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Agenda packet, regular meeting

San Mateo City Council
May 20, 2024

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Agenda packet, regular meeting
Meeting
May 20, 2024
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San Mateo City Council
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22
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Text extracted from the city's file for reading and search. Open the original on sanmateo.primegov.com. That file is the official record.

AND HOUSING NEEDS WORKSHOP SPEAKER NOTES
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CRC 9/29/2021 – meeting notes
Speaker notes (in order of speaker):

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

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

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

4. A regional center client of Housing Choice: Speaking as a representative of someone with developmental disabilities, the city has a hammer to make developers build affordable housing and should use it wisely and firmly. Cities need to ask the following questions: 1) If there are $5,000/month units, why not have 1-2 units for $1,000-2,000/month? 2) Where are people supposed to park? His place has a fire hydrant in front of the building, so there is no ability for handicapped parking or loading zone for residents/people with disabilities. 1015 of 2271
CITY OF SAN MATEO 2031 HOUSING ELEMENT
Appendix H-F
SAN MATEO COUNTYWIDE HOUSING ELEMENTS LISTENING SESSIONS – SUMMARY NOTES 1016 of 2271

1 MEETING SUMMARY A
Countywide Stakeholder Listening Session #1: Fair Housing 9/27/2021, 1-2:30 pm on Zoom
Overview
On September 27, 2021, 21 Elements hosted the first of four housing element stakeholder listening session with several organizations focused on fair housing issues. Presenters, resources and details on what we heard follow.

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

Policies & Programs to consider:
x More funding for subsidized affordable housing near transit or good access to transit x Stronger just cause protections
x Rent stabilization and rent registries as a tool
x Tenant and community first right of purchase or right of first refusal (TOPA and COPA) x Creation of more ADUs and program to increase access for lower-income people Stakeholder Presenters & Additional Resources
Organization Speaker Name Contact
Center for Independence of
Individuals with Disabilities
Benjamin McMullan, Systems
Change Advocate
[email protected]
Community Legal Services
of East Palo Alto (CLSEPA)
Michelle Trejo—Saldivar, Law
Fellow, Housing Program
[email protected]
Housing Equality Law
Project
Mary Prem, Executive Director [email protected] Legal Aid for San Mateo
County
Shirley Gibson, Directing Attorney [email protected] Project Sentinel Ann Marquart, Executive Director [email protected] Housing Choices Jan Stokley, Executive Director
Kalisha Webster, Housing Advocate
(presented at a prior meeting)
[email protected]
[email protected]
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2 Public Interest Law Project Michael Rawson, Director, (unable to attend)
[email protected]
Root Policy Research AFFH
consultant to 21E
Heidi Aggeler, Managing Director [email protected]
Jurisdictions in Attendance
Belmont Millbrae San Mateo (County)
Brisbane Pacifica South San Francisco
Burlingame Portola Valley Woodside
Daly City Redwood City
East Palo Alto San Bruno California Department of
Half Moon Bay San Carlos Housing and Community
Menlo Park San Mateo (City) Development (HCD)
Key Themes and Actions
x Eviction Moratorium: There was widespread concern about what will happen when the California eviction moratorium ends on October 1, 2021. Just Cause eviction ordinances and Covid rent relief (especially for back rent) have been important to keep people in their homes.

CLSEPA shared a flyer after the session with a summary of renters’ rights and resources. x Vulnerable Populations: The stakeholder groups shared several details about the housing needs of the most vulnerable populations.
o People with disabilities experience the most housing discrimination. Legal assistance organizations get the most calls regarding discrimination against people with and find it is the most misunderstood category.
o Displacement disproportionately affects Latinx, African American/Black households and families with children.
o Many or most evictions are no-fault evictions, not resulting from a failure to pay rent. x Anti-Displacement Policies: Jurisdictions were curious about which anti-displacement policies were favored by the stakeholder groups.
o Affordable housing: More subsidized affordable housing is needed. Stakeholders noted that it is key to locate affordable housing in places located on transit or with good access to transit.
o Just Cause protections, rent stabilization: While there are some baseline protections at the state level, they need to be strengthened. The rent gauging gap does not go far enough to protect lower-income households.
o TOPA and COPA: Currently, there is significant interest in Tenant and Community Opportunity to Purchase Act policies that give tenants and nonprofits a first right to purchase or a right of first refusal when a property goes on the market. 1018 of 2271

3 o Rent registries: Stakeholders noted that a rental registry is important in order to obtain data that can be used to inform anti-displacement policies, but it is not an antidisplacement policy on its own. o Section 8 vouchers: Stakeholders noted that while vouchers can provide opportunities for lower-income households to live or remain in the county, there are not enough vouchers to meet the need. In addition, vouchers have resulted in some concentration of low-income households in areas with less economic and educational opportunity. o Accessory dwelling units: ADUs are a great housing solution in the suburbs, as they provide suburb-appropriate density along with a good quality of life and provide more affordable options without requiring subsidy.
x Accessibility: Cities’ housing elements typically only have the minimum standard/generic language for accessibility. Some of the participating jurisdictions indicated an interest in doing more and are looking for examples of cities going beyond what is required. o Cities should be prominently promoting organizations working with tenants. City websites get the most visibility out of any form of advertisement/media o Jurisdictions were very interested in data that quantifies the existing supply of accessible housing and the demand for accessible housing. o Stakeholders suggested that affordability and accessibility must be considered together. o Transit-friendly locations are key for people with disabilities. o Stakeholders noted that “visitability” policies – making sure homes allow for access to those who are visiting – are less common today and should be considered. Consider requiring some degree of accessibility and visitability in new homes. o Lack of accessibility requirements for new townhomes were a point of concern. x Reasonable Accommodation: The speakers indicated that there is widespread confusion about the meaning of reasonable accommodation. They shared ideas that could help educate residents and landlords.
o Building departments should be posting reasonable accommodations policies. o Education for and outreach to apartment managers, property owners and homeowner associations is needed.
x Ideas for Action:
o Perform an audit of each jurisdiction website for reasonable accommodation policies. o Improve jurisdiction websites to give a more prominent platform to organizations that work with tenants on fair housing issues.
o Create a program to rent ADUs to people who need housing (run by HIP Housing?). o Look at SB 9 and how it may increase the # of duplexes (will they be accessible?). o Identify cities that go beyond the standard accessibility language in housing elements. o Find data that quantifies the need for accessible housing (and the existing supply). 1019 of 2271

4 Appendix: Raw Notes
Room 1 (Josh) Notes:

Ben McMullan – CIID

1. Areas that can use work

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

3. All new construction be accessible and visitable

4. Encourage more ADUs

5. Funding for home repairs for people with disability

6. Affordability

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

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

1. Tenant landlord

2. Mediation

3. Special emphasis

4. More visibility for fair housing

5. Make it clear how to make it more visible

6. Post reasonable accommodation

7. Most complaints about discrimination of disability

8. Reforms coming to service/companion animals rules

9. Companion animals have same civil rights protections

10. Many property owners do not understand laws

11. The lack of affordable housing

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

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

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

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

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

4. Had the benefit of expanded just cause for 18 months. Been helpful. 1020 of 2271

5 5. Goals – strengthen no fault protections

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

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

8. Covid rules did not cause the sky to fall

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

10. Time limited vouchers less useful

11. Make sure there are not group home discrimination

12. Post reasonable accommodation clearly
Michele – CLESPA

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

2. Better rent stabilization

3. COPA/TOPA – Help displacement
Room 2 (Kristy) Notes:
x Ben McMullan - Center for Independence of Individuals with Disabilities o Advocate with housing, also look at transportation and health care issues o Biggest issues: Lack of affordable, accessible housing o Like to encourage affordable housing
o On transit lines, near transit
o Q from Nancy - with more power shutoffs, fire evacuation, etc. happening these days, for units not on the 1st floor, how is that being addressed? ƒ PSPS (Public Safety Power Shutoff) program where help distribute backup power packs for people dependent on power
x Ann Marquart - Project Sentinel
o More affordable housing
o Disability is the protected category that they get the most calls about, and is the most misunderstood
o Want housing next to transportation
o Protected categories
ƒ Race
ƒ National origin
ƒ Gender
ƒ Families
ƒ Section 8 (NEW)
ƒ There is now fair housing protection for Section 8
ƒ But concern is that there are not enough certificates to go around, years of waiting lists, etc.
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6 ƒ Criminal history (is a little different)
o Q from Jennifer Rose: would be beneficial to all of the cities if you came up with collective wish-list of actions! Funding, help with promotion, policies, etc. ƒ Ann: Promote fair housing groups in big letters on a lot of city websites, give agencies a bigger platform
ƒ For example, for first-time homebuyer training in San Jose, the only promotion was a notice on the city’s website, and it became clear that people go to city websites for information! Distributing flyers, holding zoom workshops - can only go so far, reach some people. ƒ Suggestion: “How can we promote project sentinel”
ƒ HIP housing helped write language in last housing element (?) x Mary Prem - Housing Equality Law Project
o Full service
ƒ Focused on unserved or underserved areas
ƒ Investigate complaints
ƒ Counsel tenants
o Accessible housing
ƒ Not just accessibility but visitability
ƒ New construction (townhomes)
o Housing solutions for people seeking reentry
ƒ Worked with SF city and human rights commission on “unchecking the box” o Add more ADUs
ƒ housing is such a scarcity
ƒ More affordable solution
ƒ Greater life experience for people living in suburbs, not as dense o Really important that accessible housing is located near transit x MIchelle Trejo-Saldivar - Community Legal Services of East Palo Alto (CLSEPA) o San Mateo County, plus Mountain View
o Especially serve low income, very low income, LatinX
o Housing needs: stronger rent stabilization policies, just cause protections ƒ There is a state just cause and rent control, but there is a need for stronger policies
ƒ TOPA and COPA policies, other anti-displacement policies o Low income populations know where they will find affordable housing and where they will not: Recommendation jurisdictions take a look at where LI and VLI people live - they should only be paying 30% of income - where should we be pushing more affordable housing development
x Shirley GIbson - Legal Aid of San Mateo County
o Similar mission and population served as CLSEPA
ƒ But only San Mateo County
ƒ The 2 organizations share information across 2 organizations (Tableau), lots of data at fingertips
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7 o Why are these policies necessary from fair housing standpoint ƒ Displacement falls squarely and disproportionately on Black and Latinx households, households with children
ƒ Disproportionality is even bigger when you look at no-fault termination evictions (not failure to pay rent)
o Biggest barriers to housing choice?
ƒ We heavily rely on housing choice vouchers - unfortunately have managed to isolate and concentrate those tenants in areas of low economic and educational opportunity
ƒ We must take take areality check: time-limited vouchers that transition people from homelessness to permanent opportunity are not working. It’s a revolving door because there isn’t enough time to stabilize households ƒ Look at how housing vouchers are administered and distributed o Note that while a rent registry is an interesting source of data, and it is great to have more info, it is NOT a anti-displacement policy in itself. Can use the data (which is better if you require data from landlords) to inform and structure more robust antidisplacement policies: looking at turnover, tenancy, how often, why Room 3 (Vu-Bang) Notes:
x Mary Prem, Housing Equality Law Project
o Visitable housing units with accessibility on the ground floor unless there’s an elevator to other floors
o Serve areas that are deemed unserved, areas not covered by fair housing o Investigate fair housing complaints
o Training housing providers for more affordable housing o Collaborate with UC Berkeley - race studies in high school o City of SF- unchecking the box - re-entry housing programs, previously incardinated o Reasonable accommodations denial and other accessibility issues are most common work
o New construction, esp around transportation hub - housing that’s in townhome and not “visitable” (no toilet in common area, no elevators)
o Affordability and availability biggest concern - ADU units encouraged o Topic brought up with jurisdictions but haven’t seen adopted o Affordability and availability for housing
o Congestion on highways and accessibility in hubs
x Michelle Trejo-Salvidar
o Just Cause protections - provide tenants with their rights when tenant gets notice x Shirley Gibson
o Be wary of full scale models of Just Cause - can pick and choose from model ordinances to shore up the weak Just Cause ordinances
x Ann Marquart, Project Sentinel
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8 o Disability and familial status got the most complaints - reasonable modifications, can go to CID to pay for modifications, VA will pay for some of those repairs. Reasonable Accommodations - companion/service animals (anyone giving the certificate now has to note how many hours of therapy), different parking space, reminder to pay the rent, o Policies: wishlist - something to project tenants after the moratoriums and now focused on back rents
o Something (not rent control) - new housing near transportation o Education - getting word out to housing providers, raise Project Sentinel to larger visibility so people can find them
o What cities have the best visibility to Project Sentinel - will follow up. o Section 8 renters - no discrimination
o Landlord should not evict everyone in the household after domestic disturbances x Ben Mcmullan
o Systems change for Center for Independence of Individuals with Disabilities o San Bruno, SSF, County offices
o Visitability - wheelchair and mobility devices can adequately visit. Not many obstacles on different levels - Home Modification Program that people can take advantage of.

Having new housing be accessible from the get-go
o Plug for transit oriented housing - people with disabilities face needing housing and transit.
o Explore transit oriented housing - vastly great step forward o Paratransit coordinating chair on SamTrans and CalTrain accessibility advisory committee
o Biggest barriers to housing for vulnerable households - affordable and accessible housing. If it's affordable and not accessible, it only goes so far, and vice versa. x Burlingame - has standard language on accessibility - want to know what language to use to go above and beyond. Townhouse units esp have concerns with. Set up well for TOD, but linking TOD + Accessibility + Affordability . SB9 - two flats or 2 townhouses preferred when it comes to accessibility.
x Hillsborough – language is generic, actual implementation only on ADUs, but predominantly single family housing. Transportation corridor only on El Camino Real and ½ mile from Burlingame Caltrain station.
x Jan (HCC): Physical accessibility is not the only type of accessibility barrier--I am thinking of people with cognitive disabilities--they shouldn't be left out of the discussion. 1024 of 2271

1 MEETING SUMMARY A
Countywide Stakeholder Listening Session #2: Housing Advocates 10/18/2021, 1-2:30 pm on Zoom
Overview
On October 18, 2021, 21 Elements hosted the second of four housing element stakeholder listening sessions with housing advocacy organizations. A majority of 21 E jurisdictions attended the listening session. Five stakeholder advocate groups introduced themselves and spoke about their group’s interest in the Housing Element process. Detailed information about speakers and attending jurisdictions is below and in the appendix.

Key themes included:
x Ongoing outreach needed to underserved and diverse communities x Production of new housing is critical to the SMC workforce o Greatest need for deeply affordable housing, dense, infill x Connecting labor, environment and equity to housing
x Rent increases are a primary concern
x Protecting vulnerable renting populations with assistance from the governments Policies & Programs to consider:
x Additional funding for affordable housing through commercial linkage fees, inclusionary zoning, vacancy tax, sales tax, etc.
x Protections: eviction assistance, anti-harassment measures, stronger just cause, tenant right-to return, relocation assistance, improvements to the building inspection process, rental registries as a tool
x Production: Increase density within existing communities in non-high fire severity zones, eliminating harmful restrictions on density, eliminating parking minimums, streamlining housing building process, fair and inclusive zoning policies
x Prioritize BIPOC families in housing policies, outreach and practice (all stages of the practices) x Manage the threat of climate risk by adding green infrastructure.

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2 Stakeholder Presenters & Additional Resources
Organization Speaker Name Contact
Housing Leadership Council Angela Solis [email protected] Faith in Action Nani Friedman [email protected]
Greenbelt Alliance Zoe Siegel [email protected]
San Mateo County Central
Labor Council
Rich Hedges [email protected]
Peninsula for Everyone Jordan Grimes [email protected] San Mateo County Association
of Realtors
Gina Zari (invited, unable to
attend)
[email protected]
Learn more about Greenbelt Alliance’s endorsement program: https://www.greenbelt.org/climatesmart-development-endorsement-program/ Learn more about Greenbelt Alliance’s Resilience Playbook: https://www.greenbelt.org/resilienceplaybook/ Full list of Greenbelt Climate Policies can be found in the draft housing element playbook (under policies tab) https://coda.io/@gazoe-siegel/housing-element-toolkit For those who wish to learn more about the focus groups in Redwood City that Trinidad from Faith in Action mentioned,, you can read the report here (posted on the City of Redwood City website):
https://www.redwoodcity.org/home/showpublisheddocument/23755/637623096709130000 Faith in Action supported with two other reports (tenant protections and preservation), found here:
https://www.redwoodcity.org/departments/city-manager/housing-services/housing-policies/antidisplacement-strategic-plan Note Faith in Action works mostly with renter leaders in Daly City, San Mateo and Redwood City, but they have a presence in several other cities in the county as well.

