1) A housing element or housing element amendment prepared pursuant to subdivision (e) of Section 65588 or Section 65584.02, when a city, county, or city and county submits a draft to the department for review pursuant to Section 65585 more than 90 days after the effective date of the amendment to this section.

N/A
(2) Any housing element or housing element amendment prepared pursuant to subdivision (e) of Section 65588 or Section 65584.02, when the city, county, or city and county fails to submit the first draft to the department before the due date specified in Section 65588 or 65584.02.

N/A
(f) – (j): Not applicable N/A
Section 65583.1(a)
(a) The Department of Housing and Community Development, in evaluating a proposed or adopted housing element for substantial compliance with this article, … may also allow a city or county to identify sites for accessory dwelling units based on the number of accessory dwelling units developed in the prior housing element planning period whether or not the units are permitted by right, the need for these units in the community, the resources or incentives available for their development, and any other relevant factors, as determined by the department.

Base document H-39 et seq.

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(b) Sites that contain permanent housing units located on a military base undergoing closure or conversion as a result of action pursuant to the Defense Authorization Amendments and Base Closure and Realignment Act (Public Law 100-526), the Defense Base Closure and Realignment Act of 1990 (Public Law 101-510), or any subsequent act requiring the closure or conversion of a military base may be identified as an adequate site if the housing element demonstrates that the housing units will be available for occupancy by households within the planning period of the element. No sites containing housing units scheduled or planned for demolition or conversion to nonresidential uses shall qualify as an adequate site.

N/A
Note: If communities are using the provisions of Section 65583.1(c), which allow RHNA credit for conversion of non-affordable to affordable housing and for preservation of existing affordable housing at risk of loss, the applicable provisions need to be added to this table.

N/A
Section 65583.2
(a) A city’s or county’s inventory of land suitable for residential development pursuant to paragraph (3) of subdivision (a) of Section 65583 shall be used to identify sites throughout the community, consistent with paragraph (10) of subdivision (c) of Section 65583,
Base document methodology discussion, H-27
through H-44
(a) that can be developed for housing within the planning period and that are sufficient to provide for the jurisdiction’s share of the regional housing need for all income levels pursuant to Section 65584. As used in this section, “land suitable for residential development” includes all of the following sites that meet the standards set forth in subdivisions (c) and (g):

See below
(a)(1) Vacant sites zoned for residential use. See electronic sites inventory in Appendix C, Housing Resources starting on page H-C-53, as
well as individual sites analyses in the same
Appendix, H-C-16 through H-C-51.
(a)(2) Vacant sites zoned for nonresidential use that allows residential development. See electronic sites inventory in Appendix C, Housing Resources starting on page H-C-53, as
well as individual sites analyses in the same
Appendix, H-C-16 through H-C-51.
(a)(3) Residentially zoned sites that are capable of being developed at a higher density, including sites owned or leased by a city, county, or city and county
See electronic sites inventory in Appendix C,
Housing Resources starting on page H-C-53, as

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
well as individual sites analyses in the same
Appendix, H-C-16 through H-C-51.
(a)(4) Sites zoned for nonresidential use that can be redeveloped for residential use, and for which the housing element includes a program to rezone the site, as necessary, rezoned for, to permit residential use, including sites owned or leased by a city, county, or city and county.

See electronic sites inventory in Appendix C,
Housing Resources starting on page H-C-53, as
well as individual sites analyses in the same
Appendix, H-C-16 through H-C-51.
(b) The inventory of land shall include all of the following:
(b)(1) A listing of properties by assessor parcel number. See electronic sites inventory in Appendix C, Housing Resources starting on page H-C-53
(b)(2) The size of each property listed pursuant to paragraph (1), and the general plan designation and zoning of each property.

See electronic sites inventory in Appendix C,
Housing Resources starting on page H-C-53
(b)(3) For nonvacant sites, a description of the existing use of each property. See electronic sites inventory in Appendix C, Housing Resources starting on page H-C-53
(b)(3) If a site subject to this paragraph is owned by the city or county, the description shall also include whether there are any plans to dispose of the property during the planning period and how the city or county will comply with Article 8 (commencing with Section 54220) of Chapter 5 of Part 1 of Division 2 of Title 5.

See electronic sites inventory in Appendix C,
Housing Resources starting on page H-C-53.

Publicly owned sites generally have pending
projects on them
(b)(4) A general description of any environmental constraints to the development of housing within the jurisdiction, the documentation for which has been made available to the jurisdiction. This information need not be identified on a site-specific basis.

See discussion on-site constraints in Appendix
C, H-C-13 et seq.

See electronic sites inventory in Appendix C,
Housing Resources starting on page H-C-53, as
well as individual sites analyses in the same
Appendix, H-C-16 through H-C-51.

See also discussion in Appendix B, H-B-52
through H-B-54
(b)(5)(A) A description of existing or planned water, sewer, and other dry utilities supply, including the availability and access to distribution facilities.

See discussion on-site constraints in Appendix
C, H-C-13 et seq.

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
See electronic sites inventory in Appendix C,
Housing Resources starting on page H-C-53, as
well as individual sites analyses in the same
Appendix, H-C-16 through H-C-51.

See also discussion in Appendix B, H-B-52
through H-B-54
(b)(5)(B) Parcels included in the inventory must have sufficient water, sewer, and dry utilities supply available and accessible to support housing development or be included in an existing general plan program or other mandatory program or plan, including a program or plan of a public or private entity providing water or sewer service, to secure sufficient water, sewer, and dry utilities supply to support housing development. This paragraph does not impose any additional duty on the city or county to construct, finance, or otherwise provide water, sewer, or dry utilities to parcels included in the inventory.

See discussion on-site constraints in Appendix
C, H-C-13 et seq.

See electronic sites inventory in Appendix C,
Housing Resources starting on page H-C-53, as
well as individual sites analyses in the same
Appendix, H-C-16 through H-C-51.

See also discussion in Appendix B, H-B-52
through H-B-54
(b)(6) Sites identified as available for housing for above moderate-income households in areas not served by public sewer systems. This information need not be identified on a site-specific basis.

N/A
(b)(7) A map that shows the location of the sites included in the inventory, such as the land use map from the jurisdiction’s general plan, for reference purposes only.

See map figures in base document, pages H-38
and H-43, and Appendix C, pages H-C-15 and H-
C-51
(c) Based on the information provided in subdivision (b), a city or county shall determine whether each site in the inventory can accommodate the development of some portion of its share of the regional housing need by income level during the planning period, as determined pursuant to Section 65584. The inventory shall specify for each site the number of units that can realistically be accommodated on that site and whether the site is adequate to accommodate lower income housing, moderate-income housing, or above moderate-income housing.

Base document methodology discussion, H-27
through H-44
(c) A nonvacant site identified pursuant to paragraph (3) or (4) of subdivision (a) in a prior housing element and a vacant site that has been included in two or more consecutive planning periods that was not approved to develop a portion of the locality’s housing need shall not be deemed adequate to accommodate a portion of the housing need for lower income households that must be accommodated in the current housing element planning period unless the site is zoned at residential densities consistent with paragraph (3) of this Appendix C, H-C-14 et seq.

Note: No rezoning required.

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
subdivision and the site is subject to a program in the housing element requiring rezoning within three years of the beginning of the planning period to allow residential use by right for housing developments in which at least 20 percent of the units are affordable to lower income households. An unincorporated area in a nonmetropolitan county pursuant to clause (ii) of subparagraph (B) of paragraph (3) shall not be subject to the requirements of this subdivision to allow residential use by right. (c) Notwithstanding the foregoing, for a local government that fails to adopt a housing element that the department has found to be in substantial compliance with state law within 120 days of the statutory deadline in Section 65588 for adoption of the housing element, rezoning pursuant to this subdivision shall be completed no later than one year from the statutory deadline in Section 65588 for adoption of the housing element.

To be adopted by January 31, 2023.
(c) The analysis shall determine whether the inventory can provide for a variety of types of housing, including multifamily rental housing,
See base document programs, H-71 through H-
87; see also discussion in Constraints, Appendix
B, beginning on H-B-5
(c) factory-built housing, mobilehomes, Appendix B, H-B-44 (c) housing for agricultural employees, Appendix B, H-B-43 (c) supportive housing, Appendix B, H-B-42
(c) single-room occupancy units, Appendix B, H-B-45; see also base document H- 44 (c) emergency shelters, and Appendix B, H-B-39 et seq. (c) transitional housing Appendix B, H-B-42
(c) and whether the inventory affirmatively furthers fair housing. For AFFH analysis of inventory, see Appendix D, H-D-72 et seq.
(c) The city or county shall determine the number of housing units that can be accommodated on each site as follows:

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(c)(1) If local law or regulations require the development of a site at a minimum density, the department shall accept the planning agency’s calculation of the total housing unit capacity on that site based on the established minimum density. If the city or county does not adopt a law or regulation requiring the development of a site at a minimum density, then it shall demonstrate how the number of units determined for that site pursuant to this subdivision will be accommodated.

See base document (2023-231 City of San
Mateo Draft Housing Element) for detailed
methodology of inventory (H-27 et seq.)
(c)(2) The number of units calculated pursuant to paragraph (1) shall be adjusted as necessary, based on the land use controls and site improvements requirement identified in paragraph (5) of subdivision (a) of Section 65583,
See base document (2023-231 City of San
Mateo Draft Housing Element) for detailed
methodology of inventory (H-27 et seq.)
(c)(2) the realistic development capacity for the site, See base document (2023-231 City of San Mateo Draft Housing Element) for detailed
methodology of inventory (H-27 et seq.)
(c)(2) typical densities of existing or approved residential developments at a similar affordability level in that jurisdiction,
See base document (2023-231 City of San
Mateo Draft Housing Element) for detailed
methodology of inventory (H-27 et seq.)
(c)(2) and on the current or planned availability and accessibility of sufficient water, sewer, and dry utilities. See base document (2023-231 City of San Mateo Draft Housing Element) for detailed
methodology of inventory (H-27 et seq.)
See also electronic sites inventory in Appendix
C, Housing Resources starting on page H-C-53,
as well as individual sites analyses in the same
Appendix, H-C-16 through H-C-51.
(c)(2)(A) A site smaller than half an acre shall not be deemed adequate to accommodate lower income housing need unless the locality can demonstrate that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower income housing units as projected for the site or unless the locality provides other evidence to the department that the site is adequate to accommodate lower income housing.

N/A – no sites less than half an acre are
included as sites for lower income
(c)(2)(B) A site larger than 10 acres shall not be deemed adequate to accommodate lower income housing need unless the locality can demonstrate that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower income housing units as projected for the site or Base Housing Element document, H-35 through
H-37

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
unless the locality provides other evidence to the department that the site can be developed as lower income housing.
(c)(2)(B) For purposes of this subparagraph, “site” means that portion of a parcel or parcels designated to accommodate lower income housing needs pursuant to this subdivision. (c)(2)(C) A site may be presumed to be realistic for development to accommodate lower income housing need if, at the time of the adoption of the housing element, a development affordable to lower income households has been proposed and approved for development on the site.

See pipeline projects, base document H-39 and
Appendix C, H-C-22 through H-C-34
(c)(3) For the number of units calculated to accommodate its share of the regional housing need for lower income households pursuant to paragraph (2), a city or county shall do either of the following:
(c)(3)(A) Provide an analysis demonstrating how the adopted densities accommodate this need. The analysis shall include, but is not limited to, factors such as market demand, financial feasibility, or information based on development project experience within a zone or zones that provide housing for lower income households.

See base document (2023-231 City of San
Mateo Draft Housing Element) for detailed
methodology of inventory (H-27 et seq.)
See also electronic sites inventory in Appendix
C, Housing Resources starting on page H-C-53,
as well as individual sites analyses in the same
Appendix, H-C-16 through H-C-51.
(c)(3)(B) The following densities shall be deemed appropriate to accommodate housing for lower income households:
(i) For an incorporated city within a nonmetropolitan county and for a nonmetropolitan county that has a micropolitan area: sites allowing at least 15 units per acre. (ii) For an unincorporated area in a nonmetropolitan county not included in clause (i): sites allowing at least 10 units per acre.
(iii) For a suburban jurisdiction: sites allowing at least 20 units per acre. (iv) For a jurisdiction in a metropolitan county: sites allowing at least 30 units per acre.

See base document (2023-231 City of San
Mateo Draft Housing Element) for detailed
methodology of inventory (H-27 et seq.)
See also electronic sites inventory in Appendix
C, Housing Resources starting on page H-C-53,
as well as individual sites analyses in the same
Appendix, H-C-16 through H-C-51.
(4)(A) For a metropolitan jurisdiction:
(4)(A)(i) At least 25 percent of the jurisdiction’s share of the regional housing need for moderate-income housing shall be allocated to sites with zoning that allows at least 4 units of housing, but not more than 100 units per acre of housing.

See base document, H-45

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(4)(A)(ii) At least 25 percent of the jurisdiction’s share of the regional housing need for above moderate- income housing shall be allocated to sites with zoning that allows at least 4 units of housing.

See base document, H-45
(B) The allocation of moderate-income and above moderate-income housing to sites pursuant to this paragraph shall not be a basis for the jurisdiction to do either of the following:
(i) Deny a project that does not comply with the allocation. (ii) Impose a price minimum, price maximum, price control, or any other exaction or condition of approval in lieu thereof. This clause does not prohibit a jurisdiction from imposing any price minimum, price maximum, price control, exaction, or condition in lieu thereof, pursuant to any other law. (iii) The provisions of this subparagraph do not constitute a change in, but are declaratory of, existing law with regard to the allocation of sites pursuant to this section. (C) This paragraph does not apply to an unincorporated area. (D) For purposes of this paragraph:
(i) “Housing development project” has the same meaning as defined in paragraph (2) of subdivision (h) of Section 65589.5.
(ii) “Unit of housing” does not include an accessory dwelling unit or junior accessory dwelling unit that could be approved pursuant to Section 65852.2 or Section 65852.22 or through a local ordinance or other provision implementing either of those sections. This paragraph shall not limit the ability of a local government to count the actual production of accessory dwelling units or junior accessory dwelling units in an annual progress report submitted pursuant to Section 65400 or other progress report as determined by the department.
(E) Nothing in this subdivision shall preclude the subdivision of a parcel, provided that the subdivision is subject to the Subdivision Map Act (Division 2 (commencing with Section 66410)) or any other applicable law authorizing the subdivision of land.
(d) For purposes of this section, a metropolitan county, nonmetropolitan county, and nonmetropolitan county with a micropolitan area shall be as determined by the United States Census Bureau. A nonmetropolitan county with a micropolitan area includes the following counties: Del Norte, Humboldt,

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Lake, Mendocino, Nevada, Tehama, and Tuolumne and other counties as may be determined by the United States Census Bureau to be nonmetropolitan counties with micropolitan areas in the future. (e) (1) Except as provided in paragraph (2), a jurisdiction shall be considered suburban if the jurisdiction does not meet the requirements of clauses (i) and (ii) of subparagraph (B) of paragraph (3) of subdivision (c) and is located in a Metropolitan Statistical Area (MSA) of less than 2,000,000 in population, unless that jurisdiction’s population is greater than 100,000, in which case it shall be considered metropolitan. A county, not including the City and County of San Francisco, shall be considered suburban unless the county is in an MSA of 2,000,000 or greater in population in which case the county shall be considered metropolitan. (2)(A)(i) Notwithstanding paragraph (1), if a county that is in the San Francisco-Oakland-Fremont California MSA has a population of less than 400,000, that county shall be considered suburban. If this county includes an incorporated city that has a population of less than 100,000, this city shall also be considered suburban.

This paragraph shall apply to a housing element revision cycle, as described in subparagraph (A) of paragraph (3) of subdivision (e) of Section 65588, that is in effect from July 1, 2014, to December 31, 2028, inclusive. (2)(A)(ii) A county subject to this subparagraph shall utilize the sum existing in the county’s housing trust fund as of June 30, 2013, for the development and preservation of housing affordable to low- and very low income households.
(2)(B) A jurisdiction that is classified as suburban pursuant to this paragraph shall report to the Assembly Committee on Housing and Community Development, the Senate Committee on Housing, and the Department of Housing and Community Development regarding its progress in developing low- and very low income housing consistent with the requirements of Section 65400. The report shall be provided three times: once, on or before December 31, 2019, which report shall address the initial four years of the housing element cycle, a second time, on or before December 31, 2023, which report shall address the subsequent four years of the housing element cycle, and a third time, on or before December 31, 2027, which report shall address the subsequent four years of the housing element cycle and the cycle as a whole. The reports shall be provided consistent with the requirements of Section 9795. (f) A jurisdiction shall be considered metropolitan if the jurisdiction does not meet the requirements for “suburban area” above and is located in an MSA of 2,000,000 or greater in population, unless that jurisdiction’s population is less than 25,000 in which case it shall be considered suburban.

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(g)(1) For sites described in paragraph (3) of subdivision (b) [non-vacant sites], the city or county shall specify the additional development potential for each site within the planning period and shall provide an explanation of the methodology used to determine the development potential. (g)(1) The methodology shall consider factors including the extent to which existing uses may constitute an impediment to additional residential development,
See base document (2023-231 City of San
Mateo Draft Housing Element) for detailed
methodology of inventory (H-27 et seq.)
See also electronic sites inventory in Appendix
C, Housing Resources starting on page H-C-53,
as well as individual sites analyses in the same
Appendix, H-C-16 through H-C-51.
(g)(1) the city’s or county’s past experience with converting existing uses to higher density residential development,
See base document (2023-231 City of San
Mateo Draft Housing Element) for detailed
methodology of inventory (H-27 et seq.)
See also electronic sites inventory in Appendix
C, Housing Resources starting on page H-C-53,
as well as individual sites analyses in the same
Appendix, H-C-16 through H-C-51.
(g)(1) the current market demand for the existing use, See base document (2023-231 City of San Mateo Draft Housing Element) for detailed
methodology of inventory (H-27 et seq.)
See also electronic sites inventory in Appendix
C, Housing Resources starting on page H-C-53,
as well as individual sites analyses in the same
Appendix, H-C-16 through H-C-51.
(g)(1) an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development, See base document (2023-231 City of San
Mateo Draft Housing Element) for detailed
methodology of inventory (H-27 et seq.)
See also electronic sites inventory in Appendix
C, Housing Resources starting on page H-C-53,

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as well as individual sites analyses in the same
Appendix, H-C-16 through H-C-51.
(g)(1) development trends, See base document (2023-231 City of San Mateo Draft Housing Element) for detailed
methodology of inventory (H-27 et seq.)
See also electronic sites inventory in Appendix
C, Housing Resources starting on page H-C-53,
as well as individual sites analyses in the same
Appendix, H-C-16 through H-C-51.
(g)(1) market conditions, See base document (2023-231 City of San Mateo Draft Housing Element) for detailed
methodology of inventory (H-27 et seq.)
See also electronic sites inventory in Appendix
C, Housing Resources starting on page H-C-53,
as well as individual sites analyses in the same
Appendix, H-C-16 through H-C-51.
(g)(1) and regulatory or other incentives or standards to encourage additional residential development on these sites.

See base document (2023-231 City of San
Mateo Draft Housing Element) for detailed
methodology of inventory (H-27 et seq.)
See also electronic sites inventory in Appendix
C, Housing Resources starting on page H-C-53,
as well as individual sites analyses in the same
Appendix, H-C-16 through H-C-51.
(g)(2) In addition to the analysis required in paragraph (1), when a city or county is relying on nonvacant sites described in paragraph (3) of subdivision (b) to accommodate 50 percent or more of its housing need for lower income households, the methodology used to determine additional development potential shall demonstrate that the existing use identified pursuant to paragraph (3) of subdivision (b) does not constitute an impediment to additional residential development during the period covered by the housing element. 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.

See base document for detailed methodology
of inventory (H-27 et seq.)
See also electronic sites inventory in Appendix
C, Housing Resources starting on page H-C-53,
as well as individual sites analyses in the same
Appendix, H-C-16 through H-C-51.

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(g)(3) Notwithstanding any other law, and in addition to the requirements in paragraphs (1) and (2), sites that currently have residential uses, or within the past five years have had residential uses that have been vacated or demolished, that are or were subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low or very low income, subject to any other form of rent or price control through a public entity’s valid exercise of its police power, or occupied by low or very low income households, shall be subject to a policy requiring the replacement of all those units affordable to the same or lower income level as a condition of any development on the site. Replacement requirements shall be consistent with those set forth in paragraph (3) of subdivision (c) of Section 65915.

Base document Policy H2.6
(h) The program required by subparagraph (A) of paragraph (1) of subdivision (c) of Section 65583 shall accommodate 100 percent of the need for housing for very low and low-income households allocated pursuant to Section 65584 for which site capacity has not been identified in the inventory of sites pursuant to paragraph (3) of subdivision (a) on sites that shall be zoned to permit owner-occupied and rental multifamily residential use by right for developments in which at least 20 percent of the units are affordable to lower income households during the planning period.

No rezoning is required to meet the RHNA
allocation. All sites in the inventory on which
lower income units are identified are zoned at
least 30 units per acre
See also base document Policy H1.7 (allow
residential as a permitted use in C and E
districts) and Policy H1.10 (allow housing by-
right for prior housing sites that propose a
minimum of 20 percent affordable).
(h) These sites shall be zoned with minimum density and development standards that permit at least 16 units per site at a density of at least 16 units per acre in jurisdictions described in clause (i) of subparagraph (B) of paragraph (3) of subdivision (c),
No rezoning is required to meet the RHNA
allocation. All sites in the inventory on which
lower income units are identified are zoned for
at least 30 units per acre.

See also base document Policy H 1.9 (establish
minimum densities for multi-family and mixed-
use projects) and H1.10 (allow housing by-right
for prior housing sites that propose a minimum
of 20 percent affordable). Zoning at these sites
would be at least 30 units per acre.
(h) shall be at least 20 units per acre in jurisdictions described in clauses (iii) and (iv) of subparagraph (B) of paragraph (3) of subdivision (c)
No rezoning is required to meet the RHNA
allocation. All sites in the inventory on which
lower income units are identified are zoned for
at least 30 units per acre.

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GOVERNMENT CODE PROVISION HOUSING ELEMENT COMPLIANCE
(h) and shall meet the standards set forth in subparagraph (B) of paragraph (5) of subdivision (b). All sites in the inventory have available and accessible sewer, water, and dry utilities supply
as described in base document page H-5.
(h) At least 50 percent of the very low and low-income housing need shall be accommodated on sites designated for residential use and for which nonresidential uses or mixed uses are not permitted, except that a city or county may accommodate all of the very low and low-income housing need on sites designated for mixed uses if those sites allow 100 percent residential use and require that residential use occupy 50 percent of the total floor area of a mixed-use project.

No rezoning is required to meet the RHNA
allocation. All sites in the inventory on which
lower income units are identified are zoned for
at least 30 units per acre
See base document H1.9 (code amendment to
require that properties designated for mixed
use sites in the Sites Inventory List to allow 100
percent residential uses and require that
residential uses occupy 50 percent or more of
the total floor area of a mixed-use project, and
establish a minimum density for mixed-use
projects elsewhere in the city).
(i) For purposes of this section and Section 65583, the phrase “use by right” shall mean that the local government’s review of the owner-occupied or multifamily residential use may not require a conditional use permit, planned unit development permit, or other discretionary local government review or approval that would constitute a “project” for purposes of Division 13 (commencing with Section 21000) of the Public Resources Code. Any subdivision of the sites shall be subject to all laws, including, but not limited to, the local government ordinance implementing the Subdivision Map Act. (i) A local ordinance may provide that “use by right” does not exempt the use from design review. However, that design review shall not constitute a “project” for purposes of Division 13 (commencing with Section 21000) of the Public Resources Code.
(i) Use by right for all rental multifamily residential housing shall be provided in accordance with subdivision (f) of Section 65589.5.
(j) Notwithstanding any other provision of this section, within one-half mile of a Sonoma-Marin Area Rail Transit station, housing density requirements in place on June 30, 2014, shall apply.

39 of 1732

40 of 1732

Exhibit B
Revisions in Response to HCD Comment Letter dated September 28, 2022 Comment
Number Section HCD Comment City Response Location
1 Past
Housing
Element
Review
As part of the evaluation of programs in the past cycle, the element must analyze the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers and persons experiencing homelessness). Programs should be revised as appropriate to reflect the results of this evaluation.

Reviewed/updated past HE evaluation to
analyze effectiveness, and identified areas
where GPPs in 23-31 HE will be
strengthened/expanded, as needed.

See Appendix E
and base
document H-
90 2 Needs -
AFFH
Fair Housing Issues: The element must include other relevant factors that contribute to fair housing issues in the jurisdiction. For instance, the element can analyze historical land use and investment practices or other information and demographic trends
The requested information has been
updated.

See Appendix D
H-D-6, and H-D-
17 et seq.
3 Needs -
AFFH
Enforcement: While the element lists fair housing laws in Appendix D, it must state whether the City complies with federal and state fair housing laws. If the City does not currently comply, a program should be added as appropriate.

Revised 23-31 HE to add more specific
language on how it complies with federal
and state fair housing laws.

See Appendix D
H-D-16 through
H-D-23
4 Needs -
AFFH
Integration and Segregation: The element provided some data regarding segregation and integration of race, disability, familial status, and income. The element must describe the census tracts that have geographic concentrations of race (i.e., concentrations identified as white majority). In addition, the element must discuss and analyze data on persons with disabilities for trends over time and patterns across census tracts as well as evaluate patterns at a regional basis, comparing the City to the region. The element must also include a local and regional analysis of integration and segregation for familial status. Lastly, the element must describe and analyze concentrations of income geographically throughout the City.

Additional language has been added to
address this comment.

See Appendix D
H-D-24 through
H-D-49
5 Needs -
AFFH
Racial/Ethnic Areas of Concentration of Poverty and Affluence (R/ECAP): The element includes information relative to R/ECAP within the City but should also analyze where they are in the region. The element must also address concentrated areas of affluence both locally and regionally. The combination of the R/ECAP and areas of affluence analyses will help guide goals and actions to address fair housing issues. The analysis should evaluate the patterns and changes over time at a local (e.g., neighborhood to neighborhood) and regional level (e.g., city to region).

As information was not yet available on
RCAAs when the draft was submitted, it is
included in this revision.

See Appendix D
H-D-41 and
through H-D-

49. 41 of 1732

6 Needs -
AFFH
Disproportionate Housing Needs including Displacement: While the element includes some data on disproportionate needs, additional information is needed. The element must describe any geographic concentration of cost burden and overcrowding by tenure, as well as any concentrations of substandard housing both locally and regionally. In addition, the element must describe and analyze the census tracts with displacement risk. While the map depicts a lot of areas vulnerable to displacement, this must be supported with an analysis.

More narrative has been provided on
disproportionate needs.

See Appendix D
H-D-57 though
H-D-71
7 Needs -
AFFH
Sites Inventory: While the element includes a summary of some factors, the analysis must identify whether sites improve or exacerbate conditions and whether sites are isolated by income group. A full analysis should address the income categories of identified sites with respect to location, the number of sites and units by all income groups and how that affects the existing patterns for all components of the assessment of fair housing (e.g., segregation and integration, access to opportunity). If sites exacerbate conditions, the element should identify further program actions that will be taken to promote equitable quality of life throughout the community (e.g., anti-displacement and place-based community revitalization strategies).

The Draft HE contained an extensive
discussion of how the inventory relates to
AFFH criteria. This analysis was crafted by
Root Policy in conjunction with staff.

See Appendix D
H-D-72 through
H-D-77
8 Needs -
AFFH
Contributing Factors: The element identifies many contributing factors to fair housing issues. The element must prioritize these factors to better formulate policies and programs and carry out meaningful actions to Affirmatively Furthering Fair Housing (AFFH). In addition, the element must describe how the actions in Appendix D Fair Housing Plan are tied to the housing element programs and include implementation.

The 23-31 HE has been updated to include
prioritization of contributing factors.

See Appendix D
H-D-14 et seq.
9 Needs -
AFFH
Goals, Actions, Metrics, and Milestones: The element must be revised to add or modify goals and actions based on the outcomes of a complete analysis.

Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have specific commitment, metrics, and milestones as appropriate and must address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization and displacement protection.

The 23-31 HE Implementation Plan has been
revised to provide more defined metrics,
outcomes and timing, as appropriate.

See
implementation
plan in base
document,
beginning on H-

84. 10 Needs -
Other
Extremely Low-Income Households (ELI): The element must quantify the number of existing and projected ELI households, and also analyze their housing needs. The analysis of ELI housing needs should consider tenure and rates of overpayment.

This information is included in the needs
packet provided by ABAG and the 23-31 HE
has been updated to provide expand
information, including in AFFH.

See throughout
Appendix A,
starting on H-A-
22; see also
narrative
woven

42 of 1732

throughout
Appendix D.
11 Needs -
Other
Overpayment: The element must quantify and analyze the number of lower- income households overpaying by tenure (i.e., renter and owner).

This information has been added to
Appendix A.

See Appendix A
H-A-43 through
H-A-46
12 Needs -
Other
Housing Costs: While the element includes estimated rents for residents, it utilizes American Community Survey (ACS) data. The element should supplement census data with other sources (e.g., local knowledge).

This information was included in Appendix
A.

See Appendix A
H-A-41 through
H-A-43
13 Inventory Progress in Meeting the Regional Housing Need Allocation (RHNA): The City’s RHNA may be reduced by the number of new units built since June 30, 2022; however, the element must demonstrate their affordability based on actual sales price, rent level or other mechanisms ensuring affordability (e.g., deed restrictions). The element should also discuss the status, any barriers to development and other relevant factors to demonstrate their availability in the planning period.

Detailed information for pipeline projects, as
well as other sites in the Sites Inventory,
added to Appendix C.

See detailed
sites discussion
in Appendix C,
beginning on
page H-C-22.
14 Inventory Realistic Capacity: While the element provides assumptions of buildout for sites included in the inventory, it must also provide support for these assumptions. For example, the element should demonstrate what specific trends, factors, and other evidence led to the assumptions. The estimate of the number of units for each site must be adjusted as necessary, based on the land use controls and site improvements and typical densities of existing or approved residential developments at a similar affordability level. The element currently assumes realistic capacity at 100 percent of base zoned density for multifamily units in R-3, R-4, and R-5 zones. The analysis must provide substantial support and demonstrate a history of developing at maximum density within the City. Examples to support realistic capacity assumptions should also include affordability levels, and percent of maximum densities.

The 23-31 HE has been updated to provide
additional narrative to support and justify
using 100% of zoned capacity as the realistic
capacity for a site on the Sites Inventory.

See base
document for
detailed
methodology of
inventory (H-27
et seq.). Also
see detailed
sites discussion
in Appendix C.
15 Inventory The calculation of residential capacity must also account for the likelihood of residential development in zoning where 100 percent nonresidential uses are allowed. The analysis should be based on factors such as development trends including nonresidential, performance standards requiring residential uses or other relevant factors such as enhanced policies and programs. For example, the element could analyze all development activity in these nonresidential zones, how often residential development occurs and adjust residential capacity calculations, policies, and programs accordingly.

Additional language has been added to the
23-31 HE to address this comment
See base
document for
detailed
methodology of
inventory (H-27
et seq.). Also
See detailed
sites discussion
in Appendix C.

43 of 1732

16 Inventory Small and Large Sites: Sites smaller than an half acre and larger than 10 acres in size are deemed inadequate to accommodate housing for lower-income housing unless it is demonstrated that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower-income housing units as projected for the site or unless the housing element describes other evidence to HCD that the site is adequate to accommodate lower-income housing (Gov. Code, § 65583.2, subd. (a) (3) This information is provided in 23-31 HE
narrative (i.e. Concar Passage) for large sites;
there are no small sites that have been
identified as potentially affordable.

See base
document H-35
through H-37
17 Inventory In addition, the element must describe feasibility of the Hillsdale and Bridgepointe sites including likelihood of development during the planning period, whether a specific plan is needed, and if the existing uses will remain. 23-31 HE has been updated to include
additional information on individual
development sites, including Hillsdale Mall
and Bridgepointe Shopping Center.

See base
document H-35
through H-37
18 Inventory Lastly the element must describe a history of lot consolidation as a method of developing housing as well as whether the City has any incentives to consolidate lots with different owners.

Analysis added to Appendix C with specific
projects identified
See Appendix C
H-C-14 and
individual sites
analyses.
19 Inventory Suitability of Nonvacant Sites: The element must include an analysis demonstrating the potential for redevelopment of nonvacant sites. To address this requirement, the element describes in general the existing use of each nonvacant site, for example, “commercial” or “parking lot”. This alone is not adequate to demonstrate the potential for redevelopment in the planning period. The description of existing uses should be sufficiently detailed to facilitate an analysis demonstrating the potential for additional development in the planning period.

Greater analysis of individual sites has been
included in the Housing Resources Appendix
and a new policy added to the 23-31 HE.

See individual
sites' analysis in
Appendix C,
beginning on H-
C-14, and base
document new
Policy H4.5
(conduct
outreach to
Sites Inventory
property
owners).

44 of 1732

20 Inventory In addition, the element must analyze the extent that existing uses may impede additional residential development. For example, the element includes sites identified as parking lots, church, gas station, an auto repair, and a warehouse; but must also demonstrate whether these existing uses would impede development of these sites within the planning period. The element can summarize past experiences converting existing uses to higher density residential development, include current market demand for the existing use, provide analysis of existing leases or contracts that would perpetuate the existing use or prevent additional residential development and include current information on development trends and market conditions in the City and relate those trends to the sites identified. The element could also consider indicators such as age and condition of the existing structure, expressed developer interest, existing versus allowable floor area, low improvement to land value ratio, and other factors.

Greater analysis of individual sites has been
included in the Housing Resources Appendix.

See individual
sites' analysis in
Appendix C.

Some sites
were removed
or realistic
capacity was
reduced based
on additional
analysis.
21 Inventory In addition, as noted in the housing element, the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households. For your information, the housing element must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period (Gov. Code, § 65583.2, subd. (g)(2).). Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the regional housing need allocation.

Additional analysis and information has
been included in the Housing Resources
Appendix to justify the inclusion of non-
vacant sites in the inventory.

Appendix C, H-
C-14 et seq.

The required
findings are
also included in
the HE
Adoption
Resolution.
22 Inventory City-Owned Sites: The element must include additional discussion on each of the City- owned sites identified to accommodate the RHNA. Specifically, the analysis should address general plan designations, allowable densities, support for residential capacity assumptions, existing uses and any known conditions that preclude development in the planning period and the potential schedule for development. If zoning does not currently allow residential uses at appropriate densities, then the element must include programs to rezone sites pursuant to Government Code section 65583.2, subdivisions (h) and (i). In addition, the housing element must include a description of whether there are any plans to sell the property during the planning period and how the jurisdiction will comply with the Surplus Land Act Article 8 (commencing with Section 54220) of Chapter 5 of Part 1 of Division 2 of Title 5.

Two City-owned sites were identified on the
sites inventory list - 445 S. B Street (APN:
034-179-050;-060) and 505 S. B Street (APN:
042-242-170). The City has a preliminary
agreement with a developer to construct a
60-unit, 100% affordable housing project at
445 S. B Street. The 505 S. B Street site has
been removed as it does not appear feasible
for housing development during this cycle.

The 23-31 HE and Appendix C have been
updated to provide further information
about the 445 S. B St site.

Base
document, H-
41 and H-42;
and Appendix
C, detailed sites
narratives.

45 of 1732

23 Inventory Replacement Housing Requirements: If the sites inventory identifies sites with existing residential uses, it must identify whether the current residential uses are affordable to lower-income households or describe whether the additional residential development on the site requires the demolition of the existing residential use. For nonvacant sites with existing, vacated, or demolished residential uses and occupied by, or subject to an affordability requirement for, lower-income households within the last five years there must be a replacement housing program for units affordable to lower-income households. (Gov. Code, § 65583.2, subd. (g)(3).)
Absent a replacement housing program, these sites are not adequate sites to accommodate lower-income households. The replacement housing program has the same requirements as set forth in Government Code section 65915, subdivision (c)(3). The housing element must be revised to include such analysis and a program, if necessary.

The sites inventory table identifies sites with
existing residential uses and a preliminary
check indicated that none of these units are
deed restricted or affordable to low-income
households. The City has an existing
replacement housing program under the
Housing Crisis Act. The Housing Element
includes a policy (H-2.6) to require no net
loss of all housing units (per the Housing
Crisis Act sunset date of 2034) and to study
implementation beyond 2034.

See revised
language in
base document
H-45 and Policy
H2.6.
24 Inventory Previously Identified Nonvacant and Vacant Sites: If nonvacant sites identified in a prior adopted housing element or vacant sites identified in two or more consecutive planning periods, the sites are inadequate to accommodate housing for lower-income households unless:
• The site’s current zoning is appropriate for the development of housing affordable to lower-income households by either including analysis or meeting the appropriate density and
• The site is subject to a housing element program that requires rezoning within three years of the beginning of the planning period to allow residential use by right for housing developments in which at least 20 percent of the units are affordable to lower-income households. (Gov. Code, § 65583.2, subd. (c).) A program has been added to address this
comment.

See base
document
Policy H1.10.
25 Inventory Accessory Dwelling Units (ADU): The element projects 480 ADUs over the planning period or approximately 60 ADUs per year over the eight-year planning period. The element also notes permitting 44 ADUs in 2019, 47 in 2020, and 66 in 2021. The trend does not consider the number of permits in 2018 (eight ADUs) and does not support an assumption of 60 ADUs per year.

To support assumptions for ADUs in the planning period, the element should reduce the number of ADUs assumed per year and reconcile trends with HCD records, including additional information such as more recent permitted units and inquiries, resources and incentives, other relevant factors and modify policies and programs as appropriate. Further, programs should commit to additional incentives and strategies, frequent monitoring (every other year) and specific commitment to adopt alternative measures such as rezoning or amending the element within a specific time (e.g., six months) if needed.

More analysis and discussion has been
added to the 23-31 HE, the ADU production
estimates have been adjusted to align with
the four-year permitting average and the
policy has updated with more detailed/new
implementation programs has been added
to ensure ongoing monitoring, compliance
with state law and robust ADU development
to meet production estimates.

See base
document H-39
and H-40, and
Policy H1.4.

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26 Inventory AB 725: For jurisdictions that are considered Metropolitan, the element must identify at least 25 percent of the remaining moderate and above moderate RHNA on sites that allow at least four units of housing (e.g., four plex or greater) (Gov. Code, § 65583.2, subd. (c)(4)).

Language has been included to address this
requirement.

See base
document H-45
27 Inventory Infrastructure: While the element includes a general discussion on water and sewer capacity, it must demonstrate sufficient existing or planned water and sewer capacity to accommodate the City’s regional housing need for the planning period. (Gov. Code, § 65583.2, subd. (b).).

The 23-31 HE is using existing zoning
capacity to meet its RHNA, and both of the
City's water providers have an adopted
Urban Water Management Plans based on
this existing zoning capacity; sewer capacity
has been demonstrated with the current
and future treatment plant.

See base
document H-19
and H-20; and
new Policy
H1.20
28 Inventory In addition, the element generally mentions infrastructure constraints for infill development. The element must describe and analyze the constraints as well as their impacts on the identified sites to meet the RHNA.

The individual sites analysis in Housing
Resources includes site-by-site discussion of
infrastructure constraints. In addition, added
narrative is found in Appendix B.

See Appendix B
H-B-17 and H-
B- 51, and
individual sites
tear sheets in
Appendix C
29 Inventory For your information, water and sewer service providers must establish specific procedures to grant priority water and sewer service to developments with units affordable to lower-income households. (Gov. Code, § 65589.7.) Local governments are required to immediately deliver the housing element to water and sewer service providers. HCD recommends including a cover memo describing the City ’s housing element, including the City’s housing needs and regional housing need. The element should demonstrate compliance with these requirements and add or modify programs, if necessary. For additional information and sample cover memo, see the Building Blocks at https://www.hcd.ca.gov/priority-for-water-and-sewer.

The 23-31 HE includes information to
demonstrate compliance with this
requirement.

See base
document H-19
and H-20; and
new Policy
H1.20
30 Inventory Environmental Constraints: While the element generally describes a few environmental conditions within the City (p. H-B-44), it must relate those conditions to identified sites and describe any other known environmental or other constraints that could impact housing development on identified sites in the planning period.

The individual sites analysis in Housing
Resources includes site-by-site discussion of
infrastructure constraints.

See Appendix C
individual sites
tear sheets
starting on H-C-
16 47 of 1732

31 Zoning for
Housing
Types
Emergency Shelters: The housing element must demonstrate the permit processing, development, and management standards for emergency shelters are objective and encourage and facilitate the development of, or conversion to, emergency shelters. In particular, the element describes development standards for emergency shelters; however these standards are beyond the development standards allowed under housing element law. The element must demonstrate that emergency shelters are subject to the same development and management standards applicable to residential or commercial development within the same zone except for those standards prescribed by Government Code section 65583 (a)(4)(A).
32 Zoning for
Housing
Types
The element must also clarify that emergency shelters are allowed without discretionary action in the C2 zone and describe sufficient and suitable capacity in the identified zone.
33 Zoning In addition, the element should describe how emergency shelter parking requirements comply with AB139/Government Code section 65583, subdivision (a)(4)(A) or include a program to comply with this requirement.

The Constraints Analysis provides general
information about zoning capacity,
strategies and programs to provide
emergency shelters and address
homelessness. In addition, a new policy has
been added to address this comment.

See Appendix B
H-B-39 et seq.,
and base
document
Policy H3.7 with
explicit
references to
the code.
34 Zoning Low Barrier Navigation Centers: While the element includes a program to allow Low Barrier Navigation Centers, it is limited to emergency shelter zones.

Low Barrier Navigation Centers shall be a use by-right in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65660. The element must demonstrate compliance with this requirement and include programs as appropriate.

Discussion in Constraints Analysis has been
updated to include information on these
uses, and a new program addresses this
comment.

See Appendix B
H-B-42 et seq.;
and base
document
Policy H3.7.
35 Zoning Single Room Occupancy (SRO) Units: The element must describe where SROs are allowed or add a program as appropriate.

The 23-31 HE has been updated to include a
program that explicitly identifies where
SROs can be located.

See base
document
Policy H1.7.
36 Zoning Manufactured Housing: The element must clarify whether manufactured homes are subject to additional regulations beyond state law if on a permanent foundation and add a program as needed
The 23-31 HE has been updated to include a
program to explicitly allow manufactured
housing and be subject to the same zoning
requirements as single-family homes.

See base
document
Policy H1.7.
37 Zoning Accessory Dwelling Unit (ADU): The element indicates the City modifies its zoning code to ease barriers to the development of ADU’s. However, after a cursory review of the City’s ordinance, HCD discovered several areas which are not consistent with State ADU Law. HCD will provide a complete listing of ADU non-compliance issues under a separate cover. As a result, the element should add a program to update the City’s ADU ordinance in order to comply with state law. For more information, please consult HCD’s ADU Guidebook, published in December 2020, which provides detailed information on new state requirements surrounding ADU development
The City has still not received a letter from
HCD which identifies the non-compliance
issues with the City’s ADU Ordinance;
however, a program has been added to
address this comment once it has been
received.

See base
document
Policy H1.4.

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38 Constraints Land Use Controls: The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types. The analysis should analyze land use controls independently and cumulatively with other land use controls. The analysis should specifically address requirements related to parking, heights, lot coverage and limits on allowable densities. The analysis should address any impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints.

The Constraints Analysis has been updated
throughout to address this comment.

See Appendix B
in its entirety.
39 Constraints The element must analyze the maximum heights of 35 feet in multifamily zones and whether three-story buildings are allowed as well as whether allowed densities can be met in the TOD Hillsdale Station with a 24-foot height restriction.

The maximum height in multi-family zones
ranges between 35 to 55 feet. There are no
limits on building stories in the City. The
Hillsdale Station TOD area allows maximum
heights of 24 feet to 55 feet. The 24 feet
height limit applies to single-family zoned
parcels in the Hillsdale TOD Specific Plan.

The narrative has been edited in the Land
Use Controls section (Table 2) to clarify the
height requirements as up to 55 feet.

See Appendix
B, beginning on
H-B-5
40 Constraints The element should also analyze the open space requirements for the R-3 zone.

A program was identified to study
impediments to missing middle housing
(including open space requirements). The
Constraints Analysis was updated to
evaluate the impacts.

See Appendix B
H-B-6 and base
document
Policy H1.13.
41 Constraints In addition, the element should analyze requiring more than one parking space for studio and one-bedroom units and the minimum requirement of 2.2 spaces for 1,400 square foot units regardless of bedroom size and add programs to specifically address the constraints.

Additional narrative has been added to
address this comment, and a policy has been
amended to reflect compliance a variety of
parking requirements.

See Appendix B
H-B-11 and
base document
Policy H1.7.
42 Constraints In addition, the element should clarify how multifamily developments are allowed in the E and C zones and whether they require a use permit.

Both in the element and in public comments, height restrictions, floor area definitions, maximum densities of 50 dwelling units an acre, and design review guidelines were identified as constraints to development and should be addressed in programs as appropriate.

Multi-family developments are allowed in
certain E and C zones, both by-right and
through a Special Use Permit (noted in
Appendix B, Section 2.7.7). The 23-31 HE
analysis and policies have been updated to
address this comment as follows:
- Revise floor area definition (Policy H1.7)
- Adopt Objective Design Standards (Policy
H1.8).
- Existing height and density requirements
do not preclude multi-family development
or prevent the City from meeting its RHNA.

See Appendix B
H-B-5 and base
document
Policies H1.7,
H1.8, H1.13,
and H1.21

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- The General Plan Update process is
anticipated to allow for increased heights
and densities.
43 Constraints Fees and Exaction: The element must describe all required fees for single family and multifamily housing development, including impact fees, and analyze their impact as potential constraints on housing supply and affordability. For example, the analysis could identify the total amount of fees and their proportion to the development costs for both single family and multifamily housing. While Table 4 lists fee deposits, the element should also include typical fees for each and clarify whether the fees are the same for single family and multifamily developments.

Constraints Analysis included fees and
analysis by typical single-family and multi-
family development (Table 6). Additional
narrative has been included to add to the
analysis.

See Appendix B
beginning on H-
B-20
44 Constraints The element should also identify fees related to annexation, variances, conditional use permits (CUP), general plan amendments, zone changes, site plan review, planned unit developments, specific plans, development agreements, and environmental fees. Table 6 should also describe the typical fees as a percent of the total development cost for both single family and multifamily developments and add a program as appropriate.

Additional narrative and analysis have been
included.

See Appendix B
beginning on H-
B-20 and then
beginning on H-
B-31, as well as
Table 6.
45 Constraints Local Processing and Permit Procedures: While the element includes information about processing times, it should also describe the procedures for a typical single family and multifamily development. The analysis should address the approval body, the number of public hearing if any, approval findings and any other relevant information, specifically for special use permits, site plans and architectural review (as well as whether finding five is related to a crime free ordinance). The analysis should address impacts on housing cost, supply, timing and approval certainty. The element should identify and analyze approval findings for impacts on approval certainty, the presence of processes or guidelines to promote certainty and add or modify programs as appropriate. The element should also clarify whether the listed typical approval times are for both single family and multifamily developments. Lastly, it should clarify whether the preapplication process adds six to nine months in addition to the typical approval times listed and add or modify programs as appropriate.

Additional narrative and analysis have been
included.

See Appendix B
beginning on H-
B-24
46 Constraints Local Ordinances: While the element identifies the City’s community benefit program, it must describe whether the incentives are in addition to state density bonus law. The element must clarify how the 75 dwelling units an acre allowed using the community benefit program interacts with the restricted densities under measure Y. In addition, the element must describe how the inclusionary program, community benefit program, and state density bonus law interact with incentives provided.

Constraints analysis has been updated to
describe the envisioned layering of density
bonus and community benefits.

See Appendix B
H-B-13 and
Policy H1.3.

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47 Constraints Zoning Fees and Transparency: The element must clarify its compliance with new transparency requirements for posting all zoning and development standards, and inclusionary requirements for each parcel on the jurisdiction’s website pursuant to Government Code section 65940.1(a)(1).

The constraints section states that the City
meets all transparency requirements for
Gov. Code Section 65940.1(a)(1).

See Appendix
B, Section 2.7.1,
links to
webpages
added in
footnotes,
cross-
references in
Sections 2.7.1
& 2.7.2
48 Constraints Measure Y: The element must describe the impacts of Measure Y on height and density restrictions as a constraint on housing development and affordability. The element must add a program to include outreach and mitigation measures for the impact of Measure Y on housing development throughout the planning period. The element should analyze the measure as a constraint on development based on site suitability for development.

The 23-31 HE identifies a path to meeting
the City's 6th cycle RHNA allocation within
the limits of Measure Y; and Measure Y was
discussed in the Constraints Analysis, noting
it as non-governmental constraint on
housing production that results in additional
sites needed to meet the City's RHNA. The
community discussion about Measure Y and
housing growth in the City over the next 20
years is happening and will continue as part
of the GPU adoption process. New narrative
added to the HE.

See Appendix B
beginning on
page H-B-55,
and base
document H-40
and Policy
H1.21
49 Constraints State Density Bonus Law: The City’s current density bonus ordinance should be reviewed for compliance with current state density bonus law and programs should be added as necessary. (Gov. Code, § 65915.) The City's current Density Bonus Ordinance
was last updated in 2018 and may not be
fully consistent with State law. The City has
been defaulting to the state statutes for
implementation. A policy has been added to
review and update as necessary to be
consistent with state law.

See base
document
Policy H1.3
(update
ordinance in
2023-24).
50 Constraints Design Review: The element must describe and analyze the design review guidelines and process, including approval procedures and decision-making criteria, for their impact as potential constraints on housing supply and affordability. For example, the analysis could describe required findings and discuss whether objective standards and guidelines improve development certainty and mitigate cost impacts. The element must demonstrate this process is not a constraint or include a program to address this permitting requirement, as appropriate.

The City is in the process of developing
Objective Design Standards and has a
program to implement. Additional narrative
has been provided to address this comment.

See Appendix B
H-B-29 et seq.,
and base
document
Policy H1.6.
51 Constraints On/Off-Site Improvements: The element must identify subdivision level improvement requirements, such as minimum street widths (e.g., 40-foot The Constraints Analysis has been updated
to provide additional narrative to address
this comment.

See Appendix B
H-B-18

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minimum street width) and analyze their impact as potential constraints on housing supply and affordability.
52 Constraints Constraints on Housing for Persons with Disabilities: The element briefly describes its reasonable accommodation procedures. However, the element should also describe the process and decision-making criteria such as approval findings and analyze any potential constraints on housing for persons with disabilities.

More narrative has been included on the
City's Reasonable Accommodation
requirements, including those that can be
accomplished by-right.

See Appendix B
beginning on H-
B-38
53 Constraints In addition, the element states that Policy H.1.14 commits to revise the definition of family, but there are no actions within the program to revise the definition of family to remove constraints. The element must add or revise a program to remove the constraints as noted.

A program has been modified to address this
comment.

See base
document
Policy H1.14
54 Constraints Lastly, group homes for seven or more persons appears to be excluded from several zones allowing residential uses and subject to a CUP. The element should evaluate these requirements as constraints and include specific commitment to amend zoning and permit procedures to allow these uses in all residential zones with objectivity to facilitate approval certainty.

This was included as a program to allow
larger group homes consistent with State
law and fair housing requirements.

Additional narrative has been added to the
constraints section about group homes.

See Appendix B
H-B-37 et seq.
and base
document
Policy H1.14
(updated)
55 Constraints Developed Densities and Permit Times: The element must be revised to include analysis of requests to develop housing at densities below those anticipated, and the length of time between receiving approval for a housing development and submittal of an application for building permits that potentially hinder the construction of a locality’s share of the regional housing need.

The Draft HE included an analysis of time
lapse between planning approval and
building permit submittal, as well as
requests for developments at reduced
densities.

See Appendix B
H-B-51
56 Needs Special Needs Populations: While the element quantifies the City’s special needs populations, it must also analyze their special housing needs. For a complete analysis of each population group, the element should discuss challenges faced by the population, the existing resources to meet those needs (availability senior housing units, # of large units, # of deed restricted units, etc.), an assessment of any gaps in resources, and proposed policies, programs, and funding to help address those gaps. In addition, the element must quantify and analyze the number of elderly persons in the City This information was provided in the needs
packet supplied by ABAG, and in other
places throughout the Element (such as in
the resources section).

See both
Appendix A
(Needs) as well
as Appendix D
(AFFH).
57 GPPs To address the program requirements of Government Code section 65583, subdivision (c)(1-6), and to facilitate implementation, programs should include: (1) a description of the City’s specific role in implementation; (2) definitive implementation timelines; (3) objectives, quantified where appropriate; and (4) identification of responsible agencies and officials.

Programs to be revised include the following:

With respect to all comments on programs
requiring additional information, please see
the revised implementation plan at the end
of the 23-31 HE for revisions.

See base
document
GPPs.

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58 Policy 1.2 (Utilize Public Funding): This program should include proactive outreach to developers throughout the planning period as well as a geographic target for the metric.

Policy has been updated. Policy H1.2
59 Policy 1.4 (Incentivize ADU Development): This program should revise action C to include discrete timing of how often it will be completed and monitored. In addition, action D should include back-up actions if estimates are not met (e.g., identify additional sites or provide additional incentives) as well as monitor affordability.

Policy has been updated. Policy H1.4
60 Policy 1.5 (Encourage Family Housing): The program should include back-up actions, with specific timing, if the identified incentives are not implemented.

The current program measure and
implementation action discuss proposing 3-
bedroom affordable units as part of the
City's inclusionary requirements. However,
this requires further study before
implementation. Back up implementation
measure added.

Policy H1.5
61 Policy 1.6 (Streamline Housing Application Review): Action B must include specific timing of when permit application requirements will be updated. In addition, the timing of action C must be completed earlier in the planning period.

Policy has been updated. Policy H1.6
62 Policies 1.15 (Supportive Housing Requirements) and 1.16 (Mobile Home Parks): These programs must revise timing to be implemented earlier in the planning period for a beneficial impact.

Policy has been updated. Policy H1.15
63 Policy 1.17 (Farmworker Housing): This program must move up timing to be implemented earlier in the planning period. In addition, the program should cite the Government Code for farmworker housing.

Policy has been updated. Policy H1.17
64 Policy 1.18 (Permitting and Development Fee Review): This program must clarify timing in Action A, specifically whether the study will be complete within the identified timeframe or if the fees will be reduced by that date. In addition, Action B must specify when the first review will occur and when adjustments will take place.

Policy has been updated. Policy H1.18
65 Policy 1.19 (Senior Housing): This program must clarify what potential actions will be implemented for seniors as well as whether other special needs groups are included in the program.

Policy has been updated. Policy H1.19
66 Policy 2.1 (Housing Rehabilitation Efforts), 2.3 (Energy and Water Efficiency),

3.4 (Expand Tenant Protections), and 4.3 (Community Education and Outreach): This program must describe how often outreach will occur throughout the planning period.

Policies have been updated. See base
document,
implementation
programs
updated for
each of the

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referenced
policies
67 Policy 3.3 (Evaluate Housing Revenue Sources): This program must describe the implementation component for action A.

Policy has been updated. Policy H3.3
68 Policy 3.5 (Creation of Below Market Rate Set Asides): This program must add implementation and timing for what will result from the study.

Policy has been updated. Policy H3.5
69 Policy 4.2 (Countywide Below Market Rate Unit Waitlist): This program must clarify how support will be provided as well as how often throughout the planning period.

Policy has been updated. Policy H4.2
70 Policy 4.4 (Enable Affirmative Marketing): Timing must be clarified to state whether the marketing will occur once in the planning, or on a project-by- project basis.

Policy has been updated. Policy H4.4
71 Policy 5.1.2 (Regional Down Payment Assistance): This program should include outreach for education.

Policy has been updated. Policy H5.1.2
72 Policy 5.2.2 (Incentivize Developers): This program must clarify whether incentives are in place, timing to implement the incentives, as well as conducting proactive outreach.

Policy has been updated. Policy H5.2.2
73 Policy 5.3.2 (Fund Minor Home Repairs): The program should clarify how often outreach will occur as well as specify whether the metrics are annually or throughout the planning period.

Policy has been updated. Policy H5.3.2
74 Policy 5.4.2 (Project Sentinel): This program should be revised to include outreach and describe how awareness will be increased.

Policy has been updated. Policy H5.4.2
75 Policy 5.4.3 (Fair Housing Webpage): This program should describe how often the website will be updated and whether outreach will be included.

Policy has been updated. Policy H5.4.3
76 Policy 5.4.5 (Future Improvements in Disadvantaged Communities): This program must include an action to implement the feasibility study as well as a back-up if the study is not implemented.

Policy has been updated. Policy H5.4.5
77 Other GPPs Policy 1.1 (Monitor RHNA): While this program ensures sufficient sites are identified, it should commit to identifying additional sites throughout the planning period if needed to accommodate the City’s RHNA.

Policy has been updated. Policy H1.1

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78 Other GPPs Policy 1.10 (Establish By-Right Housing for Prior Housing Sites) and 2.6:

Previously identified nonvacant sites are inadequate to accommodate the need for lower-income households unless the site is subject to a housing element program that requires rezoning within three years of the beginning of the planning period to allow residential use by-right for housing developments in which at least 20 percent of the units are affordable to lower-income households. (Gov. Code, § 65583.2, subd. (c).) The program must be revised to comply as well as clarify that the densities for the identified sites are appropriate for lower-income households. In addition, timing of Policy 2.6 should occur no later than 3 years from the start of the planning period.

Policy has been updated. Policy H1.10
79 Other GPPs Policy 1.12 (Encourage Residential Uses within Housing Overlay): The program must clarify which commercial zones will be included in the program actions.

Policy has been updated. Policy H1.12
80 Other GPPs Policy 2.4 (Capital Improvements in Lower-Resourced Neighborhoods): The program should describe what capital improvements will be included.

Policy has been updated. Policy H2.4
81 Other GPPs Policy 3.7 (Expanding Homeless Shelters): This program must clarify implementation actions after the study in action A. In addition, a government citation must be added for Action C and implementation timing must be earlier in the planning period to ensure beneficial impact.

Policy has been updated. Policy H3.7
82 Other GPPs While the element includes Policy 5.1.3 (Regional Forgivable Loan Program) to support the regional program to assist ELI households, it is a regional policy.

The element should specify what actions the City is taking to address the ELI need. The program should also specify whether proactive outreach will occur to implement the program.

Policy has been updated. Policy H5.1.3
83 Other GPPs Policy 1.3 (Increase Below Market Rate Unit Production): This program should be revised to include an action to comply with State Density Bonus law as well as specific timing for implementation. The program should clarify whether the action currently listed is in addition to state law requirements.

Policy has been updated. Policy H1.3
84 Other GPPs Policy 1.7 (Update Zoning Code Development Standards): This program must make a firm commitment to remove parking requirements that are a constraint to multifamily development.

Policy has been updated. Policy H1.7
85 Other GPPs Policy 1.13 (Encourage Development of Missing Middle Housing): This program should include specific implementation and specify whether the identified policies and codes will be revised to remove constraints.

Policy has been updated. Policy H1.13
86 Other GPPs Policy 1.14 (Evaluate and Update Special Needs Group Housing Requirements): This policy should commit to reviewing and revising procedural requirements to permit group homes for seven or more persons in all zones allowing residential uses based on objective criteria to facilitate Policy has been updated. Policy H1.14

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approval certainty. In addition, the program must be implemented earlier in the planning period to ensure a beneficial impact.
87 GPPs AFFH While programs in Table 13 include specific timelines, all programs in the element that AFFH must include specific metrics and milestones with geographic targets that address the fair housing analysis. In addition, Policy

5.2.1 (City Supported Housing) should specify what actions will be taken to add more affordable housing to moderate and high resource areas as well as whether incentives are provided.

Policy has been updated. Policy H5.2.1
88 Other GPPs Policy 2.2 (Retention of Existing Lower-Income Units) and 5.3.3 (Monitor Affordable Housing Projects) should reference State Preservation Notice Law (Gov. Code, § 65863.10, 65863.11, and 65863.13) and state noticing requirements to tenants and affected public entities. The program should also be expanded to include other potential at-risk properties not included in the analysis. HCD will send additional information under separate cover.

Policy has been updated. Policy H2.2
89 Quantified
Objectives
The element must include quantified objectives to establish an estimate of housing units by income category that can be constructed, rehabilitated, and conserved over the planning period. While the element includes these objectives for construction, it must also include estimates for rehabilitation and not limit conserved units to at-risk properties.

The City anticipates doing 31 rehab projects
annually through CDBG (248 over the eight
year cycle); and 10 CALHOME rehabs
annually (80 over the eight year cycle). This
information was included in the Draft.

See base
document H-89
90 Public
Participation
While the element includes a summary of public participation including outreach to the community, it must also describe whether translation services were available outside of the Let’s Talk Housing sessions.

Information on translation services has been
included in the public participation Appendix
and the 23-31 HE.

See base
document H-50
through H-52
and H-58 and
Appendix F
pages 458-467
91 Consistency
with the GP
While the element discusses how internal consistency will be achieved with other elements of the general plan as part of the housing element update, it should also discuss how internal consistency will be maintained throughout the planning period.

Additional narrative has been added to
address this comment.

See base
document, H-
19 56 of 1732

CITY OF SAN MATEO
RESOLUTION NO. ____ (2023)

A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF SAN MATEO, RECOMMENDING THAT THE CITY COUNCIL DECLINE TO ADOPT A GENERAL PLAN AMENDMENT TO REPEAL THE 2015-2022

HOUSING ELEMENT AND ADOPT THE HOUSING ELEMENT OF THE GENERAL PLAN FOR THE PERIOD OF 2023-2031, IN ORDER TO AFFIRMATIVELY FURTHER FAIR HOUSING AND TO COMPLY WITH STATE LAW

WHEREAS, the legislature has found that, “California has a housing supply and affordability crisis of historic proportions. The consequences of failing to effectively and aggressively confront this crisis are hurting millions of Californians, robbing future generations of the chance to call California home, stifling economic opportunities for workers and businesses, worsening poverty and homelessness, and undermining the state’s environmental and climate objectives.” (Gov. Code Section 65589.5.); and WHEREAS, the legislature has further found that, “Among the consequences of those actions are discrimination against low-income and minority households, lack of housing to support employment growth, imbalance in jobs and housing, reduced mobility, urban sprawl, excessive commuting, and air quality deterioration.” (Gov. Code Section 65589.5.); and WHEREAS, the legislature adopted the Housing Crisis Act of 2019 (SB 330) which states, “In 2018, California ranked 49th out of the 50 states in housing units per capita… California needs an estimated 180,000 additional homes annually to keep up with population growth, and the Governor has called for

3.5 million new homes to be built over 7 years;” and
WHEREAS, the State Housing Element Law (Government Code Sections 65580 et seq.) requires that the City Council adopt a Housing Element for the eight-year period of 2023-2031 to accommodate the City of San Mateo’s (City’s) regional housing need allocation (RHNA) of 7,015 housing units, comprised of 1,777 very low-income units, 1,023 low-income units, 1,175 moderate-income units, and 3,040 above moderate-income units; and
WHEREAS, the City has not prepared its 2023-2031 Housing Element (“Housing Element”) in full compliance with State Housing Element Law and has not identified a sufficient number of sites to fully and completely demonstrate that they can accommodate housing units to meet the City’s RHNA plus a buffer; and
WHEREAS, as provided in Government Code Section 65350 et seq., adoption of the Housing Element constitutes a General Plan Amendment; and
WHEREAS, Government Code Section 65354 requires that the Planning Commission make a written recommendation to the City Council on the adoption a General Plan Amendment; and WHEREAS, State law and San Mateo Municipal Code Section 27.06.040(b) require the Planning Commission to review and provide a recommendation to the City Council on General Plan Amendments; and

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WHEREAS, as provided in Government Code Sections 65352 – 65352.5, on April 22, 2022, the City mailed a public notice to all California Native American tribes on the contact list provided by the Native American Heritage Commission and other entities listed; and WHEREAS, no California Native American tribe requested consultation; and WHEREAS, the City has conducted extensive community outreach over the last two years, including 19 public and community meetings and workshops, five intercept/pop-up events, four surveys, and additional community engagement through partnership with 21 Elements (San Mateo County regional planning collaborative); and
WHEREAS, in accordance with Government Code Section 65585 (b), on April 6, 2022, the City published the Draft Housing Element and requested public comment for a 30-day review period, and on July 1, 2022, after responding to public comments, the City submitted the Draft Housing Element to the State Department of Housing and Community Development (HCD) for its first review; and WHEREAS, on September 28, 2022, the City received a letter from HCD providing its comments regarding the Draft Housing Element; and
WHEREAS, on December 30, 2022, the City published a Revised Draft Housing Element responding to HCD’s comments, and made the Revised Draft available for public review through January 9, 2023; and
WHEREAS, the Housing Element was reviewed for conformance with the California Environmental Quality Act and was found to be exempt under Section 15061(b)(3) as it can be seen with certainty that the proposed adoption of the Housing Element (which proposes no rezonings or intensification of land use) would not have a significant effect on the environment; and WHEREAS, on January 12, 2023, the Planning Commission conducted a duly and properly noticed public hearing to take public testimony and consider this Resolution regarding the Housing Element, reviewed the Housing Element and all pertinent maps, documents and exhibits, including HCD’s comments, the City’s response to HCD’s comments, the agenda report and all attachments, and oral and written public comments.

NOW, THEREFORE BE IT RESOLVED, THAT THE PLANNING COMMISSION OF THE CITY OF SAN MATEO, CALIFORNIA HEREBY finds and determines that, based on substantial evidence in the record:

1. The foregoing recitals are true and correct and are incorporated by reference into this action.

2. The Revised Draft Housing Element does not substantially comply with statutory requirements as follows:
a. The Sites Inventory does not include substantial evidence to demonstrate realistic capacity and housing development feasibility for all of the identified opportunity sites; b. The Fair Housing Plan does not fully address all Affirmatively Furthering Fair Housing (AFFH) requirements;
c. The Housing Element does not adequately address the City’s constraints to housing production necessary to meet its RHNA; and
d. The goals, policies and programs have not been sufficiently updated to address HCD comments.

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3. The Planning Commission recommends that the City Council decline to adopt the proposed 2023- 2031 Housing Element, which is incorporated by this reference.

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64 of 1732

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STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov

September 28, 2022

Christina Horrisberger, Director
Director of Community Department
City of San Mateo
330 West 20
th Avenue
San Mateo, CA 94403

Dear Christina Horrisberger:

RE: City of San Mateo’s 6
th Cycle (2023-2031) Draft Housing Element

Thank you for submitting the City of San Mateo’s (City) draft housing element received for review on July 1, 2022. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. Our review was facilitated by a conversation on August 31, 2022 with yourself, Zachary Dahl, Eloiza Murillo-Garcia, Manira Sandhir, Nicholas Vu, and consultant Diana Elrod. In addition, HCD considered comments from Housing Leadership Council, YIMBY Law and Greenbelt Alliance, One San Mateo,
Adam Nugent, and Adam Buchbinder pursuant to Government Code section 65585, subdivision (c).

The draft element addresses many statutory requirements; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code).

The enclosed Appendix describes the revisions needed to comply with State Housing Element Law.

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City should continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available and considering and incorporating comments where appropriate. Please be aware, any revisions to the element must be posted on the local government’s website and to email a link to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD.

For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if a local government fails to adopt a compliant housing element within 120 days of the statutory deadline (January 31, 2023), then any rezoning to accommodate the regional

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Christina Horrisberger, Director

housing needs allocation (RHNA), including for lower-income households, shall be completed no later than one year from the statutory deadline. Otherwise, the local government’s housing element will no longer comply with State Housing Element Law, and HCD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i).

Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD’s Affordable Housing and Sustainable Communities programs; and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City will meet housing element requirements for these and other funding sources.

We are committed to assist the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Hillary Prasad, of our staff, at [email protected] .

Sincerely,

Paul McDougall
Senior Program Manager

Enclosure

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APPENDIX

CITY OF SAN MATEO

The following changes are necessary to bring the City’s housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code.

Housing element technical assistance information is available on HCD’s website at https://www.hcd.ca.gov/hcd-memos
. Among other resources, the housing element section
contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at
https://www.hcd.ca.gov/building-blocks and includes the Government Code addressing State Housing Element Law and other resources.

A. Review and Revision

Review the previous element to evaluate the appropriateness, effectiveness, and progress in implementation, and reflect the results of this review in the revised element. (Gov. Code, § 65588 (a) and (b).)

The review requirement is one of the most important features of the element update. The review of past programs should analyze the City's accomplishments over the previous planning period. This information provides the basis for developing an effective housing program.

A thorough program-by-program review is necessary to evaluate City's performance in addressing housing goals. While the element describes actual results of the prior element’s programs, it must provide a description of how the objectives and programs of the updated element incorporate changes resulting from the evaluation.

As part of the evaluation of programs in the past cycle, the element must analyze the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers and persons experiencing homelessness). Programs should be revised as appropriate to reflect the results of this evaluation.

B. Housing Needs, Resources, and Constraints

1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).)

Fair Housing Issues: The element must include other relevant factors that contribute to fair housing issues in the jurisdiction. For instance, the element can analyze historical land use and investment practices or other information and demographic trends.

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Enforcement: While the element lists fair housing laws in Appendix D, it must state whether the City complies with federal and state fair housing laws. If the City does not currently comply, a program should be added as appropriate.

Integration and Segregation: The element provided some data regarding segregation and integration of race, disability, familial status, and income. The element must describe the census tracts that have geographic concentrations of race (i.e., concentrations identified as white majority). In addition, the element must discuss and analyze data on persons with disabilities for trends over time and patterns across census tracts as well as evaluate patterns at a regional basis, comparing the City to the region. The element must also include a local and regional analysis of integration and segregation for familial status.

Lastly, the element must describe and analyze concentrations of income geographically throughout the City.

Racial/Ethnic Areas of Concentration of Poverty and Affluence (R/ECAP): The element includes information relative to R/ECAP within the City but should also analyze where they are in the region. The element must also address concentrated areas of affluence both locally and regionally. The combination of the R/ECAP and areas of affluence analyses will help guide goals and actions to address fair housing issues. The analysis should evaluate the patterns and changes over time at a local (e.g., neighborhood to neighborhood) and regional level (e.g., city to region).

Disproportionate Housing Needs including Displacement: While the element includes some data on disproportionate needs, additional information is needed. The element must describe any geographic concentration of cost burden and overcrowding by tenure, as well as any concentrations of substandard housing both locally and regionally. In addition, the element must describe and analyze the census tracts with displacement risk. While the map depicts a lot of areas vulnerable to displacement, this must be supported with an analysis.

Sites Inventory: While the element includes a summary of some factors, the analysis must identify whether sites improve or exacerbate conditions and whether sites are isolated by income group. A full analysis should address the income categories of identified sites with respect to location, the number of sites and units by all income groups and how that affects the existing patterns for all components of the assessment of fair housing (e.g., segregation and integration, access to opportunity). If sites exacerbate conditions, the element should identify further program actions that will be taken to promote equitable quality of life throughout the community (e.g., anti-displacement and place-based community revitalization strategies).

Contributing Factors: The element identifies many contributing factors to fair housing issues. The element must prioritize these factors to better formulate policies and programs and carry out meaningful actions to Affirmatively Furthering Fair Housing (AFFH). In addition, the element must describe how the actions in Appendix D Fair Housing Plan are tied to the housing element programs and include implementation.

Goals, Actions, Metrics, and Milestones: The element must be revised to add or modify goals and actions based on the outcomes of a complete analysis. Goals and actions must

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specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have specific commitment, metrics, and milestones as appropriate and must address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization and displacement protection.

2. Include an analysis of population and employment trends and documentation of projections and a quantification of the locality's existing and projected needs for all income levels, including extremely low-income households. (Gov. Code, § 65583, subd. (a)(1).)

Extremely Low-Income Households (ELI): The element must quantify the number of existing and projected ELI households, and also analyze their housing needs. The analysis of ELI housing needs should consider tenure and rates of overpayment.

3. Include an analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).)

Overpayment: The element must quantify and analyze the number of lower-income households overpaying by tenure (i.e., renter and owner).

Housing Costs: While the element includes estimated rents for residents, it utilizes American Community Survey (ACS) data. The element should supplement census data with other sources (e.g., local knowledge).

4. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov.

Code, § 65583, subd. (a)(3).)

Progress in Meeting the Regional Housing Need Allocation (RHNA): The City’s RHNA may be reduced by the number of new units built since June 30, 2022; however, the element must demonstrate their affordability based on actual sales price, rent level or other mechanisms ensuring affordability (e.g., deed restrictions). The element should also discuss the status, any barriers to development and other relevant factors to demonstrate their availability in the planning period.

Realistic Capacity: While the element provides assumptions of buildout for sites included in the inventory, it must also provide support for these assumptions. For example, the element should demonstrate what specific trends, factors, and other evidence led to the assumptions. The estimate of the number of units for each site must be adjusted as necessary, based on the land use controls and site improvements and typical densities of existing or approved residential developments at a similar affordability level. The element currently assumes realistic capacity at 100 percent of base zoned density for multifamily units in R-3, R-4, and R-5 zones. The analysis must provide substantial support and demonstrate a history of developing at maximum density within the City. Examples to support realistic capacity assumptions should also include affordability levels, and percent of maximum densities.

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The calculation of residential capacity must also account for the likelihood of residential development in zoning where 100 percent nonresidential uses are allowed. The analysis should be based on factors such as development trends including nonresidential, performance standards requiring residential uses or other relevant factors such as enhanced policies and programs. For example, the element could analyze all development activity in these nonresidential zones, how often residential development occurs and adjust residential capacity calculations, policies, and programs accordingly.

Small and Large Sites: Sites smaller than an half acre and larger than 10 acres in size are deemed inadequate to accommodate housing for lower-income housing unless it is demonstrated that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower-income housing units as projected for the site or unless the housing element describes other evidence to HCD that the site is adequate to accommodate lower-income housing (Gov. Code, § 65583.2, subd. (c)(2)(A).). For example, a site with a proposed and approved housing development that contains units affordable to lower-income households would be an appropriate site to accommodate housing for lower-income households. (Gov. Code, § 65583.2, subd. (c)(2)(C).) In addition, the element must describe feasibility of the Hillsdale and Bridgepointe sites including likelihood of development during the planning period, whether a specific plan is needed, and if the existing uses will remain. Lastly the element must describe a history of lot consolidation as a method of developing housing as well as whether the City has any incentives to consolidate lots with different owners.

Suitability of Nonvacant Sites: The element must include an analysis demonstrating the potential for redevelopment of nonvacant sites. To address this requirement, the element describes in general the existing use of each nonvacant site, for example, “commercial” or “parking lot”. This alone is not adequate to demonstrate the potential for redevelopment in the planning period. The description of existing uses should be sufficiently detailed to facilitate an analysis demonstrating the potential for additional development in the planning period. In addition, the element must analyze the extent that existing uses may impede additional residential development. For example, the element includes sites identified as parking lots, church, gas station, an auto repair, and a warehouse; but must also demonstrate whether these existing uses would impede development of these sites within the planning period. The element can summarize past experiences converting existing uses to higher density residential development, include current market demand for the existing use, provide analysis of existing leases or contracts that would perpetuate the existing use or prevent additional residential development and include current information on development trends and market conditions in the City and relate those trends to the sites identified. The element could also consider indicators such as age and condition of the existing structure, expressed developer interest, existing versus allowable floor area, low improvement to land value ratio, and other factors.

In addition, as noted in the housing element, the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households.

For your information, the housing element must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning

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period (Gov. Code, § 65583.2, subd. (g)(2).). Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the regional housing need allocation.

City-Owned Sites: The element must include additional discussion on each of the City- owned sites identified to accommodate the RHNA. Specifically, the analysis should address general plan designations, allowable densities, support for residential capacity assumptions, existing uses and any known conditions that preclude development in the planning period and the potential schedule for development. If zoning does not currently allow residential uses at appropriate densities, then the element must include programs to rezone sites pursuant to Government Code section 65583.2, subdivisions (h) and (i). In addition, the housing element must include a description of whether there are any plans to sell the property during the planning period and how the jurisdiction will comply with the Surplus Land Act Article 8 (commencing with Section 54220) of Chapter 5 of Part 1 of Division 2 of Title 5.

Replacement Housing Requirements: If the sites inventory identifies sites with existing residential uses, it must identify whether the current residential uses are affordable to lower-income households or describe whether the additional residential development on the site requires the demolition of the existing residential use. For nonvacant sites with existing, vacated, or demolished residential uses and occupied by, or subject to an affordability requirement for, lower-income households within the last five years there must be a replacement housing program for units affordable to lower-income households. (Gov.

Code, § 65583.2, subd. (g)(3).) Absent a replacement housing program, these sites are not adequate sites to accommodate lower-income households. The replacement housing program has the same requirements as set forth in Government Code section 65915, subdivision (c)(3). The housing element must be revised to include such analysis and a program, if necessary.

Previously Identified Nonvacant and Vacant Sites: If nonvacant sites identified in a prior adopted housing element or vacant sites identified in two or more consecutive planning periods, the sites are inadequate to accommodate housing for lower-income households unless:

• The site’s current zoning is appropriate for the development of housing affordable to lower-income households by either including analysis or meeting the appropriate density and

• The site is subject to a housing element program that requires rezoning within three years of the beginning of the planning period to allow residential use by right for housing developments in which at least 20 percent of the units are affordable to lower-income households. (Gov. Code, § 65583.2, subd. (c).)

Accessory Dwelling Units (ADU): The element projects 480 ADUs over the planning period or approximately 60 ADUs per year over the eight-year planning period. The element also notes permitting 44 ADUs in 2019, 47 in 2020, and 66 in 2021. The trend does not consider the number of permits in 2018 (eight ADUs) and does not support an assumption

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of 60 ADUs per year. To support assumptions for ADUs in the planning period, the element should reduce the number of ADUs assumed per year and reconcile trends with HCD records, including additional information such as more recent permitted units and inquiries, resources and incentives, other relevant factors and modify policies and programs as appropriate. Further, programs should commit to additional incentives and strategies, frequent monitoring (every other year) and specific commitment to adopt alternative measures such as rezoning or amending the element within a specific time (e.g., six months) if needed.

AB 725: For jurisdictions that are considered Metropolitan, the element must identify at least 25 percent of the remaining moderate and above moderate RHNA on sites that allow at least four units of housing (e.g., four plex or greater) (Gov. Code, § 65583.2, subd. (c)(4)).

Infrastructure: While the element includes a general discussion on water and sewer capacity, it must demonstrate sufficient existing or planned water and sewer capacity to accommodate the City’s regional housing need for the planning period. (Gov. Code, § 65583.2, subd. (b).). In addition, the element generally mentions infrastructure constraints for infill development. The element must describe and analyze the constraints as well as their impacts on the identified sites to meet the RHNA.