Jurisdictions in Attendance:

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

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3 Key Themes and Actions:

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

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

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4 Appendix: Additional Stakeholder Information & Input
o Housing Leadership Council: Angela Solis
ƒ Network of organizers to support affordable housing
ƒ Advocating for and preserving affordable housing
ƒ Greatest need:
ƒ Deeply affordable homes
ƒ Focused on funding for affordable homes with example policies:
ƒ Commercial linkage fees
ƒ IZ, vacancy tax, sales tax, etc.
ƒ Seeking greater outreach from jxs for Housing Element process- window into populations
o Faith in Action Bay Area: Trinidad Villagomez
ƒ Focus in Redwood City
ƒ Community organizers, leaders working in congregations schools, neighborhoods and apartments across SMC to uphold dignity of all people ƒ Listening to community experiences with housing (phone calls, door knocking, church involvement, people at food distribution sites)
ƒ What the group heard from the community:
x Poor building conditions, harassment, discimination, rent increases, fear to speak to authorities, difficulty relocated, evictions for renovations and owner move in, unclear how to enforce existing rental rights, pandemic insecurity, rental debt, financial hardship, credit limitations, application fees
ƒ From focus groups:
x Rent increase is the majority primary issue
ƒ Vision:
x Regulations on eviction due to renovations
x Preventing harassment of tenants
x Partnership with city to work with tenants and landlords as a mediator o City to inspect buildings
o Rental assistance
o Process relocation assistance
o Report rent increases, eviction notices, their business license and taxes
o Education for tenant about rights
ƒ Policies:
x Stronger just cause policy (define substantial renovation) and give tenants right to return (right of first refusal)
x Stronger relocation assistance administered by the city x Improvements to the building inspection process, with greater confidentiality with the tenant
x Rental registry program by city-tenant/landlord office x Anti-harassment policy
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5 ƒ More information:
https://www.redwoodcity.org/home/showpublisheddocument/23755/6376230 96709130000
o Greenbelt Alliance: Zoe Siegel
ƒ Inclusive, climate resilient communities for all to thrive ƒ Housing and climate are linked
ƒ Advocating for climate smart development
o SMART: Sustainable, Mixed, Affordable, Resilient, TransitOriented development x Resilience Playbook
o Resources for local decision-makers and community leaders with policies, model ordinances, etc.
ƒ Ensure fair and inclusive zoning policies that makes housing accessible to everyone
x Prioritize BIPOC families in housing policies, outreach and practice (all stages of the practices)
x Advance racial and social equity in process
ƒ Increase density within existing communities in non-high fire severity zones ƒ Manage the threat of climate risk by adding green infrastructure. x Prepare for climate impacts, require nature-based solutions for climate resilience
o San Mateo County Labor Council: Richard Hedges
ƒ Advocate for increased outreach
ƒ Increases for min. wage, building of housing for all workers (safe and affordable) ƒ Builders: getting the work/pay required to live in San Mateo County (can afford to rent/own home)
x Service workers are struggling to live in SMC (especially retail pay) ƒ Advocated for housing built at Bay Meadows, advocated for 10% inclusive ƒ State law to allow for more density for affordable housing ƒ Qualified workforce is critical
ƒ Removing barriers for Section 8 voucher holders
o Peninsula for Everyone: Jordan Grimes
ƒ Frustration with lack of dense infill housing in SMC
ƒ Member engage in local project advocacy, and planning meetings and are politically active at the local and state level
ƒ Huge housing shortage in the county, decades of underbuilding ƒ Focus on as much being built as quickly as possible
ƒ 3 Ps of housing policy, preservation, production, protection (interested in rental registries, want more rent data)
x Protection: Rent control, right to counsel with the eviction process x Production: eliminating harmful restriction on density, parking min, streamlining housing building process
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1 MEETING SUMMARY A
Countywide Stakeholder Listening Session #3: Builders/Developers 11/1/2021, 1-2:30 pm on Zoom
Overview
On September 27, 2021, 21 Elements hosted the third of four housing element stakeholder listening sessions with housing developers and builders, including both affordable housing developers and market-rate housing developers. Detailed information about speakers and attending jurisdictions is below.

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

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2 Stakeholder Presenters & Additional Resources
Organization Speaker Name Contact
MidPen Housing
(Affordable)
Abby Goldware Potluri [email protected]
HIP Housing
(Affordable)
Kate Comfort [email protected]
BRIDGE Housing
(Affordable)
Brad Wiblin [email protected]
Mercy Housing
(Affordable)
William Ho [email protected]
Habitat for Humanity—
Greater SF
(Affordable)
Maureen Sedonaen [email protected]
Eden Housing
(Affordable)
Ellen Morris [email protected]
Affirmed Housing
(Affordable)
Rob Wilkins [email protected]
The Core Companies
(Affordable, Market
Rate)
Chris Neale [email protected]
Sand Hill Property
Company (Affordable,
Market Rate)
Candice Gonzalez (invited,
unable to attend)
[email protected]
Sares | Regis
(Market Rate)
Andrew Hudacek (invited,
unable to attend)
[email protected]
Summerhill Apartment
Communities
(Market Rate)
Elaine Breeze [email protected]
Greystar
(Market Rate)
Jonathan Fearn [email protected]
Jurisdictions in attendance:

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

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3 Roundtable Discussion Questions/Answers
Affordable Housing Developers

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

11. What are ways that you think jurisdictions could facilitate the development of moderate and middle income housing?
o Projects with JPA programs
o Property tax relief for moderate-income units
o Once upon a time, market-rate housing delivered housing for middle income households, we just don’t have a lot of housing opportunities. Restricting supply doesn’t restrict demand. Allow more housing generally
o Access to specialized loan products and property tax incentives would help with middle income housing
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1 MEETING SUMMARY A
Countywide Stakeholder Listening Session #4: Service Providers 11/15/2021, 1-2:30 pm on Zoom
Overview
On November 15, 2021, 21 Elements hosted the fourth of four housing element stakeholder listening sessions with San Mateo County service providers. Detailed information about speakers (see appendix for organizational information) and attending jurisdictions is below.

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

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2 Stakeholder Presenters & Additional Resources
Organization Speaker Name Contact
Daly City Partnership
(one of San Mateo
County’s Core Agencies)
Marya Ouro-Gbeleou [email protected]
HIP Housing Laura Moya [email protected]
LifeMoves Jacob Stone [email protected]
Mental Health
Association of San
Mateo County
Melissa Platte [email protected]
National Alliance on
Mental Illness
Michael Lim [email protected]
Ombudsman of San
Mateo County
Bernadette Mellott [email protected]
Samaritan House San
Mateo (one of San
Mateo County’s Core
Agencies)
C. LaTrice Taylor [email protected]

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

Roundtable Discussion Questions/Answers

1. We assume that transit-oriented or transit accessible housing is important. Are there any other location characteristics that you would highlight are important for the people you serve? o Mental Health Association – access to transit, medical care, grocery stores, pharmacy o Daly City Partnership – in Daly city all services are sited in the govt center by design, so housing should either be close to it or have direct transit access o Youth Leadership Institute – parks within or near housing developments are important to young people, new community centers or access to existing ones, high walkability o HIP Housing – agree with all mentioned, near schools for family housing, senior centers for senior housing
o National Alliance on Mental Illness – justice-informed community (people who have experience with law enforcement, ranging from a 5150 call or involuntary hold to being incarcerated in jail or prison system) need access to services 1038 of 2271

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

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

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

4. Do affordable units need to be designed in a certain way or certain size to meet the needs of the people you serve?
o Mental Health Association – definitely need more units that are available for people with physical disabilities. Serve people with serious mental illness, HIV/AIDS debilitating conditions, etc. It used to be that they would die far younger than most, but now people are now living into 60s-70s-80s. This is great but long-term effects of medications have impact on their bodies, put them at greater risk for falls, etc. Mostly studios and 1BRs (preferred), closets and storage in the unit are critical o Youth Leadership Institute – serve young people – in Half Moon Bay they are seeing 3 HH living in one unit, looking to advocate for pathway to homeownership, also single family housing (3BR/2BA). Want as much space as possible, spacious living areas. 1039 of 2271

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

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

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

7. Are there options for people that have animals?
o Mental Health Association - Most of our clients can have an animal as long as we work with them to request a reasonable accommodation. 100% of our units can and will make the accommodation.
o National Alliance on Mental Illness – pets are huge thing for our clients, not only with soothing them but also creating a sense of responsibility, gives them second thoughts when they are thinking of ending their lives
o HIP Housing – it is still a big barrier in affordable housing when their pet is not a service or supportive animal. Many people have more than one pet which is also a barrier. 1041 of 2271

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

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

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

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

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

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

OSSMC works to ensure the protection of these residents through advocacy, direct intervention and collaboration with service providers.
x Where you operate: OSSMC provides services to all licensed LTC facilities in San Mateo County. x Whom you serve: We service all residents in licensed LTC facilities in SMC. We presently serve 442 facilities with a total of 9278 residents
El Concilio of San Mateo County
x Mission: ECSMC is committed to increasing education, employment and access to quality of life services to underserved communities in San Mateo County x Where you operate: County wide, East Palo Alto, Menlo Park, North Fair Oaks/Redwood City x Whom you serve: Low Income, non/limited English speaking and non/limited literacy residents Abode Services
x Mission: Abode Services' mission is to end homelessness by assisting low-income, un-housed people, including those with special needs, to secure stable, supportive housing; and to be advocates for the removal of the causes of homelessness. x Where you operate: Alameda, Santa Clara, San Francisco, Santa Cruz, San Mateo, and Napa counties.
x Whom you serve: People identified as homeless or at risk of becoming homeless 1044 of 2271
CITY OF SAN MATEO 2031 HOUSING ELEMENT
Appendix H-F
ROOT POLICY FAIR HOUSING SURVEY SUMMARY – SUMMARY OF PUBLIC FEEDBACK 1045 of 2271
ROOT POLICY RESEARCH CITY OF SAN MATEO RESIDENT SURVEY, PAGE 1 City of San Mateo Resident Fair Housing
Survey Preliminary Results
As of January 20, 2022, the San Mateo County Fair Housing Survey has gathered 108 responses from residents in the City of San Mateo. Main findings are listed below.

Top challenges in housing situation.

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

Top challenges in paying for housing:

I can’t keep up with my utilities (15%);
I can’t keep up with my property taxes (12%).

Top challenges in neighborhood:

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

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

Availability of housing. Seventy-three respondents have looked for housing seriously in the past five years of those, 17 (24%) indicated that a “Landlord did not return calls and/or emails asking about a unit”, and 31 (44%) indicated they have been denied housing to rent or buy in San Mateo County in the past 5 years. The main reason for denial (37%) was “income too low.”
Voucher holders. The survey gathered responses from 25 voucher holders. The majority (77%) indicated that finding an affordable unit is somewhat or very difficult. Six of them indicated this is due to “Landlords have policies of not renting to voucher holders.” 1046 of 2271
ROOT POLICY RESEARCH CITY OF SAN MATEO RESIDENT SURVEY, PAGE 2 Residents with a disability. Twenty-seven percent of respondents indicated having a disability or having a member of their household with a disability. Seventy-five percent indicated their home does not meet the needs of their household member with a disability.

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

When asked what type of help they need to improve their housing security, top answers were:

Help me with a down payment/purchase (39%);
Help me get a loan to buy a house (27%); and
Help me with the housing search (23%).

When asked what type of help they need to improve their neighborhood, top answers were:

Better lighting (38%);
Improve street crossings (30%); and
Reduce crime (27%).

When asked what type of help they need to improve their health, top answers were:

Make it easier to exercise (41%);
More healthy food (37%); and
Better/access to mental health care (26%).

When asked what type of help they need to improve their job situation, top answers were:

Increase wages (49%);
Find a job near my apartment/house (28%); and
Help paying for college (24%).

When asked what type of help they need to improve children’s education, top answers were:

Stop bullying/crime/drug use at school (29%);
Make school more challenging (28%); and
Have more activities afterschool (26%).
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CITY OF SAN MATEO 2031 HOUSING ELEMENT
Appendix H-F
COMMUNITY CORRESPONDENCE RECEIVED BY THE CITY PRIOR TO APRIL 6, 2022, AND BETWEEN MAY 7, 2022 AND DECEMBER 20, 2022
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WĞŽƉůĞǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐŚĂǀĞĂĚŝƐĂďŝůŝƚLJƚŚĂƚĞŵĞƌŐĞĚďĞĨŽƌĞĂŐĞϭϴ͕ŝƐĞdžƉĞĐƚĞĚƚŽďĞ ůŝĨĞůŽŶŐ͕ĂŶĚŝƐŽĨƐƵĨĨŝĐŝĞŶƚƐĞǀĞƌŝƚLJƚŽƌĞƋƵŝƌĞĂĐŽŽƌĚŝŶĂƚĞĚƉƌŽŐƌĂŵŽĨƐĞƌǀŝĐĞƐĂŶĚƐƵƉƉŽƌƚŝŶŽƌĚĞƌƚŽ ůŝǀĞƐƵĐĐĞƐƐĨƵůůLJŝŶƚŚĞĐŽŵŵƵŶŝƚLJ͘ĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐŝŶĐůƵĚĞŝŶƚĞůůĞĐƚƵĂůĚŝƐĂďŝůŝƚLJ͕ĂƵƚŝƐŵ͕ ŽǁŶƐLJŶĚƌŽŵĞ͕ĞƉŝůĞƉƐLJ͕ĐĞƌĞďƌĂůƉĂůƐLJ͕ĂŶĚŽƚŚĞƌĚŝƐĂďůŝŶŐĐŽŶĚŝƚŝŽŶƐƐŝŵŝůĂƌŝŶƚŚĞŝƌĨƵŶĐƚŝŽŶĂůŝŵƉĂĐƚ ƚŽĂŶŝŶƚĞůůĞĐƚƵĂůĚŝƐĂďŝůŝƚLJ͘hŶĚĞƌĂůŝĨŽƌŶŝĂ͛ƐĞǀĞůŽƉŵĞŶƚĂůŝƐĂďŝůŝƚŝĞƐ^ĞƌǀŝĐĞƐĐƚĂŶĚƚŚĞh͘^͘ ^ƵƉƌĞŵĞŽƵƌƚ͛ƐϭϵϵϵĚĞĐŝƐŝŽŶŝŶ KůŵƐƚĞĂĚǀ͘>͕͘͘ ƉĞŽƉůĞǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐĂƌĞĞŶƚŝƚůĞĚ ƚŽ ƌĞĐĞŝǀĞĐŽŵŵƵŶŝƚLJͲďĂƐĞĚƐĞƌǀŝĐĞƐƚŚĂƚĂůůŽǁƚŚĞŵƚŽůŝǀĞŝŶƚŚĞůĞĂƐƚƌĞƐƚƌŝĐƚŝǀĞĐŽŵŵƵŶŝƚLJƐĞƚƚŝŶŐ͘dŚŝƐ ƐŚŝĨƚƚŽĚĞͲŝŶƐƚŝƚƵƚŝŽŶĂůŝnjĂƚŝŽŶŚĂƐůĞĚƚŽƚŚĞĐůŽƐƵƌĞŽĨƚŚĞŵŽƐƚƌĞƐƚƌŝĐƚŝǀĞƐĞŐƌĞŐĂƚĞĚƐĞƚƚŝŶŐƐĂŶĚƚŽ ƚŚĞƌĞƋƵŝƌĞŵĞŶƚƚŚĂƚůŽĐĂůũƵƌŝƐĚŝĐƚŝŽŶƐŝŶƚŚĞŝƌ,ŽƵƐŝŶŐ ůĞŵĞŶƚƐĂƐƐĞƐƐĂŶĚƉůĂŶƐƉĞĐŝĨŝĐĂůůLJĨŽƌƚŚĞ
ŚŽƵƐŝŶŐŶĞĞĚƐŽĨƉĞŽƉůĞǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐǁŚŽƌĞĐĞŝǀĞƐĞƌǀŝĐĞƐĨƌŽŵƚŚĞZĞŐŝŽŶĂůĞŶƚĞƌ ŝŶŽƌĚĞƌƚŽůŝǀĞŝŶƚŚĞŝƌŚŽŵĞĐŽŵŵƵŶŝƚLJ͘
ĞŵŽŐƌĂƉŚŝĐĂŶĚKƚŚĞƌdƌĞŶĚƐĨĨĞĐƚŝŶŐƚŚĞ,ŽƵƐŝŶŐEĞĞĚƐŽĨWĞŽƉůĞǁŝƚŚ ĞǀĞůŽƉŵĞŶƚĂůŝƐĂďŝůŝƚŝĞƐ
dŚĞŝƚLJŽĨ^ĂŶDĂƚĞŽWŽƉƵůĂƚŝŽŶǁŝƚŚĞǀĞůŽƉŵĞŶƚĂůŝƐĂďŝůŝƚŝĞƐ'ƌĞǁďLJϭϮй^ŝŶĐĞƚŚĞ>ĂƐƚ,ŽƵƐŝŶŐ

ůĞŵĞŶƚĂŶĚĐĐŽƵŶƚƐĨŽƌϮϭйŽĨƚŚĞŽƵŶƚLJ͛ƐdŽƚĂůWŽƉƵůĂƚŝŽŶǁŝƚŚĞǀĞůŽƉŵĞŶƚĂůŝƐĂďŝůŝƚŝĞƐ͘ dŚĞ ŝƚLJŽĨ^ĂŶDĂƚĞŽ ŝƐŚŽŵĞƚŽ ϴϯϱ ƉĞŽƉůĞǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂů ĚŝƐĂďŝůŝƚŝĞƐ;dĂďůĞͺͺͿ͘dŚŝƐƌĞƉƌĞƐĞŶƚƐĂŶ ŝŶĐƌĞĂƐĞŽĨϭϮйŽǀĞƌƚŚĞϮϬϭϯƉŽƉƵůĂƚŝŽŶŽĨϳϰϲƌĞƉŽƌƚĞĚŝŶƚŚĞŝƚLJ͛ƐϮϬϭϱ,ŽƵƐŝŶŐ ůĞŵĞŶƚĂŶĚ
ƌĞĨůĞĐƚƐĂŵƵĐŚŚŝŐŚĞƌŐƌŽǁƚŚƌĂƚĞƚŚĂŶƚŚĞŐĞŶĞƌĂůƉŽƉƵůĂƚŝŽŶ͘/ŶĂĚĚŝƚŝŽŶ͕ƚŚĞŝƚLJ͛ƐƉŽƉƵůĂƚŝŽŶǁŝƚŚ ĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐĂĐĐŽƵŶƚƐĨŽƌϮϭйŽĨƚŚĞƚŽƚĂůŽƵŶƚLJƉŽƉƵůĂƚŝŽŶǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂů ĚŝƐĂďŝůŝƚŝĞƐ͕ĂůƚŚŽƵŐŚƚŚĞĐŝƚLJ͛ƐƚŽƚĂůƉŽƉƵůĂƚŝŽŶŝƐŽŶůLJϭϰйŽĨƚŚĞŽƵŶƚLJ͛ƐƚŽƚĂůƉŽƉƵůĂƚŝŽŶ͘ dĂďůĞͺͺͺŽŵƉĂƌŝƐŽŶŽĨƚŚĞϮϬϮϭŝƚLJĂŶĚŽƵŶƚLJWŽƉƵůĂƚŝŽŶƐǁŝƚŚĞǀĞůŽƉŵĞŶƚĂůŝƐĂďŝůŝƚŝĞƐ ŐĞ ŝƚLJŽĨ^ĂŶDĂƚĞŽ ŽƵŶƚLJŽĨ^ĂŶDĂƚĞŽ ŝƚLJŽĨ^ĂŶDĂƚĞŽ ĂƐйŽĨŽƵŶƚLJ
hŶĚĞƌĂŐĞϭϴ ϯϬϰ ϭϭϲϵ Ϯϲй
ϭϴĂŶĚŽůĚĞƌ ϱϯϭ Ϯϳϲϰ ϭϵй
dŽƚĂů ϴϯϱ ϯϵϯϯ Ϯϭй
^ŽƵƌĐĞ͗dŚĞŝƚLJŽĨ^ĂŶDĂƚĞŽĚĂƚĂŝƐďĂƐĞĚŽŶnjŝƉĐŽĚĞůĞǀĞůĚĂƚĂĨŽƌnjŝƉĐŽĚĞƐϵϰϰϬϭ͕ϵϰϰϬϮ͕ĂŶĚϵϰϰϬϯƉƵďůŝƐŚĞĚďLJƚŚĞĂůŝĨŽƌŶŝĂ ĞƉĂƌƚŵĞŶƚŽĨĞǀĞůŽƉŵĞŶƚĂů^ĞƌǀŝĐĞƐĂƐŽĨ^ĞƉƚĞŵďĞƌϯϬ͕ϮϬϮϭ͘ŽƵŶƚLJůĞǀĞůĚĂƚĂŝƐƉƵďůŝƐŚĞĚďLJƚŚĞĞƉĂƌƚŵĞŶƚŽĨĞǀĞůŽƉŵĞŶƚĂů^ĞƌǀŝĐĞƐ ĂƐŽĨ:ƵŶĞϯϬ͕ϮϬϮϭ͘ŽƚŚƐŽƵƌĐĞƐĞdžĐůƵĚĞĐŚŝůĚƌĞŶĨƌŽŵďŝƌƚŚƚŽƚŚĞƚŚŝƌĚďŝƌƚŚĚĂLJďĞĐĂƵƐĞĂƉƉƌŽdžŝŵĂƚĞůLJϳϱйŽĨƚŚŝƐĂŐĞŐƌŽƵƉŝƐĨŽƵŶĚŶŽƚ ĞůŝŐŝďůĞĨŽƌĐŽŶƚŝŶƵŝŶŐůŝĨĞůŽŶŐƐĞƌǀŝĐĞƐŽŶƚŚĞŝƌƚŚŝƌĚďŝƌƚŚĚĂLJ͘ ĞĐůŝŶĞŝŶ>ŝǀŝŶŐƌƌĂŶŐĞŵĞŶƚƐĨŽƌĚƵůƚƐǁŝƚŚĞǀĞůŽƉŵĞŶƚĂůŝƐĂďŝůŝƚŝĞƐKƵƚƐŝĚĞƚŚĞ&ĂŵŝůLJ,ŽŵĞ͘ KĨƚŚĞŝƚLJ͛ƐƚŽƚĂůƉŽƉƵůĂƚŝŽŶǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐ͕ ϱϯϭ;ϲϰйͿ ĂƌĞĂĚƵůƚƐĂŶĚ ϯϬϰ;ϯϲйͿ ĂƌĞ ϭ
1058 of 2271
ƵŶĚĞƌĂŐĞϭϴ;dĂďůĞͺͺͿ͘ƐƐĞƐƐŝŶŐƚŚĞŚŽƵƐŝŶŐŶĞĞĚƐŽĨĂĚƵůƚƐǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐŝƐŽĨ ƉĂƌƚŝĐƵůĂƌŝŵƉŽƌƚĂŶĐĞďĞĐĂƵƐĞĂƐƚŚĞLJĂŐĞƚŚĞĂĚƵůƚƐǁŝůůƌĞƋƵŝƌĞĂƌĞƐŝĚĞŶƚŝĂůŽƉƚŝŽŶŽƵƚƐŝĚĞƚŚĞĨĂŵŝůLJ ŚŽŵĞ͕ǁŚĞƌĞĂƐƚŚĞĨĂŵŝůLJŚŽŵĞŝƐƚŚĞƉƌĞĨĞƌƌĞĚůŝǀŝŶŐŽƉƚŝŽŶĨŽƌĐŚŝůĚƌĞŶǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂů ĚŝƐĂďŝůŝƚŝĞƐ͘/ŶϮϬϮϭ͕ϱϬϱŝƚLJŽĨ^ĂŶDĂƚĞŽƌĞƐŝĚĞŶƚƐǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐůŝǀĞĚŝŶƚŚĞĨĂŵŝůLJ ŚŽŵĞĐŽŵƉĂƌĞĚƚŽϯϴϵŝŶϮϬϭϯĂƐƌĞƉŽƌƚĞĚŝŶƚŚĞϮϬϭϱƚŽϮϬϮϯ,ŽƵƐŝŶŐ ůĞŵĞŶƚ͘dŚŝƐϯϬйŝŶĐƌĞĂƐĞŝŶ
ƌĞůŝĂŶĐĞŽŶƚŚĞĨĂŵŝůLJŚŽŵĞŝƐϮ͘ϱƚŝŵĞƐŐƌĞĂƚĞƌƚŚĂŶƚŚĞŝƚLJ͛ƐϭϮйŝŶĐƌĞĂƐĞŝŶƚŚĞĚĞǀĞůŽƉŵĞŶƚĂů ĚŝƐĂďŝůŝƚŝĞƐƉŽƉƵůĂƚŝŽŶĚƵƌŝŶŐƚŚĂƚƐĂŵĞƉĞƌŝŽĚ͘/ŶĐƌĞĂƐĞĚƌĞůŝĂŶĐĞŽŶƚŚĞĨĂŵŝůLJŚŽŵĞŝƐƉƌŝŵĂƌŝůLJ ĞdžƉůĂŝŶĞĚďLJŽǀĞƌĂůůŐƌŽǁƚŚŝŶƚŚĞƉŽƉƵůĂƚŝŽŶǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐĐŽƵƉůĞĚǁŝƚŚƐŝŐŶŝĨŝĐĂŶƚ ĚĞĐůŝŶĞƐŝŶŽƉƉŽƌƚƵŶŝƚŝĞƐĨŽƌƚŚĞŝƚLJ͛ƐĂĚƵůƚƐǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐƚŽůŝǀĞĞŝƚŚĞƌŝŶůŝĐĞŶƐĞĚ ĐĂƌĞĨĂĐŝůŝƚŝĞƐ;ϭϭйĚĞĐůŝŶĞͿŽƌŝŶĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐǁŝƚŚƐƵƉƉŽƌƚŝǀĞƐĞƌǀŝĐĞƐ;ϭϭйĚĞĐůŝŶĞͿ͘;dĂďůĞͺͺ͘Ϳ ƐĂĚƵůƚƐǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐĂŐĞ͕ƚŚĞLJŶĞĞĚŽƉƉŽƌƚƵŶŝƚŝĞƐƚŽůŝǀĞŽƵƚƐŝĚĞƚŚĞĨĂŵŝůLJŚŽŵĞ ďŽƚŚďĞĐĂƵƐĞŽĨƚŚĞĂŐŝŶŐŽĨƚŚĞŝƌĨĂŵŝůLJĐĂƌĞŐŝǀĞƌƐĂŶĚĂůƐŽďĞĐĂƵƐĞŵĂŶLJĂĚƵůƚƐǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂů ĚŝƐĂďŝůŝƚŝĞƐǁŽƵůĚůŝŬĞƚŽůŝǀĞŝŶƚŚĞŝƌŽǁŶĂƉĂƌƚŵĞŶƚǁŝƚŚƐƵƉƉŽƌƚŝǀĞƐĞƌǀŝĐĞƐ͘ dĂďůĞͺͺͺŚĂŶŐĞƐŝŶ>ŝǀŝŶŐƌƌĂŶŐĞŵĞŶƚƐŽĨĚƵůƚƐǁŝƚŚĞǀĞůŽƉŵĞŶƚĂůŝƐĂďŝůŝƚŝĞƐ >ŝǀŝŶŐƌƌĂŶŐĞŵĞŶƚƐ
ϮϬϭϯ
EƵŵďĞƌ
ϮϬϮϭ
EƵŵďĞƌ
ϮϬϮϭ
WĞƌĐĞŶƚŽĨdŽƚĂůĚƵůƚƐ йŚĂŶŐĞ^ŝŶĐĞϮϬϭϯ
dŽƚĂů;ĐŚŝůĚƌĞŶΘĂĚƵůƚƐͿŝŶ
ƚŚĞ&ĂŵŝůLJ,ŽŵĞ ϯϴϵ ϱϬϱ ͲͲ ϯϬй
ĚƵůƚƐ/ŶƚŚĞĨĂŵŝůLJŚŽŵĞ
EŽƚƌĞƉŽƌƚĞĚͲͲƐĞĞ
ŶŽƚĞ ϮϬϭ ϯϴй ͲͲ
KǁŶĂƉĂƌƚŵĞŶƚǁŝƚŚ
ƐƵƉƉŽƌƚŝǀĞƐĞƌǀŝĐĞƐ ϲϰ ϱϮ ϭϬй Ͳϭϭй
>ŝĐĞŶƐĞĚ&ĂĐŝůŝƚŝĞƐ Ϯϵϰ Ϯϲϱ ϱϬй Ͳϭϭй
KƚŚĞƌ;ŝŶĐůƵĚŝŶŐŚŽŵĞůĞƐƐͿ ϳ ϭϯ Ϯй ͘ϴй
dŽƚĂůĚƵůƚƐ
EŽƚƌĞƉŽƌƚĞĚͲͲƐĞĞ
ŶŽƚĞ ϱϯϭ ϭϬϬй ͲͲ
EŽƚĞ͗dŚĞϮϬϭϯĚĂƚĂĂƌĞƌĞƉŽƌƚĞĚŝŶƚŚĞϮϬϭϱ,ŽƵƐŝŶŐ
ůĞŵĞŶƚ͕ǁŚŝĐŚĨĂŝůĞĚƚŽƐĞƉĂƌĂƚĞůLJĐŽƵŶƚƚŚŽƐĞƵŶĚĞƌϭϴĂŶĚƚŚŽƐĞϭϴĂŶĚŽůĚĞƌ͕ŵĂŬŝŶŐ ŝƚĚŝĨĨŝĐƵůƚƚŽĞƐƚŝŵĂƚĞĐŚĂŶŐĞƐŝŶƚŚĞƐŝŐŶŝĨŝĐĂŶĐĞŽĨƚŚĞĨĂŵŝůLJŚŽŵĞĂƐĂƌĞƐŝĚĞŶƚŝĂůƐĞƚƚŝŶŐƐƉĞĐŝĨŝĐĂůůLJĨŽƌĂĚƵůƚƐ͘dŚĞϮϬϮϭĚĂƚĂĂƌĞƉƵďůŝƐŚĞĚ ĂƚƚŚĞnjŝƉĐŽĚĞůĞǀĞůďLJƚŚĞĂůŝĨŽƌŶŝĂĞƉĂƌƚŵĞŶƚŽĨĞǀĞůŽƉŵĞŶƚĂů^ĞƌǀŝĐĞƐĂƐŽĨ^ĞƉƚĞŵďĞƌϯϬ͕ϮϬϮϭ͘dŚĞƐĞĚĂƚĂĂƐƐƵŵĞƚŚĂƚŽĐĐƵƉĂŶƚƐŽĨ ůŝĐĞŶƐĞĚĨĂĐŝůŝƚŝĞƐĂƌĞϭϴĂŶĚŽůĚĞƌǁŚŝĐŚŝƐŐĞŶĞƌĂůůLJƚƌƵĞ͕ďƵƚŝĨŝŶĐŽƌƌĞĐƚƚŚŝƐĂƐƐƵŵƉƚŝŽŶǁŽƵůĚƚĞŶĚƚŽƵŶĚĞƌƐƚĂƚĞ͕ŶŽƚŽǀĞƌƐƚĂƚĞ͕ƚŚĞŶĞĞĚĨŽƌ ŽƚŚĞƌŚŽƵƐŝŶŐŽƉƚŝŽŶƐĨŽƌĂĚƵůƚƐǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐ͘ /ŶĐƌĞĂƐĞŽĨƵƚŝƐŵŝĂŐŶŽƐŝƐZĞĨůĞĐƚĞĚŝŶ/ŶĐƌĞĂƐĞŝŶĚƵůƚƐŝŶƚŚĞŝƌϮϬƐĂŶĚϯϬƐ͘ 'ƌŽǁƚŚŝŶƚŚĞŝƚLJ ŽĨ ^ĂŶDĂƚĞŽ͛ƐƉŽƉƵůĂƚŝŽŶǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐƐŝŶĐĞƚŚĞϮϬϭϱ,ŽƵƐŝŶŐ ůĞŵĞŶƚĐŽƌƌĞůĂƚĞƐǁŝƚŚ
ĂƐŝŐŶŝĨŝĐĂŶƚĂŶŶƵĂůŝŶĐƌĞĂƐĞŝŶƚŚĞĚŝĂŐŶŽƐŝƐŽĨĂƵƚŝƐŵƚŚĂƚďĞŐĂŶŝŶƚŚĞŵŝĚͲϭϵϴϬƐĂŶĚĚŝĚŶŽƚůĞǀĞůŽƵƚ ƵŶƚŝůĂĨƚĞƌϮϬϭϱ͘dŚĞĐƵŵƵůĂƚŝǀĞŝŵƉĂĐƚŽĨƚŚŝƐƚƌĞŶĚŝƐĂůƌĞĂĚLJƐĞĞŶŝŶƚŚĞŐƌŽǁƚŚŝŶƚŚĞ^ĂŶDĂƚĞŽ ŽƵŶƚLJƉŽƉƵůĂƚŝŽŶĂŐĞϭϴƚŽϰϭǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐĂŶĚǁŝůůĐŽŶƚŝŶƵĞŝŶƚŽƚŚĞĨƵƚƵƌĞ͘dŚŝƐ ƚƌĞŶĚŚĂƐƐŝŐŶŝĨŝĐĂŶƚŝŵƉůŝĐĂƚŝŽŶƐĨŽƌŚŽƵƐŝŶŐŶĞĞĚƐĂŵŽŶŐŝƚLJŽĨ^ĂŶDĂƚĞŽĂĚƵůƚƐǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂů ĚŝƐĂďŝůŝƚŝĞƐĚƵƌŝŶŐƚŚĞƉĞƌŝŽĚŽĨƚŚĞϮϬϮϯƚŽϮϬϯϭ,ŽƵƐŝŶŐ ůĞŵĞŶƚ͘
Ϯ
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dĂďůĞͺͺŚĂŶŐĞƐŝŶŐĞŝƐƚƌŝďƵƚŝŽŶŽĨĚƵůƚWŽƉƵůĂƚŝŽŶŝŶ^ĂŶDĂƚĞŽŽƵŶƚLJ ŐĞ ϮϬϭϱEƵŵďĞƌ ϮϬϮϭEƵŵďĞƌ йŚĂŶŐĞ
ϭϴƚŽϯϭ ϭϬϮϯ ϭϭϴϵ ϭϲй
ϯϮƚŽϰϭ ϯϵϳ ϰϱϳ ϭϱй
ϰϭƚŽϱϮ ϯϴϮ ϯϯϱ ͲϭϮй
ϱϮƚŽϲϭ ϯϴϱ ϯϰϴ ͲϭϬй
ϲϮƉůƵƐ ϯϮϳ ϰϯϱ ϯϯй
dŽƚĂůĂĚƵůƚƐ Ϯϱϭϰ Ϯϳϲϰ ϭϬй
^ŽƵƌĐĞ͗ŽƵŶƚLJůĞǀĞůĚĂƚĂŝƐƉƵďůŝƐŚĞĚďLJƚŚĞĞƉĂƌƚŵĞŶƚŽĨĞǀĞůŽƉŵĞŶƚĂů^ĞƌǀŝĐĞƐĂƐŽĨ:ƵŶĞϯϬ͕ϮϬϮϭĂŶĚĂƐŽĨ^ĞƉƚĞŵďĞƌϯϬ͕ϮϬϭϱ͘ >ŽŶŐĞƌ>ŝĨĞ^ƉĂŶƐ͘ ĞƚǁĞĞŶ^ĞƉƚĞŵďĞƌϮϬϭϱĂŶĚ:ƵŶĞ ϮϬϮϭ͕ƚŚĞĂůŝĨŽƌŶŝĂĞƉĂƌƚŵĞŶƚŽĨ ĞǀĞůŽƉŵĞŶƚĂů^ĞƌǀŝĐĞƐƌĞƉŽƌƚƐƚŚĂƚƚŚĞŶƵŵďĞƌŽĨ^ĂŶDĂƚĞŽŽƵŶƚLJƌĞƐŝĚĞŶƚƐǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂů ĚŝƐĂďŝůŝƚŝĞƐĂŐĞϲϮĂŶĚŽůĚĞƌŐƌĞǁďLJϯϯй;dĂďůĞͺͺͿ͘dŚŝƐŝƐŶŽƚĚƵĞƚŽŵŝŐƌĂƚŝŽŶŽĨƐĞŶŝŽƌĐŝƚŝnjĞŶƐǁŝƚŚ ĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐƚŽ^ĂŶDĂƚĞŽŽƵŶƚLJ͕ďƵƚƌĂƚŚĞƌƚŽǁĞůůͲĚŽĐƵŵĞŶƚĞĚŐĂŝŶƐŝŶůŝĨĞƐƉĂŶĂŵŽŶŐ ƉĞŽƉůĞǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐ͘tŝƚŚůŽŶŐĞƌůŝĨĞĞdžƉĞĐƚĂŶĐLJ͕ŵŽƌĞĂĚƵůƚƐǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂů ĚŝƐĂďŝůŝƚŝĞƐǁŝůůŽƵƚůŝǀĞƚŚĞŝƌƉĂƌĞŶƚƐĂŶĚĨĂŵŝůLJŵĞŵďĞƌƐǁŝƚŚǁŚŽŵĂŐƌŽǁŝŶŐŶƵŵďĞƌŽĨŝƚLJŽĨ^ĂŶ DĂƚĞŽĂĚƵůƚƐǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐŶŽǁůŝǀĞďĞĐĂƵƐĞŽĨƚŚĞůĂĐŬŽĨŽƚŚĞƌƌĞƐŝĚĞŶƚŝĂůŽƉƚŝŽŶƐ͘ >ŽŶŐĞƌůŝĨĞƐƉĂŶƐǁŝůůĂůƐŽƐůŽǁƚŚĞƉĂĐĞŽĨƌĞƐŝĚĞŶƚƚƵƌŶŽǀĞƌŝŶƚŚĞĐŽƵŶƚLJ͛ƐůŝŵŝƚĞĚƐƵƉƉůLJŽĨůŝĐĞŶƐĞĚ ĐĂƌĞĨĂĐŝůŝƚŝĞƐ͕ǁŚŝĐŚǁŝůůĨƵƌƚŚĞƌƌĞĚƵĐĞŽƉƉŽƌƚƵŶŝƚŝĞƐĨŽƌƚŚĞŐƌŽǁŝŶŐƉŽƉƵůĂƚŝŽŶŽĨƉĞŽƉůĞǁŝƚŚ ĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐƚŽƐĞĐƵƌĞŚŽƵƐŝŶŐŽƵƚƐŝĚĞƚŚĞĨĂŵŝůLJŚŽŵĞ͘ ĞĐůŝŶĞŝŶ>ŝĐĞŶƐĞĚĂƌĞ&ĂĐŝůŝƚŝĞƐ͘ dŚĞĂůŝĨŽƌŶŝĂ ĞƉĂƌƚŵĞŶƚŽĨĞǀĞůŽƉŵĞŶƚĂů^ĞƌǀŝĐĞƐƌĞƉŽƌƚƐƚŚĂƚ ďĞƚǁĞĞŶ^ĞƉƚĞŵďĞƌϮϬϭϱĂŶĚ:ƵŶĞϮϬϮϭ͕^ĂŶDĂƚĞŽŽƵŶƚLJůŽƐƚϱйŽĨŝƚƐƐƵƉƉůLJŽĨůŝĐĞŶƐĞĚĐĂƌĞ ĨĂĐŝůŝƚŝĞƐĨŽƌƉĞŽƉůĞǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐ;ŝŶĐůƵĚŝŶŐŽŵŵƵŶŝƚLJĂƌĞ&ĂĐŝůŝƚŝĞƐ͕/ŶƚĞƌŵĞĚŝĂƚĞ ĂƌĞ&ĂĐŝůŝƚŝĞƐ͕ĂŶĚ^ŬŝůůĞĚEƵƌƐŝŶŐ&ĂĐŝůŝƚŝĞƐͿ͕ƚŚĞƌĞďLJŝŶĐƌĞĂƐŝŶŐƚŚĞŶĞĞĚĨŽƌĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐŽƉƚŝŽŶƐ ĐŽŽƌĚŝŶĂƚĞĚǁŝƚŚƐƵƉƉŽƌƚŝǀĞƐĞƌǀŝĐĞƐĨƵŶĚĞĚďLJƚŚĞZĞŐŝŽŶĂůĞŶƚĞƌ͘dŚŝƐƚƌĞŶĚŝƐŵŝƌƌŽƌĞĚŝŶƚŚĞϭϭй ĚĞĐůŝŶĞŝŶƚŚĞŶƵŵďĞƌŽĨŝƚLJŽĨ^ĂŶDĂƚĞŽĂĚƵůƚƐĂďůĞƚŽůŝǀĞŝŶůŝĐĞŶƐĞĚĐĂƌĞŚŽŵĞƐďĞƚǁĞĞŶϮϬϭϯĂŶĚ ϮϬϮϭ;dĂďůĞͺͺͿ͘dŚĞƌĞĚƵĐĞĚƌŽůĞŽĨůŝĐĞŶƐĞĚĐĂƌĞĨĂĐŝůŝƚŝĞƐĚĞŵŽŶƐƚƌĂƚĞƐƚŚĞŶĞĞĚĨŽƌƚŚĞŝƚLJ͛Ɛ,ŽƵƐŝŶŐ