For your information, water and sewer service providers must establish specific procedures to grant priority water and sewer service to developments with units affordable to lower-income households. (Gov. Code, § 65589.7.) Local governments are required to immediately deliver the housing element to water and sewer service providers. HCD recommends including a cover memo describing the City ’s housing element, including the City’s housing needs and regional housing need. The element should demonstrate compliance with these requirements and add or modify programs, if necessary. For additional information and sample cover memo, see the Building Blocks at https://www.hcd.ca.gov/priority-for-water-and-sewer
.

Environmental Constraints: While the element generally describes a few environmental conditions within the City (p. H-B-44), it must relate those conditions to identified sites and describe any other known environmental or other constraints that could impact housing development on identified sites in the planning period.

Zoning for a Variety of Housing Types:

• Emergency Shelters: The housing element must demonstrate the permit processing, development, and management standards for emergency shelters are objective and encourage and facilitate the development of, or conversion to, emergency shelters. In particular, the element describes development standards for emergency shelters; however these standards are beyond the development standards allowed under housing element law. The element must demonstrate that emergency shelters are subject to the same development and management standards applicable to residential or commercial development within the same zone except for those standards prescribed by Government Code section 65583 (a)(4)(A). The element must also clarify that emergency shelters are allowed

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without discretionary action in the C2 zone and describe sufficient and suitable capacity in the identified zone. In addition, the element should describe how emergency shelter parking requirements comply with AB139/Government Code section 65583, subdivision (a)(4)(A) or include a program to comply with this requirement.
• Low Barrier Navigation Centers: While the element includes a program to allow Low Barrier Navigation Centers, it is limited to emergency shelter zones. Low Barrier Navigation Centers shall be a use by-right in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65660. The element must demonstrate compliance with this requirement and include programs as appropriate. • Single Room Occupancy (SRO) Units: The element must describe where SROs are allowed or add a program as appropriate.
• Manufactured Housing: The element must clarify whether manufactured homes are subject to additional regulations beyond state law if on a permanent foundation and add a program as needed.
• Accessory Dwelling Unit (ADU): The element indicates the City modifies its zoning code to ease barriers to the development of ADU’s. However, after a cursory review of the City’s ordinance, HCD discovered several areas which are not consistent with State ADU Law. HCD will provide a complete listing of ADU non-compliance issues under a separate cover. As a result, the element should add a program to update the City’s ADU ordinance in order to comply with state law. For more information, please consult HCD’s ADU Guidebook, published in December 2020, which provides detailed information on new state requirements surrounding ADU development.

5. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).)

Land Use Controls: The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types. The analysis should analyze land use controls independently and cumulatively with other land use controls. The analysis should specifically address requirements related to parking, heights, lot coverage and limits on allowable densities. The analysis should address any impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints. The element must analyze the maximum heights of 35 feet in multifamily zones and whether three-story buildings are allowed as well as whether allowed densities can be met in the TOD Hillsdale Station with a 24-foot height restriction. The element should also analyze the open space requirements for the R-3 zone. In addition, the element should analyze requiring more than one parking space for studio and one-bedroom units and the minimum requirement of 2.2 spaces for 1,400 square foot units regardless of bedroom size and add programs to specifically address the constraints. In addition, the element should clarify

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how multifamily developments are allowed in the E and C zones and whether they require a use permit. Both in the element and in public comments, height restrictions, floor area definitions, maximum densities of 50 dwelling units an acre, and design review guidelines were identified as constraints to development and should be addressed in programs as appropriate.

Fees and Exaction: The element must describe all required fees for single family and multifamily housing development, including impact fees, and analyze their impact as potential constraints on housing supply and affordability. For example, the analysis could identify the total amount of fees and their proportion to the development costs for both single family and multifamily housing. While Table 4 lists fee deposits, the element should also include typical fees for each and clarify whether the fees are the same for single family and multifamily developments. The element should also identify fees related to annexation, variances, conditional use permits (CUP), general plan amendments, zone changes, site plan review, planned unit developments, specific plans, development agreements, and environmental fees. Table 6 should also describe the typical fees as a percent of the total development cost for both single family and multifamily developments and add a program as appropriate.

Local Processing and Permit Procedures: While the element includes information about processing times, it should also describe the procedures for a typical single family and multifamily development. The analysis should address the approval body, the number of public hearing if any, approval findings and any other relevant information, specifically for special use permits, site plans and architectural review (as well as whether finding five is related to a crime free ordinance). The analysis should address impacts on housing cost, supply, timing and approval certainty. The element should identify and analyze approval findings for impacts on approval certainty, the presence of processes or guidelines to promote certainty and add or modify programs as appropriate. The element should also clarify whether the listed typical approval times are for both single family and multifamily developments. Lastly, it should clarify whether the preapplication process adds six to nine months in addition to the typical approval times listed and add or modify programs as appropriate.

Local Ordinances: While the element identifies the City’s community benefit program, it must describe whether the incentives are in addition to state density bonus law. The element must clarify how the 75 dwelling units an acre allowed using the community benefit program interacts with the restricted densities under measure Y. In addition, the element must describe how the inclusionary program, community benefit program, and state density bonus law interact with incentives provided.

Zoning Fees and Transparency: The element must clarify its compliance with new transparency requirements for posting all zoning and development standards, and inclusionary requirements for each parcel on the jurisdiction’s website pursuant to Government Code section 65940.1(a)(1).

Measure Y: The element must describe the impacts of measure Y on height and density restrictions as a constraint on housing development and affordability. The element must add a program to include outreach and mitigation measures for the impact of Measure Y

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on housing development throughout the planning period. The element should analyze the measure as a constraint on development based on site suitability for development.

State Density Bonus Law: The City’s current density bonus ordinance should be reviewed for compliance with current state density bonus law and programs should be added as necessary. (Gov. Code, § 65915.)

Design Review: The element must describe and analyze the design review guidelines and process, including approval procedures and decision-making criteria, for their impact as potential constraints on housing supply and affordability. For example, the analysis could describe required findings and discuss whether objective standards and guidelines improve development certainty and mitigate cost impacts. The element must demonstrate this process is not a constraint or include a program to address this permitting requirement, as appropriate.

On/Off-Site Improvements: The element must identify subdivision level improvement requirements, such as minimum street widths (e.g., 40-foot minimum street width) and analyze their impact as potential constraints on housing supply and affordability.

Constraints on Housing for Persons with Disabilities: The element briefly describes its reasonable accommodation procedures. However, the element should also describe the process and decision-making criteria such as approval findings and analyze any potential constraints on housing for persons with disabilities. In addition, the element states that Policy H.1.14 commits to revise the definition of family, but there are no actions within the program to revise the definition of family to remove constraints. The element must add or revise a program to remove the constraints as noted. Lastly, group homes for seven or more persons appears to be excluded from several zones allowing residential uses and subject to a CUP. The element should evaluate these requirements as constraints and include specific commitment to amend zoning and permit procedures to allow these uses in all residential zones with objectivity to facilitate approval certainty.

6. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including… …requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584... (Gov.

Code, § 65583, subd. (a)(6).)

Developed Densities and Permit Times: The element must be revised to include analysis of requests to develop housing at densities below those anticipated, and the length of time between receiving approval for a housing development and submittal of an application for building permits that potentially hinder the construction of a locality’s share of the regional housing need.

7. Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of

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households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)

Special Needs Populations: While the element quantifies the City’s special needs populations, it must also analyze their special housing needs. For a complete analysis of each population group, the element should discuss challenges faced by the population, the existing resources to meet those needs (availability senior housing units, # of large units, # of deed restricted units, etc.), an assessment of any gaps in resources, and proposed policies, programs, and funding to help address those gaps. In addition, the element must quantify and analyze the number of elderly persons in the City.

C. Housing Programs

1. Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the Housing Element. (Gov. Code, § 65583, subd. (c).)

To address the program requirements of Government Code section 65583, subdivision (c)(1-6), and to facilitate implementation, programs should include: (1) a description of the City’s specific role in implementation; (2) definitive implementation timelines; (..3) objectives, quantified where appropriate; and (4) identification of responsible agencies and officials. Programs to be revised include the following:

• P olicy 1.2 (Utilize Public Funding): This program should include proactive outreach to developers throughout the planning period as well as a geographic target for the metric.
• P olicy 1.4 (Incentivize ADU Development): This program should revise action C to include discrete timing of how often it will be completed and monitored. In addition, action D should include back-up actions if estimates are not met (e.g., identify additional sites or provide additional incentives) as well as monitor affordability. • P olicy 1.5 (Encourage Family Housing): The program should include back-up actions, with specific timing, if the identified incentives are not implemented. • P olicy 1.6 (Streamline Housing Application Review): Action B must include specific timing of when permit application requirements will be updated. In addition, the timing of action C must be completed earlier in the planning period. • Policies 1.15 (Supportive Housing Requirements) and 1.16 (Mobile Home Parks):

These programs must revise timing to be implemented earlier in the planning period for a beneficial impact.
• Policy 1.17 (Farmworker Housing): This program must move up timing to be implemented earlier in the planning period. In addition, the program should cite the government code for farmworker housing.
• Policy 1.18 (Permitting and Development Fee Review): This program must clarify timing in Action A, specifically whether the study will be complete within the

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identified timeframe or if the fees will be reduced by that date. In addition, Action B must specify when the first review will occur and when adjustments will take place. • P olicy 1.19 (Senior Housing): This program must clarify what potential actions will be implemented for seniors as well as whether other special needs groups are included in the program.
• P olicy 2.1 (Housing Rehabilitation Efforts), 2.3 (Energy and Water Efficiency), 3.4 (Expand Tenant Protections), and 4.3 (Community Education and Outreach): This program must describe how often outreach will occur throughout the planning period.
• Policy 3.3 (Evaluate Housing Revenue Sources): This program must describe the implementation component for action A.
• Policy 3.5 (Creation of Below Market Rate Set Asides): This program must add implementation and timing for what will result from the study. • Policy 4.2 (Countywide Below Market Rate Unit Waitlist): This program must clarify how support will be provided as well as how often throughout the planning period. • Policy 4.4 (Enable Affirmative Marketing): Timing must be clarified to state whether the marketing will occur once in the planning, or on a project-by-project basis. • Policy 5.1.2 (Regional Down Payment Assistance): This program should include outreach for education.
• Policy 5.2.2 (Incentivize Developers): This program must clarify whether incentives are in place, timing to implement the incentives, as well as conducting proactive outreach.
• Policy 5.3.2 (Fund Minor Home Repairs): The program should clarify how often outreach will occur as well as specify whether the metrics are annually or throughout the planning period.
• Policy 5.4.2 (Project Sentinel): This program should be revised to include outreach and describe how awareness will be increased.
• Policy 5.4.3 (Fair Housing Webpage): This program should describe how often the website will be updated and whether outreach will be included. • Policy 5.4.5 (Future Improvements in Disadvantaged Communities): This program must include an action to implement the feasibility study as well as a back-up if the study is not implemented.

2. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).)

As noted in Finding B4, the element does not include a complete site analysis, therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a

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shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised as follows:

Policy 1.1 (Monitor RHNA): While this program ensures sufficient sites are identified, it should commit to identifying additional sites throughout the planning period if needed to accommodate the City’s RHNA.

Policy 1.10 (Establish By-Right Housing for Prior Housing Sites) and 2.6: Previously identified nonvacant sites are inadequate to accommodate the need for lower-income households unless the site is subject to a housing element program that requires rezoning within three years of the beginning of the planning period to allow residential use by-right for housing developments in which at least 20 percent of the units are affordable to lower-income households. (Gov. Code, § 65583.2, subd. (c).) The program must be revised to comply as well as clarify that the densities for the identified sites are appropriate for lower-income households. In addition, timing of Policy 2.6 should occur no later than 3 years from the start of the planning period.

Policy 1.12 (Encourage Residential Uses within Housing Overlay): The program must clarify which commercial zones will be included in the program actions.

Policy 2.4 (Capital Improvements in Lower-Resourced Neighborhoods): The program should describe what capital improvements will be included.

Policy 3.7 (Expanding Homeless Shelters): This program must clarify implementation actions after the study in action A. In addition, a government citation must be added for Action C and implementation timing must be earlier in the planning period to ensure beneficial impact.

3. The Housing Element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate-income households. (Gov. Code, § 65583, subd. (c)(2).)

While the element includes Policy 5.1.3 (Regional Forgivable Loan Program) to support the regional program to assist ELI households, it is a regional policy. The element should specify what actions the City is taking to address the ELI need. The program should also specify whether proactive outreach will occur to implement the program.

4. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities.

The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)

As noted in Findings B5 and B6, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints. In addition, the element should be revised as follows:

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• P olicy 1.3 (Increase Below Market Rate Unit Production): This program should be revised to include an action to comply with State Density Bonus law as well as specific timing for implementation. The program should clarify whether the action currently listed is in addition to state law requirements. • P olicy 1.7 (Update Zoning Code Development Standards): This program must make a firm commitment to remove parking requirements that are a constraint to multifamily development.
• Policy 1.13 (Encourage Development of Missing Middle Housing): This program should include specific implementation and specify whether the identified policies and codes will be revised to remove constraints.
• Policy 1.14 (Evaluate and Update Special Needs Group Housing Requirements):

This policy should commit to reviewing and revising procedural requirements to permit group homes for seven or more persons in all zones allowing residential uses based on objective criteria to facilitate approval certainty. In addition, the program must be implemented earlier in the planning period to ensure a beneficial impact.

5. P romote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics... (Gov. Code, § 65583, subd. (c)(5).)

As noted in Finding B1, the element must include a complete analysis of AFFH. The element must be revised to add goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have specific commitment, metrics, and milestones as appropriate and must address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place- based strategies for community preservation and revitalization and displacement protection.

While programs in Table 13 include specific timelines, all programs in the element that AFFH must include specific metrics and milestones with geographic targets that address the fair housing analysis. In addition, Policy 5.2.1 (City Supported Housing) should specify what actions will be taken to add more affordable housing to moderate and high resource areas as well as whether incentives are provided.

6. The housing program shall preserve for low-income household the assisted housing developments identified pursuant to paragraph (9) of subdivision (a). The program for preservation of the assisted housing developments shall utilize, to the extent necessary, all available federal, state, and local financing and subsidy programs identified in paragraph (9) of subdivision (a), except where a community has other urgent needs for which alternative funding sources are not available. The program may include strategies that involve local regulation and technical assistance. (Gov. Code, § 65583, subd. (c)(6).)

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Policy 2.2 (Retention of Existing Lower-Income Units) and 5.3.3 (Monitor Affordable Housing Projects) should reference State Preservation Notice Law (Gov. Code, § 65863.10, 65863.11, and 65863.13) and state noticing requirements to tenants and affected public entities. The program should also be expanded to include other potential at-risk properties not included in the analysis. HCD will send additional information under separate cover.

D. Quantified Objectives

Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd. (b)(1 & 2).)

The element must include quantified objectives to establish an estimate of housing units by income category that can be constructed, rehabilitated, and conserved over the planning period. While the element includes these objectives for construction, it must also include estimates for rehabilitation and not limit conserved units to at-risk properties.

E. Public Participation

Local governments shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the Housing Element, and the element shall describe this effort. (Gov. Code, § 65583, subd.(c)(9).)

While the element includes a summary of public participation including outreach to the community, it must also describe whether translation services were available outside of the Lets Talk Housing sessions.

F. Consistency with General Plan

The Housing Element shall describe the means by which consistency will be achieved with other general plan elements and community goals. (Gov. Code, § 65583, subd. (c)(7).)

While the element discusses how internal consistency will be achieved with other elements of the general plan as part of the housing element update, it should also discuss how internal consistency will be maintained throughout the planning period.

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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

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

Acknowledgements

City Council
Amourence Lee, Mayor
Lisa Diaz Nash, Deputy Mayor
Richard Hedges, Council Member
Adam Loraine, Council Member
Robert Newsom, Jr, Council Member

Former City Council
Rick Bonilla, Mayor
Diane Papan, Deputy Mayor
Joe Goethals, Council Member
Amourence Lee, Council Member
Eric Rodriguez, Council Member

Planning Commission
Margaret Williams, Chair
John Ebneter, Vice Chair
Adam Nugent, Commissioner
Seema Patel, Commissioner
Martin Wiggins, Commissioner

San Mateo City Staff
Christina Horrisberger, Community Development Director
Zachary Dahl, Deputy Community Development Director
Manira Sandhir, Planning Manager
Eloiza Murillo-Garcia, Housing Manager
Sandy Council, Housing Manager (Former)
Julia Klein, Principal Planner
Nicholas “Nicky” Vu, Housing Specialist
Linda Ly, Associate Planner
Madelyn Faul, Planning Intern

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Vinnie Chen, Planning Intern

Consultants
Diana Elrod, Diana R. Elrod Consulting
Nicholas Hamilton, Good City Company
Heidi Aggeler, Root Policy Research

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0.1 TABLE OF CONTENTS

0.1 Table of Contents ................................ ................................ ................................ ................... 1

0.2 List of Figures ................................ ................................ ................................ ......................... 2

0.3 List of Tables ................................ ................................ ................................ .......................... 3

0.4 List of Appendices ................................ ................................ ................................ .................. 4

1. EXECUTIVE SUMMARY ................................ ................................ ................................ ........... 5

2. INTRODUCTION AND BACKGROUND ................................ ................................ .............. 13

2.1 History of San Mateo ................................ ................................ .............. 13

2.2 Legislative Context ................................ ................................ ................. 15

2.3 Consistency with the General Plan ................................ .......................... 19

2.4 Water/Sewer Capacity ................................ ................................ ............ 19

3. HOUSING NEEDS AND SITES INVENTORY ................................ ................................ ...... 21

3.1 Housing Needs Summary ................................ ................................ ........ 21

3.2 Demographics ................................ ................................ ........................ 22

3.3 Units at Risk of Conversion to Market Rate ................................ .............. 24

3.3.1 Preservation and Replacement Options ............................................................ 24

3.3.2 Rental Assistance ................................................................................................ 25

3.3.3 Transfer of Ownership ........................................................................................ 25

3.3.4 Construction of Replacement Units ................................................................... 25

3.3.5 Entities Interested in Participating in California's First Right of Refusal Program ............................................................................................................... 25

3.3.6 Funding Sources .................................................................................................. 26

3.4 RHNA Allocation Summary and Methodology ................................ ........... 27

3.4.1 Legislative Context for the Housing Element’s Inventory of Sites .................... 27

3.4.2 Site Inventory Methodology ............................................................................... 28

3.4.3 Site Inventory Approach ..................................................................................... 29

3.4.4 Pipeline Projects .................................................................................................. 39

3.4.5 Accessory Dwelling Units .................................................................................... 39

3.4.6 San Mateo General Plan Update ........................................................................ 40

3.4.7 City Properties and Funding ................................................................................ 41

3.4.8 Missing Middle Housing ...................................................................................... 44

3.4.9 Single Room Occupancies (SRO) Housing ........................................................... 44

3.5 Sites Inventory ................................ ................................ ...................... 44

4.1 Constraints Analysis Summary ................................ ................................ . 46

4.1.1 Governmental Constraints .................................................................................. 46

4.1.2 Non-Governmental Constraints .......................................................................... 46

4.2 Housing Resources Summary ................................ ................................ ... 47

4.2.1 Funding Opportunities ........................................................................................ 47

4.2.2 Existing Housing Programs ................................................................................. 48

4.3 Climate Change and Energy Conservation ................................ ................ 48

5. PUBLIC PARTICIPATION ................................ ................................ ................................ ... 50

5.1 Overview ................................ ................................ ............................... 50

5.2 Accomplishments and Key Takeaways ................................ ...................... 52

5.2.1 Website, Social Media, and Printed Mailing ...................................................... 52

5.2.2 Community Meetings .......................................................................................... 52

5.2.3 Key Takeaways .................................................................................................... 53

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5.2.4 Outreach Activities .............................................................................................. 54

5.3 Draft Housing Element Public Review Period ................................ ........... 57

5.4 How We Incorporated What We Heard into the Plan ................................ 58

5.5 Attachments included in Appendices F and G ................................ ........... 59

6. Affirmatively Furthering Fair Housing (AFFH) SUMMARY................................ ....................... 61

6.1 What is Affirmatively Furthering Fair Housing? ................................ ........ 61

6.2 History of segregation in the region ................................ ........................ 61

6.3 San Mateo’s Fair Housing Assessment ................................ ..................... 62

6.3.1 Primary Findings .................................................................................................. 62

6.3.2 Contributing factors and Fair Housing Action Plan ............................................ 65

7. HOUSING PLAN ................................ ................................ ................................ ................. 67

7.1 Goals, Policies, and Programs Summary ................................ ................... 67

7.2 Implementation Plan ................................ ................................ .............. 71

7.2.1 GOAL H1: Production of new housing at all income levels, with a focus on affordable housing ......................................................................................... 71

7.2.2 GOAL H2: Preservation of existing housing that is affordable to lower- and middle-income residents ............................................................................. 77

7.2.3 GOAL H3: Protection of current residents to prevent displacement ................ 79

7.2.4 GOAL H4: Promotion of community engagement and public outreach ........... 81

7.2.5 Goal H5: Affirmatively Furthering Fair Housing ................................................. 83

8. QUANTIFIED OBJECTIVES ................................ ................................ ................................ 88

9. PRIOR ACCOMPLISHMENTS SUMMARY ................................ ................................ ......... 90

0.2 LIST OF FIGURES
Figure 1: 2021 TCAC/HCD Opportunity Map .............................................................................................. 38 Figure 2: Sites Inventory Map ..................................................................................................................... 43 Figure 3: AFFH Definition ............................................................................................................................ 61

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0.3 LIST OF TABLES

Table 1: Income Limits for San Mateo County, 2022 .................................................................................. 21 Table 2: Final Regional Housing Needs Allocations .................................................................................... 22 Table 3: San Mateo RHNA Targets Summary .............................................................................................. 27 Table 4: 2017 – 2022 Residential Project Densities .................................................................................... 30 Table 5: 2017 – 2022 Planning Development Approvals ............................................................................ 32 Table 6: Example RHNA Income Distribution ............................................................................................. 39 Table 7: ADU/JADU Annual Permit Data ..................................................................................................... 39 Table 8: Sites Inventory Affordability Breakdown ...................................................................................... 44 Table 9: Goal H1: Production - Implementation Plan ................................................................................. 71 Table 10: Goal H2: Preservation - Implementation Plan ............................................................................ 77 Table 11: Goal H3: Protection - Implementation Plan ................................................................................ 79 Table 12: Goal H4: Promotion - Implementation Plan ................................................................................ 81 Table 13: Goal H5: AFFH - Implementation Plan ........................................................................................ 83 Table 14: Quantified Objectives for Cycle 6 (2023 – 2031) ........................................................................ 88 Table 15: Quantified Objectives Alignment with San Mateo’s RHNA......................................................... 89 Table 16: Quantified Objectives, 2015 - 2022............................................................................................. 90 Table 17: Quantified Objective Actuals, 2015 – 2022* ............................................................................... 91

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0.4 LIST OF APPENDICES
A. Needs Analysis
▪ Countywide Housing Needs
▪ Inventory of Assisted Units

B. Constraints Analysis

C. Housing Resources
▪ Sites Inventory List
▪ Housing Sites Inventory Edits

D. Affirmatively Furthering Fair Housing Narrative
▪ Fair Housing Action Plan
▪ AFFH Maps and Data
▪ Access to Educational Opportunities
▪ UC Merced Segregation Report
▪ Quotes and Narrative from Outreach
▪ State Fair Housing Laws

E. Review of Prior Housing Element
▪ Prior Housing Element Evaluation

F. Public Participation
▪ True North Survey Results – February 21, 2022
▪ Community Engagement, Pop Ups and Intercepts – Public Feedback Received ▪ Housing Element Online Survey Results
▪ Builders Focus Group – November 15, 2021
▪ Fair Housing Workshop – January 13, 2022 – Discussion and Poll Summary ▪ City of San Mateo Housing Policy Workshop – November 2, 2021 – Discussion and Poll Summary ▪ Community Relations Commission – September 29, 2021 – Community Needs and Housing Needs Workshop Speaker Notes
▪ San Mateo Countywide Fair Housing Listening Session – September 27, 2021 ▪ San Mateo Countywide Housing Advocates Listening Session – October 18, 2021 ▪ San Mateo Countywide Builders Listening Session – November 1, 2021 ▪ San Mateo Countywide Service Providers Listening Session – November 15, 2021 ▪ Root Policy Fair Housing Survey Summary of Public Feedback ▪ Community Correspondence received by the City prior to April 6, 2022, and between May 7, 2022 and December 19, 2022
▪ Public Meeting Minutes – April 26, 2022 to November 7, 2022

G. Public Review Period Comments
▪ Public Review Period Comments Received – April 6, 2022 to May 6, 2022 ▪ Second Public Review Period Comments Received – December 30, 2022 to January 9, 2023

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1. EXECUTIVE SUMMARY
San Mateo’s 2023 -2031 Housing Element is a plan to help address the region’s housing crisis, a blueprint for supporting all forms of housing, and a demonstration of the City’s commitment to achieving greater housing equity and access for all residents . The Housing Element identifies existing housing conditions and community needs, describes where new housing can be developed, establishes goals, policies and programs, and creates a plan for supporting the production of housing to meet the needs of the City’s current and future residents. It includes nine sections as outlined below.

1. Executive Summary

This Executive Summary provides a high-level summary of each section, and its findings and conclusions.

The Sites Inventory is in Section 3, the Affirmatively Furthering Fair Housing Assessment is in Section 6 and the Housing Plan, with a complete breakdow n of the goals, policies and programs, is included in Section 6. Detailed technical information and documentation to support the Housing Element’s findings and conclusions are included in the seven appendices.

2. Introduction and Background

The City of San Mateo is located in San Mateo County, California, on the San Francisco Bay Peninsula and has a population of 105,661 per the 2020 Census. It is approximately 20 miles south of San Francisco and borders Burlingame to the north, Hillsborough to the west, the San Francisco Bay and Foster City to the east and Belmont to the south.

The Housing Element is an integral part of the General Plan, which guides the City of San Mateo ’s development and policy decisions , and it is the only element that requires certification by the state.

California has also established a significant number of new housing related laws to address the state’s housing crisis and this section provides an overview of the applicable legislation that the Housing Element is required to comply with and address. The State Department of Housing and Community Development (HCD) is tasked with reviewing housing elements for compliance and adequacy and is responsible for certifying the City’s Housing Element.

All new housing units need to have access to adequate infrastructure and municipal services, and in particular, sewage disposal and water capacity must be demonstrated. The City's electrical and natural gas provider is Pacific Gas and Electric (PG&E), and the water service provider is predominantly the California Water Company, except for the portion of San Mateo east of the slough, which is served by the Estero Municipal Improvement District . Recology provides recycling, composting and waste disposal services and sewage disposal servi ces are provided by a Joint Powers Authority led by the City. An assessment of Cal Water’s Urban Water Management Plan combined with increased water efficiency and conservation requirements found that there is sufficient water capacity to serve at least 7, 015 new housing units by 2031. For sewage disposal, the City is curren tly building an updated sewage treatment facility which will have the capacity to serve the City into the future , including the new units for this housing cycle.
“Home is where one
starts from.”
– T.S. Eliot

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3. Housing Needs and Sites Inventory

For this upcoming eight-year housing cycle, HCD has identified the nine-county Bay Area region’s housing need to be 441,176 units; with this number broken down into four income categories that cover housing types for all income levels, from extremely low -income households to market rate (above moderate income) housing. This Regional Housing Needs Determination (RHND) is based on population projections produced by the California Department of Finance (DOF) as well as adjustments that incorporate the region’s existing housing need. The City of San Mateo’s Regional Housing Needs Allocation (RHNA) for this cycle is 7,015 new housing units.

A summary of facts about San Mateo’s demographic data is provided to establish a basis for the City’s housing needs and issues. A full version of the City’s demographic report can be found in Appendix A. A key fact identified in this data is that the number of homes in San Mateo increased 3.6% from 2010 to 2020, which is below the growth rate for San Mateo County and below the growth rate of the region’s housing stock during this time period. And, during this time period, home prices increased by 115.6% and rental prices increased by 74.2%. Overall, this demographic data supports the finding that the City does not have sufficient housing units to meet the needs of its residents and that housing affordabilit y is a significant barrier for many middle- and lower-income residents.

An analysis of existing affordable housing units that are at risk of conversion/reversion to market rate, rendering them no longer affordable to the people living in them, identified 65 units in two developments (Bridgepoint Condominiums and Belmont Building) that have expiring affordability covenants. The potential loss of existing affordable housing units is an important issue to the City due to displacement of lower-income tenants and the limited alternative housing available to such persons. Preservation of these units can be achieved in a variety of ways and policies and programs have been included in the Housing Plan to explore options to retain the units as affordable, replace the units elsewhere, or relocate tenants into alternative housing that is affordable to them.

To demonstrate how San Mateo can accommodate its RHNA of 7,015 new housing units, the Housing Element must identify adequate sites for housing (Sites Inventory), including rental housing, factory-built housing, and mobile homes, and make adequate provision for the existing and projec ted needs of all economic segments of the community. The Sites Inventory is required to include an inventory of land suitable for residential development, including vacant sites and sites having potential for redevelopment, and analyze the development capacity that can realistically be achieved for each site.

The purpose of the Sites Inventory is to evaluate whether there are sufficient sites with appropriate zoning capacity to meet the City’s RHNA goal. The Sites Inventory analysis does not include the e conomic feasibility of specific sites, does not necessarily take into consideration the owner’s intended use of the land now or in the future, and does not dictate where residential development will actually occur. Based on previous Housing Elements, it is anticipated that some of the sites on the list will be developed with new housing, some will not, and some housing will be built on sites not listed in the Sites Inventory.

The methodology used to estimate the development potential of each property included on the Sites Inventory was developed based on the criteria established by state law, development/redevelopment feasibility, site constraints, zoned capacity versus real capacity , and prior project history. To ensure a higher likelihood of new developments exceeding the estimates in the Sites Inventory, conservative assumptions were employed. Overall, the Sites Inventory identified sites spread around the City with

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capacity to develop up to 9,934 units, or 142% of the City’s RHNA. This development capacity exists within the City's current zoned densities and does not require any rezoning to achieve. While many of the sites identified are non-vacant sites, they have a sign ificantly high redevelopment potential as noted through example projects, individual site analysis including developer or owner interest, and other factors such as aging building stock and low utilization rates including underutilized parking lots or strip malls (Appendix C). The following table provides a summary breakdown of the Sites Inventory by income category.

San Mateo Sites Inventory Breakdown
Housing Opportunity Areas Total Units Very Low Low Moderate Above Moderate  Pipeline
Bridgepointe 1,105 220 168 162 555 -
Hillsdale Station South 2,593 627 379 407 1,180 18
101/92 Interchange 2,452 455 221 248 1,528 961
Other Sites 3,784 570 473 500 2,021 1,936
ADUs 440 22 132 220 66
Totals 9,934 1,894 1,373 1,317 5,350
RHNA 7,015  1,777 1,023 1,175 3,040
Buffer 2,919
(42%)
117
(7%)
350
(34%)
142
(12%)
2,310
(76%)

This information is included as Table 8 in Section 3.5 of the Housing Element.

4. Other Required Housing Element Components

This section provides a summary and evaluation of housing production constraints, an overview of the funding opportunities and housing resources provided by the City, and the applicable energy conservation and climate change policies and requirements for new housing developments.

The constraints section analyzes potential and actual governmental and non-governmental constraints to the maintenance, improvement, or development of housing that hinder a jurisdiction from meeting its housing goals. Governmental constraints to housing include zoning and development standards, infrastructure requirements, development impact and permitting fees, and the development review and permitting processes. N on-governmental constraints include availability of financing, the price of land, the cost of construction, Measure Y (voter approved growth limits) and the length of time to design and construct new housing.

The city is in the process of implementing measures to reduce development costs, streamline the development review process and amend/simplify the Zoning Code to reduce these constraints. A comprehensive evaluation of all housing impact and permitting fees, with a focus on reducing costs for smaller multi -family projects , will also be completed . Non-governmental constraints are largely determined by market conditions and other factors over which the City has little control. However, the General Plan Update process is facilitating a community conversation around Measure Y , with a goal of building consensus around a path forward to bring forward an updated ballot measure that would allow for the production of more housing, in particular affordable housing, to meet the City’s current and future needs.

The Housing Resources of the City are grouped into three categories. The first is the various funding sources that the City is able to leverage for affordable housing production, preservation, and protection;

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the second are the existing programs that the City manages and supports to increase the housing supply or otherwise serve past, current, and prospective residents of affordable housing; and the third is the inventory of sites that are adequate for development to meet projected housing needs.

Home energy efficiency has become an increasingly significant factor in housing construction, particularly in the past few years with the increasing demand to build energy efficient and sustainable buildings in California. The California Energy Code and the Califo rnia Green Building Code in State Title 24 establish uniform energy efficiency and green building standards that all construction must adhere. The City’s 2020 Climate Action Plan (CAP) sets standards to reduce greenhouse gas (GHG) emissions for housing and construction by exceeding minimum state requirements, providing education and outreach on benefits and financial incentives associated with energy upgrades, and continuing support for energy efficiency and electrification retrofits.

5. Public Participation

Over the past twelve months, the city has conducted a significant community outreach effort to engage with the community, with over nineteen public and community meetings and workshops, five intercept/pop-up events, four surveys and partnership with 21 Elements. The outreach effort included an emphasis on connecting with community members for whom English was not spoken at home, r enters, those under 45 years of age, low -income and very low -income households, people with disabilities, seniors, single female heads of household, people experiencing homelessness, and those from under - represented neighborhoods.

Key accomplishments of the community outreach efforts included:

• Launch of a Housing Element Update website that included links to past event video recordings, meeting materials, outreach and survey summaries, and information about upcoming meetings and ways to get involved.
• Two mailers – one citywide in October 2021 was sent to 27,000 households and a second i n January 2022 targeted to renters – inviting community members to participate in community workshops, public meetings, and online surveys. Both mailers included printed information in English and Spanish.
• Three public Housing Element workshops, six presentations/discussions at City Council and Planning Commission public meetings, a focus group discussion with builders, developers and architects, and presentations to many local community -based organizations , including the Chamber of Commerce, Downtown Merchants Association and San Mateo -Foster City School District Parent Teacher Association (SMFCSD PTA).
• Two related Housing Element Surveys conducted by the City between October 11, 2021 and January 16, 2022 received a total of 750 responses. Online responses from community members accounted for 594 responses, with 156 additional responses to a subset of questions collected by staff and the consultant team as intercept surveys during pop-up events in the North Central and Shoreview Neighborhoods, as well as Macedonia food distribution events.

Feedback and insights from tenants, non-English speakers, lower-income residents, property owners and developers helped to highlight new policy opportunities and ways to strengthen and improve existing policies, with the overarching challenge of housing affordability and availability being a reoccurring topic.

Themes that were incorporated into the Housing Plan included production of more missing middle

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housing, more outreach and education to tenants and landlords, streamlining and simplifying development review and permitting processes, doing more to address fair housing and equity, and ensuring that new housing is sustainable and addresses climate change.

On April 6, 2022, the City published the Draft Housing Element for public review. The 30-day public review period ended on May 6, 2022. During the review period, the City received 20 public comment letters.

Comments reflected a broad range of sentiments including support for housing generally and the Draft Housing Element, a desire for the Draft Housing Element to articulate methods to greatly expand the supply of housing and tenant protections, concern about the future of existing very low density neighborhoods, and worry that future growth would strain the City’s transportation infrastruc ture and available water supplies. On April 26 and May 3, 2022, the Planning Commission held public hearings and provided input on the Draft. On May 23, 2022, the City Council held a public hearing to consider the public comments and provide staff with input and direction. On November 7, 2022, the City Council held a study session to discuss HCD’s first review letter and considered public comments. Following an update to the Housing Element to address HCD comments, public comments and City Council direction, the updated Housing Element was published for public review on December 30, 2022.

6. Affirmatively Furthering Fair Housing (AFFH) Assessment

This section provides an overview of AFFH requirements; a history of segregation in the region ; and an assessment of the San Mateo’s AFFH issues.

“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. California law, as established by AB 686, requires all public agencies to “administer programs and activities relating to housing and community development in a manner that affirmatively furthers fair housing, and take no action inconsistent with this obligation.” The law also required that housing elements include an analysis of fair housing outreach and capacity, integration and segregation, access to opportunity, disparate housing needs, and current fair housing practices.

The United States’ oldest cities have a history of mandating segregated living patterns —and Northern California cities are no exception. The Association of Bay Area Governments (ABAG), in its recent Fair Housing Equity Assessment, attributes segregation in the Bay Area to historically discriminatory practices—highlighting redlining and discriminatory mortgage approvals —as well as “structural inequities” in society, and “self-segregation” (i.e., preferences to live near similar people).

A Fair Housing Assessment for all San Mateo County jurisdictions was conducted by 21 Elements, a countywide jurisdictional collaborative. For the City of San Mateo, the Assessment describes fair housing enforcement and outreach capacity, integration and segregation, access to opportunity and disparate housing needs as contributing factors that should be addressed in the city’s fair housing action plan. Some primary findings in the Fair Housing Assessment included:

• 16% of fair housing complaints filed in San Mateo County between 2017 to 2021 (57 total) were in the City of San Mateo (9 total), which is approximately aligned with the city share of the county’s population (14%).
• Racial and ethnic minority populations are disproportionately impacted by poverty, low

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household incomes, overcrowding, and homelessness compared to the non -Hispanic White population in the City of San Mat eo. Additionally, racial and ethnic minorities are more likely to live in moderate resources areas and be denied for a home mortgage loan. • The northeast area of San Mateo is disproportionately impacted by high poverty, low education opportunity, low econom ic opportunity, low environmental scores, high social vulnerability scores, concentrations of cost burdened households, overcrowding, and moderate resource scores. These areas are generally on either side of Highway 101 and stretch to the San Francisco Bay waterfront, encompassing the North Central and Shoreview neighborhoods. • The City of San Mateo has a slight concentration of residents with a disability with 9% of the population compared to 8% in the county. Residents living with a disability in the city are more likely to be unemployed and are largely concentrated in areas around Highway 101. • Racial and ethnic minority students in the City of San Mateo —served by the San Mateo Union High School District and the San Mateo -Foster Elementary School District —experience lower educational outcomes compared to other students.
• Nearly half of all renter households in the City of San Mateo are cost burdened —spending more than 30% of their gross income on housing costs—and one in four are extremely cost burdened— spending more than 50% of their gross income on housing costs.

Contributing factors to these Primary Findings include:

• Higher rates of mortgage denial rates among Hispanic households stems from decades of discrimination in housing markets and challenges building wealth through economic mobility and homeownership.
• The northern portion of the city offers the most affordable homes, and as such, residents living in these areas have lower incomes and higher rates of poverty. • Hispanic residents are more likely than others to work low wage jobs that do not support the City’s or region’s housing prices, resulting in higher rates of cost burden and overcrowding. • 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 according to TCAC’s opportunity maps.
• Concentration of naturally occurring affordable ownership and rental housing opportunities in the northeast areas of the city further concentrates poverty, cost burden, and overcrowding in areas with low economic and environmental outcomes.
• There is a relative lack of affordable housing opportunities in higher resourced areas of the city. • Highway 101 creates a major barrier between the Shoreview neighborhood and the rest of the City of San Mateo.
• The unemployment rate for the City of San Mateo’s residents with a disab ility is four times that of persons without a disability.
• The undersupply of accessible housing units, particularly for renters, creates a scarcity of units for residents living with a disability.
• There are concentrations of the population living with a disability west of Highway 101 in the North Central neighborhood.
• Residents with disabilities and Hispanic households face increased housing discrimination.