ůĞŵĞŶƚƚŽƉůĂŶĨŽƌĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐƚŚĂƚŝŶĐůƵĚĞƐƉĞŽƉůĞǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐƐŽƚŚĂƚ ĂĚƵůƚƐǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐĂƌĞŶŽƚĨŽƌĐĞĚŽƵƚŽĨƚŚĞĐŽƵŶƚLJǁŚĞŶƚŚĞLJůŽƐĞƚŚĞƐĞĐƵƌŝƚLJŽĨ ƚŚĞŝƌƉĂƌĞŶƚ͛ƐŚŽŵĞ͘
ŝƐƉůĂĐĞŵĞŶƚ͘ dŚĞĂůŝĨŽƌŶŝĂĞƉĂƌƚŵĞŶƚŽĨĞǀĞůŽƉŵĞŶƚĂů ^ĞƌǀŝĐĞƐŚĂƐĚŽĐƵŵĞŶƚĞĚĂϭϮйĚĞĐůŝŶĞŝŶ ƚŚĞĂŐĞŐƌŽƵƉϰϮƚŽϱϭĂŶĚĂϭϬйĚĞĐůŝŶĞŝŶƚŚĞĂŐĞŐƌŽƵƉϱϮƚŽϲϭŝŶ^ĂŶDĂƚĞŽŽƵŶƚLJďĞƚǁĞĞŶ ^ĞƉƚĞŵďĞƌϮϬϭϱĂŶĚ:ƵŶĞϮϬϮϭ͘;dĂďůĞͺͺͿ͘/ŶůŝŐŚƚŽĨŐĂŝŶƐŝŶůŝĨĞĞdžƉĞĐƚĂŶĐLJ͕ƚŚŝƐůŽƐƐĐĂŶƌĞĂƐŽŶĂďůLJďĞ ĂƚƚƌŝďƵƚĞĚƚŽŚŽŵĞůĞƐƐŶĞƐƐŽƌĚŝƐƉůĂĐĞŵĞŶƚĨƌŽŵƚŚĞĐŽƵŶƚLJďĞĐĂƵƐĞŽĨƚŚĞůĂĐŬŽĨƌĞƐŝĚĞŶƚŝĂůůŝǀŝŶŐ ŽƉƚŝŽŶƐ;ĞŝƚŚĞƌůŝĐĞŶƐĞĚĨĂĐŝůŝƚŝĞƐŽƌĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐͿǁŚĞŶĂŶĞůĚĞƌůLJƉĂƌĞŶƚĐĂƌĞŐŝǀĞƌƉĂƐƐĞƐĂǁĂLJŽƌ ďĞĐŽŵĞƐƵŶĂďůĞƚŽŚŽƵƐĞĂŶĚĐĂƌĞĨŽƌƚŚĞĂĚƵůƚ͘ŝƐƉůĂĐĞŵĞŶƚƚĂŬĞƐĂƉĂƌƚŝĐƵůĂƌƚŽůůŽŶĂĚƵůƚƐǁŝƚŚ ϯ
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ĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐǁŚŽĚĞƉĞŶĚŽŶĨĂŵŝůŝĂƌŝƚLJǁŝƚŚƚƌĂŶƐŝƚƌŽƵƚĞƐĂŶĚƐŚŽƉƉŝŶŐĂŶĚƐĞƌǀŝĐĞƐ͕ĂƐ ǁĞůůĂƐƐƵƉƉŽƌƚĨƌŽŵĐŽŵŵƵŶŝƚLJͲďĂƐĞĚƐĞƌǀŝĐĞƐĂŶĚŝŶĨŽƌŵĂůŶĞƚǁŽƌŬƐďƵŝůƚƵƉŽǀĞƌLJĞĂƌƐŝŶůŝǀŝŶŐŝŶƚŚĞ ŝƚLJŽĨ^ĂŶDĂƚĞŽ͘
,ŝŐŚĞƌZĂƚĞƐŽĨWŚLJƐŝĐĂůŝƐĂďŝůŝƚŝĞƐ͘ WĞŽƉůĞǁŝƚŚ ĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐĂƌĞŵŽƌĞůŝŬĞůLJƚŚĂŶƚŚĞ ŐĞŶĞƌĂůƉŽƉƵůĂƚŝŽŶƚŽŚĂǀĞĂŶĂĐĐŽŵƉĂŶLJŝŶŐƉŚLJƐŝĐĂůĚŝƐĂďŝůŝƚLJ͘dǁĞŶƚLJͲƐĞǀĞŶƉĞƌĐĞŶƚ;ϮϳйͿŽĨ^ĂŶ DĂƚĞŽŽƵŶƚLJƌĞƐŝĚĞŶƚƐǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐŚĂǀĞůŝŵŝƚĞĚŵŽďŝůŝƚLJ͕ĂŶĚϭϯйŚĂǀĞĂǀŝƐŝŽŶŽƌ ŚĞĂƌŝŶŐŝŵƉĂŝƌŵĞŶƚ͘dŚĞŶĞĞĚĨŽƌĂŶĂĐĐĞƐƐŝďůĞƵŶŝƚĐŽƵƉůĞĚǁŝƚŚƚŚĞŶĞĞĚĨŽƌĐŽŽƌĚŝŶĂƚĞĚƐƵƉƉŽƌƚŝǀĞ ƐĞƌǀŝĐĞƐĐŽŵƉŽƵŶĚƐƚŚĞŚŽƵƐŝŶŐďĂƌƌŝĞƌƐĨĂĐĞĚďLJƚŚŽƐĞǁŝƚŚĐŽͲŽĐĐƵƌƌŝŶŐŝŶƚĞůůĞĐƚƵĂůĂŶĚƉŚLJƐŝĐĂů ĚŝƐĂďŝůŝƚŝĞƐ͘
/ŶĞůŝŐŝďŝůŝƚLJĨŽƌDĂŶLJĨĨŽƌĚĂďůĞZĞŶƚĂůhŶŝƚƐ͘ ^ŽŵĞ ĂĚƵůƚƐǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐĚĞƉĞŶĚŽŶ ŵŽŶƚŚůLJŝŶĐŽŵĞŽĨƵŶĚĞƌΨϭ͕ϬϬϬĨƌŽŵƚŚĞ^ƵƉƉůĞŵĞŶƚĂů^ĞĐƵƌŝƚLJ/ŶĐŽŵĞ;^^/ͿƉƌŽŐƌĂŵ͕ƉƌŝĐŝŶŐƚŚĞŵ ŽƵƚŽĨĞǀĞŶƚŚĞůŝŵŝƚĞĚŶƵŵďĞƌŽĨ
džƚƌĞŵĞůLJ>Žǁ/ŶĐŽŵĞĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐƵŶŝƚƐŝŶƚŚĞŝƚLJŽĨ^ĂŶ DĂƚĞŽ͘dŚŽƐĞǁŝƚŚĞŵƉůŽLJŵĞŶƚƚĞŶĚƚŽǁŽƌŬƉĂƌƚͲƚŝŵĞŝŶƚŚĞůŽǁĞƐƚƉĂŝĚũŽďƐĂŶĚĂůƐŽƐƚƌƵŐŐůĞƚŽ ŝŶĐŽŵĞͲƋƵĂůŝĨLJĨŽƌŵĂŶLJŽĨƚŚĞĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐƵŶŝƚƐĨŽƌƌĞŶƚŝŶƚŚĞŝƚLJŽĨ^ĂŶDĂƚĞŽ͘ dƌĂŶƐŝƚͲĞƉĞŶĚĞŶƚ͘ DŽƐƚĂĚƵůƚƐǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂů ĚŝƐĂďŝůŝƚŝĞƐĚŽŶŽƚĚƌŝǀĞŽƌŽǁŶĂĐĂƌĂŶĚƌĞůLJŽŶ ƉƵďůŝĐƚƌĂŶƐŝƚĂƐĂŵĞĂŶƐƚŽŝŶƚĞŐƌĂƚŝŽŶŝŶƚŚĞůĂƌŐĞƌĐŽŵŵƵŶŝƚLJ͘ ĞƐƚWƌĂĐƚŝĐĞƐĨŽƌ/ŶĐůƵƐŝŽŶŽĨWĞŽƉůĞǁŝƚŚĞǀĞůŽƉŵĞŶƚĂůŝƐĂďŝůŝƚŝĞƐŝŶdLJƉŝĐĂů ĨĨŽƌĚĂďůĞ,ŽƵƐŝŶŐ
ƐĚĞŵŽŶƐƚƌĂƚĞĚďLJĂŐƌŽǁŝŶŐŶƵŵďĞƌŽĨŝŶĐůƵƐŝǀĞĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐĚĞǀĞůŽƉŵĞŶƚƐŝŶŶĞŝŐŚďŽƌŝŶŐ ũƵƌŝƐĚŝĐƚŝŽŶƐ͕ƚŚĞŝƚLJŽĨ^ĂŶDĂƚĞŽĐĂŶŵĞĞƚƚŚĞŚŽƵƐŝŶŐŶĞĞĚƐŽĨƉĞŽƉůĞǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂů ĚŝƐĂďŝůŝƚŝĞƐďLJĂĚŽƉƚŝŶŐƉŽůŝĐŝĞƐĂŶĚƉƌŽŐƌĂŵƐƚŽƉƌŽŵŽƚĞƚŚĞŝƌŝŶĐůƵƐŝŽŶǁŝƚŚĐŽŽƌĚŝŶĂƚĞĚƐĞƌǀŝĐĞƐŝŶ ƚLJƉŝĐĂůĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐ͘dŚĞĨŽůůŽǁŝŶŐĐŽŶƐŝĚĞƌĂƚŝŽŶƐƐŚŽƵůĚŐƵŝĚĞƚŚĞŝƚLJŽĨ^ĂŶDĂƚĞŽŝŶƚŚŝƐ ƉƵƌƐƵŝƚ͗
Ɣ /ŶƚĞŐƌĂƚŝŽŶŝŶƚLJƉŝĐĂůĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐ ŝƐĂƉƌŝŽƌŝƚLJ ŝŶŽƌĚĞƌƚŽĂĨĨŝƌŵĂƚŝǀĞůLJĨƵƌƚŚĞƌĨĂŝƌ ŚŽƵƐŝŶŐĨŽƌĂŐƌŽƵƉƚŚĂƚŚĂƐŚŝƐƚŽƌŝĐĂůůLJĞdžƉĞƌŝĞŶĐĞĚŶŽĂůƚĞƌŶĂƚŝǀĞƐƚŽƐĞŐƌĞŐĂƚĞĚůŝǀŝŶŐĂŶĚĂůƐŽ ƚŽĐŽƵŶƚĞƌƚŚĞĚŝƐƉůĂĐĞŵĞŶƚŽĨĂĚƵůƚƐǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐŽƵƚŽĨ^ĂŶDĂƚĞŽŽƵŶƚLJ͘ Ɣ ŽŽƌĚŝŶĂƚŝŽŶŽĨŚŽƵƐŝŶŐǁŝƚŚŽŶƐŝƚĞƐƵƉƉŽƌƚŝǀĞƐĞƌǀŝĐĞƐ ĨƵŶĚĞĚďLJƚŚĞ'ŽůĚĞŶ'ĂƚĞZĞŐŝŽŶĂů ĞŶƚĞƌƐŚŽƵůĚďĞĞŶĐŽƵƌĂŐĞĚ͘dŚĞƐĞĨƵůůLJĨƵŶĚĞĚĐŽŽƌĚŝŶĂƚĞĚƐĞƌǀŝĐĞƐƉƌŽǀŝĚĞĂƐƵƉƉŽƌƚĞĚ ƉĂƚŚǁĂLJĨŽƌƉĞŽƉůĞǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐƚŽĂƉƉůLJĨŽƌĂŶĚƌĞƚĂŝŶĂŶĂĨĨŽƌĚĂďůĞ ĂƉĂƌƚŵĞŶƚĂŶĚĂƌĞŽĨƚĞŶĂƐĞƐƐĞŶƚŝĂůƚŽĂƉĞƌƐŽŶǁŝƚŚĂĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚLJĂƐĂƉŚLJƐŝĐĂůůLJ ŵŽĚŝĨŝĞĚƵŶŝƚŝƐƚŽĂƉĞƌƐŽŶǁŝƚŚĂŵŽďŝůŝƚLJ͕ǀŝƐŝŽŶ͕ŽƌŚĞĂƌŝŶŐŝŵƉĂŝƌŵĞŶƚ͘ Ɣ ŵŝdžŽĨƵŶŝƚƐŝnjĞƐ ĂƚŝŶĐůƵƐŝǀĞŚŽƵƐŝŶŐƉƌŽƉĞƌƚŝĞƐ ǁŽƵůĚĂĚĚƌĞƐƐƚŚĞŶĞĞĚƐŽĨƚŚŽƐĞǁŚŽƌĞƋƵŝƌĞ ůŝǀĞͲŝŶĂŝĚĞƐ͕ǁĂŶƚƚŽůŝǀĞǁŝƚŚƌŽŽŵŵĂƚĞƐŽƌƉĂƌƚŶĞƌƐ͕ŽƌŚĂǀĞĐŚŝůĚƌĞŶ͘ Ɣ >ŽĐĂƚŝŽŶŶĞĂƌƉƵďůŝĐƚƌĂŶƐŝƚ ǁŽƵůĚĂĐĐŽŵŵŽĚĂƚĞƚŚĞ ƚƌĂŶƐŝƚͲĚĞƉĞŶĚĞŶĐLJŽĨŵŽƐƚĂĚƵůƚƐǁŝƚŚ ĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐ͘
Ɣ ĞĞƉůLJĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐŝƐŶĞĞĚĞĚ͕ ƚĂƌŐĞƚŝŶŐŝŶĐŽŵĞƐ ŶŽƚŵŽƌĞƚŚĂŶϯϬйŽĨƌĞĂDĞĚŝĂŶ /ŶĐŽŵĞĂŶĚƚĂŬŝŶŐĂĚǀĂŶƚĂŐĞŽĨ,ŽƵƐŝŶŐƵƚŚŽƌŝƚLJWƌŽũĞĐƚĂƐĞĚsŽƵĐŚĞƌƐŽƌ,hϴϭϭWƌŽũĞĐƚ ϰ
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ZĞŶƚĂůƐƐŝƐƚĂŶĐĞǁŚĞŶĂǀĂŝůĂďůĞƚŽĐƌĞĂƚĞŚŽƵƐŝŶŐŽƉƉŽƌƚƵŶŝƚŝĞƐĨŽƌƚŚŽƐĞǁŚŽĐĂŶŶŽƚŵĞĞƚ ŵŝŶŝŵƵŵŝŶĐŽŵĞƌĞƋƵŝƌĞŵĞŶƚƐĨŽƌƵŶŝƚƐƉƌŝĐĞĚĂƚϯϬйŽĨƌĞĂDĞĚŝĂŶ/ŶĐŽŵĞ͘ WŽůŝĐLJĂŶĚWƌŽŐƌĂŵZĞĐŽŵŵĞŶĚĂƚŝŽŶƐ
dŚĞŝƚLJŽĨ^ĂŶDĂƚĞŽŚĂƐĂƌĞƐƉŽŶƐŝďŝůŝƚLJŶŽƚƐŝŵƉůLJƚŽĂƐƐĞƐƐƚŚĞŚŽƵƐŝŶŐŶĞĞĚƐŽĨƉĞŽƉůĞǁŝƚŚ ĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐďƵƚĂůƐŽƚŽĐƌĞĂƚĞƉŽůŝĐLJ͕njŽŶŝŶŐ͕ƉƌŽŐƌĂŵĂŶĚŽƚŚĞƌĐŚĂŶŐĞƐƚŚĂƚŵĂŬĞŝƚ ŵŽƌĞĨĞĂƐŝďůĞĨŽƌĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐĚĞǀĞůŽƉĞƌƐƚŽŝŶĐůƵĚĞƉĞŽƉůĞǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐŝŶ ƚŚĞŝƌŚŽƵƐŝŶŐŝŶĐŽŽƌĚŝŶĂƚŝŽŶǁŝƚŚƚŚĞƐƵƉƉŽƌƚŝǀĞƐĞƌǀŝĐĞƐĂǀĂŝůĂďůĞĨƌŽŵƚŚĞ'ŽůĚĞŶ'ĂƚĞZĞŐŝŽŶĂů ĞŶƚĞƌ͘dŚĞŝƚLJ͛ƐϮϬϭϱ,ŽƵƐŝŶŐ
ůĞŵĞŶƚŝĚĞŶƚŝĨŝĞĚĂŶĞĞĚĨŽƌŚŽƵƐŝŶŐĨŽƌĂŶĂĚĚŝƚŝŽŶĂůϯϬƚŽϴϳƉĞŽƉůĞ ǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐ͕ďƵƚƚŚĞŶƵŵďĞƌŽĨĂĚƵůƚƐǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐůŝǀŝŶŐŝŶƚŚĞŝƌ ŽǁŶĂƉĂƌƚŵĞŶƚĂĐƚƵĂůůLJĚĞĐůŝŶĞĚďLJϭϭйƐŝŶĐĞƚŚĞůĂƐƚ,ŽƵƐŝŶŐ ůĞŵĞŶƚ͕ĞǀĞŶĂƐƚŚĞƉŽƉƵůĂƚŝŽŶŐƌĞǁďLJ
ϭϮй͘dŚĞŝƚLJ͛ƐůĂĐŬŽĨƉƌŽŐƌĞƐƐŝŶŵĞĞƚŝŶŐƚŚĞŚŽƵƐŝŶŐŶĞĞĚƐŽĨƉĞŽƉůĞǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐ ƐŝŶĐĞƚŚĞůĂƐƚ,ŽƵƐŝŶŐ