In response to this analysis, as well as community input, an Affirmatively Furthering Fair Housing Action Plan, which details how the City proposes to respond to the factors contributing to the fair housing

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challenges identified in this analysis, was developed. The Action Plan is included in App endix D and the policies and programs to implement the Action Plan are included in the Housing Plan under Goal 5.

7. Housing Plan

The City of San Mateo's primary objective is to maintain and provide a diversity of housing opportunities for current and future residents. There should be a variety of housing types and sizes, a mixture of rental and ownership housing, and housing that supports special needs populations, including seniors, farmworkers, single female heads of household, people with disabilities, and those who are unhoused.

This variety of housing opportunities should accommodate a diverse population, leading to a variety of household sizes and types at all income levels.

In addition, the city needs to increase housing supply to meet the housing demand caused by current and future job growth. The types of new housing created should accommodate all income levels consistent with the city’s RHNA. The goals, polices, and actions contained in this H ousing Plan support these overarching objectives while also ensuring that the city will meet its statutory obligations to affirmatively further fair housing and facilitate housing production at all income levels.

The City has identified five goals to guide the Housing Element’s policies and programs. The first three are based upon the “3Ps” framework that seeks to address the region’s housing needs through a combination of Production, Preservation and Protection and is endorsed by the Association of Bay Area Governments (ABAG). The fourth goal, or “fourth P,” is Promotion of community engagement and public outreach to support social resilience, and the fifth goal is to Affirmatively Further Fair Housing (AFFH).

• Production – Facilitate and support the production of new housing at all income levels, but especially affordable housing. Twenty-one policies with thirty-seven implementing actions have been identified to support this goal.
• Preservation – Preserve existing housing that is affordable to lower - and middle -income residents. Six policies with ten implementing actions have been identified to support this goal. • Protection – Protect current residents to prevent displacement. Seven policies with sixteen implementing actions have been identified to support this goal. • Promotion – Promote social resilience through public education and community outreach to make information more available and accessible. Five policies with ten implementing actions have been identified to support this goal.
• Affirmatively Further Fair Housing – Address the issues of fair housing, equity and access while reinforcing the objective that affirmatively furthering fair housing is both a stand -alone priority and decisively i nseparable from achieving the Housing Element’s other goals. Fourteen policies with sixteen quantified objectives have been identified to support this goal.

8. Quantified Objectives

In addition to the Sites Inventory and the Housing Plan, the city is required to provide an estimate of actual housing units that can be preserved and produced given available resources, permits issued and projected pipeline projects expected to be completed within the next housing cycle. State law recognizes that the city’s total housing needs exceed available resources and the community's ability to satisfy thi s need within the content of the general plan. The total development cost for the RHNA allocation would exceed

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$4 billion dollars, of which over $3 billion would be required to develop the lower-income units. Thus, the quantified objectives do not need to completely account for San Mateo’s RHNA but do establish the maximum number of housing units that can realistically be constructed, rehabilitated, and conserved in the City over an eight-year timeframe.

For the upcoming housing cycle, the city’s quantified objectives for conservation are 719 units, with 323 being affordable units , and the quantified objectives for construction are 5,639 units, with 1, 426 being affordable units. The total of quantified objectives for the city are 6,358 units, including 1,749 affordable units. For a full breakdown of units by affordability level and by project or category , see Table 1 4 – Quantified Objectives for Cycle 6 (2023 – 2031), in this Section.

9. Review of Prior Housing Element

The final section provides a summary of the key accomplishments, challenges, and opportunities learned from the city’s previous Housing Element . The city’s RHNA for the fifth housing cycle (2015 – 2022) was 3,100 units. The city was able to achieve many its goals through successful implementation of most of its policies and programs but fell short of its affordable housing goals. Key accomplishments include increased accessory dwelling unit (ADU) production, new funding sources, protecting existing affordable housing units, and using new technology to speed up development . Significant progress was also made on the design and entitlement of two affordable housing projects on city-owned properties in Downtown.

From 2015 through January 2022, the City has been able to achieve a total of 2,573 new housing units and exceed its market rate housing target; however, this only represents 81 percent of the city's RHNA . A variety of factors have contributed to this production shortfall, including high land and construction costs1, outdated policies, and community division regarding growth and building heights . The lessons learned over this past cycle have been used to help inform the Housing Plan in this Housing Element.

1 It should be noted during Cycle 5, national and global factors contributed to the high cost of construction including:
a) The Great Recession which affected the banking industry and residential investments; b) COVID-19 pandemi c which contributed to construction worker shortage, and c) 2021-2022 Global Supply Chain Crisis which contributed to construction material cost increases and delays that extended construction schedules locally by a year or more.

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2. INTRODUCTION AND BACKGROUND
The Bay Area continues to see growth in both population and jobs, which means more housing of various types and sizes is needed to ensure that residents across all income levels, ages, and abilities have a place to call home. While the number of people drawn to the region over the past 30 years has s teadily increased, housing production has not kept pace, contributing to the housing shortage that communities around the Bay Area are experiencing today. In many cities, this has resulted in residents being priced out, increased traffic congestion caused by longer commutes, and fewer people, particularly those in the middle- and lower-income tiers, being able to purchase homes or meet surging rents.

The Housing Element is part of the City’s General Plan and sets forth the policies and programs to address the housing needs for San Mateo. It is the City’s eight-year housing strategy from the period of 2023-2031 for how it will meet the community’s housing needs . State law (Government Code Sections 65580 - 65589.8) requires that every city and county in Califo rnia adopt a Housing Element, subject to State approval, as part of its General Plan. Per SB 375 (Statutes of 2008), the planning period for the Housing Element is eight years.

Since 1969, State law requires that jurisdictions throughout California complete a Housing Element. The City itself is not responsible for building or producing this housing, but it must demonstrate that it has policies and programs in place to support housing construction for all inco me levels, as well as available land appropriately zoned to accommodate new housing. The Housing Element must include a variety of statistics on housing needs, constraints to development, and policies and programs to implement a variety of housing -related land use actions, and a detailed inventory of “opportunity sites” on which future housing may be built.

The Housing Element is the only element of a locality’s General Plan that must be approved (“certified”) by the State, through its Department of Housing and Community Development (HCD) to ensure it meets all statutory requirements. Having a certified Housing Element is a prerequisite for many State grants and funding programs. This is the sixth cycle of the Housing Element and covers the eight -year period from 2023 to 2031.

2.1 The History of San Mateo

One of only two charter cities in San Mateo County, the City of San Mateo was incorporated in 1894 and is governed by a five-member City Council. The city encompasses 15.9 square miles in the San Francisco Bay Area in the center of the Peninsula and is currently home to an estimated 105,661 residents. 2 Its strategic location at the crossroad of the east-west coastal stagecoach and the north-south railroad drew a number of residents after its incorporation. The land around this settlement was controlled by some of the wealthiest families in the state , who created large suburban estates. San Mateo emerged in the postwar periods as a rapidly expanding and progressive city when the population of the city nearly

2 US Census estimate, April 2020. https://www.census.gov/quickfacts/sanmateocitycalifornia

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quadrupled between 1940 and 1990.3 Some of the current land use constraints, such as voter approved Measure H, P, and Y in 1991, 2004, and 2020, respectively, which limit heights to 55 feet and density to no more than 50 units per acre in the city were a direct result of this rapid expansion.

Despite the Measure Y growth limitations, San Mateo has seen a significant amount of growth over the past two decades. Recent development activity includes a mix of single -family homes, multi -family dwellings, senior housing, office space, retail areas, ho tels, and mixed-use (commercial and residential) projects.

San Mateo has very few remaining vacant sites with development potential ( approximately 40 parcels).

The areas that are undeveloped are generally protected as open space, parks, and waterways. However, there are many sites that have aging buildings or are under -developed that provide opportunity for new mixed-use and higher -density housing development. Development interest in San Mateo remains high with a variety of projects in the pipeline, including those in the early planning stages.

San Mateo’s economy has grown quickly in recent years, in large part due to the strength of Silicon Valley technology companies and the city’s strategic geographic location. Current low vacancy rates for retail, office, and industrial space confirm that businesses find San Mateo a desirable location, and new development projects will produce more non-residential space to help meet that demand. Between 2010 and 201 9, the number of jobs in San Mateo increased by 33 percent, and there are currently approximately 52,800 people4 employed in the city. The “professional and technical services” sector, which includes technology jobs, makes up about 20 percent of local jobs, about the same proportion as in San Francisco and more than in Silicon Valley. Retail, health care, food services, public agencies, are other primary employment sectors in the community.

San Mateo’s vibrant Downtown, desirable neighborhoods, diversity of employment options, high quality public services, and recent developments such as Hillsdale/Bay Meadows and Station Park Green, make it an ever-popular place to live and work. Major new development in San Mateo is concentrated primarily near the three Caltrain stations (in the Downtown, Hayward Park and Hillsdale areas), and along El Camino Real. The city’s three Caltrain stations, extensive bicycle and pedestrian network, SamTrans bus system, and well -maintained local roadways lead efficiently to destinations in the city, on the Peninsula, and beyond.

The city has many distinct and diverse individual neighborhoods , including two designated historic districts, the Downtown and the Glazenwood Historic D istricts. The Downtown area , which maintains a 1930s character, is of particular importance and interest with respect to historic structures. The residential neighborhood of Glazenwood is a unique early 1920's development of Spanish Colonial Revival homes.

Other areas of the city contain buildings of exceptional architectural interest and reflect local historical periods.

3 Mitchell P. Postel, San Mateo – A Centennial History,”Foreword”, 1994, Page ix. 4 City of San Mateo, General Plan Update - Alternatives Evaluation, 2019.

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San Mateo has about 41,250 housing units ; roughly half are rental units and half are occupied by homeowners, which are also split almost evenly between single-family and multi-family residences. Older homes are common in San Mateo, with almost 50 percent being 60 years or older. Local housing costs are very high, driven by high de mand and a lack of production, which is due to a variety of factors including lack of available land and regulatory limits. The average cost for a single -family home in San Mateo is about $1.7 million, up more than 80 percent in just five years.5 A typical rental unit costs $2,900 a month, 31 percent higher than five years ago. With the current median annual income of $166,000, a four-person household in San Mateo could comfortably afford to purchase a home priced at up to $700,000 – less than half of the realistic cost.6 Even with the high housing costs, the city population continues to increase and is anticipated to grow by up to 55,000 people by 2040, based on the preliminary land use map that was selected to be part of the City’s 2040 General Plan Update.

2.2 Legislative Context

Since the city’s last Housing Element was adopted and certified in 2014 , several substantive changes to State housing law and Housing Element requirements have occurred, as summarized below.

Affordable Housing Streamlined Approval Process. Senate Bill 35 (2017), Assembly Bill 168 (2020) and Assembly Bill 831 (2020 ). SB 35 created a streamlined, ministerial review process for qualifying multifamily, urban infill projects in jurisdictions that have failed to approve housing projects sufficient to meet their State‐mandated RHNA. Among other requirements, to qualify for streamlining under SB 35, a project must incorporate one of two threshold levels of affordable housing: (1) 10 percent of the project’s units in jurisdictions that have not approved housing projects sufficient to meet their RHNA for above moderate‐ income housing or have failed to submit an annual progress report as required under state law; or (2) 50 percent of t he project’s units in jurisdictions that have not approved housing projects sufficient to meet their RHNA for below moderate‐income housing. AB 168 added a requirement to provide a formal notice to each California Native American tribe that is affiliated w ith the area of the proposed project. The Housing Element must describe the City’s processing procedures related to SB 35.

This is discussed further in Appendix B.

Additional Housing Element Sites Analysis Requirements. Assembly Bill 879 (2017) and Assemb ly Bill 1397 (2017 ). These bills require additional analysis and justification of the sites included in the sites inventory of the city’s Housing Element. The Housing Element may only count non‐vacant sites included in one previous housing element inventory and vacant sites included in two previous housing elements if the sites are subject to a program that allows affordable housing by right. Additionally, the bills require additional analysis of non‐vacant sites and additional analysis of infrastructure ca pacity, and place size restrictions on all sites.

Affirmatively Furthering Fair Housing. Assembly Bill 686 (2017). AB 686 law ensures that public entities, including local governments, administer their programs relating to housing and urban development in a

5 San Mateo County Association of Realtors, 2018
6 CoStar; Economic & Planning Systems, Inc., 2018.

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manner affirmatively to further the purposes of the federal Fair Housing Act and do not take any action that is materially inconsistent with its obligation to affirmatively further fair housing. It also requires that housing elements of each city and co unty promote and affirmatively further fair housing opportunities throughout the community for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protec ted by the California Fair Employment and Housing Act, Government Code Section 65008, and any other state and federal fair housing and planning law. AB 686 requires jurisdictions to conduct an assessment of fair housing in the housing element, prepare the housing element site inventory through the lens of affirmatively furthering fair housing, and include program(s) to affirmatively further fair housing.

No‐Net‐Loss Zoning. Senate Bill 166 (2017 ). SB 166 amended the No‐Net‐Loss rule to require that the land inventory and site identification programs in the Housing Element include sufficient sites to accommodate the unmet RHNA. When a site identified in the Housing Element as available to accommodate the lower‐income portion of the RHNA is actually develo ped for a higher income group, the city must either (1) identify, and rezone if necessary, an adequate substitute site or (2) demonstrate that the land inventory already contains an adequate substitute site.

AB 1397, Low (Chapter 375, Statutes of 2017) . The law made several revisions to the site inventory analysis requirements of Housing Element Law. In particular, it requires stronger justification when nonvacant sites are used to meet housing needs, particularly for lower income housing, requires by right housing when sites are included in more than one housing element, and adds conditions around size of sites, among others.

Safety Element to Address Adaptation and Resiliency. Senate Bill 1035 (2018 ). SB 1035 requires the General Plan Safety Element to be reviewed and revised to include any new information on fire hazards, flood hazards, and climate adaptation and resiliency strategies with each revision of the housing element.

By Right Transitional and Permanent Supportive Housing. Assembly Bill 2162 (2 018) and Assembly Bill 101 (2019). AB 2162 requires the city to change its zoning to provide a “by right” process and expedited review for supportive housing. The bill prohibits the city from applying a conditional use permit or other discretionary review to the approval of 100 percent affordable developments that include a percentage of supportive housing units, either 25 percent or 12 units, whichever is greater. The change in the law applies to sites in zones where multifamily and mixed uses are permitted, including in nonresidential zones permitting multifamily use. Additionally, AB 101 requires that a Low Barrier Navigation Center development be a use by right in mixed -use zones and nonresidential zones permitting multifamily uses if it meets specified requirements.

Accessory Dwelling Units (ADUs). Assembly Bill 2299 (2016), Senate Bill 1069 (2016), Assembly Bill 494 (2017), Senate Bill 229 (2017), Assembly Bill 68 (2019), Assembly Bill 881 (2019), Assembly 587 (2019), Senate Bill 13 (2019), Assembly Bill 670 (2019), Assembly Bill 671 (2019), Assembly Bill 3182 (2020 ). In recent years, multiple bills have added requirements for local governments related to ADU ordinances.

The 2016 and 2017 updates to State law included changes pertaining to th e allowed size of ADUs, permitting ADUs by right in at least some areas of a jurisdiction, and limits on parking requirements

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related to ADUs. More recent bills reduce the time to review and approve ADU applications to 60 days, remove lot size requirements and replacement parking space requirements and require local jurisdictions to permit junior ADUs. AB 68 allows an ADU and a junior ADU to be built on a single -family lot, if certain conditions are met. The State has also removed owner-occupancy requirements for ADUs, created a tiered fee structure that charges ADUs based on their size and location, prohibits fees on units of less than 750 square feet, and permits ADUs at existing multi -family developments. AB 671 requires the Housing Element to include pla ns to incentivize and encourage affordable ADU rentals. AB 3182 prohibits homeowner’s associations from imposing rental restrictions on ADUs.

Density Bonus and Development Incentives. Assembly Bill 1763 (2019) and Assembly Bill 2345 (2020).

AB 1763 amende d California’s density bonus law to authorize significant development incentives to encourage 100 percent affordable housing projects, allowing developments with 100 percent affordable housing units to receive an 80 percent density bonus from the otherwise maximum allowable density on the site. If the project is within half a mile of a major transit stop, the city may not apply any density limit to the project, and it can also receive a height increase of up to three additional stories (or 33 feet). In addition to the density bonus, qualifying projects will receive up to four regulatory concessions.

Additionally, the city may not impose minimum parking requirements on projects with 100 percent affordable housing units that are dedicated to special needs or s upportive housing. AB 2345 created additional density bonus incentives for affordable housing units provided in a housing development project. It also requires that the annual report include information regarding density bonuses that were granted.

Housing Crisis Act of 2019. Senate Bill 330 (2019). SB 330 enacts changes to local development policies, permitting, and processes that will be in effect through January 1, 2025. SB 330 places new criteria on the application requirements and processing times for housing developments; prevents localities fro m decreasing the housing capacity of any site, such as through downzoning or increasing open space requirements, if such a decrease would preclude the jurisdiction from meeting its RHNA housing targets; prohibits localities from imposing a moratorium or si milar restriction or limitation on housing development; prevents localities from establishing non -objective standards; and requires that any proposed demolition of housing units be accompanied by a project that would replace or exceed the total number of u nits demolished. Additionally, any demolished units that were occupied by lower - income households must be replaced with new units affordable to households with those same income levels. The City’s processing procedures related to SB 330 are described further in Appendix B.

Surplus Land Act Amendments. Assembly Bill 1486 and AB 1255 (2019). AB 1486 refines the Surplus Land Act to provide clarity and further enforcement to increase the supply of affordable housing. The law requires the city to include specif ic information relating to surplus lands in the Housing Element and Housing Element Annual Progress Reports, and to provide a list of sites owned by the city or county that have been sold, leased, or otherwise disposed of in the prior year. AB 1255 require s the city to create a central inventory of surplus and excess public land each year. The city is required to transmit the inventory to HCD and to provide it to the public upon request. As of April 2022, the City of San Mateo has identified three surplus sites, two of which are under negotiations for affordable housing development (4th Avenue and Railroad Avenue know n as the Talbot’s Site ), and one is a city parking lot available for affordable

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housing development (located at 308 5th Avenue).

AB 1486, Ting (Chapter 644, Statutes of 2019). The law expanded the definition of surplus land and added additional requirements on the disposal of surplus land. In addition, local agencies must send notices of availability to interested entities on a list maintained by HCD. This list and notices of availability are maintained on HCD's website. Local agencies must also send a description of the notice and subsequent negotiations for the sale of the land, which HCD must review, and within 30 days submit writt en finding of violations of law. Violations of the Surplus Land Act can be referred to the Attorney General. Finally, it adds a requirement in Housing Element Law for the jurisdiction to identify which of the sites included in the inventory are surplus property.

Housing Impact Fee Data. Assembly Bill 1483 (2019 ). AB 1483 requires the city to publicly share information about zoning ordinances, development standards, fees, exactions, and affordability requirements. The city is also required to update such information within 30 days of changes. This Housing Element describes governmental constraints on the production of housing, including a look at zoning requirements, development standards, fees, exactions, and affordability requirements. Changes in requirements made during the Housing Element planning period will also be reported as part of the city’s annual Housing Element Progress Report.

SB 6, Beall (Chapter 667, Statutes of 2019 ). Jurisdictions are required to prepare the housing site inventory on forms developed by HCD and send an electronic version with their adopted housing element to HCD. HCD will then send those inventories to the Department of General Services by December 31 of each year.

Housing Opportunity and More Efficiency (HOME) Act. Senate Bill 9 , Atkins (Chapter 162, Statutes of 2021). SB 9 requires the City to allow up to two residential dwelling units and residential lot splits in single- family zones. SB 9 allows for reduced standards, such as setbacks, minimum parcel dimensions, a nd parking. The city must apply objective zoning standards that do not preclude construction of up to two 800 square-feet units. To prevent displacement, the State does not allow SB 9 projects to demolish any affordable or rent controlled housing, or housing that has been occupied by a tenant within the last three years. Projects that meet the qualifying criteria and requirements must be ministerially approved and are not subject to CEQA review. The City adopted a local SB 9 Ordinance as described in Policy H1.11.

Senate Bill 10, Wiener (Chapter 163, Statutes of 2021). SB 10 authorizes cities to adopt an ordinance to zone for up to ten units of residential density on any parcel located within transit rich or urban infill areas.

If adopted, the ordinance allows ministerial approval of up to ten units (not counting ADUs or JADUs) at a height specified by the City. The intent of this bill is to streamline production of housing in urban infill neighborhoods with access to transit. SB 10 includes a sunset d ate of January 1, 2029; the City has identified Policy H1.13 to evaluate sites and “Missing Middle” housing policies consistent with SB 10 by 2024.

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2.3 Consistency with the General Plan

As this Housing Element is being developed, the city is also undertaking a larger effort to comprehensively update the General Plan. Section 3.4.6 provides additional information about the General Plan Update .

The Housing Element is the only chapter in a g eneral plan with statutorily -prescribed timelines for completion, so it is being prepared on a shorter schedule than the rest of the General Plan Update, which is anticipated to be adopted by the end of 2023. To ensure internal consistency among all General Plan elements, work on both the General Plan Update and the Housing Element Update is being coordinated.

Other elements of the General Plan that specifically require updates statutorily triggered by the Housing Element include:

• Flood Hazard and Management (Gov. Code § 65302(d)(3) and (g)(2)(B)) • Fire Hazard (Gov. Code § 65302 and 65302.5) (Safety Element updates) • Environmental Justice (Gov. Code § 65302(h))
• Climate Adaptation (sustainability throughout the General Plan Update)

All four of these topics will be addressed as part of the General Plan Update. To ensure ongoing consistency among all elements of the General Plan, the City tracks all General Plan amendments as they occur and prepares revisions as needed. This will ensure ongoing consistency throughout the planning period.

2.4 Water/Sewer Capacity

As part of the Housing Element, jurisdictions must provide information regarding water and sewer capacity to accommodate future development. In addition, jurisd ictions must include narratives about how they will comply with two specific pieces of legislation, SB 1087 and SB 244.

• SB 1087 – Housing Elements – Requires a city to immediately forward its adopted Housing Element to its water providers so they can grant priority for service allocations to proposed housing developments that include units affordable to lower-income households. • SB 244 – Land Use and General Plans – Requires cities and counties, prior to adoption of a housing element, to address the infrastructure needs of disadvantaged unincorporated communities outside the city’s limits but within the city’s planning area. Because the city’s planning area does not contain any unincorporated areas, no such conditions exist.

The cities, water districts and private utilities represented by the Bay Area Water Supply and Conservation Agency (BAWSCA) rely upon the Hetch Hetchy system for water to protect the health, safety and economic well-being of 1.8 million citizens, businesses a nd community organizations. Together, the BAWSCA agencies account for two -thirds of water consumption from the system and pay for two -thirds of its upkeep.

The regional water system provides water to 2.7 million people in San Francisco, Santa Clara, Ala meda

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and San Mateo counties. Eighty-five percent of the water comes from Sierra Nevada snowmelt stored in the Hetch Hetchy reservoir situated on the Tuolumne River in Yosemite National Park. Hetch Hetchy water travels 160 miles via gravity from Yosemite to the San Francisco Bay Area. The remaining 15 percent of water comes from runoff in the Alameda and Peninsula watersheds and is captured in reservoirs located in San Mateo and Alameda counties. Overall, this regional system, which consists of over 280 miles of pipelines, over 60 miles of tunnels, 11 reservoirs, five pump stations and two water treatment plants , delivers approximately 260 million gallons of water per day.

The City’s water providers are California Water Company (Cal Water) and Estero Municipal Improvement District (EMID). Cal Water’s Mid -Peninsula District, which includes the City of San Carlos, serves the majority of San Mateo, and EMID serves the bayside portions of San Mateo east of Seal Slough and the City of Foster City.

The City’s wastewater treatment plant, which is currently undergoing upgrades that are expected to be completed in 2024, is jointly owned by the City of San Mateo and the City of Foster City/Estero Municipal Improvement District (EMID). The treatment facility serves more than 130,000 people and businesses in its service area at an average flow of 12 million gallons each day. By effectively treating wastewater at an advanced biological treatment facility, the plant helps keep San Francisco Bay environmentally clean and safe.

Both Cal Water and EMID have adopted Urban Water Management Plans that were developed based on the City’s existing zoning densities. Since the City will not need to increase density or rezone any sites to meet its RHNA, combined with increased water efficiency and conservation requirements for new development, there appears to be sufficient water capacity to serve at least 7,015 new housing units by 2031. However, it needs to be noted that the region is experiencing a prolonged drought and there are significant concerns about the ability to maintain water supply into the future if current drought conditions persist. The City will continue to collaborate with the two water providers as part of its General Plan Update to ensure there is an adequate and sustainable water supply for current and future development.

The upgrades to the sewage treatment facility will result in increased capacity to serve San Mateo and Foster City well into the future. Based on this information, i t is anticipated that the City has sufficient water service capacity and sewage processing capacity to meet new housing development needs for this housing cycle. The current facilities and/or infrastructure are reported to be in good operating condition.

Therefore, it is determined that the City has sufficient capacity to serve the 7,015 housing units stipulated the 2023-2031 Regional Housing Needs Allocation. Policy H1.20 supports this finding and helps to ensure that the City’s water and sewer providers promptly receive the adopted Housing Element and prioritize now housing projects for sewer and water connections.

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3. HOUSING NEEDS AND SITES INVENTORY

3.1 Housing Needs Summary

The Plan Bay Area 2050 Final Blueprint4 forecasts that the nine-county Bay Area will add 1.4 million new households between 2015 and 2050. For the eight-year timeframe covered by this Housing Element, the Department of Housing and Community Development (HCD) has identified the region’s housing need as 441,176 units. The total number of housing units assigned by HCD is separated into four income categories that cover housing types for all income levels, from extremely low-income households to market rate housing.

Every year, the US Department of Housing and Urban Development (HUD), in conjunction with the State of California, establish income categories based on the median income in each county. Based on new requirements for the completion of the Housing Element, jurisdictions must now report on the following categories of income:

• Extremely Low Income: 0-30% of Area Median Income, or AMI • Very Low Income: 30-50% AMI
• Low Income: 50-80% AMI
• Moderate Income: 80-120% AMI
• Above Moderate Income: 120%+ AMI

The following table illustrates the income categories for San Mateo County in 2022. The median income for a family of four is $166,000.

Table 1: Income Limits for San Mateo County, 2022
Number of
Persons in
Household:
1 2 3 4 5 6 7 8
San
Mateo
County
Area
Median
Income:
$166,000
Acutely
Low
$17,450 $19,900 $22,400 $24,900 $26,900 $28,900 $30,900 $32,850 Extremely
Low
$39,150 $44,750 $50,350 $55,900 $60,400 $64,850 $69,350 $73,800 Very Low
Income
$65,250 $74,600 $83,900 $93,200 $100,700 $108,150 $115,600 $123,050 Low
Income
$104,400 $119,300 $134,200 $149,100 $161,050 $173,000 $184,900 $196,850 Median
Income
$116,200 $132,800 $149,400 166,000 $179,300 $192,550 $205,850 $219,100 Moderate
Income
$139,450 $159,350 $179,300 $199,200 $215,150 $231,050 $247,000 $262,950 Source: State of California Department of Housing and Community Development, May 13, 2022. https://www.hcd.ca.gov/grants-funding/income-limits/state-and-federal-income-limits.shtml

The Regional Housing Needs Determination (RHND) is based on population projections produced by the

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California Department of Finance (DOF) as well as adjustments that incorporate the region’s existing housing need. The adjustments result from recent legislation requiring HCD to apply additional adjustment factors to the baseline growth projection from the DOF, in order for the regions to get closer to healthy housing m arkets. To this end, adjustments focus on the region’s vacancy rate, level of overcrowding and the share of cost burdened households and seek to bring the region more in line with comparable ones.5 These new laws governing the methodology for how HCD calculates the RHND resulted in a significantly higher number of housing units for which the Bay Area must plan compared to previous RHNA cycles.

Almost all jurisdictions in the Bay Area received a larger RHNA this cycle compared to the last cycle, primarily due to changes in state law that led to a considerably higher RHND compared to previous cycles.

The allocation that San Mateo received from the Draft RHNA Methodology is broken down by income category as follows:

Table 2: Final Regional Housing Needs Allocations
Income Group
San
Mateo
Units
San Mateo
County Units
Bay Area
Units
San Mateo
Percent
San Mateo
County
Percent
Bay Area
Percent
Very Low Income
(<50% of AMI)
1,777 12,196 114,442 25.3% 25.6% 25.9%
Low Income (50%-
80% of AMI)
1,023 7,023 65,892 14.6% 14.7% 14.9%
Moderate Income
(80%-120% of AMI)
1,175 7,937 72,712 16.7% 16.6% 16.5%
Above Moderate
Income (>120% of
AMI)
3,040 20,531 188,130 43.3% 43.1% 42.6%
Total 7,015 47,687 441,176 100.0% 100.0% 100.0%
Source: Association of Bay Area Governments Final Regional Housing Needs Allocations Plan, adopted on December 16, 2021 and approved by California Housing and Community Development on January 12, 2022.

3.2 Demographics

The following are key facts regarding the City’s demographic data and housing needs and issues from the demographic report, which can be found in Appendix A.

• Population – Generally, the population of the Bay Area continues to grow because of natural growth and because the strong economy draws new residents to the region. The population of San Mateo increased by 11.5% from 2000 to 2020, which is below the growth rate of the Bay Area.

• Age – In 2019, San Mateo’s youth population under the age of 18 was 21,827 and senior population 65 and older was 16,093. These age groups represent 20.9% and 15.4%, respectively, of San Mateo’s population.

• Race/Ethnicity – In 2020, 40.9% of San Mateo’s population was White while 1.9% was African American, 26.2% was Asian, and 25.1% was Latinx. People of color in San Mateo comprise a

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proportion below the overall proportion in the Bay Area as a whole.

• Employment – San Mateo residents most commonly work in the Financial & Professional Services industry. From January 2010 to January 2021, the unemployment rate in San Mateo decreased by

3.6 percentage points. Since 2010, the number of jobs located in the jurisdiction increased by 16,810 (42.7%). Additionally, the jobs -household ratio in San Mateo has increased from 1.17 in 2002 to 1.45 jobs per household in 2018.

• Number of Homes – The number of new homes built in the Bay Area has not kept pace with the demand, resulting in longer commutes, increasing prices, and exacerbating issues of displacement and homelessness. The number of homes in San Mateo increased 3.6% from 2010 to 2020, which is below the growth rate for San Mateo County and below the growth rate of the region’s housing stock during this time period.

• Home Prices – A diversity of homes at all income levels creates opportunities for all San Mateo residents to live and thrive in the community.
o Ownership The largest proportion of homes had a value in the range of $1M-$1.5M in 2019.

Home prices increased by 115.6% from 2010 to 2020.
o Rental Prices – The typical monthly rent for an apartment in San Mateo was $2,380 in 2019.

Rental prices increased by 74.2% from 2009 to 2019. To rent a typical apartment without cost burden, a household would need to make $95,240 per year.

• Housing Type – It is important to have a variety of housing types to meet the needs of a community today and in the future. In 2020, 44.3% of homes in San Mateo were single family detached, 9.9% were single family attached, 6.3% were small multifamily (2 -4 units), and 39.4% were medium or large multifamily (5+ units). Between 2010 and 2020, the number of multi-family units increased more than single-family units. Generally, in San Mateo, the share of the hous ing stock that is detached single family homes is below that of other jurisdictions in the region.

• Cost Burden – HUD considers housing to be affordable for a household if the household spends less than 30% of its income on housing costs. A household is considered “cost -burdened” if it spends more than 30% of its monthly income on housing costs, while those who spend more than 50% of their income on housing costs are considered “severely cost -burdened.” In San Mateo,

20.8% of households spend 30%-50% of their income on housing, while 16.8% of households are severely cost burden and use the majority of their income for housing.

• Displacement/Gentrification – 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, and 0.0% live in areas at risk of or undergoing gentrification. 63.4% of households in San Mateo live in neighborhoods where low -income households are likely excluded due to prohibitive housing costs. There are various ways to address displacement including ensuring new housing at all income levels is built.

• Neighborhood – 56.4% of residents in San Mateo live in neighborhoods identified as “Highest Resource” or “High Resource” areas by State-commissioned research, while 0.0% of residents live in areas identified by this research as “Low Resource” or “High Segregation and Poverty” areas.

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These neighborhood designations are based on a range of indicators covering areas such as education, poverty, proximity to jobs and economic opportunities, low pollution levels, and other factors.

• Special Housing Needs – Some population groups may have special housing needs that require specific program responses, and these groups may experience barriers to accessing stable housing due to their specific housing circumstances. In San Mateo, 9.1% of residents have a disability of some kind and may require accessible housing. Additionally, 9.0% of San Mateo households are larger households with five or more people, who likely need larger housing units with three bedrooms or more. 9.1% of households are female -headed families, which are often at greater risk of housing insecurity.

3.3 Units at Risk of Conversion to Market Rate

State law requires that each city provide analysis and programs for preserving existing affordable multi - family rental housing units that were developed with public subsidies. Units at risk of conversion are those units in which the restrictions, agreements or contracts to maintain the affordability of the units expire or are otherwise terminated. At expiration, units may revert to market r ate, rendering them no longer affordable to the people living in them. Loss of affordability can occur at the termination of bond funding, the expiration of density bonuses, and other similar local programs.

The potential loss of existing affordable housing units is an important issue to the City due to displacement of lower-income tenants and the limited alternative housing for such persons. It is typically less expensive to preserve the affordability of these units than to subsidize construction of new affordable units due to the inflation of land and construction costs which has occurred since the original development of the affordable housing projects.

3.3.1 Preservation and Replacement Options
Based on City records and information from the California Housing Partnership Corporation, a total of 65 units in San Mateo have affordability covenants that will expire during the next ten years (2023-2033):

Bridgepointe Condominiums. This development f rom 1999 contains the City’s first Below Market Rate (BMR) units, 59 in all, of which 24 are very low income (50% AMI) and the remainder (35) are at 120% of AMI, at the top of the moderate-income level. The expiration date for the 59 units is 2027, and the city has included a program (H 2.2) to assist in the preservation of these units. However, the 24 very low- income units are most at risk since rents at 120% of median are closer to market rate.

Belmont Building. Originally financed in 1993, this project involved the conversion of six units to family rentals, serving very low -income households (50% AMI) . The affordability of the project was created through loans in two programs. Federal HUD loans were used for the rehabilitation of the building. These loans are set to expire in 2032. The developer of this project was a private entity , but a longtime participant in the Section 8 voucher program.

Preservation of at‐risk projects can be achieved in a variety of ways, with adequate funding availability.

Alternatively, units that are converted to market rate may be replaced with new assisted multi‐family units with specified affordability timeframes.

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Rehabilitation Projects. The City funds rehabilitation projects for low-income residents of San Mateo to promote access to suitable living environments within each home. The Minor Home Repair program is funded through the Community Development Block Grant (CDBG) program and serves an annual goal of 10 units through general repairs, 14 units through accessibility modifications, and 7 units through weatherization upgrades. Furthermore, the City provides low-interest loans for rehabilitation projects of up to $60,000 per home for low-income homeowners through the CALHOME program. During this cycle, 10 rehabilitation loan projects are anticipated to be completed. Overall, these programs will result in the rehabilitation of a total of 258 affordable housing units.

3.3.2 Rental Assistance
State, local, or other funding sources can be used to provide rental subsidies to maintain the affordability of at‐risk projects. These subsidies can be structured to mirror the Housing Choice Voucher/Section 8 program, whereby the subsidy covers the cost of the unit above what is determined to be affordable for the tenant’s household income (including a utility allowance) up to the fair market value of the apartment.

Unit sizes for the at‐risk properties range from studios to two‐bedroom units and are generally reserved for very low‐income households. The total annual subsidy to maintain the 30 at‐risk units (the 24 from Bridgepointe and the six from Belmont Building) is estimated at about $600,000.

3.3.3 Transfer of Ownership
If the current organizations managing the units at risk are no longer able to maintain the project, transferring ownership of the affordable units to a nonprofit housing organization is a viable way to preserve affordable housing for the long term. The estimated market value for the 30 affordable units that are potentially at high risk of converting to market rate is nearly $350,000 per unit, or $10.5 million total.

3.3.4 Construction of R eplacement Units
The construction of new low‐income housing can be a means to replace at‐risk units, though extremely costly. The cost of developing new housing depends on a variety of factors including density, size of units, construction quality and type, location, land and development costs. Using the Terner Center’s research on the cost to develop affordable housing around the Bay Area, the cost to replace the units could be as much as $700,00 per unit, or $21 million.

3.3.5 Entities Interested in Part icipating in California's First Right of Refusal Program An owner of a multi‐family rental housing development with rental restrictions (i.e., is under agreement with federal, State, and local entities to receive subsidies for low‐income tenants), may plan to sell their “at risk” property. The California Department of Housing and Community Development (HCD) have listed qualified entities that may be interested in participating in California's First Right of Refusal Program. If an owner decides to terminate a subsidy contract or prepay the mortgage or sell or otherwise dispose of the assisted housing development, or if the owner has an assisted housing development in which there will be the expiration of rental restrictions, the owner must first give notice o f the opportunity to offer to purchase to a list of qualified entities provided to the owner.

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HCD has identified six entities that may be interested in participating in California's First Right of Refusal Program in San Mateo County:

• ROEM Development Corporation
• Northern California Land Trust, Inc.
• Housing Corporation of America
• Mid‐Peninsula Housing Coalition
• Affordable Housing Foundation
• Alta Housing (previously Palo Alto Housing Corp)

Of these entities, some have worked specifically in San Mateo, and others have completed projects in surrounding areas. If a development becomes at risk of conversion to market‐rate housing, the city will maintain contact with local organizations and housing providers who may have an interest in acquiring at‐ risk units and will assist other organizations in applying for funding to acquire at‐risk units.

3.3. 6 Funding Sources
A critical component to implement any of these preservation options is the availabi lity of adequate funding, which can be difficult to secure. In general, Low‐Income Housing Tax Credit funding is not readily available for rehabilitation and preservation, as the grant application process is highly competitive and prioritizes new construct ion. The City’s previous ongoing funding source, Low/Mod Housing Funds available through the Redevelopment Agency, no longer exists due to the dissolution of Redevelopment more than a decade ago. However, affordable housing impact fees are a new, local fun ding source, and the city may consider developing inclusionary zoning in lieu fees as well. Additional available funding sources that can support affordable housing preservation include sources from the federal and state governments, as well as local and regional funding.

Federal Funding
• HOME Investment Partnerships (HOME) Program
• Project‐Based Vouchers (Section 8)
• Section 811 Project Rental Assistance
• Veterans Affairs Supportive Housing (VASH) Vouchers

State Funding
• Affordable Housing and Sustainable Communities (AHSC) Program • Golden State Acquisition Fund (GSAF)
• Project Homekey
• Housing for a Healthy California (HHC)
• Multifamily Housing Program (MHP)
• National Housing Trust Fund
• Predevelopment Loan Program (PDLP)
• Permanent Location Housing Allocation (PLHA)

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Regional, Local, and Nonprofit Funding
• San Mateo County Affordable Housing Fund
• Housing Successor Agency for the Redevelopment Agency • City Housing Fund
• Commercial Linkage Fee (CLF)
• City General Fund

As noted in the Goals, Policies and Programs, the City will work with the owners of both the Bridgepointe and Belmont Building projects prior to the expiration of their affordability restrictions to develop a plan to retain the units as affordable, replace the units elsewhere, or relocate tenants into alternative housing that is affordable to them.

3.4 RHNA Allocation Summar y and Methodology

3.4.1 Legislative Context for the Housing Element’s Inventory of Sites Per State law, the State of California, in conjunction with Association of Bay Area Governments (ABAG), has projected future population figures for the nine Bay Areas counties which translates into the need for additional housing units. Each jurisdiction is then assigned a portion of the regional need based on factors such as growth of population and adjusted by factors including proximity to jobs, and high resource areas that have excellent access to amenities such as good school and employment centers. This assignment is known as the Regional Housing Needs Alloca tion (RHNA). Each jurisdiction must ensure that there is enough land at appropriate zoning densities to accommodate its RHNA in its Housing Element in four income categories (very low-, low-, moderate- and above moderate-income). The RHNA for City of San Mateo for the Housing Element 2023-2031 is 7,015 units, which are broken down by income category in Table 3.

Table 3: San Mateo RHNA Targets Summary
Income Category Very Low
50% AMI
Low
80% AMI
Moderate
120% AMI
Above
Market Rate
Total
2023-31 Allocation 1,777 1,023 1,175 3,040 7,015
Table Source: Housing Element Cycle 6 RHNA Allocation

A key component of the Housing Element is a projection of a jurisdiction’s housing supply. State law requires that the element identify adequate sites for housing, including rental housing, factory -built housing, and mobile homes, and make adequate provisi on for the existing and projected needs of all economic segments of the community. This sites list is required to include an inventory of land suitable for residential development, including vacant sites and sites having potential for redevelopment, including analysis of the development capacity that can realistically be achieved for each site.

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 cur rent 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. It does not dictate where resident ial development will actually occur, and the decision whether or not to develop any particular site always remains with the owner of the property, not the City. Based on previous Housing Elements, the City

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anticipates that some of the sites on the list will be developed with new housing, some will not, and some housing will be built on sites not listed in the inventory. The Sites Inventory is further outlined below, with a breakdown of the units in Table 8. The complete Sites Inventory is included as Appendix C.

A number of new housing laws have significantly changed how a sites inventory is developed, introducing changes to the following components of the site inventory:

• Design and development of the site inventory (SB 6, 2019) • Requirements in the site inventory table (AB 1397, 2017 AB 1486, 2019) • Capacity calculation (AB 1397, 2017)
• Infrastructure requirements (AB 1397, 2017)
• Suitability of nonvacant sites (AB 1397, 2017)
• Size of site requirements (AB 1397, 2017)
• Locational requirements of identified sites (AB 686, 2018) • Sites identified in previous housing elements (AB 1397, 2017) • Non-vacant site replacement unit requirements (AB 1397, 2017) • Rezone program requirements (AB 1397, 2017)

These laws are further described in Section 2.2 (Legislative Context) of the Housing Element and were adhered to for development of the Sites Inventory.

3.4.2 Site Inventory Methodology
City staff inventoried vacant and underutilized parcels in San Mateo to determine what land is available for development at various levels of density. Types of sites included:

• Vacant sites zoned for residential use.
• Vacant sites zoned for nonresidential use that allow residential development. • Residentially zoned sites, including non-residentially zoned sites with a residential overlay, that are capable of being developed at a higher density (non -vacant sites, including underutilized sites).
• Sites owned or leased by a city, county, or city and county.

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 comparable developments built on land with various zoning designations over the past five years.

The City of San Mateo's Sites Inventory for future housing includes property zoned for mul ti-family use that is currently vacant as well as land that is underutilized. Sites that are zoned commercial or office but allow residential uses were included. As seen in Table 8 below, the adequate sites analysis demonstrates that there is enough land with sufficient zoning capacity to meet the City’s RHNA. The analysis for affordable housing units for extremely low, very low, and low -income households is based on the assumption that land zoned at densities higher than 30 units to the acre can facilitate affordable housing development, given the City’s inclusionary requirements of 15%. More than 50% of the City’s below market rate housing would be developed on lands that are underutilized. However, the city is experiencing

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a high volume of residential and mixed -use development project s looking to revitalize these sites and seeking density bonus and other incentives to achieve higher density residential development. Example projects that demonstrate this trend are included in Attachment C.

3.4.3 Site Inventory Approach
Staff conducted a site -by-site review of all potential development sites, citywide. As is demonstrated below, there are enough sites with sufficient acreage that can meet the RHNA, plus a reasonable buffer, within the existing zoning densities and the growth limits of the voter -approved initiative known as Measure Y.7 However, it should be noted that because of the density limit set by Measure Y , additional sites and overall acreage are included in the Sites Inventory to meet the RHNA. It is anticipated that once the land use map in the City’s 2040 General Plan Update is adopted, half as many sites currently listed would be needed to achieve the RHNA for this housing cycle.

Development Potential Ranking. Each site – or potential aggregation of sites – was analyzed to discern the likelihood and feasibility of development during the period 2023 -2031. Factors such as underperforming or vacant uses, owner or developer interest, age and size of current improvements, site size, and site constraints were reviewed. Depending on these considerations, sites were ranked from 1 to 5, with 1 being a site unlikely to develop/redevelop within the planning period, and 5 being highly likely to develop/redevelop during the period. Samples of these rankings include, but are not limited to:

• National chain gas stations, national chain fast food restaurants, and community-serving grocery stores. The State has indicated these types of sites are the most difficult to justify including in an inventory. Generally, no sites in this category are included in the inventory; however, the city has identified two groups of sites with redevelopment interest that are ranked 4 ( sites within Bridgepointe Shopping Center and Bel Mateo’s Olympic Plaza shopping area). • Sites that are extremely small (less than 0.5 acres in size) with little opportunity for aggregation, sites that may require substantial environmental clean -up, and other heavily constrained sites.

No sites in this category are included in the inventory. • Sites with existing uses that could be redeveloped along with adjacent parcels, but which may have multiple owners, small underperforming strip malls, and certain office developments. Many of the City’s sites are within this category but follow recent trends of consolidation and development patterns in the City.
• Sites that have uses on them but in which a developer has expressed interest in the site, shopping malls with significant potential for redevelopment, adjacent sites with onl y one or two owners, and low -density commercial developments in high -density areas. Many of the City’s sites are within this category.
• Large sites with potential for substantial development, vacant sites, or sites with proposed or soon to be proposed projects and approved projects that have not yet been built. Majority of the City’s sites are in this category and have either proposed or approved projects that have not yet been built.

Zoned versus Realistic Capacity. When establishing realistic unit capac ity calculations, the jurisdiction must consider current development trends of existing or approved residential developments at a similar affordability level in that jurisdiction, as well as the cumulative impact of standards such as maximum lot

7 Measure Y imposes growth limits on the height, density and intensity of new development that can be built in San Mateo through 2030.

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coverage, height, open space, parking, and floor area ratios. The capacity methodology must be adjusted to account for any limitation as a result of availability and accessibility of sufficient water, sewer, and dry utilities. For non -residential zoned sites (mixed -use areas or commercial sites that allow residential development), the capacity methodology must account for the likelihood of residential development on these sites. While a site may be zoned to accommodate, say, 100 units, site constraints or other development standards may preclude development to the full 100 units.

Residential Zones. Since the certification of the last Housing Element, a series of new laws have been implemented that make it easier for developers to use the State density bonus provisions by providing a certain percentage of units in proposed developments as affordable.8 As a result, many developers are taking advantage of the additional density offered, which has resulted in significant changes to the realistic capacity for development. The following table illustrates that for last six years, from 2017-2022, a significant number of residential development projects have been proposed and/or approved at densities meeting or exceeding 100% of zoned density (11 of 14 infill projects). Although the State has specifically stated that cities cannot rely on density bonuses alone to calculate capacity (primarily because use of the density bonus is optional), cities can use up to 100% of zoned density as the realistic capacity as long as they can demonstrate that as-built densities are consistently above zoned density.

Table 4: 2017 – 2022 Residential Project Densities
Infill Development
Address Acres Units
Max Base
Density
(DU/A)
Percent of
Base Density
Resulting
Density
(DU/A)
1650 Delaware St. 1.1 73 50 133% 68
BM Montara, 2775 S. Delaware St. 1 68 50 136% 68
Central Park South, 31 9th Ave. 1.1 60 50 109% 56
Station Park Green, 1790 S.

Delaware St. 12 599 50 100% 50
200/210 S. Fremont St. 0.4 15 50 75% 43
BM Morgan, 2901 E. Kyne St. 1.6 82 50 103% 51
BM Res 6, 3069 E. Kyne St. 1.1 54 50 98% 50
Passage, 666 Concar Dr. 14.5 961 50 133% 66
1919 O’ Farrell St. 0.7 49 50 140% 69
4 W. Santa Inez Ave. 0.25 10 40 100% 40
1 Hayward Ave. 0.29 18 44 142% 61
222 E 4th Ave. 1.13 10 50 18% 9
500 E 3rd Ave. 1.51 111 50 148% 74
401 Concar Dr. 2.81 191 50 136% 68
Aggregate Units per Acre 33.5 1,961 112% 58.3

8 For more than forty years, California’s Density Bonus Law (Government Code Section 65915 et seq.) has been a mechanism to encourage developers to incorporate affordable units within a residential project in exchange for density bonuses and relief from other base development standards through concessions and waivers. The amount of additional density allowed depends on the level of affordability provided

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Outlier Development
Address Acres Units
Max Base
Density
(DU/A)
Percent of
Base Density
Resulting
Density
(DU/A)
1, 2 and 3 Waters Park Dr. 11.1 190 35 49% 17
Promenade, 220 N. Bayshore Blvd. 2.1 42 50 40% 20
Peninsula Heights, 2988 Campus Dr. 15.5 290 35 53% 19
Outlier Aggregate Units per Acre 28.7 522 47% 18.2

Although the maximum base densities of Multi-family Zones R3, R4 and R5 range from 35 to 50 dwelling units per acre, the average residential density for recently approved projects is 58.3 dwelling units per acre (du/ac) due to projects almost always utilizing State Density Bonus provisions. Therefore, it is appropriate and justifiable to use the maximum density of 50 du/ac as the realistic capacity for many of the new infill housing development sites that have comparable characteristics to these recently approved projects. However, there were three outlier development projects that had much lower densities than the infill housing projects. These developments had specific site and use related restrictions such as being in the flood zone, being located far away from transit, or being used for ownership housing instead of rental housing. These outlier projects had an average density of 18.2 du/ac, which can be used as a density assumption for sites that have similar challenges or site characteristics . Based on this history, the Sites Inventory generally calculates the realistic capacity as follows:

• 100% of base zoned density for infill sites zoned as multi-family residential (R3, R4, R5); • Calculated at either 50 du/ac or 35 du/ac in accordance with base zoning; • For sites smaller than 0.5 acre, 50% of base density; and • For sites with characteristics similar to the outlier projects, density estimated at 18.2 du/ac.

Mixed-Use/Commercial Zones. San Mateo has several office and commercial zones that also allow residential development. As a result, a significant number of projects in the last six years located in commercial or mixed-use zones have included a residential component. The only commercial zone that prohibits residential uses is the C-4 Service Commercial district, which includes uses such as auto repair and light industrial uses and encompasses less than 1% of the total commercial-zoned land within the city. Table 5 shows the number of approved projects on sites in commercial and mixed-use zones from 2017-2022.

Although the percentage of residential uses in these projects varied, the average density was 49 units to the acre (98% of base zoned density) . Since historically 80% of the commercially zoned sites included housing, the State guidance is to extrapolate the trend by multiplying the 80% probability times the 49 du/ac average, which results in 39 du/ac. For those sites that assume mixed -use with r esidential components in the sites inventory, potential density is assumed more conservatively at 30 to 35 du/ac.

For small sites less than 0.5 acres, it was generally assumed that the realistic capacity would be approximately 50% of zoned capacity, given the physical constraints associated with maximizing use of those sites.

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Table 5: 2017 – 2022 Planning Development Approvals
Address
Development Type Description
No. of
Dwelling
Units
% of
Project
Residential
(approx.) Base Zoning
Lot
Size/
Acres
Dwelling Units
per Acre
2946 S. Norfolk St.

Hotel
Demo 166-room
hotel. Construct new
5-story building with
182 hotel rooms.
0 0% C2-1:

Commercial
that allows
hotel

2.28 N/A
1 Franklin Pkwy
Office
New 4-story office
building located
within Bay Meadows
Phase I
0 0% BMSP:

Office per
the Bay
Meadows
Specific Plan

9.86 N/A
520 S. El Camino
Real
Office
Addition and
renovation of 9-story
office building.
0 0% E2-2: Office 2.32 N/A
2750 S. Delaware
St.

Office
New 4-story office
building located
within Bay Meadows
Phase II (Station Block
1)
0 0% BMSP:

Office per
the Bay
Meadows
Specific Plan

5.37 N/A
180 E. 3rd Ave.

Mixed-Use
Demo commercial
building. New 3-story
mixed-use building
with retail and office
uses.
0 0% CBD:

Commercia,
office, DT
residential

0.16 N/A
21 Lodato Ave.

Triplex
Demo single-family
dwelling. Construct
new, detached
townhomes.
3 100% C2-1:

Commercial

0.21 14
2089 Pacific Blvd.

Mode Apartments
Multi-Family
Conversion of eight
two-bedroom units
into 16 studio units
for a net increase of 8
units.
8 100% TOD: Mixed-
Use

2.37 3
4 W. Santa Inez
Multi-Family
Demo two single-
family dwellings.

Construct new multi-
family condominium
building.
10 100% R4: Multi-
Family
Dwelling

0.25 40
222 E 4th Ave.

Mixed-Use
Demo existing grocery
store. New mixed-use
development with
retail (grocery), office
and residential uses.
10 7% CBD/R:

Commercial
with
residential
overlay

1.13 9
405 E. 4th Ave.

Mixed-Use
Demo 2 historic
structures. New 4-
story office and
residential building.
15 16% CBD-S:

Commercial
and DT
Residential

0.51 30

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1 Hayward Ave
Mixed-Use
Demo existing
commercial and
residential uses (5
units). New mixed-use
development with
office and residential
uses.
18 77% E2-1/R4:

Office with
residential
overlay

0.29 61
406 E 3rd Ave.

Mixed-Use
Demo existing
commercial buildings.

New 4-story office
and residential
building.
25 14% CBD-S:

Commercial
and DT
Residential

0.88 28
1919 O’Farrell St.

Multi-Family
Demo existing office
building. New 5-story
residential apartment
building.
49 100% E1-1/R4:

Office with
residential
overlay

0.71 69
303 Baldwin Ave.

Mixed-Use
Demo existing grocery
store. New 5-story
mixed-use building
with ground floor
commercial and office
and residential uses
above.
64 40% C1-2/R5:

Commercial,
office with
residential
overlay

0.93 68
2700 S. El Camino
Real
Mixed-Use

Demo two
commercial buildings.

New 5-story
commercial and
residential building.
68 80% C3-1/R4:

Commercial
with
residential
overlay

1.00 68
Bay Meadows
Site Address TBD
Mixed-Use
New 4-story mixed-
use building on MU2
Block with ground
floor retail uses and
office above; and new
4-story mixed-use
building on MU3 Block
with ground floor
retail uses and
residential above.
67 15% BMSP:

Mixed-Use
per Bay
Meadows
Specific Plan

1.51 44
2775 S. Delaware
St.

Multi-Family
New residential
apartment building
(100% affordable)
68 100% BMSP:

Mixed-Use
per Bay
Meadows
Specific Plan

1.00 68
1650 S. Delaware
St.

Multi-Family
Demo the existing
office building. New 5-
story 73-unit
residential apartment
building
73 100% TOD: Mixed-
Use

1.07 68

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99-157 E. 5th Ave.

Mixed-Use
Demo existing surface
parking lot. New 5-
story mixed-use
building with retail
and residential uses.
80 90% CBD/R:

Commercial
with
residential
overlay

1.20 67
500 E 3rd Ave.

Mixed-Use
Demo existing retail
and residential
structures (8 units).

New mixed-use
development with
office and residential
uses.
111 33% CBD-S:

Commercial
and DT
Residential

1.51 74
1, 2 and 3 Waters
Park Dr.

Multi-Family

Demo office campus.

New multi-family
buildings with single-
family, townhouses
and condominium
units.
190 100% Rezoned
from E1:

Office to R3
multi-family

11.13 17
401 Concar Dr.

Mixed-Use
Demo surface parking
lot. New residential
apartment building.
191 100% TOD: Mixed-
Use

2.82 68
480 E 4th Ave.

Multi-Family
Demo surface parking
lot. Construct new 7-
story multi-family
building with 225
affordable units. New
separate 5-level
public/private parking
garage at 400 E. 5th
Ave.
225 53% CBD-S:

Commercial
and DT
residential

2.41 93
2988 Campus Dr.

Multi-Family
Demo 4 office
buildings on 2 sites.

New multi-family
residential buildings
on two parcels.
290 100% E1-1: Office 15.45 19
666 Concar Dr.

Mixed-Use

Demo existing
shopping center. New
mixed-use
development with
commercial, office
and residential uses.
961 97% TOD: Mixed
use

14.51 66
Total Projects 25
Total with
Residential
20 (80%)

Average Dwelling Unit per acre for projects
with Residential
49 Identification of Sites for Affordable Housing . Sites on the Inventory must also be classified as suitable for various income levels including very low, low, moderate and above moderate. Several housing laws impact how sites are selected for inclusion by income category. In general, sites less than 0.5 acres cannot

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be considered as available for lower income development unless the jurisdiction demonstrates that it has a track record of affordable developments at this size of lot. For this inventory, no individual site less than

0.5 acres is allocated toward lower income units; however, as per State guidance, such small sites can be considered either for moderate income, above moderate income, or both.

Sites larger than 10 acres are generally considered unavailable for affordable housing, unless the Housing Element can demonstrate a track record for developing such sites of this size, or the city can demonstrate it is otherwise feasible to develop affordable housing. The City has a demonstrated track record of large site development, typically completed i n phases, that includes affordable 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.

In this inventory, there are only three sites larger than 10 acres. This includes Concar Passage, Hillsdale Mall, and Bridgepointe Shopping Center . Concar Passage (14.53 acre ) is an approved mixed-use development proposing commercial, retail and residential uses. The project provides 961 residential units, including 73 units that are affordable for lower income families (80% AMI). Additional information on Concar Passage can be found in Appendix C. The following discussion will focus on the Hillsdale and Bridgepointe shopping centers as feasible sites for affordable housing.

Hillsdale Mall.

Originally built in the 1940’s, the Hillsdale Shopping Center is approximately 47 acres in total, of which about 33 acres are included in the inventory. The property owner, the Bohannon Organization, has expressed interest in redeveloping a significant portion of the site to address what it calls “a changing retail l andscape.” In a recent article in the Daily Journal, David Bohannon (President) stated that his organization is interested in bringing more vibrancy to the place, with additional office and housing on site. In 2019, more than 4,000 people provided input on what should happen with the Hillsdale Mall on the https://reimaginehillsdale.com/ website, and 54.2% stated that providing new housing, including affordable workforce housing, was very important to respondents. Based on the express interest in providing a mixed -use development with housing for the site, the inventory shows a distributi on of affordable units based on the RHNA calculations at 42 units per acre. It should also be noted that the preliminary land use map in the General Plan Update has identified this site for Mixed -Use Medium (up to 100 units/acres) and Mixed-Use High (up to 200 units/acre) land use designations. To support this effort and ensure sufficient development capacity through 2040, the City has a program to adopt the General Plan Update in 2023/2024 (Housing Policy H1.21).

Within the Housing Element planning period, it is a nticipated that the property owner will submit a planning application for a Master Plan to redevelop a large portion of the property. This is based upon the property owner’s letter of interest 9, as well as the owner’s ongoing commitment (since 2019) to gather input from the community through a robust outreach and engagement strategy which includes an interactive learning, ideation, and sharing space called the “Idea Store” within the center, a 25-question in-store and online survey, public presentations, dialogue sessions, website and social media. Given the

9 “Hillsdale Shopping Center—Preferred Land Use Scenario,” David Bohannan, updated April 15, 2022, https://strivesanmateo.org/wp-content/uploads/2022/04/2022_04_15_Bohannon-Organization_Redacted.pdf

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changing retail climate, it is anticipated that some of the existing commercial uses in the center may choose to relocate elsewhere while others may choose to find a new space within the new development.

While the site has a zoned capacity of 50 units per acre (approx. 2,000 units), to account for a mixed-use redevelopment of the site , a portion being maintained as a retail shopping center and per the owner’s assessment of what could be developed on the site, a realistic capacity of 1,200 units (35 units per acre) has been estimated for this site. A detailed narrative of the Hillsdale sites is provided in Appendix C.

Bridgepointe. The inventory also includes sites within Bridgepointe, an underutilized commercial shopping center, with significant amounts of surface parking, with the largest parcel at about 12 acres.

There have been a variety of discussions with the shopping center’s ownership representatives who have expressed interest in mixed-use redevelopment that includes both housing and commercial. By assuming mixed-use development on these parcels, primarily on the areas occupied by surface parking, the City is calculating the realistic capacity at 30 units per acre. The General Plan Update is exploring policies to create an updated Bridgepointe Area Plan that would guide redevelopment of the shopping center into a mixed-use neighborhood that supports a variety of housing types, including affordable housing. The draft land use plan designates Bridgepointe as Mixed-Use High, which could allow up to 200 units per acre. A detailed narrative of the Bridgepointe sites is provided in Appendix C.

The new requirements for Affirmatively Further Fair Housing (AFFH), pursuant to AB 686, dictate that the city avoid, to the extent possible, the location of potential affordable housing in the inventory in a manner that would exacerbate existing concentrations of poverty, as well as contribute to increasing the number of lower-income households in lower-income neighborhoods. The city must also consider locating housing away from environmental constraints such as sea level rise or high fire hazard severity zones, and near areas of higher or highest opportunities, including quality schools, par ks, and educational opportunities.

The State indicates that jurisdictions consider the following factors when determining the best locations for affordable housing.

• Proximity to transit.
• Access to high performing schools and jobs.
• Access to amenities, such as parks and services.
• Access to health care facilities and grocery stores.
• Locational scoring criteria for Low-income Housing Tax Credit (TCAC) Program funding. • Proximity to available infrastructure and utilities.
• Sites that do not require environmental mitigation.
• Presence of development streamlining processes, environmental exemptions, and other development incentives.

One measurement tool to evaluate neighborhood amenities and resources is the Tax Credit Allocation Committee (TCAC) Opportunity Area Map. Each site in the inventory list is rated as either Low, Moderate, High or Highest Resource area utilizing the mapping tool (there are no “Low” resource areas in San Mateo).

The Sites Inventory, which includes properties citywide, many of which are in high resource areas, appears to comply with these requirements as currently understood . Overall, the sites identified as suitable for lower income housing in San Mateo are located in moderate or high resource areas. The inventory

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currently does not project any new affordable housing to be developed in the Shoreview, North Central, and similar areas, which include higher concentration of lower -income households than other areas of the city. Information about all of the AFFH requirements and how they have been addressed in the Sites Inventory is included in Appendix D. A map that shows the HCD/TCAC Opportunity Map overlaid with the Sites Inventory housing sites is provided as Figure 1.

Distribution of Units by Affordability. Consistent with State guidance, individual sites less than 0.5 acres were assumed to be developed with moderate- and above-moderate income, split 50% to each. For sites larger than 0.5 acres, the distribution of units by income category fell into two types:

1. For sites in the pipeline, the actual proposed distribution of units by affordability was included.

For example, Concar Passage (Planning Application PA-2018-052) includes a total of 961 units, of which 73 will be very low-income. These are the figures used in the spreadsheet.

2. For all other sites, the distribution of units by affordability is in the same proportion as the RHNA allocation.

The State recommends using the proportion of units in the RHNA allocation as a guide for allocating units among sites. This mathematical process is intended to demonstrate that there are enough sites zoned at appropriate densities to accommodate all of the RHNA allocation, rather than an assumption about the specific location and number of affordable units that will actually be built. In part, this is because the city does not determine specific sites for affordable housing, but rather reviews and evaluates projects as they are proposed by property owners, developers and other outside entities.

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Figure 1: 2021 TCAC/HCD Opportunity Map
Source: California Tax Credit Allocation Committee, 2021; City of San Mateo, 2022.

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Table 6: Example RHNA Income Distribution
RHNA Allocation Income Distribution
Very Low Income Low Income Moderate Income Above Moderate Income Total 26% 15% 17% 43% 100%

Thus, for a 1-acre site at 50 du/ac, the distribution would be as follows:

RHNA Allocation Income Distribution
Very Low Income Low Income Moderate Income Above Moderate Income Total 13 7 8 21 50

In addition, because of new rules in the Housing Accountability Act’s “No Net Loss” provisions (SB 166 of 2017), the land inventory and site identification programs in the Housing Element must always include sufficient sites to accommodate the unmet RHNA, in terms of the number of housing units, as well as the level of affordability. When a site identified in the Element as available for the development of housing to accommodate the lower‐income portion of the RHNA is developed at a higher income level, the locality must either (1) identify and rezone, if necessary, an adequate substitute site, or (2) demonstrate that the land inventory already contains an adequate substitute site. By distributing units to sites according to the distribution of the RHNA allo cation – including above moderate income – it will be easier to ensure ongoing compliance with the No Net Loss provisions.

3.4.4 Pipeline Projects
In addition to the sites potentially available for development or redevelopment, projects that have been approved, permitted, or received a certificate of occupancy since the beginning of the RHNA period may be credited toward meeting the RHNA allocation b ased on the affordability and unit count of the development. For these projects, affordability is based on the actual or projected sale prices, rent levels, or other mechanisms establishing affordability in the planning period of the units within the project. These sites are included in the Sites Inventory (Appendix C ), as each project is anticipated to receive its Certificate of Occupancy during this housing cycle ( after June 30, 2022). New development currently in the pipeline includes approximately 640 new housing units under construction, 1,580 new housing units approved and 680 new housing units under review. The total number of pipeline project units is 2,915, which accounts for 42% of the City’s total RHNA.

3.4.5 Accessory Dwelling Units
Accessory dwelling units (ADUs) are a housing type that can meet the needs of middle- and lower-income individuals and households. Based on increased documentation and State guidance, jurisdictions are allowed to count projected development of ADUs based on prior year production averages. A s outlined in Table 7, the City has issued an annual average of 57 building permits for ADUs, including JADUs, over the last four years (2019-2022). Consistent with th e accepted approach using a four-year average of permitting data, the Sites Inventory includes a projection of 55 new ADUs annually, resulting in 440 new ADUs over the eight-year cycle. It should be noted that in both 2021 and 2022, ADU permits issued by the City significantly exceed the annual estimate of 55.

Table 7: ADU/JADU Annual Permit Data
2019 2020 2021 2022* 4-Year Ave.

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Applications Submitted 56 94 94 80 81
Permits Issued 44 47 66 70 57

A study conducted by the Association of Bay Area Governments (ABAG) in September 2021 found that ADUs are rented at a variety of rates and often meet lower income affordability requirements based on the incomes of the occupants and/or their rental rates. Based on these findings, local jurisdictions are justified in using certain percentages to meet their affordable housing allocations. The study’s recommended affordability breakdown that a Bay Area jurisd iction can use for ADUs, which is noted as being conservative, is 30% very low, 30% low, 30% moderate and 10% above moderate. The report also notes that if a jurisdiction has fair housing concerns, they may want to use even more conservative assumptions an d go with 5% very low, 30% low, 50% moderate and 15% above moderate. This affordability mix is consistent with the data in its study of market rate Peninsula ADUs , which specified 6% very low, 31% low, 48% moderate, and 15% above moderate. Thus, it should be noted that the City is using the very conservative assumption of 5/30/50/15 to estimate the ADU affordability mix in the Sites Inventory.

3.4.6 San Mateo General Plan Update
The City’s General Plan Update (GPU) kicked off in Fall 2018 with a series of visioning workshops and community meetings. From April 2019 through November 2022, the
City identified study areas where growth and change
would occur, to create a range of growth alternatives, and receive feedback and direction on the preferred land use and circulation scenarios from the community and, ultimately, the City Council. In April 2022, the preferred land use and circulation scenarios were selected by the City Council, and in July 2022, the draft land use map that would go into the GPU was confirmed by the City Council.

The draft land use map in the GPU’s Land Use Element includes significant changes to the allowable heights and densities within the ten Study Areas, with densities increasing from 35-50 units per acre to 100-200 units per acre. The increased density in the draft land use map will allow for up to 21,900 new housing units to be developed over the next 20 years. Adoption of the GPU will also significantly increase the housing capacity of the housing sites identified on the Sites Inventory since over 90 percent of these sites are within a Study Area and will have an updated land use designation with increased base density.

Figure 2 illustrates how the Sites Inventory sites overlay with the 10 General Plan Update Study Areas.

As part of the G PU process, a community conversation about Measure Y, the voter approved initiative that sets growth and density limits until 2030, is being facilitated in order to build consensus around a path forward that allows for the housing growth that is needed over the next 20 years while balancing community concerns about growth and change. The draft land use map in the GPU includes building heights and densities that exceed the limits set by Measure Y , so over the next year, the community discussion around Measure Y and the GPU will continue. Ultimately, all elements of the GPU that exceed the growth limits set by Measure Y will require voter approval before they can take effect. Community input, and ultimately City Council direction, will guide how to best address the elements of the GPU that

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go beyond the Measure Y height and density limits. Next steps in this discussion include a study session with the City Council in Spring 2023 and community outreach in Spring and Summer 2023. Ultimately, as part of the City Council’s adoption of the GPU, an initiative that updates and/or modifies Measure Y could be placed on the ballot in 2024. Policy H1.21 has been added to support this community discussion and highlight the non-governmental constraint on housing production posed by Measure Y.

Publication of the Draft General Plan and the Draft Environmental Impact Report (EIR) is planned for Spring 2023, with a target for adoption by the end of 2023. More information about the General Plan Update can be found at www.StriveSanMateo.org.

3.4.7 City Properties and Funding
The City of San Mateo is committed to supporting the development of affordable housing by utilizing City owned properties and funding to help achieve this goal. Two significant 100% affordable housing projects are currently underway on City owned parcels (formerly public parking lots). 480 E. 4th Avenue (Kiku Crossing)
This project will provide 225 affordable homes
for families and individuals in San Mateo,
including 22 units for formerly homeless
households and 8 units for individuals with
intellectual and developmental disabilities, and
57 units for public employees. The affordability
of the units will be a mix of ELI, VLI and LI .

Construction started in January 2022 and is
expected to complete in spring 2024. It is being
built on City owned property and funded by a combination of City, State, and Federal dollars.

445 S. B Street (Bespoke) This project is a public-private partnership that will redevelop a full City block that includes a City owned property and a City monetary contrib ution. The project will provide 60 affordable apartment units (at VELI, VLI and LI levels), community facilities, and commercial and office space. The project is currently under review, with a target for approval in 2023/2024 and construction starting in 2025/2026.

To support the ongoing development of new affordable housing in San Mateo, the City established a dedicated funding source in 2016 with the adoption of an Affordable Housing Commercial Linkage Fee (SMMC Chapter 23.61). In addition, the City has a policy to set aside 20% of the general fund property tax revenues from former Redevelopment Area (RDA) sites for its Housing Fund. Based on these two funding sources, as well as the Permanent Local Housing Allocation (PLHA) , Below Market Rate (BMR) fractional and in-lieu fees, and other miscellaneous housing funds, the City’s Affordable Housing Fund currently has approximately $5.8M, and is estimated to generate approximately $26M over the next eight years. Using the estimate of 100k per affordable unit , the City estimates that it may be able to create 260 new affordable units throughout the 6th Housing Element Cycle. The Housing Fund was used to support both the Kiku Crossing and Bespoke affordable projects and the City continues to actively look for other partnership opportunities to construct additional affordable housing in San Mateo in the coming years (Policy H1.2).

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In total, the City has contributed property and funding to support the development of 283 affordable housing units and maintains a Housing Fund with dedicated revenue that has a target of constructing an additional 260 affordable housing units, for a total of 543 new affordable housing units during this cycle.

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Figure 2: Sites Inventory Map
Universe: Sites Inventory, December 2022.

Notes: The individual sites identified as suitable for housing redevelopment are marked in pink while blue circles indicate groupings of sites. Site affordability breakdown by grouping is seen in Table 8.

Downtown
101/92
Interchange
Hillsdale
Station South
Bridgepointe
92/El Camino Real

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3.4.8 Missing Middle Housing
Missing middle housing and constraints to the development of such housing has been identified as a key programmatic priority for the City. Missing Middle housing describes small to medium-scale development such as duplexes, triplexes, and 4-10 unit projects that are compatible in scale with single‐family homes within walkable neighborhoods. To address this need and existing zoning constraints in the City that limit production of this type of housi ng, multiple policies and programs are included in th e Housing Element that would directly or indirectly support the production of such housing . Specifically, programs and implementation measures under the following policies are focused on reducing development standard constraints, reducing costs, expanding opportunities and streamlining the development review process for missing middle housing projects. The City is committed to expanding opportunities for Missing Middle housing and has included six policies that support this objective. • Policy H1.4 Incentivize Accessory Dwelling Unit Development • Policy H1.6 Streamline Housing Application Review
• Policy H1.7 Update Zoning Code Development Standards
• Policy H1.8 Adopt Objective Design Standards
• Policy H1.13 Encourage Development of Missing Middle Housing • Policy H1.18 Permitting and Development Fee Review

3.4.9 Single Room Occupancies (SRO) Housing
Single Room Occupancy (SRO) units are a type of housing alternative that is typically available to residents with low or minimal incomes. SROs are single-room (zero bedroom) units that are typically intended for occupancy by a single resident who shares a kitchen and bathrooms with other residents in a multi-tenant building. Government Code 65583(c)(1) requires local jurisdictions to specify the areas where SROs are permitted. Currently SROs are not identified as a separate allowed use in the City’s Municipal Code.

However, given the nature of the use, they would be considered similar to multiple-family dwellings and would be allowed as a special use in several zoning districts that allow multi -family developments including R3, R4 and R5. The Housing Element includes a new program in Policy H 1.7 to amend the Zoning Code to reduce or eliminate constraints to housing construction including the identification of the R3, R4 and R5 districts where SROs will be permitted consistent with state law.

3.5 Sites Inventory

Based on the methodology and approach outlined above , the Sites Inventory includes a range of sites located citywide that could be developed with up to 9,934 new housing units. Table 8 provides a high- level summary of the sites listed on the Sites Inventory broken down by income. Figure 1 shows a map of where each site is located within the city and the housing opportunity areas.

Table 8: Sites Inventory Affordability Breakdown
Housing Opportunity
Areas
Total Units Very Low Low Moderate Above
Moderate
Pipeline
Bridgepointe 1,105 220 168 162 555 -
Hillsdale Station South 2,593 627 379 407 1,180 18
101/92 Interchange 2,452 455 221 248 1,528 961
Other Sites 3,784 570 473 500 2,021 1,936
ADUs 440 22 132 220 66

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Totals 9,934 1,894 1,373 1,317 5,350 2,915
RHNA 7,015  1,777 1,023 1,175 3,040
Buffer 2,919
(42%)
177
(7%)
350
(34%)
142
(12%)
2,310
(76%)

Table Source: Housing Resources Sites Inventory

The Sites Inventory was developed to meet all applicable statutory requirements and provide a realistic and achievable roadmap for the city to meet and potentially exceed its RHNA. The Sites Inventory is summarized as follows:

• The housing sites are spread throughout the city, with a significant number located in high resource areas, to meet AFFH requirements.
• The housing projections utilize existing land use and zoning densities, and no rezoning is necessary.
• The housing sites capacity estimates utilize conservative production and density assumptions. • A significant number of housing units are a lready in the pipeline and are anticipated to be completed during this housing cycle.
o 640+ housing units are currently under construction;
o 1,580+ housing units are approved or entitled; and
o 680+ housing units are under review as active projects. • The housing projections do not have any reliance on new units developed under SB 9 and a low reliance on new ADU production.
• In accordance with AB 725, the inventory identifies more than 25 percent of the moderate and above moderate RHNA units on sites that allow at least four units of housing ; and a ll sites are zoned at least R-3 (multi-family) or equivalent, which allow five or more units by right. • For sites with existing residential units that are anticipated to be demolished for new housing development, the City will require replacement housing units subject to the requirements of Government Code Section 65915(c)(3) , for units that are restricted or have been occupied by a lower income household in the past five years. The City will also conduct a study to create a permanent replacement housing program (Policy H 2.6).

In addition, as discussed above, the City’s General Plan Update process is currently underway , with a target for adoption at the end of 2023. Over 90% of the sites listed in the Sites Inventory are located within one of the ten General Plan Land Use Study Areas that are targeted for increased density. Adoption of the updated General Plan and the updated land use map will increase the base density on most of the housing sites, further increase housing capacity throughout the City and significantly increase the City’s RHNA buffer for this and future housing cycles.

The analytical process that went into creating the Sites Inventory and the justification for commercial site redevelopment are fully detailed in the Sites Inventory Approach and Methodology sections above as well as in the Sites Inventory section of Appendix C, Housing Resources . The full list of sites adequate for housing development identified by the city is included in Appendix C.4. OTHER REQUIRED HOUSING

ELEMENT COMPONENTS

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4.1 Constraints Analysis Summary

The purpose of the constraints analysis section, per Government Code Section 65583(a)(5-6), is to identify and analyze potential and actual governmental and non-governmental constraints to the maintenance, improvement, or development of housing that hinder a jurisdiction from meeting its share of the regional housing needs. A summary of governmental and non-governmental constraints is provided below, and a more detailed analysis is contained in Appendix B.

4.1 .1 Governmental Constraints
State law (California Government Code, Section 65583(a)(5)) requires Housing Elements to contain an analysis of governmental policies and regulations that can result in both positive and negative effects on the availability and affordability of housing. Potential co nstraints to housing include zoning regulations, development standards, infrastructure requirements, permit and development impact fees, and the development approval processes. While government policies and regulations are intended to serve public objectives and further the public good, the City recognizes that its actions can potentially constrain the availability and affordability of housing to meet the community’s future needs. The City has implemented several measures to reduce development costs and str eamline the approval process and has identified additional opportunities for streamlining the City’s review process. The City has identified outdated zoning code regulations and development standards in several areas that may pose as a barrier to housing development and have included Housing Element implementation programs to review zoning code requirements and amend as necessary to remove these barriers (Policies H1.6 and H1.7). This includes evaluating development standards for parking, lot coverage, floor area ratio and existing limits on building heights. The City is also in the process of preparing and adopting Objective Design Standards (ODS) for multi-family projects (Policy H1.8). To address permitting and development impact fees, an implementation program has been included to evaluate the City’s cumulative permit fee costs for new housing developments, with the goal of reducing overall costs and a particular focus on reducing per unit costs for small multi-family or “Missing Middle” projects (Policy H1.18). Further information and analysis are provided in Appendix B.

4.1. 2 Non -Governmental Constraints
State law (California Government Code, Section 65583 (a)(6)) requires Housing Elements to contain an analysis of non-governmental constraints to the maintenance, improvement, or development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, and the length of time between receiving entitlement approval for a housing development and submittal of an application for building permits for that development. Potential non -governmental constraints are largely determined by market conditions or other factors, over which local jurisdictions have little control.