ůĞŵĞŶƚĚĞŵŽŶƐƚƌĂƚĞƐƚŚĞŶĞĞĚĨŽƌ ƉŽůŝĐŝĞƐĂŶĚƉƌŽŐƌĂŵƐƚŚĂƚƐƉĞĐŝĨŝĐĂůůLJ ŝŶĐĞŶƚŝǀŝnjĞŝŶĐůƵƐŝŽŶŽĨƉĞŽƉůĞǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐŝŶĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐǁŝƚŚĐŽŽƌĚŝŶĂƚĞĚ ƐĞƌǀŝĐĞƐƉƌŽǀŝĚĞĚďLJƚŚĞ'ŽůĚĞŶ'ĂƚĞZĞŐŝŽŶĂůĞŶƚĞƌ͘
Ɣ
ƐƚĂďůŝƐŚĂŶĚŵŽŶŝƚŽƌĂƋƵĂŶƚŝƚĂƚŝǀĞŐŽĂů͘ dƌĂĐŬŝŶŐ ƚŚĞŝƚLJ͛ƐƐƵĐĐĞƐƐŝŶŚŽƵƐŝŶŐƉĞŽƉůĞǁŝƚŚ ĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐŝƐĞƐƐĞŶƚŝĂůƚŽĚĞƚĞƌŵŝŶĞǁŚĞƚŚĞƌƉŽůŝĐŝĞƐĂŶĚƉƌŽŐƌĂŵƐĂƌĞŚĂǀŝŶŐĂŶ ĞĨĨĞĐƚŝŶŽǀĞƌĐŽŵŝŶŐŚŝƐƚŽƌŝĐƉĂƚƚĞƌŶƐŽĨĚŝƐĐƌŝŵŝŶĂƚŝŽŶĂŶĚĞdžĐůƵƐŝŽŶŽĨƉĞŽƉůĞǁŝƚŚ ĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐĨƌŽŵĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐ͘ŐŽĂůŽĨ ϭϱϬŶĞǁ džƚƌĞŵĞůLJ>ŽǁͲ/ŶĐŽŵĞ
ŚŽƵƐŝŶŐƵŶŝƚƐĨŽƌ ŝƚLJŽĨ^ĂŶDĂƚĞŽ ƌĞƐŝĚĞŶƚƐǁŝƚŚ ĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐŽǀĞƌƚŚĞƉĞƌŝŽĚŽĨ ƚŚĞϮϬϮϯ,ŽƵƐŝŶŐ
ůĞŵĞŶƚǁŽƵůĚƌĞƉƌĞƐĞŶƚŵĞĂŶŝŶŐĨƵůƉƌŽŐƌĞƐƐƚŽǁĂƌĚƐƚŚĞƚŽƚĂůƵŶŵĞƚ ŚŽƵƐŝŶŐŶĞĞĚŽĨƚŚŝƐƐƉĞĐŝĂůŶĞĞĚƐƉŽƉƵůĂƚŝŽŶ͘
^ĂŵƉůĞ>ĂŶŐƵĂŐĞ͗dŚĞŝƚLJŽĨ^ĂŶDĂƚĞŽƐŚĂůůŵŽŶŝƚŽƌƉƌŽŐƌĞƐƐƚŽǁĂƌĚƐĂƋƵĂŶƚŝƚĂƚŝǀĞŐŽĂůŽĨ ϭϱϬŶĞǁ
džƚƌĞŵĞůLJ>Žǁ/ŶĐŽŵĞŚŽƵƐŝŶŐƵŶŝƚƐƚŚĂƚĂƌĞƐƵďũĞĐƚƚŽĂƉƌĞĨĞƌĞŶĐĞĨŽƌƉĞŽƉůĞǁŝƚŚ ĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐŶĞĞĚŝŶŐƚŚĞĐŽŽƌĚŝŶĂƚĞĚƐĞƌǀŝĐĞƐƉƌŽǀŝĚĞĚďLJ'ŽůĚĞŶ'ĂƚĞZĞŐŝŽŶĂů ĞŶƚĞƌƚŽůŝǀĞŝŶĐůƵƐŝǀĞůLJŝŶĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐ͘
Ɣ dĂƌŐĞƚŝƚLJͲKǁŶĞĚ>ĂŶĚ͕>ĂŶĚĞĚŝĐĂƚĞĚƚŽĨĨŽƌĚĂďůĞ,ŽƵƐŝŶŐƵŶĚĞƌƚŚĞ/ŶĐůƵƐŝŽŶĂƌLJ KƌĚŝŶĂŶĐĞĂŶĚŝƚLJ,ŽƵƐŝŶŐ&ƵŶĚƐƚŽDĞĞƚŝƚLJͲ^ƉĞĐŝĨŝĐWƌŝŽƌŝƚŝĞƐ͘ ŝƚLJͲŽǁŶĞĚůĂŶĚ͕ůĂŶĚ ĚĞĚŝĐĂƚĞĚƚŽĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐŝŶůŝĞƵŽĨƉƌŽǀŝĚŝŶŐĂĨĨŽƌĚĂďůĞƵŶŝƚƐƵŶĚĞƌƚŚĞŝŶĐůƵƐŝŽŶĂƌLJ ŽƌĚŝŶĂŶĐĞ͕ĂŶĚĐŝƚLJŚŽƵƐŝŶŐĨƵŶĚƐĂƌĞŽĨƚĞŶĞƐƐĞŶƚŝĂůƚŽƚŚĞĚĞǀĞůŽƉŵĞŶƚŽĨĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐ ƚŚĂƚŝƐĨŝŶĂŶĐŝĂůůLJĨĞĂƐŝďůĞŝŶŚŝŐŚͲĐŽƐƚŝƚLJŽĨ^ĂŶDĂƚĞŽ͘/ŶĐƌĞĂƚŝŶŐŐƵŝĚĞůŝŶĞƐĨŽƌƚŚĞƐĐŽƌŝŶŐŽĨ ĂŶLJĐŽŵƉĞƚŝƚŝǀĞƌĞƋƵĞƐƚƐĨŽƌƉƌŽƉŽƐĂůƐĨŽƌƚŚĞƐĞƐĐĂƌĐĞƌĞƐŽƵƌĐĞƐ͕ƚŚĞŝƚLJƐŚŽƵůĚŐƌĂŶƚ ĂĚĚŝƚŝŽŶĂůƉŽŝŶƚƐƚŽĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐƉƌŽũĞĐƚƐƚŚĂƚĂĚĚƌĞƐƐƚŚĞŚŽƵƐŝŶŐŶĞĞĚƐŽĨŝƚLJŽĨ^ĂŶ DĂƚĞŽƌĞƐŝĚĞŶƚƐǁŚŽĂƌĞŵŽƐƚĚŝĨĨŝĐƵůƚƚŽŚŽƵƐĞƵŶĚĞƌĞdžŝƐƚŝŶŐƐƚĂƚĞĂŶĚĨĞĚĞƌĂůŚŽƵƐŝŶŐĨŝŶĂŶĐĞ ƉƌŽŐƌĂŵƐͲͲĨŽƌĞdžĂŵƉůĞ͕ďLJƉƌŝŽƌŝƚŝnjŝŶŐƉƌŽƉŽƐĂůƐǁŝƚŚĂŚŝŐŚĞƌŶƵŵďĞƌŽĨĞdžƚƌĞŵĞůLJůŽǁŝŶĐŽŵĞ ƵŶŝƚƐŽƌƚŚĂƚŵĂŬĞĂƉĞƌĐĞŶƚĂŐĞŽĨƵŶŝƚƐƐƵďũĞĐƚƚŽĂƉƌĞĨĞƌĞŶĐĞĨŽƌŝĚĞŶƚŝĨŝĞĚĐĂƚĞŐŽƌŝĞƐŽĨ ƐƉĞĐŝĂůŶĞĞĚƐƉĞŽƉůĞǁŚŽǁŽƵůĚďĞŶĞĨŝƚĨƌŽŵĐŽŽƌĚŝŶĂƚĞĚŽŶƐŝƚĞƐĞƌǀŝĐĞƐ͕ŝŶĐůƵĚŝŶŐďƵƚŶŽƚ ůŝŵŝƚĞĚƚŽƉĞŽƉůĞǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐǁŚŽďĞŶĞĨŝƚĨƌŽŵƐĞƌǀŝĐĞƐŽĨƚŚĞ'ŽůĚĞŶ'ĂƚĞ ZĞŐŝŽŶĂůĞŶƚĞƌ͘
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^ĂŵƉůĞ>ĂŶŐƵĂŐĞ͗/ŶƉƵďůŝƐŚŝŶŐƌĞƋƵĞƐƚƐĨŽƌĐŽŵƉĞƚŝƚŝǀĞƉƌŽƉŽƐĂůƐĨŽƌĂŶLJĐŝƚLJͲŽǁŶĞĚůĂŶĚ͕ůĂŶĚ ĚĞĚŝĐĂƚĞĚƚŽĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐƵŶĚĞƌƚŚĞĐŝƚLJ͛ƐŝŶĐůƵƐŝŽŶĂƌLJŽƌĚŝŶĂŶĐĞŽƌĐŝƚLJŚŽƵƐŝŶŐĨƵŶĚƐ͕ƚŚĞ ŝƚLJŽĨ^ĂŶDĂƚĞŽƐŚĂůůŐƌĂŶƚĂĚĚŝƚŝŽŶĂůƉŽŝŶƚƐƚŽƉƌŽƉŽƐĂůƐƚŚĂƚĂĚĚƌĞƐƐƚŚĞĐŝƚLJ͛ƐŵŽƐƚĚŝĨĨŝĐƵůƚ ƚŽĂĐŚŝĞǀĞŚŽƵƐŝŶŐƉƌŝŽƌŝƚŝĞƐ͕ďLJ͕ĨŽƌĞdžĂŵƉůĞ͕ƉƌŽǀŝĚŝŶŐĂŐƌĞĂƚĞƌŶƵŵďĞƌŽĨĞdžƚƌĞŵĞůLJ ůŽǁͲŝŶĐŽŵĞƵŶŝƚƐŽƌĐŽŵŵŝƚƚŝŶŐƚŽŵĂŬĞĂƉĞƌĐĞŶƚĂŐĞŽĨƚŚĞƵŶŝƚƐƐƵďũĞĐƚƚŽĂƉƌĞĨĞƌĞŶĐĞĨŽƌ ƉĞŽƉůĞǁŝƚŚƐƉĞĐŝĂůŶĞĞĚƐǁŚŽǁŝůůďĞŶĞĨŝƚĨƌŽŵĐŽŽƌĚŝŶĂƚĞĚŽŶƐŝƚĞƐĞƌǀŝĐĞƐ͕ƐƵĐŚĂƐƉĞŽƉůĞǁŝƚŚ ĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐǁŚŽƌĞĐĞŝǀĞƐĞƌǀŝĐĞƐĨƌŽŵƚŚĞ'ŽůĚĞŶ'ĂƚĞZĞŐŝŽŶĂůĞŶƚĞƌ͘ Ɣ KĨĨĞƌĞǀĞůŽƉĞƌƐĂZĂŶŐĞŽĨĨĨŽƌĚĂďŝůŝƚLJKƉƚŝŽŶƐhŶĚĞƌƚŚĞ/ŶĐůƵƐŝŽŶĂƌLJKƌĚŝŶĂŶĐĞ͘ DŽƐƚ ĂĚƵůƚƐǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐŚĂǀĞŝŶĐŽŵĞƐƚŽŽůŽǁƚŽƐĂƚŝƐĨLJŵŝŶŝŵƵŵŝŶĐŽŵĞ ƌĞƋƵŝƌĞŵĞŶƚƐĨŽƌƚŚĞ>Žǁ/ŶĐŽŵĞƵŶŝƚƐĐƵƌƌĞŶƚůLJŽĨĨĞƌĞĚƵŶĚĞƌƚŚĞĐŝƚLJ͛ƐŝŶĐůƵƐŝŽŶĂƌLJŽƌĚŝŶĂŶĐĞ ĂŶĚĂƌĞĞĨĨĞĐƚŝǀĞůLJĞdžĐůƵĚĞĚĨƌŽŵƚŚŝƐŚŽƵƐŝŶŐŽƉƚŝŽŶ͘ĂůŝĨŽƌŶŝĂůĂǁ;ϭϱϬϱ͕ƚŚĞ͞WĂůŵĞƌ&ŝdž͟Ϳ ĞdžƉůŝĐŝƚůLJĂůůŽǁƐĐŝƚŝĞƐƚŽĂĚŽƉƚŝŶĐůƵƐŝŽŶĂƌLJŚŽƵƐŝŶŐŽƌĚŝŶĂŶĐĞƐƚŚĂƚĂĚĚƌĞƐƐĂƌĂŶŐĞŽĨŝŶĐŽŵĞ ůĞǀĞůƐĨƌŽŵŵŽĚĞƌĂƚĞͲŝŶĐŽŵĞƚŽĞdžƚƌĞŵĞůLJůŽǁͲŝŶĐŽŵĞ͘dŚĞŝƚLJƐŚŽƵůĚƚĂŬĞĂĚǀĂŶƚĂŐĞŽĨƚŚŝƐ ĂƵƚŚŽƌŝƚLJƚŽŵĂŬĞŝƚƐŽƌĚŝŶĂŶĐĞŵŽƌĞƌĞƐƉŽŶƐŝǀĞƚŽůŽĐĂůŶĞĞĚƐďLJŽĨĨĞƌŝŶŐĚĞǀĞůŽƉĞƌƐŽĨŵĂƌŬĞƚ ƌĂƚĞŚŽƵƐŝŶŐĂŵĞŶƵŽĨŽƉƚŝŽŶƐĨŽƌŝŶĐůƵĚŝŶŐĂĨĨŽƌĚĂďůĞƵŶŝƚƐ͕ĨŽƌĞdžĂŵƉůĞ͕ďLJƐĞƚƚŝŶŐĂŚŝŐŚĞƌ ƉĞƌĐĞŶƚĂŐĞŽĨƵŶŝƚƐƉƌŝĐĞĚĂƚŵŽĚĞƌĂƚĞŝŶĐŽŵĞĂŶĚĂůŽǁĞƌƉĞƌĐĞŶƚĂŐĞŽĨƵŶŝƚƐƐĞƚĂƚĞdžƚƌĞŵĞůLJ ůŽǁŝŶĐŽŵĞ͘^ƵĐŚĂŵĞŶƵǁŽƵůĚĂĚĚƌĞƐƐĂďƌŽĂĚĞƌƌĂŶŐĞŽĨŝƚLJŽĨ^ĂŶDĂƚĞŽŚŽƵƐŝŶŐŶĞĞĚƐ͕ ǁŚŝůĞŐŝǀŝŶŐĚĞǀĞůŽƉĞƌƐŵŽƌĞŽƉƚŝŽŶƐĨŽƌŵĞĞƚŝŶŐƚŚĞŝŶĐůƵƐŝŽŶĂƌLJƌĞƋƵŝƌĞŵĞŶƚ͘ ^ĂŵƉůĞ>ĂŶŐƵĂŐĞ͗dŚĞŝƚLJŽĨ^ĂŶDĂƚĞŽƐŚĂůůƌĞǀŝƐĞŝƚƐŝŶĐůƵƐŝŽŶĂƌLJŚŽƵƐŝŶŐŽƌĚŝŶĂŶĐĞƚŽŽĨĨĞƌ ĚĞǀĞůŽƉĞƌƐĂŵĞŶƵŽĨŽƉƚŝŽŶƐĨŽƌĂĐŚŝĞǀŝŶŐĂĨĨŽƌĚĂďŝůŝƚLJ͕ĂĚũƵƐƚŝŶŐƚŚĞƉĞƌĐĞŶƚĂŐĞŽĨƵŶŝƚƐ ƌĞƋƵŝƌĞĚƚŽďĞĂĨĨŽƌĚĂďůĞĚĞƉĞŶĚŝŶŐŽŶƚŚĞĚĞŐƌĞĞŽĨĂĨĨŽƌĚĂďŝůŝƚLJĂĐŚŝĞǀĞĚ;ŵŽĚĞƌĂƚĞͲŝŶĐŽŵĞ͕ ůŽǁŝŶĐŽŵĞ͕ǀĞƌLJůŽǁŝŶĐŽŵĞ͕ĂŶĚĞdžƚƌĞŵĞůLJůŽǁŝŶĐŽŵĞͿ͘ Ɣ ZĞĚƵĐĞWĂƌŬŝŶŐZĞƋƵŝƌĞŵĞŶƚƐĨŽƌWĞŽƉůĞǁŝƚŚĞǀĞůŽƉŵĞŶƚĂůĂŶĚKƚŚĞƌŝƐĂďŝůŝƚŝĞƐ͘ ĚƵůƚƐ ǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐŚĂǀĞƌĞĚƵĐĞĚƉĂƌŬŝŶŐŶĞĞĚƐďĞĐĂƵƐĞƚŚĞLJƌĂƌĞůLJŚĂǀĞĂĚƌŝǀĞƌΖƐ ůŝĐĞŶƐĞŽƌŽǁŶĂĐĂƌ͘dŚŝƐŵĂLJĂůƐŽďĞƚƌƵĞŽĨŽƚŚĞƌĐĂƚĞŐŽƌŝĞƐŽĨƉĞŽƉůĞǁŝƚŚĚŝƐĂďŝůŝƚŝĞƐ͘dŚĞ ŝƚLJƐŚŽƵůĚƌĞǀŝƐĞŝƚƐŽƌĚŝŶĂŶĐĞƐƚŽůŝŵŝƚƉĂƌŬŝŶŐƌĞƋƵŝƌĞĚĨŽƌĂĨĨŽƌĚĂďůĞƵŶŝƚƐĨŽƌƉĞŽƉůĞǁŝƚŚ ĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐƚŽ͘ϱƐƉĂĐĞĨŽƌĞĂĐŚĂĨĨŽƌĚĂďůĞƐƚƵĚŝŽŽƌϭďĞĚƌŽŽŵƵŶŝƚĂŶĚϭƐƉĂĐĞ ĨŽƌĂŶĂĨĨŽƌĚĂďůĞϮďĞĚƌŽŽŵƵŶŝƚŽƌůĂƌŐĞƌ͘ƐŝŵŝůĂƌƌĞĚƵĐƚŝŽŶƐŚŽƵůĚďĞĐŽŶƐŝĚĞƌĞĚĨŽƌ ƉŚLJƐŝĐĂůůLJĂĐĐĞƐƐŝďůĞƵŶŝƚƐƌĞƋƵŝƌĞĚƚŽďĞŝŶĐůƵĚĞĚŝŶĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐ͘ ^ĂŵƉůĞ>ĂŶŐƵĂŐĞ͗dŚĞŝƚLJƐŚĂůůĞŶĐŽƵƌĂŐĞƚŚĞŝŶĐůƵƐŝŽŶŽĨƉĞŽƉůĞǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĂŶĚ ŽƚŚĞƌĚŝƐĂďŝůŝƚŝĞƐŝŶĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐďLJƌĞĐŽŐŶŝnjŝŶŐƚŚĞŝƌƚƌĂŶƐŝƚĚĞƉĞŶĚĞŶĐĞĂŶĚĞƐƚĂďůŝƐŚŝŶŐ ůŽǁĞƌƉĂƌŬŝŶŐƌĂƚŝŽƐĨŽƌƵŶŝƚƐƚĂƌŐĞƚĞĚƚŽƉĞŽƉůĞǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĂŶĚŽƚŚĞƌĚŝƐĂďŝůŝƚŝĞƐƚŚĂŶ ǁŽƵůĚŽƚŚĞƌǁŝƐĞďĞƌĞƋƵŝƌĞĚĨŽƌĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐ͘
Ɣ >ŽĐĂůĞŶƐŝƚLJŽŶƵƐŽŶĐĞƐƐŝŽŶƐ͘ dŚĞƐƚĂƚĞĚĞŶƐŝƚLJ ďŽŶƵƐůĂǁĐƵƌƌĞŶƚůLJƉƌŽǀŝĚĞƐĂĚĚŝƚŝŽŶĂů ĚĞŶƐŝƚLJĨŽƌŚŽƵƐŝŶŐƉƌŽũĞĐƚƐƚŚĂƚŝŶĐůƵĚĞĂƚůĞĂƐƚϭϬйŽĨƚŚĞƵŶŝƚƐĨŽƌĚŝƐĂďůĞĚǀĞƚĞƌĂŶƐ͕ ƚƌĂŶƐŝƚŝŽŶͲĂŐĞĨŽƐƚĞƌLJŽƵƚŚ͕ĂŶĚŚŽŵĞůĞƐƐƉĞƌƐŽŶƐĂƚƚŚĞǀĞƌLJůŽǁŝŶĐŽŵĞůĞǀĞů͘ ďŽǀĞĂŶĚ ďĞLJŽŶĚƚŚĞĚĞŶƐŝƚLJďŽŶƵƐŐƵŝĚĞůŝŶĞƐŵĂŶĚĂƚĞĚďLJƐƚĂƚĞůĂǁ͕ƚŚĞŝƚLJƐŚŽƵůĚĂĚĚƚŚĞƐĂŵĞ ŝŶĐĞŶƚŝǀĞƐǁŚĞŶĂƚůĞĂƐƚϭϬйŽĨƚŚĞƵŶŝƚƐĂƌĞƐƵďũĞĐƚƚŽƉƌĞĨĞƌĞŶĐĞĨŽƌƉĞŽƉůĞǁŝƚŚ ϲ
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ĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐǁŚŽǁŝůůďĞŶĞĨŝƚĨƌŽŵĐŽŽƌĚŝŶĂƚĞĚŽŶƐŝƚĞƐĞƌǀŝĐĞƐƉƌŽǀŝĚĞĚďLJƚŚĞ 'ŽůĚĞŶ'ĂƚĞZĞŐŝŽŶĂůĞŶƚĞƌ͘
^ĂŵƉůĞ>ĂŶŐƵĂŐĞ͗/ŶŝŵƉůĞŵĞŶƚŝŶŐƚŚĞĂůŝĨŽƌŶŝĂĚĞŶƐŝƚLJďŽŶƵƐƐƚĂƚƵƚĞ͕ƚŚĞŝƚLJƐŚĂůůƉƌŽǀŝĚĞ ĨŽƌƚŚĞƐĂŵĞĚĞŶƐŝƚLJďŽŶƵƐ͕ŝŶĐĞŶƚŝǀĞƐ͕ŽƌĐŽŶĐĞƐƐŝŽŶƐĨŽƌŚŽƵƐŝŶŐƉƌŽũĞĐƚƐƚŚĂƚŝŶĐůƵĚĞĂƚůĞĂƐƚ ϭϬйŽĨƚŚĞƵŶŝƚƐĨŽƌƉĞŽƉůĞǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐĂƚƚŚĞǀĞƌLJůŽǁͲŝŶĐŽŵĞůĞǀĞůĂƐĂƌĞ ĂǀĂŝůĂďůĞƚŽƉƌŽũĞĐƚƐƚŚĂƚŝŶĐůƵĚĞĂƚůĞĂƐƚϭϬйŽĨƚŚĞƵŶŝƚƐĨŽƌĚŝƐĂďůĞĚǀĞƚĞƌĂŶƐ͕ƚƌĂŶƐŝƚŝŽŶͲĂŐĞ ĨŽƐƚĞƌLJŽƵƚŚ͕ĂŶĚŚŽŵĞůĞƐƐƉĞƌƐŽŶƐĂƚƚŚĞǀĞƌLJůŽǁͲŝŶĐŽŵĞůĞǀĞů͘ ĨĨŝƌŵĂƚŝǀĞDĂƌŬĞƚŝŶŐŽĨWŚLJƐŝĐĂůůLJĐĐĞƐƐŝďůĞhŶŝƚƐ͗ ĞǀĞůŽƉĞƌƐĂƌĞĂůůŽǁĞĚƚŽĂĨĨŝƌŵĂƚŝǀĞůLJ ŵĂƌŬĞƚĂĐĐĞƐƐŝďůĞƵŶŝƚƐƚŽĚŝƐĂďŝůŝƚLJͲƐĞƌǀŝŶŐŽƌŐĂŶŝnjĂƚŝŽŶƐŝŶ^ĂŶDĂƚĞŽŽƵŶƚLJ;ŝ͘Ğ͘'ŽůĚĞŶ'ĂƚĞ ZĞŐŝŽŶĂůĞŶƚĞƌ͕,ŽƵƐŝŶŐŚŽŝĐĞƐŽĂůŝƚŝŽŶĨŽƌWĞƌƐŽŶǁŝƚŚĞǀĞůŽƉŵĞŶƚĂůŝƐĂďŝůŝƚŝĞƐ͕ĞŶƚĞƌ ĨŽƌ/ŶĚĞƉĞŶĚĞŶĐĞŽĨ/ŶĚŝǀŝĚƵĂůƐǁŝƚŚŝƐĂďŝůŝƚŝĞƐĂŶĚŽƚŚĞƌƐͿďƵƚƌĂƌĞůLJƚĂŬĞƚŚŝƐƐƚĞƉ͘ ĨĨŝƌŵĂƚŝǀĞŵĂƌŬĞƚŝŶŐŝƐƉĂƌƚŝĐƵůĂƌůLJŶĞĞĚĞĚďLJƉĞŽƉůĞǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐǁŚŽ͕ ďĞĐĂƵƐĞŽĨĐŽŐŶŝƚŝǀĞ͕ĐŽŵŵƵŶŝĐĂƚŝŽŶĂŶĚƐŽĐŝĂůŝŵƉĂŝƌŵĞŶƚ͕ŵĂLJƌĞůLJŽŶŚŽƵƐŝŶŐŶĂǀŝŐĂƚŝŽŶ ƐĞƌǀŝĐĞƐĨƵŶĚĞĚďLJƚŚĞ'ŽůĚĞŶ'ĂƚĞZĞŐŝŽŶĂůĞŶƚĞƌƚŽůĞĂƌŶĂďŽƵƚĂŶĚĂƉƉůLJĨŽƌĂĨĨŽƌĚĂďůĞ ŚŽƵƐŝŶŐ͘
^ĂŵƉůĞ>ĂŶŐƵĂŐĞ͗ƐĂĐŽŶĚŝƚŝŽŶŽĨƚŚĞĚŝƐƉŽƐŝƚŝŽŶŽĨĂŶLJĐŝƚLJͲŽǁŶĞĚůĂŶĚ͕ůĂŶĚĚĞĚŝĐĂƚĞĚƚŽ ĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐƵŶĚĞƌƚŚĞĐŝƚLJ͛ƐŝŶĐůƵƐŝŽŶĂƌLJŽƌĚŝŶĂŶĐĞ͕ƚŚĞĂǁĂƌĚŽĨĐŝƚLJĨŝŶĂŶĐŝŶŐ͕ĂŶLJ ĚĞŶƐŝƚLJďŽŶƵƐĐŽŶĐĞƐƐŝŽŶƐ͕ŽƌůĂŶĚƵƐĞĞdžĐĞƉƚŝŽŶƐŽƌǁĂŝǀĞƌƐĨŽƌĂŶLJĂĨĨŽƌĚĂďůĞŚŽƵƐŝŶŐƉƌŽũĞĐƚ͕ ƚŚĞŝƚLJƐŚĂůůƌĞƋƵŝƌĞƚŚĂƚƚŚĞŚŽƵƐŝŶŐĚĞǀĞůŽƉĞƌŝŵƉůĞŵĞŶƚĂŶĂĨĨŝƌŵĂƚŝǀĞŵĂƌŬĞƚŝŶŐƉůĂŶĨŽƌ ƉŚLJƐŝĐĂůůLJĂĐĐĞƐƐŝďůĞƵŶŝƚƐǁŚŝĐŚ͕ĂŵŽŶŐŽƚŚĞƌŵĞĂƐƵƌĞƐ͕ƉƌŽǀŝĚĞƐĚŝƐĂďŝůŝƚLJͲƐĞƌǀŝŶŐ ŽƌŐĂŶŝnjĂƚŝŽŶƐĂĚĞƋƵĂƚĞƉƌŝŽƌŶŽƚŝĐĞŽĨƚŚĞĂǀĂŝůĂďŝůŝƚLJŽĨƚŚĞĂĐĐĞƐƐŝďůĞƵŶŝƚƐĂŶĚĂƉƌŽĐĞƐƐĨŽƌ ƐƵƉƉŽƌƚŝŶŐƉĞŽƉůĞǁŝƚŚƋƵĂůŝĨLJŝŶŐĚŝƐĂďŝůŝƚŝĞƐƚŽĂƉƉůLJ͘ Ɣ
džƚƌĞŵĞůLJ>ŽǁͲ/ŶĐŽŵĞĐĐĞƐƐŽƌLJǁĞůůŝŶŐhŶŝƚƐ͘ Ɛ ƉĂƌƚŽĨĂůĂƌŐĞƌƉůĂŶƚŽŝŶĐƌĞĂƐĞƚŚĞƐƵƉƉůLJ ŽĨĐĐĞƐƐŽƌLJǁĞůůŝŶŐhŶŝƚƐ;hƐͿ͕ƚŚĞŝƚLJƐŚŽƵůĚĐŽŶƐŝĚĞƌĐƌĞĂƚŝŶŐĂĨŽƌŐŝǀĂďůĞůŽĂŶƉƌŽŐƌĂŵ ĨŽƌŚŽŵĞŽǁŶĞƌƐǁŚŽďƵŝůĚhƐĂŶĚƌĞŶƚƚŚĞŵĨŽƌĂƚůĞĂƐƚϭϱLJĞĂƌƐĂƚ džƚƌĞŵĞůLJ>Žǁ/ŶĐŽŵĞ
ƌĞŶƚůĞǀĞůƐƚŽƉĞŽƉůĞǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐ͘
^ĂŵƉůĞ>ĂŶŐƵĂŐĞ͗^ƵďũĞĐƚƚŽĨƵŶĚŝŶŐĂǀĂŝůĂďŝůŝƚLJ͕ƚŚĞŝƚLJƐŚĂůůĚĞǀŝƐĞĂƉƌŽŐƌĂŵŽĨĨŝŶĂŶĐŝŶŐĨŽƌ ĐĐĞƐƐŽƌLJǁĞůůŝŶŐhŶŝƚƐƐƵďũĞĐƚƚŽƌĞŶƚƌĞƐƚƌŝĐƚŝŽŶƐĨŽƌĂƚůĞĂƐƚϭϱLJĞĂƌƐĂƚ džƚƌĞŵĞůLJ
>ŽǁͲ/ŶĐŽŵĞƌĞŶƚůĞǀĞůƐƚŽƉĞŽƉůĞǁŝƚŚĚĞǀĞůŽƉŵĞŶƚĂůĚŝƐĂďŝůŝƚŝĞƐǁŚŽǁŽƵůĚďĞŶĞĨŝƚĨƌŽŵ ĐŽŽƌĚŝŶĂƚĞĚŚŽƵƐŝŶŐƐƵƉƉŽƌƚĂŶĚŽƚŚĞƌƐĞƌǀŝĐĞƐƉƌŽǀŝĚĞĚďLJƚŚĞ'ŽůĚĞŶ'ĂƚĞZĞŐŝŽŶĂůĞŶƚĞƌ͘ Ɣ ĨĨŝƌŵĂƚŝǀĞůLJ&ƵƌƚŚĞƌ&Ăŝƌ,ŽƵƐŝŶŐ͘ EŽƚŽŶůLJŝƐĚŝƐĂďŝůŝƚLJ ƚŚĞŚŝŐŚĞƐƚͲƌĂŶŬĞĚƐŽƵƌĐĞŽĨ&Ăŝƌ ,ŽƵƐŝŶŐĐŽŵƉůĂŝŶƚƐ͕ĂŐƌŽǁŝŶŐďŽĚLJŽĨ^ĂŶDĂƚĞŽŽƵŶƚLJĚĂƚĂŝŶĚŝĐĂƚĞƐƚŚĂƚůĂĐŬ͕/ŶĚŝŐĞŶŽƵƐ ĂŶĚŽƚŚĞƌWĞŽƉůĞŽĨŽůŽƌ;/WKͿǁŝƚŚĚŝƐĂďŝůŝƚŝĞƐĞdžƉĞƌŝĞŶĐĞŚŝŐŚĞƌƌĂƚĞƐŽĨŚŽƵƐŝŶŐ ĚŝƐĐƌŝŵŝŶĂƚŝŽŶĂŶĚƐĞǀĞƌĞƌĞŶƚďƵƌĚĞŶƚŚĂŶĞŝƚŚĞƌ/WKǁŝƚŚŽƵƚĚŝƐĂďŝůŝƚŝĞƐŽƌǁŚŝƚĞƐǁŝƚŚ ĚŝƐĂďŝůŝƚŝĞƐ͘ƵƌƌĞŶƚůLJƚŚĞŝƚLJŽĨ^ĂŶDĂƚĞŽŽĨĨĞƌƐŝƚƐƌĞƐŝĚĞŶƚƐĞdžĐĞƉƚŝŽŶĂůĞŵƉůŽLJŵĞŶƚ͕ ĞĚƵĐĂƚŝŽŶĂůĂŶĚƐŽĐŝĂůŽƉƉŽƌƚƵŶŝƚŝĞƐďƵƚƚŚĞƐĞǀĞƌĞƐŚŽƌƚĨĂůůŽĨ džƚƌĞŵĞůLJ>Žǁ/ŶĐŽŵĞƵŶŝƚƐ
ŵĞĂŶƐƚŚĂƚ/WKͲͲƉĂƌƚŝĐƵůĂƌůLJƚŚŽƐĞǁŝƚŚĚŝƐĂďŝůŝƚŝĞƐͲͲĂƌĞƚŽŽŽĨƚĞŶĞdžĐůƵĚĞĚĨƌŽŵĞŶũŽLJŝŶŐ ϳ
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ƚŚŽƐĞĐŽŵŵƵŶŝƚLJĂƐƐĞƚƐ͘DƵůƚŝƉůĞďĂƌƌŝĞƌƐŝŶĐůƵĚŝŶŐŚŝŐŚůĂŶĚĂŶĚĐŽŶƐƚƌƵĐƚŝŽŶĐŽƐƚƐĂŶĚ ůŝŵŝƚĞĚĨƵŶĚŝŶŐŵĂŬĞŝƚĚŝĨĨŝĐƵůƚĨŽƌĚĞǀĞůŽƉĞƌƐƚŽƉƌŽĚƵĐĞ džƚƌĞŵĞůLJ>Žǁ/ŶĐŽŵĞƵŶŝƚƐƚŚĂƚǁŝůů
ŽǀĞƌĐŽŵĞƐƵĐŚĚŝƐƉĂƌŝƚŝĞƐ͘WŽůŝĐŝĞƐƚŚĂƚůĞĂĚƚŽŝŶĐƌĞĂƐĞĚƉƌŽĚƵĐƚŝŽŶŽĨ džƚƌĞŵĞůLJ>Žǁ/ŶĐŽŵĞ
ƵŶŝƚƐ͕ĂƐǁĞůůĂƐĐŝƚLJƐƚĂĨĨĚĞĚŝĐĂƚĞĚƚŽŝŵƉůĞŵĞŶƚŝŶŐĂŶĚŽǀĞƌƐĞĞŝŶŐƚŚŽƐĞƉŽůŝĐŝĞƐ͕ǁŝůů ĨĨŝƌŵĂƚŝǀĞůLJ&ƵƌƚŚĞƌ&Ăŝƌ,ŽƵƐŝŶŐŝŶƚŚĞŝƚLJŽĨ^ĂŶDĂƚĞŽĂŶĚĚĞĐƌĞĂƐĞĚŝƐƉůĂĐĞŵĞŶƚĂŶĚ ŚŽŵĞůĞƐƐŶĞƐƐŶĞƐƐĨŽƌƚŚĞŵŽƐƚĂƚͲƌŝƐŬŝƚLJŽĨ^ĂŶDĂƚĞŽƌĞƐŝĚĞŶƚƐ͘ ^ĂŵƉůĞ>ĂŶŐƵĂŐĞ͗dŚĞŝƚLJŽĨ^ĂŶDĂƚĞŽΖƐƉůĂŶƐƚŽĨĨŝƌŵĂƚŝǀĞůLJ&ƵƌƚŚĞƌ&Ăŝƌ,ŽƵƐŝŶŐĨŽƌůĂĐŬ͕ /ŶĚŝŐĞŶŽƵƐĂŶĚŽƚŚĞƌWĞŽƉůĞŽĨŽůŽƌ͕ƉĂƌƚŝĐƵůĂƌůLJƚŚŽƐĞǁŝƚŚĚŝƐĂďŝůŝƚŝĞƐ͕ƐŚĂůůŝŶĐůƵĚĞƉŽůŝĐŝĞƐ ĚĞƐŝŐŶĞĚƚŽŝŶĐƌĞĂƐĞƚŚĞƉƌŽĚƵĐƚŝŽŶŽĨ
džƚƌĞŵĞůLJ>Žǁ/ŶĐŽŵĞƵŶŝƚƐ͕ĂƐǁĞůůĂƐĂĚĞƋƵĂƚĞƐƚĂĨĨ
ĐĂƉĂĐŝƚLJƚŽŝŵƉůĞŵĞŶƚĂŶĚŵŽŶŝƚŽƌƚŚĞŝŵƉĂĐƚŽĨƚŚĞƐĞƉŽůŝĐŝĞƐ͘ ϴ
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TENANT-PROTECTION POLICY OPTIONS FOR SAN MATEO
Proposed by ONE SAN MATEO | For more information:
[email protected]
March 3, 2021
According to many sources, nearly 47 percent of San Mateo households are renters. On average, these renter households have significantly lower incomes than homeowner households. According to the Affordable Housing Task Force’s 2016 final report, median household income for renters at the time was $64,445, whereas the median household income for owners was $117,700. Faced with constrained incomes and high rents, many renters in San Mateo pay a disproportionately high percentage of their income on housing, and many renter households are badly overcrowded. Latinos and African Americans are affected in especially large numbers by these adverse conditions.