However, local governments can influence market conditions and their associated costs indirectly.

Aside from the high costs of land and construction in the Bay Area, the most significant Non-Governmental Constraint that affects housing production in San Mateo is the voter-approved ballot initiative Measure Y, which restricts density, heights, and intensity of new development. Under Measure Y, building height is limited to 55 feet (up to 75 feet in specific areas) and residential density is limited to 50 dwelling units per acre. Measure Y was approved in November 2020 and sunsets in 2030. The City’s original growth control ballot initiative (Measure H) was approved by the voters in 1990 , followed by the adoption of Measure P in 2004, and then Measure Y in 2020.

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Additional discussion about how the City plans to address the constraints created by Measure Y is provided in Section 3.4.6 (General Plan Update) and accounted for in Policy H1.21 . Further information and analysis about Measure Y and other non-governmental constraints are provided in Appendix B.

4. 2 Housing Resources Summary

The Housing Resources of the City of San Mateo can be summarized into three sections . The first is the various funding sources the City is able to pool together for affordable housing production, preservation, and protection. The second is a list of the existing programs the City manages and supports to increase the housing supply or otherwise serve past, current, and prospective residents of affordable housing. The third is an inventory of sites that are adequate for projected housing needs . A full description of each funding source and housing program are included in Appendix C - Housing Resources, including detailed inventory.

4.2.1 Funding Opportunities
Activities that housing funding may be used for includes but is not limited to the following:
predevelopment, acquisition, construction, rehabilitation, conversion and preservation. Also included is funding that is used for housing related activities, which provide service to the residents of low-income housing. A list of the most relevant funding sources is as follows:

Federal Programs
• Community Development Block Grant (CDBG)
• HOME Investment Partnerships Program (HOME)
• Low Income Housing Tax Credits (LIHTC)
• Section 8 Rental Assistance Program
• Other Federal Sources (Section 811 Project Rental Assistance, Veterans Affairs Supportive Housing (VASH) Vouchers)

State Programs
• Permanent Local Housing Allocation (PLHA)
• Other State Sources (CALHome, CalHFA, Infill Infrastructure Grant (IIG), Local Housing Trust Fund (LHTF), Affordable Housing and Sustainable Communities (AHSC) Program, Golden State Acquisition Fund (GSAF), Project Homekey, Housing for a Healthy California (HHC), Multifamily Housing Program (MHP), Predevelopment Loan Program (PDLP))

Other Public Funds
• Housing Successor Agency for the Redevelopment Agency • Below Market Rate Program (BMR)
• City Housing Fund
• San Mateo County Affordable Housing Fund

Private For-Profit and Nonprofit Sources
• Community Reinvestment Act (CRA)
• Private Developers
• Non-Profit Agencies
• Housing Endowment and Regional Trust (HEART)

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4.2.2 Existing Housing Programs
The city manages and supports several programs that aim to either increase the housing supply, improve existing housing, or serve residents of San Mateo within the scope of housing or hom elessness. While many of these programs are a direct effort of the City, some are part of a regional collaboration across San Mateo County, of which the City is an active participant. A list of these programs are as follows:

• Minor Home Repair
• Home Rehabilitation
• Lead-Based Paint Hazard Reduction
• First Time Home Buyers Program
• Acquisition of Land
• Acquisition and Rehabilitation of Existing Housing
• Community Housing Development Organizations (CHDO)
• New Construction
• Accessory Dwelling Units
• Special Needs Housing Operation Subsidies
• Homeless Programs
• Regional Collaborations
• Chronic Homelessness
• Homeless Prevention
• Discharge Policy

4. 3 Climate Change and Energy Conservation

Home energy efficiency has become an increasingly significant factor in housing construction, particularly in the past few years with the increasing demand to build energy efficient and sustainable buildings in California. Energy costs related to housing include not only the energy required for home heating, cooling and the operation of appliances, but the energy required for transportation to and from home.

State Title 24 Part 6 is the California Energy Code, first enacted in the 1980s, permits builders of new residential units to achieve compliance either by calculating energy performance in a prescribed manner or by performance based on computer modeling. The energy code is updated every three years by the Energy Commission to advance the energy efficiency standards for buildi ng construction. In addition to the energy code, the state Green Building code establishes sustainable building construction standards.

The Green Building code addresses the use of sustainable materials, methods of construction, recycling of construction waste, and electric vehicle infrastructure. These measures contribute to overall building energy efficiency and sustainability and have an added ongoing benefit throughout the useful life of a building.

In order to save natural resources and to make utilities more affordable, the City's Home Repair programs, implemented under Policy H2.3, provide both funding and information referral for participants to include weatherization improvements and utilize energy and water efficient appliances and fixtures. Program participants are encouraged to use the energy conservation programs provided by Pacific Gas and Electric (PG&E).

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All new development, including housing projects, are also subject to compliance with applicable greenhouse gas (GHG) emission reduction strategies contained in the City’s Climate Action Plan (CAP). The CAP, which was last updated in 2020, demonstrates the City’s leadership to reduce GHG emissions and provides a comprehensive list of community -wide actions that will help reduce the community’s GHG emissions. Specifically, for housing and new construction, the CAP includes Measures EE 1, EE 2, EE 3, ME 1 and ME 2 for exceeding minimum state energy efficiency requirements, providing education and outreach on benefits and financial incentives associated with energy upgrades, and continuing support for energy efficiency upgrades through utility programs and programs with local and regional agencies.

The CAP also identifies building electrification strategies (Measures BE 1, BE 2 and ME 3) to encourage the transition from gas to electric equipment, in line with the City’s goal to phase out natural gas in existing buildings by 2030. Strategies include outreach and education to residents, businesses and contractors on the benefits of building electrification and rebates for electric technologies (e.g., induction cooktops, heat pump water heaters, electric clothes dr yers) and adopting policies to encourage or require eliminating the use of natural gas in new or existing buildings.

Policies and programs that explicitly address the City’s CAP, as well as energy efficiency and sustainability, will be contained in other elements of the City’s updated General Plan, but are not contained the Housing Element. However, as outlined above, addressing climate change, continuing to improve energy efficiency and building homes sustainably are key City priorities and will be applied to housing projects and housing program implementation for the upcoming housing cycle.

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5. PUBLIC PARTICIPATION

5.1 Overview

The City of San Mateo recognizes an engaged community is essential to drafting and implementing a strong Housing Element. A key strength of this draft Housing Element is the incorporation of key findings collected at over nineteen public and community meetings and workshops, five intercept/pop-up events, and four surveys. A summary of public participation and community outreach activities and key takeaways are included here. The collected public input received is included as an appendix to this draft Elemen t (Appendix F). To reach as many community members who live in or are a part of the San Mateo as possible, the city developed and implemented a proactive outreach plan at the outset of the draft Housing Element development process. Its goals were to:
• Raise awareness among San Mateo residents of the importance of the Housing Element update on shaping the future of the community
• Have robust and diverse community participation throughout the process that is representative of the full range of demographics, perspectives, and experiences in the San Mateo community • Build a level of public trust in the update process and support for the Housing Element that will lead to its successful implementation after adoption.

The city proactively engaged community members for whom English was not spoken at home, renters, those under 45 years of age, low -income and very low -income households, people with disabilities, seniors, single female heads of household, people experiencing homelessness, and those from under- represented neighborhoods.

In recent years, the community has participated in many conversations about affordable housing, tenant rights, displacement, and fair housing. In addition to conversations focused on the Housing Element, the City’s efforts to establish district elections , the ongoing General Plan Update effort, and the 2019 Community Conversations: Housing in San Mateo event series have provided opportunities for many additional collaborative outreach activities. For other outreach work, we partnered with other San Mateo County jurisdictions for a first -of-its-kind countywide outreach effort, through an award -winning collaboration called 21 Elements. Specific activities included:

Website, Social Media, and Printed Mailing. The City of San Mateo launched a Housing Element Update website, and conducted extensive email and social media outreach beginning in March 2021. Physical mailers were sent city-wide in October 2021 (to 27,000 households), and a second targeted mailer was sent out in January 2022. Physical mailers included printed information in English and Spanish. City staff and consultants also participated in and helped shape the Let’s Talk Housing initiative. Through this award-winning collaborative, the jurisdictions of San Mateo County worked together to increase awareness of and participation in the Housing Element Update process and make sure everyone is involved in shaping our shared future.

Community Meetings. The city organized three public Housing Element workshops and presented at five public commission/council meetings. These included:
• Community and Housing Needs Workshop /Community Relations Commission 9/29/21 • Housing Element Update/Planning Commission 10/12/21
• Housing Policy Workshop 11/2/21

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• Housing Element Update/Senior Commission 11/8/21
• Housing Element Update/City Council 11/15/21
• Fair Housing Workshop 1/13/22
• Joint PC/CC Study Session - Housing Programs /Policies Study Session 2/7/22

Focus groups and presentations at the meetings of local community-based organizations included:
• Housing Element and General Plan Update/ Bay Area Community Health Advisory Council (BACHAC) 9/9/21
• Builders Focus Group 11/15/21
• Housing Element Update/Chamber of Commerce 12/14/21
• Housing Element Update/Downtown Merchants Association 12/14/21 • Housing Element Update/ SMFCSD PTA Association 1/10/22

The city also participated in several meetings and webinars in partnership with 21 Elements, including:
• Let’s Talk Housing - Introduction to the Housing Element o 3/25/21 (Joint with Millbrae, Burlingame, Hillsborough, East Palo Alto) o 7/26/21 (Virtual countywide meeting about the Housing Element update in Spanish) • All About RHNA - 4/23/21 (countywide)
• Listening Sessions (countywide)
o Fair Housing 9/27/21
o Housing Advocates 10/18/21
o Builders 11/01/21
o Service Providers 11/15/21

Outreach Activities. City staff and consultants conducted an online survey, in-person intercept surveys at pop-up events and other community events, and a statistically reliable community survey that included some Housing Element-related questions.

These efforts included:
• Harvest Festival at King Park in North Central 10/16/21 • Central Park Storytime in the Park 10/27/21
• Mi Rancho Market in North Central 10/29/21
• Chavez Market in Shoreview 11/18/21
• Macedonia Food Distribution, Various Tuesdays October to December • Online Survey 10/11/21 to 1/16/22
• Intercept Surveys 10/16/21 to 12/21/21
• True North Community Survey 1/21/22 to 2/2/22

The City also supported an Equity Advisory Group with 21 Elements to ensure outreach was set up to meet people where they were at as much as possible . Specifically, all intercept surveys were conducted in printed and conducted in both English-language and Spanish-language, with English and Spanish speakers available to engage and facilitate completion of the surveys and record first person accounts of housing needs and challenges. Examples of the Spanish and English intercept surveys are included in Appendix F.

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5.2 Accomplishments and Key Takeaways

5.2.1 Website, Social Media, and Printed Mailing
As a starting point for accomplishing extensive research, San Mateo launched a Housing Element Update website that included links to past event video recordings, meeting materials, outreach and survey summaries, and information about upcoming meetings and ways to get involved. It also contained draft Housing Element documents and collected community feedback. Email Blasts and social media efforts from March 2021 through January 2022 included invitations to participate in community workshops, public meetings, and online survey to several city -maintained email lists. The City was als o successful in similar messages being circulated in the newsletters of at least five community groups including: San Mateo High School District Employees Newsletter, San Mateo -Foster City School District Parent Teacher Association (SMFCSD PTA) Newsletter, Chamber of Commerce Newsletter, Downtown San Mateo Association Newsletter, and to the affordable housing residents of Human Investment Project (HIP) Housing and MidPen Housing properties within San Mateo.

A Citywide mailer was sent to every household (27,000) on October 18, 2021 and a second mailer targeted to renters was sent on January 2, 2022 also inviting community members to participate in community workshops, public meetings, and online surveys. Mailers included printed information in English and Spanish. An example of the mailer is included in Appendix F (Additional Community Outreach Collateral and Activities). Community intermediaries also distributed stacks of printed fliers with similar content to businesses with significant Spanish-speaking clientele in the North Central and Shoreview neighborhoods. an example is also included in Appendix F.

From September t o November 2021, four joint Housing Element and General Plan Update -focused Facebook live events were conducted in Spanish by Peninsula Conflict Resolution Center (PCRC), a trusted community partner in Spanish-speaking communities to introduce the Housing Element and General Plan Update and keep community members informed about events and updates. Participants expressed an interest in a variety of housing and community safety topics and supported the City’s emphasis on getting input from the Latinx community.

The City also participated in, and helped shape, the Let’s Talk Housing initiative with 21 Elements, which included a countywide website available in five languages, detailing our timeline, engagement activities, and resources, videos about the process in several languages, and a social media presence. As of February 2022, the website had been visited more than 17,000 times, with more than 20% from mobile devices.

5.2.2 Community Meetings
The city held three public Housing Element workshops, presented at five public commission/council meetings, hosted a focus group discussion with housing architects and developers, and provided presentations to local community-based organizations including the Chamber of Commerce, Downtown Merchants Association, San Mateo-Foster City School District Parent Teacher Association (SMFCSD PTA) and neighborhood associations. The workshops were advertised and offered in Spanish and English- language formats.

In partnership with 21 Elements/Let’s Talk Housing: An Introduction to the Housing Element event, provided a housing element overview with breakout discussion rooms that was part of a series of introductory meetings attended by more than 32 people in San Mateo and over 1,000 community

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members countywide. Additionally, Let’s Talk Housing held an All About RHNA webinar and a countywide four‐part webinar series to help educate and inform San Mateo County residents and stakeholders on regional and local housing issues. The four‐part series took place on Zoom in fall of 2021, focusing on the following topics and how they intersect with the Bay Area’s housing challenges and opportunities: Why Affordability Matters, Housing and Racial Equity, Housing in a Climate of Change, Putting it All Together for a Better Future. The series included speaker presen tations, audience Q&A, breakout sessions for connection and debrief discussions.

The sessions were advertised and offered in Spanish, Mandarin and Cantonese, though participation in non‐English channels was limited. The All About RHNA webinar provided an in-depth dive into sites methodology. On July 26th, San Mateo joined a virtual countywide meeting about the Housing Element update in Spanish, hosted by El Comité, a trusted community organization. English interpretation was provided so non -Spanish speaking staff could participate in the conversation , and a total of 57 people participated.

5.2.3 Key Takeaways
• Housing is personal: People often have differing views on housing because it is a very personal issue tied to feelings of safety, belonging and identity. Often the comments reflected people’s current housing situation. Many people shared meaningful stories of being priced ou t of their communities or of their children not being able to live in the community where they grew up. • The price of housing is a major concern: Many voiced concerns about the high cost to rent or buy a home today, either for themselves, friends, or famil y. It is an issue that touches a lot of lives.

There was significant concern raised that service workers, teachers, first responders, and small business owners were being priced out of San Mateo.
• More housing is needed: Generally, people believe we need more housing, particularly affordable housing. However, there are diverging views on how to accomplish this, where housing should go, and what it should look like. There was strong interest in locating higher density developments close to transit, in walkable, mixed-use areas.
• Single-family neighborhoods are polarizing: 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. • Affordable housing is a top concern: Many felt that more needs to be done to promote affordable housing. They also felt that developers should be eligible for incentives and opportunities that make them more competitive, and that affordable housing should be spread throughout the entire city.
• Specific concern for individuals with all types of disabilities: There was interest in prioritizing the creation of new units and prioritizing accessible units for people with disabilities. • Other common themes : equity, regional considerations, the difficulty of the development process, the interconnected nature of land-use and transportation decisions, and diversity.

Also, in partnership with 21 Elements/Let’s Talk Housing, a series of four stakeholder listening sessions allowed jurisdictions to listen to and interact with sta keholder groups arranged by topic: Fair Housing, Housing Advocates, Builders, Service Providers. More than 30 groups participated. Key takeaways include:

• Fair Housing: Concern for the end of the eviction moratorium, the importance of transit-oriented affordable housing and anti -displacement policies, and the need for education around

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accessibility regulations and tenant protections. Eight ( 8) stakeholder groups provided this feedback.
• Housing Advocates: Concern for rent increases and the need for ongoing outreach to underserved and diverse communities, workforce housing, deeply affordable and dense infill, and tenant protections for the most vulnerable. 6 stakeholder groups provided this feedback. • Builders and Developers: Local funding, tax credit availability, and concern that appropriate sites limit their ability to develop affordable housing while limited sites, construction costs, and city development review requirements and processes limit the development of market-rate housing. 12 stakeholder groups provided this feedback.
• Service Providers: More affordable housing and vouchers or subsidies for market-rate housing are needed, along with on-site services and housing near transit, and jurisdictions should work with providers and people experiencing issues before creating programs. Ten (10) stakeholder groups provided this feedback.

The following key themes were collected as part of a builder’s focus group discussion with housing developers, builders, and architects on policies and programs for San Mateo’s Housing Element on November 15, 2021. The Constraints Analysis Section also includes key themes from the builders focus group and related feedback. Seven external participants, including non -profit housing developers, for - profit housing developers, and architects familiar with multi-family construction provided feedback. Key themes include:

• Relaxing height restrictions, particularly as they can conflict with minimum height requirements for ground floor uses.
• Streamlining the development review and entitlement process and establishing clearer objective development standards.
• Expanding incentive programs for affordable housing, including local density bonus incentives. • Relaxing parking requirements, particularly in walkable areas close to transit. • A walkable downtown is an amenity and could be a rationale for exceptions to other required amenities, including required open space.

5.2.4 Outreach Activities
San Mateo conducted a Housing Element online survey from October 11, 2021 to January 16, 2022. Th e online survey received 594 responses. In the fall, to ensure survey results were as representative as possible, City staff and their consultant team also organized pop -up events and conducted an intercept survey and received 156 responses in the North Ce ntral and Shoreview Neighborhoods, as well as Macedonia food distribution events. True North Research, Inc. was retained to conduct statistically reliable community survey in January and February of 2022 across a variety of topics, including some housing-related questions.

Community-wide survey. In order to provide decision makers with a statistically reliable understanding of its residents’ satisfaction, priorities, opinions, and concerns as they relate to city services, facilities, and policies, True North Research, Inc. was retained to conduct a community -wide survey. The survey was specifically designed to avoid the self -selection bias common in informal feedback mechanisms, public comment fora, and other mechanisms for public engagem ent. A statistically reliable community survey was conducted in January and February of 2022 across a variety of topics, including some housing-related questions and was completed by 775 community members. Key Housing Element-related themes include:

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• When residents were asked to indicate the one thing city government could change to make San Mateo a better place to live, now and in the future, providing more affordable housing was the most common (19%)
• Respondents were less satisfied with the City’s effor ts to facilitate the creation of affordable housing (33%), and address homelessness (42%)
• Approximately two-thirds of residents indicated that there is currently too little housing that is affordable
• Factors that were viewed as most important in planning f or future housing were ensuring adequate water supplies, minimizing greenhouse gases, creating homes that are affordable for low- and middle-income residents, preserving open space and parklands, and creating pedestrian friendly areas that encourage people to walk rather than drive. • 63% were willing to support higher density buildings up to 12 stories near downtown/transit

Housing Element Online Survey. Results of the “Housing Needs in San Mateo – Housing Element 2023- 31” online survey conducted by the City between October 11, 2021 and January 16, 2022 are presented below. A total of 594 surveys were completed online by community members. The information in this report should be considered with a similar weight as other qualitative forms of feedback and should not be treated as statistically reliable. When compared to City averages overall, survey respondents tended to be older, more white, more likely to own their own home, more likely to live in a single -family home, and less likely to be low income. Some areas resulted in conflicting input from the community with many commenters emphasizing their belief that increasing housing supply was a top priority for the city, while many others emphasizing the view that “new housing is not needed or desired”. Key themes are summarized below:

• Most important housing related challenges : “Service workers’ salaries cannot support existing rents in San Mateo” and “Service workers, teachers, first responders, and small business owners are moving out of San Mateo.”
• Best location to place additional housing : “New housing should be walkable/bikeable to shops and services,” and “New housing should be concentrated near public transit.” Key themes from open ended responses: “new housing should be located in high opportunity areas ,” and “new housing is not needed or not desired.”
• Best strategies to manage production of new housing : “Encourage mixed-use projects that have both commercial and residential uses,” “Create housing by redeveloping existing properties that have additional potential,” and “Increase allowable density in areas that are close to transit.” Key themes from open ended responses: “increase density throughout the city,” “new housing is not needed or not desired’” and “prioritize single family housing.” • What types of housing should be prioritized: “Smaller units that are less expensive to live in.” Key themes from open ended responses: “support for building housing in general ,” “prioritize affordable housing, require affordable housing, or establish mandatory inclusionary zoning,” and “prioritize senior housing.”
• Best ways to address housing affordability : “Incentives for private developers to build more affordable housing,” “Locate affordable housing near transit and jobs,” and “Financial assistance for people who cannot afford housing, such as subsidized rent and down payment loans.” Key themes from open ended responses: “strengthen rent regulations or establish rent control” and “streamline regulations: reduce height, density, parking, or other regulations.”

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• Most important ways to ensure housing opportunities are available to all members of San Mateo, especially those who have not had fair access to housing in the past : “Ensure affordable housing opportunities are created throughout the entire city” and “Improve infrastructure, transit and services in underserved neighborhoods.” Key theme from open ended responses: “more housing equals more opportunity, focus on expanding supply.”
• Common themes: Additional comments (296 open-ended responses) were analyzed for common themes, these included:
o Housing is a priority issue: use whatever means are available to substantially increase supply
o Improve public transportation and make walking and biking safer, this is also better for the environment
o Infrastructure improvements should happen before housing is built, with particular emphasis on traffic congestion, roads, parking, and water o Locate new housing in Transit Oriented Developments (TOD)/increase density most in transit-rich areas
o New housing is not needed or not desired

Intercept surveys. In the Fall, to ensure survey results were as representative as possible, City staff and their consultant team also organized pop-up events and conducted an intercept survey and received 156 responses in the North Central and Shoreview Neighborhoods, as we ll as Macedonia food distribution events. The locations, dates, and times of these events were selected with the advice of Peninsula Conflict Resolution Center (PCRC), who also helped to staff these events. Events at Mi Rancho Market in North Central (10/29/21), Chavez Market in Shoreview (11/18/21), and Macedonia food distribution events were staffed by English-Spanish bilingual community outreach staff. The information in this report should be considered with a similar weight as other qualitative forms of feedback and should not be treated as statistically reliable. When compared to City averages overall, intercept survey respondents were more likely to be Hispanic or Latinx, 35-50 years old, and reside in the 94401 zip code, which includes the North Central and North Shoreview neighborhoods. Key themes are summarized below:

• To manage the production of housing overall, there was notable interest in redeveloping existing properties that have potential for more housing (45%), creating accessory units on existing single- family properties (22%), and encouraging mixed -use projects that have both commercial and residential uses (21%).
• To address housing affordability, there was substantial interest in financial assistance programs for people who cannot afford ho using, such as subsidized rent and down payment loans (47%), and public funding to construct new housing (26%).
• The current housing situation in San Mateo is affecting them or people they know due to the high cost of housing in general; the cost of housing’s impact on types of individuals (childcare workers, adult children, older adults); inability to purchase a home due to cost; self or others moving away due to price, traffic, and difficulty commuting.
• Some direct quotes : “Include up -scale neighborhoods in zoning changes,” “Always include preferences for people w/ developmental disabilities + others,” “I have to move b/c its getting too expensive, I will move away from County to an in -law unit with relatives in Marin,” and “I'm homeless, I sleep on street behind the gas station. I can't afford rent, I can hardly get food.”

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Equity Advisory Group . In partnership with 21 Elements / Let’s Talk Housing, and in alignment with community outreach best practices, it was important to include the guid ance of and foster partnerships with community organizations to help ensure everyone’s voices were heard during the Housing Element update. In response, an Equity Advisory Group (EAG) was formed consisting of 15 organizations or leaders across the county t hat are advancing equity and affordable housing. To date, EAG members have facilitated and hosted community meetings in partnership with 21 Elements, collected community housing stories to put a face to housing needs, advised on messaging, and amplified events and activities to their communities. All participating organizations are featured on the Let’s Talk Housing website.

San Mateo County Fair Housing Survey . In partnership with 21 Elements / Let’s Talk Housing, and conducted by Root Policy, the San Mateo County Fair Housing Survey has gathered 108 responses from residents in the City of San Mateo as of January 20, 2022. Key challenges include:
• Income is too low to find housing
• Housing unit is too small
• Displacement
• Denied housing when looking due to “income too low”
• Difficulty for voucher holders to find an affordable unit • Homes not meeting needs of a household member with a disability • When asked what type of help they need ed to improve their h ousing security, top answers included: Help me with a down payment/purchase (39%); Help me get a loan to buy a house (27%); and Help me with the housing search (23%). Other resources to improve quality of life were also identified in the survey results.

5.3 Draft Housing Element Public Review Period

During the formal 30-day public review period of the Draft Housing Element, which ran from April 6, 2022 to May 6, 2022, a total of 20 comment letters were received, and are included in Appendix G . The comments received by the City offered a wide variety of opinions and input on the Draft Housing Element.

Those that expressed opposition to the planned growth noted concerns about whether the City’s resources, specifically water supply, would be able to support the population increase and that single- family neighborhoods would be negatively impacted or even eliminated. Other comments pushed for the Housing Element to go further beyond the goals currently outlined in the plan, noting concern that the City is too optimistic in redevelopment potential of the site s contained in the Sites Inventory. They encouraged the City to include re -zoning of the single -family neighborhoods as a program while going further to remove existing constraints to development (namely Measure Y) to increase housing production potential. Both those for and against the draft plan agreed that if housing density were to increase, commensurate upgrades to transit options must be made to mitigate traffic impacts and not reduce quality of life for residents. Finally, some commenters emphasized the importance of working towards housing affordability as vital for protecting individuals with disabilities, for sheltering low-income families in danger of experiencing homelessness, and to affirmatively further fair housing through racial equity.

On April 26 and May 3, 2022, the Planning Commission also received public comments and provided input on the Draft Housing Element. On May 23, 2022, the City Council held a special meeting to consider the Draft Housing Element, receive public comments and provide staff with direction . Overall, the Council expressed support for the Draft, with several modifications and updates, and directed staff to submit the

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draft to HCD for first review. The minutes from these meetings are included in Appendix G. Additionally, during this period, city staff conducted intercept outreach activities to inform the public of the draft plan and invite their attendance and participation in the public meetings. A key activity included engaging and distributing information to approximately 150 households in English and Spanish during the very popular annual city-wide community event known as “Eggstravaganza” on April 16, 2022 . Intercept materials, designed to engage families with young children were developed and distributed in English and Spanish- language formats. Examples are included in Appendix F.

5.4 How We Incorporated What We Heard into the Plan

The extensive outreach and community engagement conducted over the past year played a significant role in the development of the goals, policies, and programs within the 2023 -2031 Housing Element.

Feedback and insights from tenants, non-English speakers, lower-income residents, property owners and developers helped to highlight new policy opportunities and ways to strengthen and improve existing policies. And the overarching challenge of housing affordability and availability was heard during most every meeting and conversation. In addition, themes such as investing in disadvantaged communities, improving walkability in neighborhoods and access to transit, and addressing climate change helped inform policies in the Housing Element as well as the General Pla n Update which is being prepared concurrently. The following is a summary list of topics and the associated policy(s) that were added or improved as a result of that community and stakeholder feedback.

• Support the production of more missing middle housing. (Policies H1.4, H1.11 and H1.13) • Improve awareness and availability of resources for landlords and tenants. (Policies H4.1, H4.2, H4.3 and H4.4)
• Streamline the permitting process and simplify the rules and regulations for new housing development. (Policies H1.6, H1.7 and H1.8)
• Fair housing – setup a rental registry, adopt first right of refusal for existing tenants’ rules. (Policies H3.4 and H3.6)
• New housing should be sustainable and support the City’s climate action plan. (Policies H2.3 and H2.5)
• Provide more materials and information in languages other than English. (Policies H4.1 and H4.4) • Improve walkability and access to transit in disadvantaged communities. (Policy H2.4) • Provide training/education about fair housing laws to landlord. (Policy H3.2) • Support the construction of more accessory dwelling units (ADUs). (Policy H1.4) • Establish a BMR unit set-aside for tenants with physical or developmental needs. (Policy H3.5) Support the development of larger units with more bedrooms for families. (Policy H1.5)

In response to the public comments made during and after the Public Review Period, and City Council discussion and direction, multiple additional revisions, clarifying edits, and corrections were made to the Draft prior to submittal to HCD. Those revisions and updates include:

All policies and programs were reviewed and, where appropriate, updated, to be more specific and action oriented.
• Sites inventory methodology was updated to remove outliers and distinguish average densities by project types; and additional information was provided for justification of the ADU projections. • Constraints summary was modified based on updates to Appendix B.

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• Policies and programs were updated to reflect public comments and decision-maker direction to increased housing support for people with disabilities including those with developmental disability; greater support for missing middle housing options; and incr eased attention to identifying new funding sources for housing programs.
• The Sites Inventory was reviewed and updated to add information related to site selection, anticipated GPU land use designation, and explanations for density projections were bolstered. • The Constraints analysis was updated to include corrections and further information related to the City’s fees.
• Staff followed-up with water providers (Cal Water and Estero Municipal Improvement District) to provide additional information on existing water infrastructure and future supply to support the projected growth in the Housing Element.
• Policies and programs related to transportation and circulation upgrades will be addressed as part of the updated Circulation Element in the GPU.

5.5 Attachments included in Appendices F and G

Appendix F includes community feedback, communications and documentation that support the findings and conclusions in this Section.

• True North Survey Results (Excerpts)– February 21, 2022 • Community Engagement, Pop-Ups and Intercepts – Public Feedback Received • Online Housing Element Survey Results
• Builders Focus Group – November 15, 2021 – Feedback Received • Fair Housing Workshop – January 13, 2022 – Discussion and Poll Summary • Housing Policy Workshop – November 2, 2021 – Discussion and Poll Summary • Community Relations Commission – September 29, 2021 – Community Needs and Housing Needs Workshop – Speaker Notes
• San Mateo Countywide Housing Elements Listening Sessions – Summary Notes ▪ Fair Housing – September 27, 2021
▪ Housing Advocates – October 18, 2021
▪ Builders – November 1, 2021
▪ Service Providers – November 15, 2021
• Root Policy Fair Housing Survey Summary – Summary of Public Feedback • Community Correspondence received by the City prior to April 6, 2022, and between May 7, 2022 and December 30, 2022.
• Planning Commission and City Council Minutes – April 26, 2022 to November 7, 2022 • Additional Community Outreach collateral and activities ▪ Citywide mailer sent October 2021
▪ Mailer targeted to renters sent January 2022
▪ Housing Element Flyer
▪ Intercept Surveys (English and Spanish), October-December, 2021 ▪ Where do you live/Donde Vives interactive activity results, October 16, 2021 ▪ “Eggstravaganza” outreach activity, April 16, 2022
Appendix G includes public review period comments received by the City during the 30-day public review

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period.

• 30-Day Public Review Period Comments Received – April 6, 2022 to May 6, 2022 • Second Public Review Period Comments Received – December 30, 2022 to January 9, 2023

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6. AFFIRMATIVELY FURTHERING FAIR HOUSING (AFFH) SUMMARY

6.1 What is Affirmatively Furthering Fair Housing?

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. Specifically, affirmatively furthering fair housing means taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, t ransforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws. The duty to affirmatively further fair housing extends to all of a public agency’s activities and programs relating to housing and community development. (Gov. Code, § 8899.50, subd. (a)(1).)”
Figure 3: AFFH Definition
Source: California Department of Housing and Community Development Guidance, 2021, page 14.

California Assembly Bill 686, which was signed into law in 2018 requires that all public agencies in the state affirmatively further fair housing (AFFH) beginning January 1, 2019. Public agencies receiving funding from the U.S. Department of Housing and Urban Development (HUD) are also required to demonstrate their commitment to AFFH. The federal obligation stems from the fair housing component of the federal Civil Rights Act mandating federal fund recipients to take “meaningful actions” to address segregation and related barriers to fair housing choice.

AB 686 requi res all public agencies to “administer programs and activities relating to housing and community development in a manner that affirmatively furthers fair housing, and take no action inconsistent with this obligation”[1]

AB 686 also makes changes to Housing Element Law to incorporate requirements to AFFH as part of the housing element and general plan to include an analysis of fair housing outreach and capacity, integration and segregation, access to opportunity, disparate housing needs, and current fair housing practices.

6.2 History of segregation in the region

The United States’ oldest cities have a history of mandating segregated living patterns—and Northern California cities are no exception. ABAG, in its recent Fair Housing Equity Assessment, attributes segregation in the Bay Area to historically discriminatory practices —highlighting redlining and discriminatory mortgage approvals—as well as “structural inequities” in society, and “self -segregation” (i.e., preferences to live near similar people).

Researcher Richard Rothstein’s 2017 book The Color of Law: A Forgotten History of How Our Government Segregated America chronicles how the public sector contributed to the segregation that exists today.

Rothstein highlights several significant developments in the Bay Area region that played a large role in where the region’s non-White residents settled.

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Pre-civil rights San Mateo Coun ty faced resistance to racial integration, yet it was reportedly less direct than in some Northern California communities, taking the form of “blockbusting” and “steering” or intervention by public officials. These local discriminatory practices were exace rbated by actions of the Federal Housing Administration which excluded low-income neighborhoods, where the majority of people of color lived, from its mortgage loan program.

According to the San Mateo County Historical Association , San Mateo County’s ear ly African Americans worked in a variety of industries, from logging, to agriculture, to restaurants and entertainment.

Expansion of jobs, particularly related to shipbuilding during and after World War II attracted many new residents into the Peninsula, i ncluding the first sizable migration of African Americans. Enforcement of racial covenants after the war forced the migration of the county’s African Americans into neighborhoods where they were allowed to occupy housing —housing segregated into less desira ble areas, next to highways, and concentrated in public housing and urban renewal developments.

The private sector contributed to segregation through activities that discouraged (blockbusting) or prohibited (restrictive covenants) integrated neighborhood s. In the City of San Mateo, builders of the Hillsdale neighborhood in the mid -1900s recorded deeds that specified that only “members of the Caucasian or White race shall be permitted” to occupy sold homes —the exception being “domestics in the employ[ment] on the premises.” [2] This developer went on to develop many race -restricted neighborhoods in the Bay Area, became president of the National Association of Home Builders (NAHB), became national president of the Urban Land Institute (ULI), and was inducted into California’s Homebuilding Foundation Hall of Fame.

The timeline of major federal Acts and court decisions related to fair housing choice and zoning and land use appears on the following page. As shown in the timeline, exclusive zoning practices were common in the early 1900s. Courts struck down only the most discriminatory practices and allowed those that would be considered today to have a “disparate impact” on classes protected by the Fair Housing Act. For example, the 1926 case Village of Euclid v. Ambler Realty Co. (272 U.S. 365) supported the segregation of residential, business, and industrial uses, justifying separation by characterizing apartment buildings as “mere parasite(s)” with the potential to “utterly destroy” the character and desirability of neighborhoods.

At that time, multifamily apartments were the only housing options for people of color, including immigrants.

The Federal Fair Housing Act was not enacted until nearly 60 years after the first racial zoning ordinances appeared in U.S. cities. This coincided with a shift away from federal control over low -income housing toward locally-tailored approaches (block grants) and market-oriented choice (Section 8 subsidies)—the latter of which is only effective when adequate affordable rental units are available.

6.3 San Mateo’s Fair Housing Assessment

The Fair Housing Assessment (Appendix D) follows the April 2021 State of California State Guidance for AFFH. The study was conducted as part of the 21 Elements process, which facilitates the completion of Housing Elements for all San Mateo County jurisdictions. It includes the following sections:

6.3.1 Primary Findings
Primary findings from the Fair Housing Assessment for the City of San Mateo describes fair housing enforcement and outreach capacity, integration and segregation, access to opportunity, disparate

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housing needs, and contributing factors and the city’s fair housing action plan.

• 16% of fair housing complaints filed in San Mateo County from 2017 to 2021 (57 total) were in the City of San Mateo (9 total), which is approximately aligned with the city share of the county’s population (14%). The most common issues cited in the city were refusal to rent and discrimination in terms, conditions, privileges relating to rental. Most complaints were on the basis of disability status (6 complaints) and race (3 complaints) in the city.

Racial and ethnic minority populations are disproportionately impacted by poverty, low household incomes, overcrowding, and homelessness compared to the non -Hispanic White population in the City of San Mateo. Additionally, racial and ethnic minoritie s are more likely to live in moderate resources areas and be denied for a home mortgage loan.

• Racial and ethnic minority populations generally have higher rates of poverty (Figure II -5) and lower household incomes (Figure II-4) compared to the non-Hispanic White population in the City of San Mateo.
• Racial and ethnic minorities are more likely than non-Hispanic White households to experience overcrowding (Figure IV -17). Low- and moderate-income households are also more likely to be overcrowded (Figure IV-18).
• People who identify as American Indian or Alaskan Native, Black, White, and Hispanic are overrepresented in the homeless population compared to their share of the general population (Figure IV-22).
• Hispanic, Asian, and Black residents are more likely to live in moderate resource areas compared to high resource areas (Figure III-12). It is important to note there are no designated low resource areas in the City of San Mateo.
• Hispanic and American Indian or Alaska Native households have the highest denial rates for mortgage loan applications in 2018 and 2019 (Figure IV-33).

Geospatially, the northeast area of the city is disproportionately impacted by high poverty, low education opportunity, low economic opportunity, low environmental scores, high social vulnerability scores, concentrations of cost burdened households, overcrowding, and moderate resource scores. These areas are generally on either side of Highway 101 and stretch to the San Francisco Bay waterfront, encompassing the North Central and Shoreview neighborhoods. These areas have:

• Higher poverty rates between 10% and 20% (Figure II-28). • Education opportunity scores between 0.25 and 0.5—meaning they have lower education scores compared to the rest of the city (Figure III-1).
• Low economic opportunity scores between zero and 0.5 (Figure III-7). • Low environmental scores—which account for PM2.5, diesel PM, drinking water, pesticides, toxic release, traffic, cleanup sites, groundwater threats, hazardous waste, impaired water bodies, and solid waste sites (Figure III -9). The northeast area of the City of San Mateo has particularly poor environmental outcomes for traffic, impaired water, groundwater threats, hazardous waste, and asthma.
• The composite opportunity score for the City of San Mateo shows Census Tracts in the northeast area of the city fall within moderate resource areas while the rest of the city is within high or highest resource areas (Figure III-14).

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• The Social Vulnerability Index (SVI) provided by the Centers for Disease Control and Prevention (CDC) ranks census tracts based on their ability to respond to a disaster and includes four themes of socioeconomic status, household composition, race or ethnicity, and housing and transportation. The northeast area of the city is most vulnerable according to the SVI (Figure III - 15).
• Concentration (60% to 80% of households) of cost burdened households (Figure IV-13). • Overcrowded households are concentrated in the same areas as cost burdened households (Figure IV-19).
• These areas are also within Special Flood Hazard Areas (Figure IV -31) and are vulnerable to displacement (Figure IV-28).

The City of San Mateo has a slight concentration of residents with a disability with 9% of the population compared to 8% in the county (Figure III-17). Residents living with a disability in the city are more likely to be unemployed and are largely concentrated in areas around Highway 101. Finally, the aging population is putting a strain on paratransit access countywide.

• Unemployment is disproportionately high among residents living with a disability at 12% compared to 3% for residents without a disability in the City of San Mateo —particularly when compared to the county (Figure III-20).