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

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

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

CLOSING GAPS AND LOOPHOLIES IN AB 1482

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

Since AB 1482 stipulates that just cause protections apply to tenants who have been in place 12 months or more, the ordinance deprives compliant tenants of the security they would have if the protections were to go into effect on Day One. The most effective way to address this shortcoming is to pass an ordinance requiring that the just cause provisions under AB 1482 go into effect on Day One. Many local city councils have adopted just cause policies that go into effect on Day One, among them San Jose, Hayward, Oakland, and Alameda. Most just cause policies exist in combination with rent stabilization, but not all.
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Resources on just cause policies adopted by local city councils:
x Information about Hayward’s just cause ordinance:
https://www.hayward-ca.gov/discover/news/mar19/just-cause-evictionprotections-extended-more-hayward-tenants x Article on Alameda’s just cause ordinance:
https://www.eastbaytimes.com/2019/06/05/alameda-adopts-additionalprotection-for-renters/ x Alameda city staff report from 5/21/19 with link to ordinance:
https://alameda.legistar.com/LegislationDetail.aspx?ID=3943916&GUID=B6 65E57F-45B4-4ECF-9269-3D98649DD5E3&Options=&Search=&FullText=1 A less effective approach to the problem is to pass a minimum lease requirement requiring that landlords provide tenants with the option of a one-year lease. This would provide tenants with security for the first year of tenancy but leave them vulnerable to eviction at the end of the first year before the just cause protections under AB 1482 go into effect.

Resources on minimum leases
x Menlo Park FAQ on minimum lease ordinance (with link to the ordinance):
https://www.menlopark.org/Faq.aspx?QID=386

x Redwood City minimum lease ordinance:
https://library.municode.com/ca/redwood_city/codes/code_of_ordinances? nodeId=CH42AMILETEREREUN

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

Under the terms of AB 1482, a landlord can evict a tenant if s/he intends to demolish or “substantially remodel” the property. The law says that the landlord has to be doing substantial modification that requires a permit from a governmental agency, that cannot be reasonably accomplished with the tenant in place, and that requires the tenant to vacate the property for at least 30 days. Now that there are fewer acceptable rationales for evicting tenants, landlords have manipulated the substantial remodel clause to their advantage. Shirley Gibson, attorney for Legal Aid of San Mateo County, said that in the months before COVID, “substantial remodel” was the most frequently chosen reason for 1067 of 2271
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60-day termination notices. She further said that when landlords were challenged about their intentions in the unlawful detainer process, it would often turn out that the plans were mostly cosmetic or possibly could be done within 30 days. In response to landlord abuses under the "substantial remodel" provision, several cities have passed an ordinance requiring that landlords obtain permits before serving tenants an eviction notice. Among these are Long Beach, Los Angeles and South Pasadena. The Long Beach and South Pasadena ordinances were passed by a unanimous vote. While One San Mateo has not yet confirmed the vote on the Los Angeles ordinance, we are aware that it was adopted as an urgency ordinance, which requires approval by at least three-fourths of the 15-member council.

Resources on renovictions:
x Article about Long Beach ordinance:
https://www.presstelegram.com/2020/02/18/long-beach-ordinance-tacklessubstantial-remodel-loophole-in-tenant-protection-act x Long Beach staff report from 2/11/20:
http://longbeach.legistar.com/View.ashx?M=F&ID=8060909&GUID=66F42 362-6D3D-4F94-B8E0-2106FFE60EBE
x Long Beach ordinance adopted with first reading on 2/18/20 with second reading on 3/11/20:
http://longbeach.legistar.com/View.ashx?M=F&ID=8075455&GUID=4EBE9 48B-965A-4FEE-8D72-873E14400F28
x Article about the Los Angeles ordinance adoption:
https://www.the-newinth.com/closing_a_loophole_in_the_tenant_protection_act

x Los Angeles ordinance:
http://clkrep.lacity.org/onlinedocs/2020/20-0203_ORD_186586_04-03- 2020.pdf
x Article about South Pasadena ordinance adoption:
https://southpasadenareview.com/city-council-passes-tenant-protection-forremodels/ 1068 of 2271
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3. Create a data registry to track compliance.

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

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

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

Resources on data registry:
x El Cerrito FAQ on rent registry:
https://el-cerrito.org/DocumentCenter/View/14344/FAQ_RentRegistry_2020-Final_v1 x El Cerrito rent registry ordinance:
http://www.el-cerrito.org/1356/Rent-Registry
x Article on Concord rent registry:
https://www.mercurynews.com/2021/01/15/east-bay-city-to-post-rentincreases-eviction-details-online x Concord municipal code describing tenant protection program, including rent registry:
https://www.codepublishing.com/CA/Concord/html/Concord19/Concord194

0.html#19.40.110
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x Link to January 12, 2021 Concord City Council meeting, Agenda Item 9A, when implementation details for the registry were discussed (what info should be collected, what would be made public, etc):
https://stream.ci.concord.ca.us/OnBaseAgendaOnline/Meetings/ViewMeetin g?id=578&doctype=1 (scroll to Agenda Item 9A for relevant documents) x Staff report from the January 12, 2021 Concord City Council meeting https://stream.ci.concord.ca.us/OnBaseAgendaOnline/Documents/ViewDoc ument/Agenda%20Staff%20Report%20for%20-
%20RENT%20REGISTRY%20REPORT%20INFORMATION%20(11054).pdf ?meetingId=578&documentType=Agenda&itemId=11054&publishId=7780&i sSection=false
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1082 of 2271
1 Sandra Council
From: Mary Way
Sent: Monday, February 7, 2022 4:31 PM
To: Joan Diskin
Cc: Sandra Council
Subject: FW: Joint Meeting on Housing Element
Hi Joan,
Here is another Public Comment for tonight’s meeting.