Racial and ethnic minority students in the City of San Mateo—served by the San Mateo Union High School District and the San Mateo-Foster Elementary School District—experience lower educational outcomes compared to other students. Many high schoolers in the county met admission standards for a University of California (UC) or California State University (CSU ) school. However, Pacific Islander, Hispanic, and Black students in the San Mateo Union district were less likely to meet the admission standards .

Although San Mateo Union High School has relatively low dropout rates —4% of students—compared to other distr icts in the county, dropout rates among Hispanic (7%), Black (6%), and Pacific Islander students are higher (Figures will be included in the access to education supplement).

• Nearly half of all renter households in the City of San Mateo are cost burdened—spending more than 30% of their gross income on housing costs—and one in four are extremely cost burdened— spending more than 50% of their gross income on housing costs (Figure IV -9). There are disparities in housing cost burden in the City of San Mateo by race and ethnicity and family size (Figure IV-11 and Figure IV-12).

• 15% of respondents to the resident survey conducted for this AFFH said that schools in their neighborhood were of poor quality.

Resident needs collected through local survey. A survey administered to capture residents’ needs and support the AFFH found the following housing challenges. Nearly 150 residents completed the survey:

• About 26% of residents said their house or apartment is too small for their family; o 36% for racial and/or ethnic minority households;
o 42% for single parent households
• 14% of renters said they worry that if they request a repair they will experience rent increase or get evicted;

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o 16% for racial and/or ethnic minority households
o 21% for single parent households
• 27% of respondents indicated they had been discriminated against when looking for housing in San Mateo County;
o 31% for racial and/or ethnic minority respondents;
o 43% for residents with a disability;
• 10% (14% for single parent households) of rent ers are often late on rent and 14% (20% for residents with a disability) can’t afford utilities.

6.3.2 Contributing factors and Fair Housing Action Plan The disparities in housing choice and access to opportunity discussed above stem from historical actions, socioeconomic factors that limit employment and income growth, the inability of the broader region to respond to housing demand, regional barriers to open housing choice, and, until recently, very limited resources to respond to needs.

Fair housing issue: Hispanic households have disproportionate housing needs. These needs are evident in mortgage denial gaps, geographic distribution of affordable housing, cost burden, and overcrowding.

Contributing factors:
• Higher rates of mortgage denial rates among Hispanic households stems from decades of discrimination in housing markets and challenges building wealth through economic mobility and homeownership.
• Although voucher holders and affordable housing (as captured in the HCD Location Affordability Index) are not as highly concentrated in the City of San Mateo as in many surrounding jurisdictions, the northern portion of the city offers the most affordable homes. As such, residents living in these areas have lower incomes and higher rates of poverty. Preference may be at play as well: A recent article in Cityscape found that Hispanic homebuyers —when controlled for demographics, loan characteristics, and finances —are more likely to purchase homes in neighborhoods with fewer non-Hispanic White homeowners and lower economic opportunity.[1] • Hispanic residents are more likely than others to work low wage jobs that do not support the City’s or region’s housing prices, resulting in higher rates of cost burden and overcrowding.

Although, it is customary for Hispanic households to live in multigenerational settings, which may account for higher rates of perceived o vercrowding, overcrowding is also an indicator of lack of access to affordable and right-sized housing.
• 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 according to TCAC’s opportunity maps.

Fair housing issue: Hispanic residents and single female parent households are concentrated in census tracts with higher poverty, low economic and environmental opportunity, high -cost burden, overcrowding, and flood hazards compared to the rest of the City of San Mateo.

Contributing factors:
• Concentration of naturally occurring affordable ownership and rental housing opportunities in the northeast areas of the city further concentrates poverty, cost burden, and overcrowding in

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areas with low economic and environmental outcomes.
• There is a relative lack of affordable housing opportunities in higher resourced areas of the city. • Highway 101 creates a major barrier between the Shoreview neighborhood —where the geographic concentrations of these groups exist—and the rest of the City of San Mateo.

Fair housing issue: Persons with disabilities have higher housing needs due to challenges accessing employment and housing discrimination and are concentrated in areas with lower environmental and economic opportunity scores.

Contributing factors:
• The unemployment rate for the City of San Mateo’s residents with a disability is four times that of persons without a disability. The exact reasons for this disparity are unclear and are likely related to limited job opportunities, access to employment, and market discrimination. • The undersupply of accessible housing units, particularly for renters, creates a scarcity of units for residents living with a disability.
• There were six complaints—out of the nine total complaints in the city—filed with HUD in the City of San Mateo from 2017 to 2020 where the issues cited included a failure to make reasonable accommodations. Landlords and property owners are required to provide reasonable accommodations to residents living with a disability upon request. • There are conc entrations of the population living with a disability west of Highway 101 in the North Central neighborhood. This area of the city has a concentration of low- and moderate- income households (more than 50% per census tract) and scores low on TCAC’s environm ental and economic opportunity scores.

Fair housing issue: Persons with disabilities and persons of color are most likely to file complaints of housing discrimination due to discriminatory terms, conditions, privileges, or services and facilities and failure to make reasonable accommodations.

Contributing factors:
• Housing discrimination residents with disabilities and Hispanic households. • Lack of understanding of reasonable accommodation requirements by landlords and p roperty owners.

The Affirmatively Furthering Fair Housing (AFFH) Action Plan, developed in response to this analysis as well as community input, is included in Appendix D and as Goal 5 in the Housing Element. The AFFH Action Plan details how the city proposes to respond to th e factors contributing to the fair housing challenges identified in this analysis. The updated Appendix D includes extensive new narrative on a variety of topics in response to State HCD comments, including more information on the history of the City’s development; the prioritization of contributing factors; detail on fair housing legal cases and inquiries; data on changes in racial composition in the City; enhanced discussion of special needs groups; and greater analysis of R/ECAPs and RCAAs.

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7. HOUSING PLAN
The City of San Mateo has many positive attributes, especially being a desirable residential community to live in, work, and play in. Thus, one of the City’s primary objectives is to expand housing opportunities and increase the diversity of housing supply. There should be a variety of housing types and sizes, a mixture of rental and ownership housing, and housing that supports special needs populations, including single - female heads of household, people with disabilities, those who are unhoused and farmworkers. This variety of housing opportunities will need to accommodate a diverse population, leading to a variety of household sizes, all age groups and a wide range of income levels in order for the City to continue to thrive into the future.

In addition, San Mateo will need to increase its housing supply to meet the housing demand caused by current and future job growth. The types of new housing created should accommodate all income levels consistent with the Regional Housing Needs Allocation. The goals, polices, and actions contained in this Housing Plan support these overarching objectives while also ensuring that the City will meet its statutory obligations, affirmatively further fair housing and facilitate housing production at all income levels.

7.1 Goals , P olicies, and Programs Summary

The City has identified five goals to guide the Housing Element’s policies and programs. The first three are based upon the “3Ps” framework that seeks to address the region’s housing needs through a combination of Production, Preservation and Protection and is endorsed by the Association of Bay Area Governments (ABAG). The fourth goal, or “fourth P,” is Promotion of community engagement and public outreach to support social resilience , and th e fifth goal is to Affirmatively Further Fair Housing (AFFH ). This goal provides a framework for how the City will comprehensively address fair housing issues and mee t State law requirements. Many of the policies and programs that support AFFH also support the Housing Element’s other goals, which just further highlights how the issue of fair housing is interwoven with achieving the City's larger housing production, preservation, protection and promotion goals.

The first goal, Goal H1, is to facilitate and support the production of new housing at all income levels, but especially affordable housing. Twenty-one policies have been identified to achieve this goal. • Policy H1.1 - Monitor Regional Housing Needs Allocation • Policy H1.2 - Utilize Public Funding for New Affordable Housing • Policy H1.3 - Increase Affordable Housing Production
• Policy H1.4 - Incentivize Accessory Dwelling Unit Development • Policy H1.5 - Encourage Family Housing
• Policy H1.6 - Streamline Housing Application Review
• Policy H1.7 - Update Zoning Code Development Standards • Policy H1.8 - Adopt Objective Design Standards
• Policy H1.9 - Establish Minimum Densities for Mixed-Use Projects • Policy H1.10 - Establish By-Right Housing Designation for Prior Housing Sites • Policy H1.11 - Implement the SB 9 Ordinance
• Policy H1.12 - Encourage Residential Uses within Housing Overlay • Policy H1.13 - Encourage Development of Missing Middle Housing

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• Policy H1.14 - Evaluate and Update Special Needs Group Housing Requirements • Policy H1.15 - Evaluate and Update Supportive Housing Requirements • Policy H1.16 - Update Requirements for Mobile Home Parks Requirements • Policy H1.17 - Update Requirements for Farmworker Housing Requirements • Policy H1.18 - Permitting and Development Fee Review
• Policy H1.19 - Increase Senior Housing Production
• Policy H1.20 - Provide Housing Element to Water and Sewer Providers • Policy H1.21 - Adopt San Mateo General Plan 2040

The second goal, Goal H2, is to preserve existing housing that is affordable to lower- and middle-income residents. Six policies have been identified to support this goal:
• Policy H2.1 - Fund Housing Rehabilitation Efforts
• Policy H2.2 - Support Retention of Existing Lower Income Units • Policy H2.3 - Increase Energy and Water Efficiency in Existing Units • Policy H2.4 - Implement Capital Improvements in lower-resourced Neighborhoods • Policy H2.5 - Promote Housing Resilience
• Policy H2.6 - Require Replacement Units

The third goal, Goal H3, is to protect current residents and prevent displacement . Seven policies have been identified to support this goal:
• Policy H3.1 - Prevent Homelessness
• Policy H3.2 - Investigate Fair Housing Cases
• Policy H3.3 - Evaluate Housing Revenue Sources
• Policy H3.4 - Expand Tenant Protections
• Policy H3.5 - Study the Creation of Below Market Rate Set Asides • Policy H3.6 - Evaluate Rental Registry Options
• Policy H3.7 - Evaluate City Policies and Encourage Collaboration Opportunities for Expanding Homeless Shelters

The fourth goal, Goal H4, is the promotion of social resilience through public education and outreach, which is a priority identified by staff based on community input and feedback. This can be achieved by making information more available and accessible, and conducting targeted outreach to ensure more universal awareness of housing programs and policies. Five policies have been identified to support this goal:
• Policy H4.1 - Update the Housing Webpage
• Policy H4.2 - Support a Countywide Below Market Rate Unit Waitlist • Policy H4.3 - Expand Community Education and Outreach • Policy H4.4 - Enable Affirmative Marketing
• Policy H4.5 - Conduct Outreach to Sites Inventory Property Owners

The fifth goal, Goal H5, is simultaneously the Fair Housing Action Plan, meant to implement the overarching goal of Affirmatively Furthering Fair Housing (AFFH) , with many policies overlapping with those in the previous goals. This approach is intentional and meant to reinforce that the objective of that Fair Housing is both enough a stand-alone priority that warrants its own section but decisively inseparable from achieving the main goals of the Housing Element. To address the many fair housing issues that

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disparately impact Hispanic, single-female, and disabled households, as identified in the AFFH summary, fourteen policies have been identified:
• Policy H5.1.1 - 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. • Policy H5.1.2 - 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.
• Policy H5.1.3 - 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. • Policy H5.2.1 - Add more City supported housing with affordability restrictions in moderate and high resource areas ; and a ffirmatively market the units to households with disproportionate housing needs including persons with disabilities, farmworkers, single -parents, and Hispanic households.
• Policy H5.2.2 - Incentivize developers through direct subsidies, fee waivers, and/or density bonuses, to increase accessibility requirements beyond the federal requirement of 5% for subsidized developments.
• Policy H5.2.3 - Prioritize City funding proposals for city -funded affordable housing that are committed to serving hard to serve residents.
• Policy H5.3.1 - As part of the General Plan Update, conduct an area plan for the North Shoreview and North Cent ral neighborhoods and prioritize land use and design around Highway 101 to improve access and reduce the division of the urban form produced by the highway. • Policy H5.3.2 - Continue to fund minor home repairs and implement a preference for projects in low opportunity census tracts identified in the analysis. • Policy H5.3.3 - Monitor affordable housing projects that are at risk of conversion to market rate; support regional and local efforts to examine displacement of affordable housing and lower income households; and assist with the retention of special needs housing that is at risk of expiring affordability requirements.
• Policy H5.4.1 - Establish tenant protectio ns in local ordinance to extend measures of AB 1482 related to relocation, documentation, and right to return policy in eviction cases. • Policy H5.4.2 - Partner with Project Sentinel to perform fair housing training for landlords and tenants; and f ocus enfo rcement efforts on race -based discrimination and reasonable accommodations.
• Policy H5.4.3 - Create a webpage specific to fair housing including resources for residents who feel they have experienced discrimination, information about filing fair housing com plaints with HCD or HUD, and information about protected classes under the Fair Housing Act. • Policy H5.4.4 - Ensure that all multifamily residential developments contain signage to explain the right to request reasonable accommodations for persons with disabilities. Make this information available and clearly transparent on the city's website and fund landlord training and outreach on reasonable accommodations.

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• Policy H5.4.5 - Ensure that future improvements in disadvantaged communities will not produce a net loss of affordable housing or the displacement of residents and seek to increase the amount of affordable housing in disadvantaged communities.

To implement each of these policies, t he city has identified specific programs and actions, which are outlined in the Implementation Plan (Tables 9, 10, 11, 12 and 13).

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7.2 Implementation Plan

7.2.1 GOAL H1 : Production of new housing at all income levels, with a focus on affordable housing The need for additional affordable housing was the most prominent and pervasive sentiment noted throughout the Housing Element outreach process. Households of various sizes and socioeconomic backgrounds have reported feeling the pressure of the high costs of housing. To meet the targets set by RHNA, the city must facilitate the production of abundant and affordable new housing in a wide diversity of forms. To support this goal, the city will be employing two approaches, with the first being directly involved in housing production. This can be done by utilizing public funds to build more units, partnering with nonprofits and other groups to support the production of all types of housing, including ADUs, and using local ordinances to require that developers create more affordable units that can serve a diverse variety of populations and providing incentives for additional affordable unit development. In addition, the policies outlined below would encourage and streamline housing development through the adoption of objective design standards, updates to the Zoning Code, creating minimum densities for housing projects , developing policies for missing middle housing, and streamlining the application review and processing timelines for affordable development projects. And, to address the housing constraint associated with the growth limits imposed by Measure Y, there is a policy to support adoption of the General Plan Update which is facilitating a community conversation about Measure Y and building consensus about a path forward for updating the growth limits.

Table 9: Goal H1: Production - Implementation Plan
Number Policy Lead Agency/Department/Division Funding
Source(s) Program Measure(s) Implementation Action(s) Target Timeline New/Existing Program Policy H

1.1 Monitor Regional Housing
Needs Allocation
Housing Division N/A Monitor housing production against ABAG Fair Share Allocation in compliance with no
net loss requirements during planning
period.

Provide an annual report on housing production to the City Council each March, prior to submittal of the Annual
Progress Report to HCD by April 1st. The report will include an assessment on the City’s RHNA progress and, as
needed, identify additional sites to ensure ongoing
compliance with “no net loss” provisions of State law.
2023 – 2031 (Annually) Existing
Policy H

1.2 Utilize Public Funding for New
Affordable Housing
City of San Mateo City funds
and state,
and federal
funds, as
available
Produce City supported housing projects with
affordability restrictions utilizing local public
funds; and use this funding to leverage other
regional, state, and federal funding sources
to increase the number of affordable housing
units developed in each project.
a) Continue to set aside 20% of general fund property tax revenues from former RDA areas (aka "Boomerang
Funds”), as well as the Affordable Housing Commercial
Linkage Fee Fund to use for affordable housing
development.
b) Identify ways to create a stand-alone Housing Trust
Fund using available funding sources and utilizing that fund to leverage new funding sources, including the
Bay Area Housing Finance Authority (BAHC) and the
Bay Area Preservation Pilot (BAPP).
c) Prioritize available local housing funds to assist in the production of at least 543 below market rate units by
2031, including within the study areas of the General
Plan that allow high-density housing by holding
developer roundtable meetings at least once per year.

This item is connected to Policy H5.1.2 and H5.2.3.
a) 2023 – 2031
(Ongoing)
b) 2024 – 2025
c) 2023 – 2031
(Ongoing)

Existing
New
New

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Number Policy Lead Agency/Department/Division Funding
Source(s) Program Measure(s) Implementation Action(s) Target Timeline New/Existing Program Policy H

1.3 Increase Affordable Housing
Production through
Inclusionary Housing, Density
Bonus, and Community
Benefit Programs
Community Development
Department
N/A Update the City’s Inclusionary Housing
requirements for ownership and rental
residential developments to allow for
alternative compliance options other than
on-site construction and to establish an
updated Density Bonus/Community Benefits
program that incentivizes production of
additional affordable units.

a) Amend the Affordable Housing Ordinance (SMMC
Chapter 27.16.050) and Inclusionary Housing Policy to
allow for alternative compliance options to onsite
inclusionary unit development within one year of
Housing Element adoption.
b) Adopt an updated Density Bonus/Community Benefits
program that provides additional incentives and/or
streamlining options for housing projects that provide
additional affordable units or the most needed unit
types beyond minimum state requirements.

Both of these actions would include an assessment of
applicable state law to ensure that the City meets or
exceeds all requirements.

This item is connected to Policy H5.1.1 and H5.2.2.
a) 2023 – 2024
b) 2024 – 2025
New
New
Policy
H1.4
Incentivize Accessory Dwelling
Unit Development
Planning Division N/A Implement and maintain programs to encourage and support ADU production to
increase lower income housing
opportunities.
a) Amend the City’s ADU Ordinance (SMMC Chapter

27.19) to align with current State law and to resolve
any inconsistencies identified by HCD.
b) Maintain and expand the ADU information and
resources available to home owners and applicants
provided on the City’s website.
b)c) Collaborate with 21 Elements and other countywide
jurisdictions to collaborate on ways to enhance
available ADU resources, establish uniform standards
and requirements, and effective ways to monitor ADU
affordability.
c)d) Continue to offer flat fees for ADU building permits, and review ADU permit fees every 2-3 years to
evaluate if reductions are necessary to reduce cost
barriers.
d)e) Provide an annual report on ADU permitting data to verify that Housing Element production targets are
being achieved. If ADU production targets are not
achieved for two consecutive years, then, within six
months, pursue additional actions, including fee
reductions, increased homeowner resources and
assistance, funding assistance and/or code
amendments, to incentivize ADU production.

This item is connected to Policy H 5.1.3.
a) 2023 – 2024
b) 2023 – 2031
(Ongoing)
c) 2023 – 2031
(Ongoing)
d) 2023 – 2031
(Ongoing)
c)e) 2023 – 2031
(Annually)

New
Existing
New
Existing
New

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Number Policy Lead Agency/Department/Division Funding
Source(s) Program Measure(s) Implementation Action(s) Target Timeline New/Existing Program Policy
H1.5
Encourage Family Housing Planning Division N/A Prioritize acquisition and new construction of housing that accommodates families (larger
units) when possible and require subsidized
projects to include family-sized units.
a) Present options to City Council for requiring a
minimum percentage of three-bedroom units in City
subsidized projects;
b) Present options to City Council for requiring a
minimum percentage of family-sized units in private
development projects as part of the Inclusionary
Policy update.
a)c) Should such policy recommendations not materialize into code amendments, explore alternative methods
to promote family sized units through the community
benefits program.

This item is connected to Policy H5.1.1 and H5.2.3.
a. 2025 – 2026
b) 2023 – 2025
a)c) 2025 – 2026
New
New
New
Policy H

1.6 Streamline Housing
Application Review including
for Design Review
Community Development
Department
N/A Reduce the development review timeline for
housing projects by streamlining the
development review process and simplifying
design review and submittal requirements.
a) Update the City Council resolutions that establish the pre-application and development review processes to
simplify and streamline requirements.
b) Update permit application submittal requirements.
c) Develop Zoning Code amendments to align City
requirements with SB 330 and make a
recommendation to the City Council.
c)d) Streamline the Design Review process for residential and mixed-use projects to either increase the
threshold for review or completely eliminate the third- party design review requirement.
a) 2023 – 2024
b) 2024 – 2025
c) 2024 – 2025
d) 2024 - 2025
New
New
New
New
Policy H

1.7 Update Zoning Code
Development Standards
relating to floor area ratios
and parking requirements
Planning Division N/A Evaluate Zoning Code development
standards that apply to multi-family
residential projects to reduce or eliminate
constraints, incentivize production of
additional housing units and support
development of a variety of housing types.
a) Evaluate the standards and requirements in all zone
districts that allow for multi-family residential and
Aamend the Zoning Code as needed to reduce or
eliminate constraints to housing construction.

Specifically: 1) Exclude covered parking and other
elements as needed from Floor Area Ratio (FAR)
calculation for housing projects with affordable units, 2) Specify where Single-Room Occupancy (SRO) units
are permitted consistent with government Code
65583(c)(1), and 3) specify that Manufactured Homes
that are built on a permanent foundation are subject
to the same zoning requirements and development
standards as single-family homes.
b) Evaluate off-street parking requirements for multi-
family and mixed-use development projects in and
amend SMMC Chapter 27.64 (Off-Street Parking) to
remove any requirements that are identified as a
constraint.
a) 2024 – 2025
b) 2025 – 2026
New
New
Policy
H1.8
Adopt Objective Design
Standards
Planning Division N/A Adopt Objective Design Standards to expedite production of housing.

Adopt Objective Design Standards for multi-family
residential projects and mixed-use projects with a
residential component.

2023 – 2024

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Number Policy Lead Agency/Department/Division Funding
Source(s) Program Measure(s) Implementation Action(s) Target Timeline New/Existing Program Policy H

1.9 Establish Minimum Densities
for Mixed-Use Residential
Projects
Planning Division N/A Create minimum residential density requirements to ensure mixed-use
development will contain an appropriate
amount of housing in commercial/office
developments.
a) Amend the Zoning Code to establish a minimum
residential density for mixed-use projects that include a residential component.
b) Study and present to City Council options for requiring a residential component in all mixed-use projects in
certain zones or areas.
a) 2023 – 2024
b) 2023 – 2024
New
New
Policy
H1.10
Establish By-Right Housing
Designation for Prior Housing
Sites
Planning Division N/A Designate housing sites that have carried over from the prior Housing Element to allow
housing development by-right.

Amend the Zoning Code to establish a By-Right designation for housing sites reused from prior Housing Elements for housing projects that propose a minimum of 20%
affordable units. Zoning for these sites must be at least 30 units/acre to meet default density requirements for lower- income households per Gov. Code Section 65583.2©(c).
2024 – 2025
(must be completed
within three years of
certification)
New
Policy H

1.11 Implement the SB 9
Ordinance
Planning Division N/A Implement the Zoning Code to allow duplexes and lot splits on appropriate single-
family sites consistent with SB 9.

Implement the City’s ordinance amendments adopted in
September 2022 to implement the provisions of SB 9 in
single-family zones (R1).
2023 – 2031 (ongoing) New
Policy
H1.12
Encourage Residential Uses
within Housing Overlay
Planning Division N/A Amend Housing Overlay to encourage residential projects in commercial zones (not
just mixed-use).

Amend Housing Overlay Ordinance to allow multi-family
housing as a permitted use in the C1, C2 and C3 Zoning
Districts.
2024 – 2025 New
Policy
H1.13
Encourage Development of
Missing Middle Housing by
removing zoning constraints
and exploring SB 10
Planning Division N/A Support small infill residential construction (Missing Middle, 4-10 units) through policy
updates and Zoning Code amendments.
a) Evaluate residential zoning districts that have sites with potential for Missing Middle Housing (R2, R3 and
R4 zones) and identify development standards that
create barriers for small-scale development, including
minimum lot size, setbacks, floor area ratio, parking
and open space requirements, and amend the Zoning
Code to reduce or eliminate any identified constraints. b) Research and evaluate policies and code amendments
to allow for Missing Middle housing under SB 10 and
schedule for City Council consideration and adoption.
a) 2025 – 2026
b) 2025 – 2026
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Number Policy Lead Agency/Department/Division Funding
Source(s) Program Measure(s) Implementation Action(s) Target Timeline New/Existing Program Policy
H1.14
Evaluate and Update Special
Needs Group Housing
Requirements
Planning Division N/A Research current code requirement regarding special needs group homes for
people with disabilities for consistency with
Fair Housing Requirements.
a) Review and amend the Zoning Code to allow group
homes and residential care facilities for seniors and
non-seniors (including persons with disabilities) in all residential zones, only subject to those objective
standards that apply to other residential uses of the
same type in the same zone in conformance with state
law.
b) Review and amend the Zoning Code definition for
family, and other related regulations, to ensure
consistency with State and Federal fair housing laws
related to persons with disabilities. This effort may
also include consideration of new definitions such as
single-unit and multi-unit dwellings to accommodate
various housing situations.
c) Study best practices and develop a universal design
ordinance that may better address housing needs
for persons with disabilities.

This item is connected to Policy H5.1.1 and H5.2.3
a) 2024 – 2025
b) 2024 – 2025
a)c) 2026 – 2027
New
Policy
H1.15
Evaluate and Update
Supportive Housing
Requirements
Planning Division N/A Review and amend zoning code regarding multi-family housing development.

Amend the Zoning Code to be consistent with AB 2162 to
allow by-right 100% affordable housing that has 25% or 12 units of permanent supportive housing, where multi-family or mixed-use housing is permitted.

This item is connected to Policy H5.1.1 and H5.2.3.
2025 – 2026 New
Policy
H1.16
Update Mobile Home Parks
Requirements
Planning Division N/A Amend zoning code requirements regarding mobile home parks.

Amend the Zoning Code to allow mobile home parks as a
special use in all residential zones to be consistent with Government Code Section 65852.7
2024 – 2025 New
Policy
H1.17
Update Farmworker Housing
Requirements
Planning Division N/A Amend zoning code requirements regarding farmworker housing.

Amend the Zoning Code to define and allow farmworker
housing within the Agricultural District consistent with Government Code Section 17021.6.
2024 – 2025 New
Policy
H1.18
Permitting and Development
Fee Review
Community Development
Department
N/A Regularly review development application,
building permit and impact fees to identify
opportunities to reduce per unit costs for
housing developments, with a focus on
reducing per unit costs for small multi-family
projects (Missing Middle).
a) Study cumulative permit fee costs for new housing
development of various sizes and use information to
identify opportunities to reduce per unit permitting
costs; with fee reductions for small multi-family
projects being prioritized. Present findings to the City Council with recommendations for adoption.
b) Conduct a comprehensive review and update of the
fee schedule every 5-6 years, with a focus on
evaluating and adjusting fees with potential barriers
to housing production. Next review will be conducted
in 2026 (last fee study completed in 2021).
a) 2024 – 2025
b) 2023 – 2031
(Ongoing)
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Number Policy Lead Agency/Department/Division Funding
Source(s) Program Measure(s) Implementation Action(s) Target Timeline New/Existing Program Policy
H1.19
Increase Senior Housing
Production
Community Development
Department
N/A Evaluate potential policies and code
amendments to support the production of
housing for seniors.

Evaluate code amendments and/or policies to encourage
and support the development of senior housing, including through shared‐ housing arrangements, community care
facilities, supportive housing, and assisted living for seniors, and make a recommendation to the City Council. 2029 – 2030 New
Policy
H1.20
Provide Housing Element to
Water and Sewer Providers
Community Development
Department
N/A All City water and sewer providers shall
promptly receive amendments to Housing
Element, per Government Code Section
65589.7.
a) Deliver the adopted Housing Element to local water
providers, California Water Company and Estero
Municipal Improvement District, and the local sewer
provider, City of San Mateo, within one month of
adoption.
b) Work with California Water Company and Estero
Municipal Improvement District to establish procedures
to prioritize water service connections to developments with affordable housing units.

Note: Action b) does not apply to the City’s sewer service provider since improvements to the wastewater treatment plant ensure that there is sufficient capacity for all new development through 2031, and beyond, so prioritization of service connections is not necessary.
a) 2023
b) 2023 – 2031
(Ongoing)
New
New
Policy
H1.21
Adopt San Mateo General
Plan 2040
Community Development
Department
N/A Adopt a General Plan Update that provides
sufficient development capacity to meet the
City’s housing needs through 2040.

Complete the General Plan Update process and present
final draft to the City Council for adoption. The GPU will include an approach to address all components of the GPU that exceed the growth limits set by Measure Y.
2023 – 2024 Existing

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7.2.2 GOAL H2 : Preservation of existing housing that is affordable to lower - and middle -income residents As the City continues to grow, it remains important to maintain and preserve existing affordable housing as well as non-deed restricted housing that is naturally affordable for middle and lower-income households. The most direct method of achieving this goal would be to prevent the conversion of existing affordable units from becoming market rate by renegotiating agreements, using public funds to acquire the units, or requiring developers to replace any lost units. Alternatively, the city can indirectly preserve affordable housing by improving the quality of life for individuals and families who currently reside in them. Residents that are able to thrive in low-income housing are less likely to be displaced. Therefore, the city proposes to incentivize u pgrades to low -income homes through rehabilitation, accessibility modifications, or energy efficiency changes. In addition, enhancements to low-income neighborhoods can also be achieved through capital improvements and resiliency projects that protect against threats posed by climate change.

Table 10: Goal H2: Preservation - Implementation Plan
Number Policy Lead
Agency/Department/Division Funding Source(s) Program Measure(s) Implementation Action(s) Target Timeline New/Existing Program
Policy
H2.1
Fund Housing
Rehabilitation Efforts
Housing Division CDBG/CALHome a) Fund minor home repairs and accessibility improvements
b) Provide opportunity for home
rehabilitation loans for low- income
residents.
c) Allow accessibility
improvements on rental properties
with owner permission.
a) Complete annual goals of 10 minor home repairs and 14 accessibility modifications through grants for low-income residents.
b) Provide home rehabilitation loans for low-income residents up to a total of approximately $500,000 available.
c) Affirmatively market the availability of these funds to both homeowners and renters to increase awareness. Marketing efforts include translating flyers into Spanish and distributing flyers to various locations throughout the City, including libraries, senior and community centers and non -profit agencies. Outreach will be conducted biannually.

This item is connected to Policy H5.3.2.
2023 - 2031 (Annually by
June 30)
Existing
Existing
New
Policy
H2.2
Support Retention of
Existing Lower Income
Units
Housing Division TBD (potential
sources include:

PLHA)
a) Identify funding source for
preservation
b) Monitor affordable housing
projects that are at risk of
conversion to market rate.
c) Support regional and local efforts
to examine displacement of
affordable housing and lower
income households.
d) Assist with the retention of
special needs housing that is at risk
of expiring affordability
requirements.

Bridgepointe Condominiums affordability requirements for 59 affordable units expire in 2027, out of which 24 are very low-income units (35 are at 120% AMI). Belmont Building affordability requirements for 6 units expire in 2032.

The rental property is owned by a for-profit entity, potential for loss of units is high.

Proactively coordinate with owners to preserve the 24 very low-income units as affordable, including identifying potential funding sources, advertise conversion units to non-profits, conduct tenant outreach and education, add a displacement preference for new affordable housing for people displaced , including those displaced as a result of conversion. Outreach and negotiate with owners for affordability extensions. Provide noticing to tenants and affected public entities in accordance with Gov. Code, § 65863.10, 65863.11, and 65863.13
This item is connected to Policy H 5.3.3.
a) 2025-2027
(Bridgepointe
Condominiums)
b) 2030-2032 (Belmont
Building)
New
New
Policy
H2.3
Increase Energy and
Water Efficiency in
Existing Units
Community Development
Department, City Manager’s Office
CDBG/City Funds Increase energy and water
efficiency in all existing residential
units. Fund weatherization
upgrades for low- and moderate-
income homeowners.
a) Complete seven weatherization upgrades through grants for low-income residents annually.
b) Implement energy-efficiency and electrification strategies identified in the City's Climate Action Plan through updates to the City’s Reach Codes as part of the building permit review process. Outreach will be conducted biannually.

This item is connected to Policy H5.3.2.
a) 2023 - 2031
(Annually, June 30)
b) Reach codes are
updated every three
years.

Existing
New

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Number Policy Lead
Agency/Department/Division Funding Source(s) Program Measure(s) Implementation Action(s) Target Timeline New/Existing Program
Policy
H2.4
Implement Capital
Improvements in
Lower-Resourced
Neighborhoods
Housing Division CDBG Invest more resources in lower
resource neighborhoods (utilize
federal CDBG to provide capital
improvements).

Use available CDBG funds to make CIP improvements in identified Equity Priority Neighborhoods (including North Central and North Shoreview neighborhoods). Potential improvements may include: street work, crosswalk implementation, ADA ramp installation, striping, sidewalk improvements, traffic signal replacement, and other pedestrian/bicycle enhancements.

Allocate available CDBG funds on an annual basis.

Implement Bike Master Plan and Pedestrian Master Plan through capital improvements in Equity Priority Neighborhoods.

Conduct proactive public outreach to identify and prioritize capital improvements that best align with a neighborhood’s most critical needs. 2023 - 2031 (Annually) Existing
Policy
H2.5
Promote Housing
Resilience
Public Works Department City Funds Use resources to protect housing at risk of damage due to changing
environmental conditions.

Provide Flood Improvements for the North Shoreview neighborhood through the levee project with Public Works.

Started in Fall 2020, with
completion anticipated
in Spring 2023
Existing
Policy
H2.6
Require Replacement
Units
Planning Division N/A Require equivalent replacement
units for all housing units lost during
any construction or demolition
projects (Housing Crisis Act).
a) Conduct a study to determine whether the City should update the zoning ordinance and other policies to permanently require replacement of units (beyond Housing Crisis Act sunset date of 2034).This action must be completed within three years from the start of the planning period. a)b) The City will require replacement housing units subject to the requirements of Government Code Section 65915(c)(3), when a development project or demolition occurs on sites with existing residential units that are restricted or have been occupied by a lower income household in the past five years.
a) 2024-2026

b) Effective Immediately

b)c)
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7.2.3 GOAL H3 : Protection of current residents to prevent displacement San Mateo’s demographics will fluctuate as the city continues to grow and evolve. But while change is inevitable, the loss of the existing community is not. Therefore, it remains a priority for the city to prevent gentrification and displacement through protection of lower-income residents. Policy tools included within this goal such as commercial linkage fees, relocation fees, documentation requirements for landlords, and right to return policies help balance the scales against the market forces that lead to displacement while extending vital tenant protections. Programs are included to address homelessness and increase shelter capacity that can protect housing insecure individuals and families from having to leave the City entirely. These programs allow service providers an opportunity to intervene and lead clients to housing stability. The City also proactively affirms its commitment to combat inequities in housing that exist across people of protected classes through affirmative marketing, prioritizing special needs tenants in below market rate units, establishing a rental registry to monitor trends in evictions, and undertaking several actions to affirmatively further fair housing.

Table 11: Goal H3: Protection - Implementation Plan
Number Policy Lead
Agency/Department/Division
Funding
Source(s) Program Measure(s) Implementation Action(s) Target Timeline New/Existing Program
Policy
H3.1
Prevent
Homelessness
Housing Division CDBG/PLHA/City Support where feasible programs and facilities to prevent homelessness through city actions, while
coordinating with County and Continuum of Care.
a) Allocate PLHA, CDBG, and other local funds to support homeless prevention these may include the following programs: LifeMoves Rapid Rehousing Program, Safe Harbor Shelter, Vendome Hotel supportive units, LifeMoves First Step for Housing program, HIP Housing home sharing and Montara assisted units for the formerly homeless. b) Support the County in its efforts to convert the Stone Villa Hotel into a 44-room temporary shelter space as part of the Project Homekey programs.
a) 2023 – 2031
(Annually by June
30)
b) 2023 – 2031
(Annually)
Existing
New
Policy
H3.2
Investigate Fair
Housing Cases
Housing Division CDBG Continue funding and support for outreach services for homeowners and renters at risk of being
displaced and/or facing fair housing challenges.

As CDBG funding permits, achieve the Annual Fair Housing Activity Goals:
• Investigate at least 18 cases;
• Provide consultation to at least 30 individuals;
• Public Education/Outreach to at least 26 individuals; and • Provide legal assistance to at least 185 renters.

These numbers are subject to change based on funding availability.

See Goal H5/AFFH Action Plan for full list of items.
2023 - 2031 (Annually
by June 30)
Existing
Policy
H3.3
Evaluate Housing
Revenue Sources
Community Development
Department
N/A a) Conduct a feasibility study to determine a potential increase of the Commercial Linkage Fee to ensure
commensurate housing funding with commercial
development.
b) Explore other funding opportunities to support
affordable housing development. Efforts include
actively tracking available Federal, State, Regional
and Local funding opportunities for affordable
housing and determining how to leverage these funds
to build or rehabilitate more affordable housing.
a) Conduct a feasibility study on increasing the fee to generate additional housing funds gathered from commercial development, analyze the study, conduct community outreach and make a recommendation to the City Council. Proceed as directed by Council.
b) Examine other possible revenue sources and bring the proposals before City Council for consideration. Actively track available funding opportunities and coordinate with City partners, including non-profit housing developers on how best to leverage these resources. a) 2025 - 2026
b) 2023 - 2031
(Annually, as
opportunities
become available)
New
New
Policy
H3.4
Expand Tenant
Protections
Community Development
Department
N/A Expand tenant protections in local ordinance to
extend measures of AB1482 related to relocation,
documentation, and right to return policy in eviction
cases.
a) Extend AB1482 provisions to require tenant relocation payments for No Fault evictions for those with tenure less than one year . b) Make recommendations to the City Council for establishing tenant protection policies that include the requirement of documentation from landlords who use the substantial remodel exemption to evict tenants and a Right to Return policy for tenants displaced from homes due to demolition or substantial remodels.
c) Amend the Code to strengthen enforcement penalty structure to aid in protecting tenants from unsafe or substandard units. c)d) Conduct outreach to the community on a biannual basis.

This item is connected to Policy H5.4.1.
a) 2023 – 2024
b) 2025 – 2026
c) 2023 – 2024
c)d) 2023 – 2031
(biannually)
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Number Policy Lead
Agency/Department/Division
Funding
Source(s) Program Measure(s) Implementation Action(s) Target Timeline New/Existing Program
Policy
H3.5
Study the Creation
of Below Market
Rate Set Asides
Community Development
Department
N/A Examine the feasibility of establishing priority
allocation for households with special needs and
large families in City-assisted and private
development projects with BMR units.

Conduct a best practices research on prioritization of households with special needs and large families. Analyze the data, conduct community outreach and make recommendations to the City Council. Proceed as directed by Council.
2025 – 2026 New
Policy
H3.6
Evaluate Rental
Registry Options
Community Development
Department
N/A Explore a rental registry to track rents and evictions citywide.

Research options and best practices for a rental registry list, including determining necessary financial and human resources needed to establish such a program. Make recommendations to City Council.
2023 - 2024 New
Policy H

3.7 Evaluate
Opportunities for
Expanding
Homeless Shelters
Community Development
Department
N/A Examine best practices and policies to expand shelter capacity for individuals experiencing homelessness.

Study feasibility of new shelter programs and
collaborate with the County to end homelessness.
a) Study best practices for expansion of homeless shelter sites. b) Regularly evaluate zoning to ensure enough sites are available to accommodate the capacity for emergency shelters, based on the countywide Point in Time Homeless Count.
c) Review and amend the zoning code to allow emergency shelters in C2, C3, and other zones as needed to ensure there is sufficient capacity on available sites to accommodate the need for emergency shelter as identified in the most recent point-in-time count conducted before the start of the planning period, in compliance with Government Code 65583.
b)d) Review and amend the zoning code as needed to comply with Government Code 65583 including to remove the 300 feet buffer from a single-family dwelling, clarify that emergency shelters are not required to be more than 300 feet apart and adopt objective development standards, such as parking for shelters in compliance with Government Code Section 65583(a)(4)(A)(ii).
c)e) Review and amend the zoning code as needed to comply with requirements of AB 101 (2019) to allow Low Barrier Navigation Centers (LBNC) as a permitted use by right in areas zoned for mixed use and nonresidential zones permitting (by right or through a Special Use Permit) multifamily uses if it meets specific requirements in Government Code sections 65660 – 65668.
a) 2023 – 2031
(Ongoing)
b) 2023 – 2031
(Ongoing)
c) 2023-2031
(Ongoing)
d) 2023-2025
c)e) 2023-2025
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New
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7.2.4 GOAL H4 : Promotion of community engagement and public outreach To increase effectiveness and successfully achieve the Housing Element’s goals and policies, the City should increase access and awareness of housing programs through use of new technology as part of a robust and proactive public outreach strategy. By expanding availability of digital resources, the barriers of proximity, transportation, and time opportunity cost can be reduced for many. In addition, by providing education and information on regulatory requirements and specific programs and protections offered locally, regionally, and by the state, the city can improve access to housing for all income groups and special needs communities. Public outreach in a diversity of methods, forms and languages can be used to reach the widest breadth of residents and program beneficiaries to ensure those in need can find supportive programs and service providers. Targeted digital, print, and in -person outreach and engagement methods can also be effective at reaching the communities most affected by housing policies and programs.

Table 12: Goal H4: Promotion - Implementation Plan
Number Policy Lead
Agency/Department/Division
Funding
Source(s) Program Measure(s) Implementation Action(s) Target Timeline New/Existing Program
Policy
H4.1
Update the
Housing
Webpage
Housing Division N/A Increase community outreach and availability of resources in multiple languages through the Housing Webpage.
a) Maintain and improve webpage with comprehensive housing related information and materials, and coordinate with providers to market programs electronically.
b) Provide information in multiple languages using common terms.

This item is connected to Policy H5.4.3.
2023 - 2031
(Ongoing)
Existing
New
Policy
H4.2
Support a
Countywide
Below Market
Rate Unit Waitlist
County of San Mateo N/A Support development of the countywide affordable rental waitlist to streamline and centralize occupancy of BMR units by joining the County’s waiting list process.

Support the county’s online portal for a BMR waitlist by transitioning the City’s BMR waiting list to the Countywide system. In addition, work with BMR property managers/owners to advertise available BMR units on the County’s portal to streamline the rental process.
2023 – 2024
(Transition to
Countywide
portal)
(and ongoing)
Existing
Policy
H4.3
Expand
Community
Education and
Outreach
Community Development
Department
N/A Support and engage in efforts to educate community stakeholders and residents, including those with special needs (such as farmworkers, people with disabilities including those with developmental disability, and single-female head of household), about housing gaps and the effects of programs and policies on addressing those gaps. Proactively create opportunities for all communities to have a voice and be involved in shaping policies and programs.
a) Housing initiatives and policy implementation shall be supported with robust and adaptive community engagement including surveys, workshops, pop-up events, mailings, and targeted outreach to underrepresented groups. Outreach will be conducted biannually. b) Continue to participate in Countywide (and other) efforts to share best practices on equitable engagement and inclusive outreach. (e.g.

Home For All “Learning Network”)
c) Actively provide information on County and State resources for tenant protections, discriminatory practices (CC&R's), special needs groups, and households with disproportionate housing needs.
2023 - 2031
(Ongoing)
Existing
New
New
Policy
H4.4
Enable
Affirmative
Marketing
Housing Division N/A Develop Marketing Plan with developers of affordable housing projects during final phase of construction on a project-by-project basis. Focus outreach to special needs individuals and those least likely to apply based on racial make-up of neighborhood. a) Research other best practices to create an affirmative marketing strategy and implement strategies in San Mateo where appropriate. b) Include farm workers, people with disabilities, and households with disproportionate housing needs, as new target group where appropriate.
c) Include Spanish marketing materials and ensure bilingual interpretation services are available. The City will conduct outreach and education on a project-by-project basis and will ensure that programs target/affirmatively market to households in impacted neighborhoods, including North Central and North Shoreview, among others.

This item is connected to Policy H5.1.2 and H5.2.1.
a) 2025 – 2026
b) 2023 – 2031
(ongoing)
a)c) 2023 – 2031
(ongoing)
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Number Policy Lead
Agency/Department/Division
Funding
Source(s) Program Measure(s) Implementation Action(s) Target Timeline New/Existing Program
Policy
H4.5
Conduct
Outreach to Sites
Inventory
Property Owners
Community Development
Department
N/A Conduct focused outreach to the owners of properties on the Sites Inventory to determine interest in redevelopment or construction of additional housing.

Conduct focused outreach to the owners of properties on the Sites Inventory to determine interest in redevelopment or construction of additional housing on their site(s). The outreach shall include provision of information on the City’s development process, fees, and timelines associated with such applications. Initial outreach shall be conducted within two years of adoption and shall be ongoing throughout the housing cycle.
2023 – 2031
(ongoing)
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7.2.5 Goal H5 : Affirmatively Furthering Fair Housing
To reinforce the objective that AFFH is a top priority for the city, an AFFH Fair Housing Action Plan with programs and actions h as been included as the fifth goal of the Housing Element . This Action Plan cross references items that are interwoven with the Housing Plan’s other four goals, policies, and programs. The actions to achieve the Fair Housing goal are meant to address the fair housing issues found in the AFFH analysis, specifically for groups that have disparate housing impacts when compared to the whole of San Mateo. This includes, for example, Hispanic and single-female heads of households who have disproportionate housing needs while being concentrated in census tracts that have high rates of poverty. Persons with disabilities are also more likely to experience housing discrimination due to low economic opportunity and failure of landlords to provide reasonable accommodations. Each of the actions identified in Table 13 have specific quantified objectives to reach the target households.

Table 13: Goal H5: AFFH - Implementation Plan
Actions Fair Housing Issues Contributing Factors
Fair Housing
Category Action
Type of
Action Responsible Party Objectives Quantified Objectives Timeline Action Area 1. Enhancing housing mobility strategies: consist of removing barriers to housing in areas of opportunity and strategically enha ncing access.

Policy H5.1.1: 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
(e.g., accessible/visit able units for
persons with disabilities, child-
friendly developments with day care
on site for single parents, and 3-4
bedroom units for larger families).

Hispanic and single
female parent
households are
concentrated in low
opportunity census
tracts.

Lack of affordable housing
in high opportunity areas;
Lack of accessible
affordable units
Disparities in access
to opportunities
Assist in
development of
housing for low-
income
households and
households with
special needs
Land use
resources
City of San Mateo Expand the variety of
housing units produced
under the inclusionary
housing program. Currently
developments of 11 or more
units require 15% affordable
to moderate income families
for ownership and 15% for
low -income families for
renters.

Perform a feasibility analysis to redesign
the program to allow a menu of options.

Ensure analysis includes review housing
for households with disproportionate
housing needs, along with income levels.

This item is connected to Policy H 1.3,
Policy H 1.5., Policy H 1.14, and Policy H

1.15. Complete feasibility analysis
by Fall 2023; Implement
redesigned program by Spring
2024.

Policy H5.1.2: 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 (e.g., Spanish
and English, targeted to northeast
neighborhoods).

Hispanic households
have
disproportionate
housing needs.

Historic discrimination and
continued mortgage
denials; Concentration in
low opportunity census
tracts; High housing costs
and low wages
Disparities in access
to opportunities
Promote equal
housing
opportunity
Financial
resources
Regional
Partnership with
HEART (San Mateo
County has
program with
them)
Improve accessibility to
home mortgage loans for
Hispanic households who
have the highest loan denial
rates. Provide wealth
building through
homeownership for
moderate income
households.

Affirmatively market down payment
assistance to 20 Hispanic households;
Provide down payment assistance to 30
total households; Provide homebuyer
education to 200 households. In
addition, the City will work with other
jurisdictions to conduct outreach and
education. Ensure that programs
target/affirmatively market to
households in impacted neighborhoods,
including North Central and North
Shoreview, among others.

This item is connected to Policy H 4.4.

Meet quantified objectives by
the end of the Housing
Element period in 2031;
Conduct homebuyer/outreach
and education quarterly in
partnership with HEART
Policy H5.1.3: 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.

Hispanic and single
female parent
households are
concentrated in low
opportunity census
tracts.

Lack of affordable housing
in high opportunity areas;
Lack of accessible
affordable units
Disparities in access
to opportunities
Incentivize
accessory
dwelling units
(ADUs)
Land use
resources
21 Elements/HEART Increase opportunities for
lower-income households to
find housing that is
affordable.

Design a regional loan forgiveness
program. Ensure that programs
target/affirmatively market to
households in impacted neighborhoods,
including North Central and North
Shoreview, among others. Target those
with disproportionate housing needs,
with a goal to reach 5 households
annually.

This item is connected to Policy H1.4.

Begin design in Summer 2025
and complete by winter 2026.

Action Area 2. Encouraging new housing choices and affordability in high resource areas: promoting housing supply, choices, and affordability in areas of high opportunity and outside of areas of concentrated poverty.

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Actions Fair Housing Issues Contributing Factors
Fair Housing
Category Action
Type of
Action Responsible Party Objectives Quantified Objectives Timeline Policy H5.2.1: Add more city
supported housing with affordability
restrictions in moderate and high
resource areas. Affirmatively market
the housing to households with
disproportionate housing needs
including persons with disabilities,
farmworkers, single parents, and
Hispanic households (e.g., Spanish
and English, targeted to northeast
neighborhoods).

Hispanic and single
female parent
households are
concentrated in low
opportunity census
tracts.

Lack of affordable housing
in high opportunity areas;
Lack of accessible
affordable units;
Concentration of Naturally
Occurring Affordable
Housing (NOAH) in low
opportunity census tracts.

Disproportionate
housing need for
low-income
households and
protected classes
Assist in
development of
housing for low-
income
households and
households with
special needs
Financial
resources
City of San Mateo Affirmatively market the
housing to households with
disproportionate housing
needs including persons
with disabilities, single
parents, farmworkers, and
Hispanic households (e.g.,
Spanish and English,
targeted identified
neighborhoods).

Require developers to affirmatively
market 1,000 units to those with
disproportionate housing needs over the
eight-year period (approximately 125
annually). Ensure that programs
target/affirmatively market to
households with disproportionate
housing needs. Continue to update the
housing inventory and provide on the
City’s website so that developers can
target housing in moderate and high
opportunity areas.

This item is connected to Policy H1.2.
and Policy H 4.4.
2023 - 2031 (Annually); as
development projects come in
for approvals/financing
Policy H5.2.2: Incentivize developers
through direct subsidies, fee
waivers, and/or density bonuses, to
increase accessibility requirements
beyond the federal requirement of
5% for subsidized developments.

Persons with
disabilities have
disproportionate
housing needs.

AND

Persons with
disabilities and
persons of color are
most likely to file fair
housing complaints
with HUD.

Lack of accessible
affordable units; Lack of
access to economic
opportunity; Concentration
in low income and low
opportunity census tracts.

Disproportionate
housing need for
low-income
households and
protected classes
Promote equal
housing
opportunity
Financial
resources
City of San Mateo Increase development of
accessible units beyond
minimum requirements
a. Update development agreements for
projects with City subsidies to
include additional accessible units.
b. Update the City’s Inclusionary
Housing Policy to require projects
that receive City subsidies to
increase the percentage of units that
meet accessibility requirements. This
item is connected to Policy H1.3
2023 - 2031 (ongoing) as
development opportunities
come available.
2025 - 2026 Update
Inclusionary Housing Policy;
make recommendations to
City Council in 2025 - 2026
Policy H5.2.3: 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)
Persons with
disabilities have
disproportionate
housing needs.

AND

Persons with
disabilities and
persons of color are
most likely to file fair
housing complaints
with HUD.

Lack of accessible
affordable units; Lack of
access to economic
opportunity; Concentration
in low income and low
opportunity census tracts.

Disparities in access
to opportunity
Promote equal
housing
opportunity
Financial
resources
City of San Mateo Create more housing for
hard to serve households.

Conduct a best practices review and
develop a program to prioritize City
funding for housing projects. This item is
connected to Policy H1.5, Policy H1.14,
and Policy H1.15.
2027 - 2028 Conduct a review
of best practices and develop
a program for City Council
adoption
Action Area 3. Improving place-based strategies to encourage community conservation and revitalization including preservation of existing affordable housing: involves approaches that are focused on conserving and improving assets in areas of lower opportun ity and concentrated poverty.

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Actions Fair Housing Issues Contributing Factors
Fair Housing
Category Action
Type of
Action Responsible Party Objectives Quantified Objectives Timeline Policy H5.3.1: As part of the General
Plan, conduct an area plan for the
North Shoreview and North Central
neighborhoods and prioritize land
use and design around Highway 101
to improve access and reduce the
division of the urban form produced
by the highway.

Hispanic and single
female parent
households are
concentrated in low
opportunity census
tracts.

Lack of affordable housing
in high opportunity areas;
Lack of accessible
affordable units;
Concentration of NOAH in
low opportunity census
tracts.

Segregation/
integration
patterns; disparities
in access to
opportunities
Conserve and
improve the
existing
affordable
housing stock
Land use
resources
City of San Mateo Reduce overcrowding,
improve health and safety,
and improve mobility and
access to services in
impacted neighborhoods.

Prepare an area plan for North
Shoreview and North Central
neighborhoods.

Create plan through the
General Plan Update
implementation process (2027
- 2029)
Policy H5.3.2: Continue to fund
minor home repairs and implement
a preference for projects in low
opportunity census tracts identified
in the analysis.

Hispanic and single
female parent
households are
concentrated in low
opportunity census
tracts.

Lack of affordable housing
in high opportunity areas;
Lack of accessible
affordable units
Disparities in access
to opportunity
Conserve and
improve the
existing
affordable
housing stock
Financial
resources
City of San Mateo Fund minor home repairs
and accessibility
improvements. Provide
opportunity for home
rehabilitation loans for low-
income residents. Allow
accessibility improvements
on rental properties with
owner permission.

Complete annual goals of 10 minor
home repairs and 14 accessibility
modifications through grants for low-
income residents. Provide home
rehabilitation loans for low- income
residents. Affirmatively market to
Hispanic and single female heads of
household biannually; ensure that
programs target/affirmatively market to
households in impacted neighborhoods,
including North Central and North
Shoreview, among others.

This item is connected to Policy H2.1 and
Policy H2.3.
2023-2031 (Fund annually;
consistent with Policy H2.1;
outreach biannually in target
neighborhoods)
Policy H5.3.3: Monitor affordable
housing projects that are at risk of
conversion to market rate. Support
regional and local efforts to examine
displacement of affordable housing
and lower income households. Assist
with the retention of special needs
housing that is at risk of expiring
affordability requirements.

Hispanic households
have
disproportionate
housing needs.

Historic discrimination and
continued mortgage
denials; Concentration in
low opportunity census
tracts; High housing costs
and low wages
Outreach capacity
and enforcement
Conserve and
improve the
existing
affordable
housing stock
Human
resources
City of San Mateo Monitor affordable units
whose subsidies are set to
expire within the planning
period develop a plan for
preservation of the units to
keep them affordable long
term.

Bridgepointe Condominiums
affordability requirements for 59
affordable units expire in 2027, out of
which 24 are very low- income units (35
are at 120% AMI). Belmont Building
affordability requirements for 6 units
expire in 2032. The rental property is
owned by a for-profit entity, potential
for loss of units is high.

Proactively coordinate with owners to
preserve the 24 very low- income units
as affordable, including identifying
potential funding sources, advertise
conversion units to non-profits, provide
conduct tenant outreach and education,
add a displacement preference for new
affordable housing for people displaced,
including those displaced as a result of
conversion. Provide noticing to tenants
and affected public entities in
accordance with Gov. Code, § 65863.10,
65863.11, and 65863.13 Outreach and
negotiate with owners for affordability
extensions beginning at least two years
prior to the affordability expiration date.

This item is connected to Policy H2.2
a) 2025-2027 (Bridgepointe
Condominiums)

b) 2030-2032 (Belmont
Building); Consistent with
Policy H2.2

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Actions Fair Housing Issues Contributing Factors
Fair Housing
Category Action
Type of
Action Responsible Party Objectives Quantified Objectives Timeline Action Area 4. Protecting existing residents from displacement: strategies that protects residents in areas of lower or moderate opportunity and concentrated poverty and preserves housing choices and affordability.

Policy H5.4.1: Establish tenant
protections in local ordinance to
extend measures of AB1482 related
to relocation, documentation, and
right to return policy in eviction
cases.

Persons with
disabilities have
disproportionate
housing needs.

AND

Persons with
disabilities and
persons of color are
most likely to file fair
housing complaints
with HUD.

AND

Hispanic households
have
disproportionate
housing needs.

Lack of accessible
affordable units; Lack of
access to economic
opportunity; Concentration
in low income and low
opportunity census tracts;
Historic discrimination and
continued mortgage
denials; High housing costs
and low wages
Disparities in access
to opportunity
Address
governmental and
non-
governmental
constraints
Human
resources
City of San Mateo Increase tenant protections
to prevent displacement of
those with disproportionate
housing needs.
a) Extend AB1482 provisions to require
tenant relocation payments for No
Fault evictions for those with tenure
less than one year.
b) Make recommendations to the City
Council for establishing tenant
protection policies that include the
requirement of documentation from
landlords who use the substantial
remodel exemption to evict tenants
and a Right to Return policy for
tenants displaced from homes due to
demolition or substantial remodels.
c) Amend the Code to strengthen
enforcement penalty structure to aid
in protecting tenants from unsafe or
substandard units. This item is
connected to Policy H 3.4.
a) 2023 – 2024
b) 2025 – 2026
c) 2023 – 2024; consistent
with Policy H3.4
Policy H5.4.2: Partner with Project
Sentinel to perform fair housing
training for landlords and tenants.

Focus enforcement efforts on race-
based discrimination and reasonable
accommodations.

Persons with
disabilities have
disproportionate
housing needs.

AND

Persons with
disabilities and
persons of color are
most likely to file fair
housing complaints
with HUD.

Lack of accessible
affordable units; Lack of
access to economic
opportunity; Concentration
in low income and low
opportunity census tracts;
Lack of understanding of
reasonable accommodation
requirements by landlords
and property owners.

Outreach capacity
and enforcement
Promote equal
housing
opportunity
Human
resources
City of San
Mateo/Project
Sentinel
Increase awareness of fair
housing laws and tenants'
rights to reduce unlawful
discrimination and
displacement.

Provide annual funding to Project
Sentinel to provide training every two
years in the Spring, targeting 200
landlords each training. Awareness will
be increased through outreach to
landlords.

Annually as part of CDBG
allocation in the spring
(Annually by July 1)
Policy H5.4.3: Create a webpage
specific to fair housing including
resources for residents who feel
they have experienced
discrimination, information about
filing fair housing complaints with
HCD or HUD, and information about
protected classes under the Fair
Housing Act.

Persons with
disabilities have
disproportionate
housing needs.

AND

Persons with
disabilities and
persons of color are
most likely to file fair
housing complaints
with HUD.

Lack of accessible
affordable units; Lack of
access to economic
opportunity; Concentration
in low income and low
opportunity census tracts;
Lack of understanding of
reasonable accommodation
requirements by landlords
and property owners.

Outreach capacity
and enforcement
Promote equal
housing
opportunity
Human
resources
City of San Mateo Increase awareness of fair
housing laws and tenants'
rights to reduce unlawful
discrimination and
displacement.

Provide information on the City's
website about housing discrimination,
laws, and protections. This item is
connected to Policy H4.1. Update the
webpage every two years, along with
other transparency updates.
2024 and bi-annually
thereafter; consistent with
Policy H3.4

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Actions Fair Housing Issues Contributing Factors
Fair Housing
Category Action
Type of
Action Responsible Party Objectives Quantified Objectives Timeline Policy H5.4.4: Ensure that all multi-
family residential developments
contain signage to explain the right
to request reasonable
accommodations for persons with
disabilities. Make this information
available and clearly transparent on
the city's website and fund landlord
training and outreach on reasonable
accommodations.

Persons with
disabilities have
disproportionate
housing needs.

AND

Persons with
disabilities and
persons of color are
most likely to file fair
housing complaints
with HUD.

Lack of accessible
affordable units; Lack of
access to economic
opportunity; Concentration
in low income and low
opportunity census tracts;
Lack of understanding of
reasonable accommodation
requirements by landlords
and property owners.

Outreach capacity
and enforcement
Promote equal
housing
opportunity
Human
resources
City of San Mateo Increase awareness of fair
housing laws and tenants'
rights to reduce unlawful
discrimination and
displacement.

Initially, create ongoing condition of
approval to ensure both BMR and all-
affordable developments contain this
information. Explore options for
recording against the property and/or
including in the affordable housing
agreement.

Create ongoing conditions of
approval by fall 2024; conduct
best practices review on
options to record reasonable
accommodation language by
January 2025, and implement
a program by January 2026
Policy H5.4.5: Ensure that future
improvements in disadvantaged
communities will not produce a net
loss of affordable housing or the
displacement of residents and seek
to increase the amount of affordable
housing in disadvantaged
communities.

Persons with
disabilities and
persons of color
have
disproportionate
housing needs.

Lack of accessible
affordable units; Lack of
access to economic
opportunity; Concentration
in low income and low
opportunity census tracts;
Lack of investment in older
housing stock.

Disparities in access
to opportunity
Promote equal
housing
opportunity
Human
resources
City of San Mateo Ensure that lower-income
and protected class
households are not
displaced because of
community improvements.

In collaboration with nonprofit and for-
profit housing developers, study the
feasibility of collaborating with the
Northern California Land Trust, or
establishing a new community land
trust, that will support long-term
community ownership and housing
affordability in disadvantaged
communities. Implement findings as part
of the General Plan Update.

To be completed as part of the
larger General Plan Update,
with the expected date of
completion by 2027

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8. QUANTIFIED OBJECTIVES
The quantified objectives section estimates the number of units likely to be constructed, rehabilitated, or conserved/preserved by income level during the 2023-2031 planning period. The quantified objectives do not represent a ceiling on development, but rather set a target goal for the jurisdiction to achieve, based on needs, resources, and constraints.

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. However, State law recognizes that the total housing needs identified may exceed available resources and the community's ability to satisfy this need within the content of the general plan. Under these circumstances, the quantified objectives need not match the identified existing housing needs but should establish the maximum number of housing units that can be constructed, rehabilitated, and conserved over an eight-year time frame. The quantified objectives do not necessarily meet the goals of RHNA because they are not a full projection of anticipa ted housing development within the Housing Element Cycle. It is an estimate of actual production, given available resources and projected pipelines projects.

With respect to affordable units, the City has estimated the potential subsidies available during the planning period and has calculated the potential number of units that could be assisted and/or constructed with these funds. In addition, staff has compi led a list of known or expected development projects in the next few years, including preservation projects, anticipated to be completed within the next eight years.

Based on these estimates, along with the known pipeline projects that have been initiall y reviewed , approved or are under construction , the total quantified objective for affordable units is 1,732. This includes 323 conserved/preserved affordable units, 543 City funded new construction a ffordable units and 866 non-subsidized affordable units in new private development.

The total development cost for the City’s RHNA allocation would exceed $4 billion dollars, of which over $3 billion would be required to develop the affordable units. Thus, the quantified ob jectives do not completely account for San Mateo’s RHNA but do establish the maximum number of housing units that can realistically be constructed, rehabilitated, and conserved in the City over an eight-year timeframe with current resources. A breakdown of the total quantified objectives for housing production over the next eight years and how they align with the City’s overall RHNA are outlined in the two tables below.

Table 14: Quantified Objectives for Cycle 6 (2023 – 2031) Conservation/Preservation Affordable Total ELI VLI LI MOD Market Bridgepointe Condominiums 59 24 35 396
Belmont Building 6 6
Rehabilitation Projects 258 258
Sub Total 323 0 30 258 35 396
Total Conservation 719

New Construction Affordable Total ELI VLI LI MOD Market Kiku Crossing (City Funded) 223 43 45 135 2

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New Construction Affordable Total ELI VLI LI MOD Market 445 S. B St. (City Funded) 60 6 39 14 1 0
Future Affordable TBD (City Funded) 260 70 120 70
Concar Passage 73 73 888
303 Baldwin Ave. (Trags) 6 6 58
Bay Meadows Res 6 5 5 49
Bay Meadows MU 3 7 7 60
Waters Park 19 19 180
406 E. 3rd Ave. (Windy Hill) 3 3 22
500 E. 3rd Ave (Block 21) 12 12 111
500 E. 4th Ave. (Block 20) 9 9 86
1885 S. Norfolk St. (Fish Market) 60 27 16 17 45
Hillsdale Terrace 6 6 62
200/210 S. Fremont St. 2 2 13
Peninsula Heights 29 29 261
222 S Fremont St. 4 4 36
477 E. Hillsdale Blvd. (Hillsdale Inn) 23 23 207
222 E. 4th Ave. (Draeger’s Market) 10 10 0
401 Concar Dr. (Hayward Park
Station Parking Lot)
28 16 12 161
616 S. B. St. (Nazareth Vista) 5 5 43
477 9th Ave. 12 12 108
1919 O’Farrell St. 4 4 45
Accessory Dwelling Units 374 22 132 220 66
Future Private Development TBD 252 152 60 40 1,670 Sub Total 1,426 119 574 482 291 4,173
Total Construction 5,639

Total Quantified Objectives Affordable Total ELI VLI LI MOD Market Total (Preserved Units plus New
Construction)
1,749 119 604 740 326 4,569
Grand Total 6,358

Table 15: Quantified Objectives Alignment with San Mateo’s RHNA Income Quantified Objective Eight-Year RHNA Figure % of RHNA to be Produced ELI/VLI 723 1,777 41%
LI 740 1,023 72%
MOD 326 1,175 28%
Market 4,569 3,040 150%
TOTAL 6,358 7,015 91%

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9. PRIOR ACCOMPLISHMENTS SUMMARY
The update of the Housing Element provides an opportunity to reflect on past achievements and challenges. The following summary highlights key accomplishments and challenges from the previous Housing Element’s planning period (2015 to 202 2), as well as identifies opportunities for where the city took lessons learned and applied them as future tasks for current Housing Element. A detailed evaluation of the prior housing element can be found in Appendix E - Review of Prior Housing Element.

The following achievements were made:
• Progress towards meeting affordable housing goals
• New policies to generate affordable housing funds
• Market rate housing goals were met
• The rate of ADU production have increased greatly
• Accessing new funding sources from non-local sources
• Increasing efficiency in the housing development process • Interventions to preserve affordable housing

The following challenges were experienced:
• A divided and polarized vision for the future of the city • High land and construction costs
• Outdated housing programs and policies
• Falling short of the quantified objectives

The following opportunities were identified:
• Rewrite the zoning code
• The General Plan update
• New opportunities for Transit Oriented Development
• Creative solutions to site limitations
• More uses for technology to increase efficiency of housing programs • New affordable housing opportunities identified

The 2015-2022 quantified objectives goal for total housing units, including market rate housing, was 3,164 units. Through the seventh year of this housing cycle , a total of 2,573 units have been completed or are expected to be completed from the projects identified in the quantified objectives . The following two tables summarize the quantified objectives from the last Housing Element Update and detail the City’s progress in achieving those objectives.

Table 16: Quantified Objectives, 2015 - 2022
Conservation/Preservation Total ELI VLI LI MOD
Lesley Park Towers 200 200
Humboldt House 9 9
Sub Total 209 0 209 0 0

New Construction Total ELI VLI LI MOD
2000 S. Delaware 60 60

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New Construction Total ELI VLI LI MOD
Bay Meadows Affordable Site 60 20 40
Bay Meadows BMR 65 25 40
Station Park Green BMR 60 60
Other BMR 150 45 25 80
Other Affordable TBD 85 30 45 10
Sub Total 480 50 190 60 180
AFFORDABLE TOTAL 689 50 399 60 180
Private Sector/Market Rate 2,475
GRAND TOTAL 3,164

Table 17: Quantified Objective Actuals, 2015 – 2022*
Conservation/Preservation Total ELI VLI LI MOD
Lesley Park Towers 200 200
Humboldt House 9 9
1110 Cypress 7 7
Sub Total 216 0 209 7 0

New Construction Total ELI VLI LI MOD
2000 S. Delaware 60 60
Bay Meadows Affordable Site 67 14 36 17
Bay Meadows BMR 54 31 23
Station Park Green BMR 60 60
Other BMR 117 82 23 12
Other Affordable (Kiku Crossing) 223 43 45 135
Sub Total 581 57 223 206 95
AFFORDABLE TOTAL 797 57 432 213 95
Private Sector/Market Rate 1,776
GRAND TOTAL 2,573
*Information is current as of January 2022. Final housing numbers for the 8th year of the 2015-2022 cycle will be tabulated with the City’s APR that will be submitted by April 1, 2023.

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APPENDIX A

NEEDS ANALYSIS

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APPENDIX A | NEEDS ANALYSIS

0.1 Table of Content

0.1 Table of Content .................................................................................................................................................... 2

0.2 List of Figures ......................................................................................................................................................... 2

0.3 List of Tables .......................................................................................................................................................... 4

0.4 List of Attachments ................................................................................................................................................ 4 1 Introduction ........................................................................................................................................................... 5 2 Summary of Key Facts ............................................................................................................................................. 6 3 Looking to the Future: Regional Housing Needs ...................................................................................................... 9

3.1 Regional Housing Needs Determination ................................................................................................................ 9

3.2 Regional Housing Needs Allocation ..................................................................................................................... 10 4 Population, Employment and Household Characteristics ...................................................................................... 11

4.1 Population ........................................................................................................................................................... 11

4.2 Age ....................................................................................................................................................................... 12

4.3 Race and Ethnicity ............................................................................................................................................... 14

4.4 Employment Trends ............................................................................................................................................. 15

4.4.1 Balance of Jobs and Workers ...................................................................................................................... 15

4.4.2 Sector Composition ..................................................................................................................................... 19

4.4.3 Unemployment ........................................................................................................................................... 20

4.5 2018-2028 Occupation Projections ...................................................................................................................... 21

4.6 Extremely Low-Income Households ..................................................................................................................... 22

4.7 Tenure .................................................................................................................................................................. 27

4.8 Displacement ....................................................................................................................................................... 30 5 Housing Stock Characteristics ............................................................................................................................... 32

5.1 Housing Types, Year Built, Vacancy, and Permits ................................................................................................ 32

5.2 Assisted Housing Developments At-Risk of Conversion ....................................................................................... 35

5.3 Substandard Housing ........................................................................................................................................... 36

5.4 Home and Rent Values......................................................................................................................................... 37

5.5 Housing Affordability ........................................................................................................................................... 41

5.5 Overpayment and Overcrowding ......................................................................................................................... 43 6 Special Housing Needs .......................................................................................................................................... 53

6.1 Large Households ................................................................................................................................................ 53

6.2 Female-Headed Households ................................................................................................................................ 54

6.3 Seniors ................................................................................................................................................................. 55

6.4 People with Disabilities ........................................................................................................................................ 56

6.5 Homelessness ...................................................................................................................................................... 59

6.6 Farmworkers ........................................................................................................................................................ 66

6.7 Non-English Speakers .......................................................................................................................................... 68

0.2 List of Figures
Figure 1: Population Growth Trends ........................................................................................................... 12 Figure 2: Population by Age, 2000-2019 ..................................................................................................... 13

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Figure 3: Senior and Youth Population by Race .......................................................................................... 13 Figure 4: Population by Race, 2000-2019 ................................................................................................... 14 Figure 5: Jobs in a Jurisdiction .................................................................................................................... 15 Figure 6: Workers by Earnings, by Jurisdiction as Place of Work and Place of Residence ......................... 16 Figure 7: Jobs-Worker Ratios, By Wage Group ........................................................................................... 17 Figure 8: Jobs-Household Ratio .................................................................................................................. 18 Figure 9: Resident Employment by Industry ............................................................................................... 19 Figure 10: Resident Employment by Occupation ....................................................................................... 20 Figure 11: Unemployment Rate .................................................................................................................. 21 Figure 12: Households by Household Income Level ................................................................................... 23 Figure 13: Household Income Level by Tenure ........................................................................................... 25 Figure 14: Poverty Status by Race ............................................................................................................... 26 Figure 15: Housing Tenure .......................................................................................................................... 27 Figure 16: Housing Tenure by Race of Householder ................................................................................... 28 Figure 17: Housing Tenure by Age .............................................................................................................. 29 Figure 18: Housing Tenure by Year Moved to Current Residence .............................................................. 29 Figure 19: Housing Tenure by Housing Type .............................................................................................. 30 Figure 20: Households by Displacement Risk and Tenure .......................................................................... 31 Figure 21: Housing Type Trends .................................................................................................................. 32 Figure 22: Housing Units by Year Structure Built ........................................................................................ 33 Figure 23: Vacant Units by Type ................................................................................................................. 34 Figure 24: Substandard Housing Issues ...................................................................................................... 36 Figure 25: Home Values of Owner-Occupied Units .................................................................................... 38 Figure 26: Zillow Home Value Index (ZHVI) ................................................................................................ 39 Figure 27: Contract Rents for Renter-Occupied Units ................................................................................ 40 Figure 28: Median Contract Rent ................................................................................................................ 41 Figure 29: Cost Burden by Tenure .............................................................................................................. 44 Figure 30: Cost Burden by Income Level ..................................................................................................... 45 Figure 31: Cost Burden by Race .................................................................................................................. 47 Figure 32: Cost Burden by Household Size ................................................................................................. 48 Figure 33: Cost-Burdened Senior Households by Income Level ................................................................. 49 Figure 34: Overcrowding by Tenure and Severity ...................................................................................... 50 Figure 35: Overcrowding by Income Level and Severity ............................................................................. 51 Figure 36: Overcrowding by Race ............................................................................................................... 52 Figure 37: Household Size by Tenure .......................................................................................................... 53 Figure 38: Housing Units by Number of Bedrooms .................................................................................... 54 Figure 39: Household Type ......................................................................................................................... 54 Figure 40: Female-Headed Households by Poverty Status ......................................................................... 55 Figure 41: Senior Households by Income and Tenure ................................................................................ 56 Figure 42: Disability by Type ....................................................................................................................... 57 Figure 43: Homelessness by Household Type and Shelter Status, San Mateo County .............................. 60

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Figure 44: Racial Group Share of General and Homeless Populations, San Mateo County ....................... 61 Figure 45: Latinx Share of General and Homeless Populations, San Mateo County .................................. 62 Figure 46: Characteristics for the Population Experiencing Homelessness, San Mateo County ................ 63 Figure 47: Farm Operations and Farm Labor by County, San Mateo County ............................................. 67 Figure 48: Population with Limited English Proficiency .............................................................................. 68

0.3 List of Tables
Table 1: State Income Limits for San Mateo County, 2022 .......................................................................... 9 Table 2: Final Regional Housing Needs Allocations .................................................................................... 10 Table 3: Population Growth Trends ............................................................................................................ 11 Table 4: Occupations with the Most Job Openings, 2018-2028 ................................................................. 21 Table 5: Household Distribution by Race/Ethnicity and Income ................................................................ 24 Table 6: Housing Permitting ........................................................................................................................ 34 Table 7: Assisted Units at Risk of Conversion ............................................................................................. 35 Table 8: Age of Housing Stock and Estimated Rehabilitation Needs .......................................................... 37 Table 9: Housing Opportunity Index, First Quarter 2021 ........................................................................... 42 Table 10: Housing Affordability by Zip Code ............................................................................................... 42 Table 11: Affordable Rents for Two- and Three-Person Households ......................................................... 43 Table 12: Quantified Cost Burden of Low-Income Households by Tenure ................................................. 46 Table 13: Population with Developmental Disabilities by Age ................................................................... 58 Table 14: Population with Developmental Disabilities by Residence ......................................................... 59 Table 15: Students in Local Public Schools Experiencing Homelessness .................................................... 64 Table 16: Migrant Worker Student Population .......................................................................................... 66

0. 4 List of Attachment s
▪ Countywide Housing Needs
▪ Inventory of Assisted Units

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1 INTRODUCTION
The Bay Area continues to see growth in both population and jobs, which means more housing of various types and sizes is needed to ensure that residents across all income levels, ages, and abilities have a place to call home. While the number of people drawn to the region over the past 30 years has steadily increased, housing production has stalled, contributing to the housing shortage that communities are experiencing today. In many cities, this has resulted in residents being priced out, increased traffic congestion caused by longer commutes, and fewer people across incomes being able to purchase homes or meet surging rents.

The 2023-2031 Housing Element Update provides a roadmap for how to meet our growth and housing challenges. Required by the state, the Housing Element identifies what the existing housing conditions and community needs are, reiterates goals, and creates a plan for more housing. The Housing Element is an integral part of the General Plan, which guides the policies of San Mateo.

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2 SUMMARY OF KEY FACTS
• Population – Generally, the population of the Bay Area continues to grow because of natural growth and because the strong economy draws new residents to the region. The population of San Mateo increased by 11.5% from 2000 to 2020, which is below the growth rate of the Bay Area. • Age – In 2019, San Mateo’s youth population under the age of 18 was 21,827 and senior population 65 and older was 16,093. These age groups represent 20.9% and 15.4%, respectively, of San Mateo’s population.
• Race/Ethnicity – In 2020, 40.9% of San Mateo’s population was White while 1.9% was African American, 26.2% was Asian, and 25.1% was Latinx. People of color in San Mateo comprise a proportion below the overall proportion in the Bay Area as a whole.0F0F 1 • Employment – San Mateo residents most commonly work in the Financial & Professional Services industry. From January 2010 to January 2021, the unemployment rate in San Mateo decreased by

3.6 percentage points. Since 2010, the number of jobs lo cated in the jurisdiction increased by 16,810 (42.7%). Additionally, the jobs -household ratio in San Mateo has increased from 1.17 in 2002 to 1.45 jobs per household in 2018.
• Number of Homes – The number of new homes built in the Bay Area has not kept pace with the demand, resulting in longer commutes, increasing prices, and exacerbating issues of displacement and homelessness. The number of homes in San Mateo increased, 3.6% from 2010 to 2020, which is below the growth rate for San Mateo County and below the growth rate of the region’s housing stock during this time period.
• Home Prices – A diversity of homes at all income levels creates opportunities for all San Mateo residents to live and thrive in the community.
– Ownership The largest proportion of homes had a value in the range of $1M -$1.5M in 2019. Home prices increased by 115.6% from 2010 to 2020. – Rental Prices – The typical contract rent for an apartment in San Mateo was $2,380 in 2019. Rental prices increased by 74.2% from 2009 to 2019. To rent a typical apartment without cost burden, a household would need to make $95,240 per year.1F1F 2 1 The Census Bureau’s American Community Survey accounts for ethnic origin separate from racial identity. The numbers reported here use an accounting of both such that the racial categories are shown exclusive of Latinx status, to allow for an accounting of the Latinx population regardless of racial identity. The term Hispanic has historically been used to describe people from numerous Central American, South Americ an, and Caribbean countries. In recent years, the term Latino or Latinx has become preferred. This report generally uses Latinx, but occasionally when discussing US Census data, we use Hispanic or Non - Hispanic, to clearly link to the data source.
2 Note that contract rents may differ significantly from, and often being lower than, current listing prices.