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

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

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

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

Funding:

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

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

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

On sites:

1. Beyond following state guidelines on the process for developing a sites list, look at publicly owned sites, including areas that are owned by other agencies, for the opportunity to provide affordable homes. 1083 of 2271
2 2. Also look at quasi public sites (churches, nonprofits). If an institution is interested in developing affordable homes, what steps (including rezoning) does the city need to take to enable that development.

Overcoming Constraints:

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

2. Strategies for parcel assembly

3. Lower your parking requirements, where appropriate

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

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

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

Thank you for your time and leadership.

Evelyn Stivers
Executive Director
Housing Leadership Council of San Mateo County
2905 S El Camino Real
San Mateo, CA 94403
510-334-3362 cell
www.hlcsmc.org
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February 28, 2022
Policy Recommendations for 6th Cycle Housing Element
Dear Planning staff:

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

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

Our policy goals are as follows:

Affirmatively Furthering Fair Housing

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

Many of the highest resource neighborhoods with the best access to jobs, good schools, and other amenities have histories of exclusion which are still reflected in their zoning. Cities should rezone to allow more housing opportunities in those neighborhoods, particularly those with low Vehicle Miles Traveled, as part of their 1 1097 of 2271
Housing Elements.

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

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

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

3. Support homeownership opportunities for historically excluded groups.

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

Site Capacity

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

5. Provide sufficient zoned capacity to accommodate all income levels, including a minimum No Net Loss buffer of 30%. Not every site will be developed at maximum density during the eight-year planning period. Identify an ample amount of opportunity sites and zone the sites to accommodate lower-income housing types (usually a statutory minimum of 30 dwelling units per acre) to give the city the best chance at meeting its RHNA. 1098 of 2271

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

Accessory Dwelling Units

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

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

Zoning

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

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

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

10. Allow flexibility in inclusionary zoning. Cities should require different percentages for different AMI levels. Additionally, we urge cities to incentivize land 1099 of 2271
dedication to affordable developers in order for market-rate developers to meet their inclusionary requirements. Avoid getting trapped into thinking that the affordable units must be “sprinkled throughout” the market-rate units, or require the market-rate units to look exactly the same as the affordable ones. This should be balanced against not locating all of the affordable units in one place and ghettoizing neighborhoods by creating or perpetuating racially concentrated areas of poverty.

Better Entitlement Process & Reducing Barriers to Development

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

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

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

14. Provide local funding. One of the largest barriers to building new affordable homes is the lack of city/county funds available to assemble sites, provide gap funding, and to pay for dedicated staff. Without new funding, especially at the local level, we will not be able to build more affordable homes. There are three 1100 of 2271
new revenue streams that should be considered: 1) Transfer tax, a one-time payment levied by a jurisdiction on the sale of a home, may be utilized to raise much needed revenue to fund affordable homes; 2) Vacancy tax may be collected on vacant land to convince landowners to sell their underutilized properties and be used to fund the construction of affordable homes; 3) Commercial linkage fees should be adopted or revisited for increases on new commercial developments.

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

Best regards,
Sonja Trauss
Executive Director
YIMBY Law
[email protected]
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Dear Sir or Madame,
Please accept the attached letter from the Carpenters Union as input on the San Mateo Housing Element. Thank you.

All the best,

Ed Evans
Senior Field Representative/Financial Secretary-Treasurer Local 217, San Mateo County
Nor Cal Carpenters Union
1113 of 2271

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

All the best,

Ed Evans
Senior Field Representative/Financial Secretary-Treasurer Local 217, San Mateo County
1128 of 2271

Nor Cal Carpenters Union
"Any time you have an opportunity to make a difference in this world and you don't, then you are wasting your time on earth." Roberto Clemente

1129 of 2271
1130 of 2271
1131 of 2271
1132 of 2271

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dŚĂŶŬƐĂŐĂŝŶ͕ĂŶĚŚĂǀĞĂŶŝĐĞĂĨƚĞƌŶŽŽŶ͘

1133 of 2271

Zachary Dahl, AICP
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From: Katrina Salas-Padilla < >
Sent: Sunday, May 22, 2022 9:56 PM
To: Clerk <[email protected]>
Subject: Draft 2023-2031 Housing Element Public Hearing Dear Mayor Bonilla and Members of the City Council:

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

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

Since I sent this letter to the planning commission, I have been in correspondence with commissioner Adam Nugent. He provided me with the current draft of the Housing Element, as well as his notes pertaining to the prior draft as well as this draft. I have reviewed each of those three documents extensively, as well as appendix D of the Housing Element. I am writing to say that I fully support his concerns, particularly those around affordable housing in the North Central neighborhood of San Mateo, and the lack of explicit planning on how to address this issue, along with other issues of segregation in San Mateo. I believe that, as it stands, the Housing Element fails to address In addition to supporting Adam's points, which he details in his notes on the current draft of the Housing Element that will be discussed tomorrow, Monday, May 23, I have some adjacent concerns detailed below:
x In the current draft of the Housing Element, I don’t see actionable evidence of real programs and policies intended to address issues of inequality, scarcity, and vulnerability among the low income population in San Mateo
x I am also struck by the fact that the North Central region was not identified as a location in need of more affordable housing, yet it cited multiple times throughout the Housing Element and subsequent appendices, that the region was “overcrowded”, thus I can only assume the assessment is made on a technicality that bases on raw volume of housing currently at or under market rate rather than the very observable fact that it still isn’t enough?
x I also don’t see acknowledgement around what COVID did to the rental and real estate market, which is an extremely temporary phenomena that will inevitably rebound and thus should be further factored into the immediate analysis regarding market value.

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

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

I appreciate your taking my concerns to heart when reviewing the Housing Element and subsequent city planning and development projects, particularly as they apply to the vibrant low-income and predominantly hispanic and latino communities in the North Central and North Shoreline neighborhoods of San Mateo. We should be contributing to a better, healthier community with real, sustainable longevity and opportunity for all of its members, and setting an 1138 of 2271
example for the greater Bay Area and state of California at large. We should not continue to contribute to the issues of displacement, segregation, inequality, and housing crisis by overlooking the obvious threat of improperly calculated developments and failing to follow through with creating programs and resources for those struggling to get by.

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

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

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

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

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

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

This is due to the fact that San Mateo possesses one of the most inspiring elements of any other city I’ve found in the SF Bay Area; an extremely diverse mix of races, ethnicities, and economic classes. The wealth gap here is very comfortably mended by a strong middle and upper middle class, and the surrounding cities are able to pick up the slack enough to prevent extreme inequality from doing what it does best; push people who do not deserve to suffer - to their very edge.
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The economic views that the Harvest Properties representative proposed in last night's meeting were, at best, very flawed. Sure, regions that have a history of being red-lined might make prime real estate for developers who allow the few who own properties in such regions to profit on their coat tails, but how many of the working class families in the north central San Mateo area that pushes out toward the bay actually own their homes? I’d like to remind you that the state of California has recently put several measures in place to strengthen tenants rights for renters. They are also making it much harder to out zone multi family complexes precisely for reasons of scarcity around affordable housing. I am not a legal professional, but I am a policy professional within the National Laboratory system, funded by the U.S. Department of Energy, and I believe that Harvest Properties’ pursuit of turning the corner of B St. and 1st in downtown San Mateo solely into a mid-rise commercial and office building could be illegal according to current state regulations, and it is certainly unethical.

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

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

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

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

I appreciate that two out of three of the commissioners who responded last night felt similarly to my above points, but to the one who did not; I encourage you to spend 15 minutes on this specific street corner at 9:45pm on ANY day of the week. It’s rather quiet, despite the train, and most of the dinner rush is gone by then. This includes most of the bar scene. Regardless, I lived in the heart of the Mission District as well as North Beach in San Francisco for a long time, and the bustle of a night scene is, for some people, very attractive. This might be especially true for the kind of people you want to work and live in a place like downtown San Mateo; young students, recent grads, working class people with strong work ethics. People who have a very long life and relationship to cultivate with this city - not just those who want to clog the streets on weekends for brunch and then leave like with Burlingame. 1140 of 2271
I will be sharing these concerns with other officials and interest groups who may also have a concern in the matter, and I will make an effort to continue to show up at planning meetings where this particular project is being discussed.

Respectfully,
Katrina Monet Salas-Padilla
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San Mateo City Council
Who:

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

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

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

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

Open for discussion.

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

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

Ah Sam and our family and staff have a plan to continue in this community. We have grown and want to make plans to continue to thrive and that will not be possible unless we are able to do something about affordable housing and parking. No we are not selling our property and No we are not going out of business. We have fought this battle since 1985 when the business transferred from the 2nd generation to the current generation. We invite each member of the Council, Mayor and planning staff to visit with us to discuss this more. 1144 of 2271

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Greetings, San Mateo Housing Element Update.

Can you please provide the most up-to-date list and map of the opportunity sites? Can you please tell me what the proposed densities and heights are as it relates to multifamily development? I assume those densities/heights cannot supersede Measure Y constraints, or can they? Please advise.

Kindly,
Blake Wellen
Bella Vista Land Advisors
Real Estate Brokerage & Development
www.bvla.net
1147 of 2271

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

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

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

1. Funding a dedicated study of parking reforms, particularly how smart parking policies could positively impact housing, transportation and other goals. 1 https://www.shoupdogg.com/wp-content/uploads/sites/10/2016/05/Cutting-the-Cost-of-Parking-Requireme nts.pdf
| WWW.TRANSFORMCA.ORG
1 1157 of 2271

2. Requiring unbundled parking for certain transit oriented developments.This is easier for building managers to implement now with new parking tech tools like Parkade.

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

To show the tremendous transportation and climate benefits of these policies, as well as some of the financial savings for residents and reduced costs for development, we have used our GreenTRIP Connect tool to create scenarios for a potential future development site at 480 N Bayshore Blvd. This site is identified in San Mateo’s draft Housing Element Site Inventory as a potential future opportunity site outside of any specific zoning district. The California Office of Planning and Research recommends GreenTRIP Connect as a tool to use while developing General Plans and is especially useful during the development of Housing Elements (the tool is free to use and supports better planning at the site and city-wide level).

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

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

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

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

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

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

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

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

1.6. Not only do these households use transit more and drive much less than average, but | WWW.TRANSFORMCA.ORG
2 1158 of 2271
success in this area can help provide homes for unsheltered individuals and families. A commitment to these programs will show that San Mateo is committed to planning for all levels of the 3,975 RHNA BMR units anticipated in this cycle.

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

Sincerely,
Kendra Ma
Housing Policy Analyst
| WWW.TRANSFORMCA.ORG
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Please share your comments regarding the Draft Housing Element.

Comment period for the draft document is April 6 through May 6, 2022. &ŝƌƐƚEĂŵĞ 7RP
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[1 of 1]

VIA EMAIL
October 24, 2022
Zachary Dahl
Deputy Director
City of San Mateo
Community Development Department
330 West 20th Avenue
San Mateo, CA 94403
RE: 2745 S. El Camino, San Mateo (APN 039-351-070) - Development Capacity Dear Mr. Dahl:

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

Sincerely,
Yosef Tahbazof, Esq.

Principal
CC:

Eloiza Murillo-Garcia
Christina Horrisberger





  







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Hello, San Mateo Planning.

When do you expect to send HCD an updated draft of the Housing Element Update? When will the updated draft be available to view?
Kindly
Blake Wellen
Bella Vista Land Advisors
Real Estate Brokerage/Investment
DRE #02130931
www.bvla.net
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DĂŬĞŶĂ
Makena Wong
Project Manager | San Mateo County Flood and Sea Level Rise Resiliency District (OneShoreline) OneShoreline.org
Pronouns: she/her
1164 of 2271
City of San Mateo
330 W 20th Ave.

San Mateo, CA 94403
To the honorable San Mateo City Council,
The Housing Leadership Council of San Mateo County appreciates this opportunity to engage the City of San Mateo on its housing element. Earlier this year, we sent the city two letters outlining opportunities to approve the initial draft of its housing element, one focused primarily on needs and constraints, the other focused on affirmatively furthering fair housing, the sites inventory, and the goals, policies, and programs.

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

It should be noted that HCD certification is not required for a housing element to be found substantially compliant with State law. State law provides that a local jurisdiction may adopt its own findings explaining why its housing element is substantially compliant with State law despite HCD’s findings. Thus, a local jurisdiction can continue to work with HCD to achieve certification of its adopted housing element after the deadline without being deemed out of compliance.

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

In order to plan for the needs of its entire community and comply with state law, San Mateo must revise large portions of its housing element as follows:

1. Adjust realistic capacity for sites within the inventory based on site-specific information, and remove unrealistic sites: Currently, San Mateo’s site inventory assumes all parcels will be built out to 100% of zoned capacity. On some sites, such as Hillsdale Mall, 100% buildout is inconceivable even if the city made dramatic policy 1165 of 2271
changes. 12 acres of the ~40-acre Hillsdale site were renovated within the past 3 years, making them extremely unlikely to become new homes anytime soon. Yet San Mateo’s current draft housing element assumes that 100% of the Hillsdale site will become new homes at 100% of zoned capacity, a clear violation of the law.1 In another example, the Bridgepoint Shopping Center recently renewed long term leases with several tenants, making development of the site highly unlikely. Unless the city can provide compelling evidence that these sites will be developed, such as property owner interest and the provision of favorable development standards, they must be removed from the inventory.2 As referenced earlier, Manhattan Beach has been sued twice for including sites that will not become housing in the next eight years within its inventory. Other sites have similar pre-existing uses that impede housing. Upon removal of unrealistic sites from the inventory and appropriate reduction of realistic capacity for other sites, San Mateo will no longer be able to demonstrate capacity to meet its Regional Housing Needs Allocations. As a result, the city will need to upzone beyond the limits created by Measure Y.

2. Fully analyze constraints to housing: The matrix of responses to HCD’s review letter provided by staff still makes no commitment to address Measure Y within the housing element. In its review letter, HCD writes “The element must describe the impacts of measure Y on height and density restrictions as a constraint on housing development and affordability. The element must add a program to include outreach and mitigation measures for the impact of Measure Y.” Addressing the constraint “as part of the GPU [General Plan Update] adoption process,” as staff offer in their matrix of responses, does not suffice. The housing element is a chapter of the general plan; as such, constraints to housing, including Measure Y, should be addressed within the housing element. HCD lists a number of other significant underanalyzed and unaddressed constraints, including discretionary review processes, development fees, and parking requirements.

3. Fully analyze Affirmatively Furthering Fair Housing: In its current housing element, San Mateo seeks to justify current patterns of segregation rather than analyze and address them. In fact, by concentrating all of its opportunity sites outside of San Mateo’s highest opportunity areas, the housing element actively promotes segregation. In order to satisfy AFFH requirements, the city needs new policies to protect lower-income renters and promote housing in its highest-opportunity areas.

4. Implement new policies and programs to increase validity of site inventory: Based on complete analyses of sites, constraints, and AFFH, San Mateo will need to implement new policies and programs. State law is particularly clear: Identified constraints must be 2 Gov. Code, § 65583.2(g)(2): “An existing use shall be presumed to impede additional residential development, absent findings based on substantial evidence that the use is likely to be discontinued during the planning period.”
1 HCD Site Inventory Guidebook, p. 20: “The capacity calculation must be adjusted to reflect the realistic potential for residential development capacity on the sites in the inventory. Specifically, when the site has the potential to be developed with nonresidential uses, requires redevelopment, or has an overlay zone allowing the underlying zoning to be utilized for residential units, these capacity limits must be reflected in the housing element.”
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removed to the extent possible.3 Programs must promote AFFH goals.4 HLC recommends the following programs:
○ Implement an affordable housing overlay focused on land owned by religious institutions and schools in high-opportunity single-family neighborhoods. The overlay should allow development standards at least as generous as the city’s R6-D development standards to provide maximum flexibility for these public and semi-public institutions to create new homes. Furthermore, proposals for housing on sites owned by religious institutions or schools should be exempt from design review hearings and limited to two planning commission hearings. (AFFH) ○ Implement a rental registry to track rentals and provide data to the city regarding prices and evictions. Data from a rental registry will help the city identify landlords violating the law and devise additional renter protections as needed. (AFFH) ○ Reduce fees on affordable housing, especially impact fees and open space fees.

Waive fees entirely for low- and very low-income units, defer them until reception of occupancy permit for moderate-income units. (AFFH, constraints) ○ Allow ministerial approval for all opportunity sites, eliminating design review and planning commission review. Discretionary review processes add cost and uncertainty to the development process; these processes also put a heavy burden on planning staff time, which the city is eminently short of. (constraints) ○ Reduce parking requirements by (1) requiring only 1 parking space for 1-bedroom, 2-bedroom, and 3-or-more-bedroom units (2) eliminating guest parking requirements throughout the city (3) eliminating parking requirements for units serving those with physical or mental disabilities. (constraints) ○ Upzone opportunity sites above Measure Y limits to promote viability of opportunity sites. The exact quantity of upzoning required will depend in part on the results of a complete site inventory analysis. HLC believes that, in order to demonstrate viability of opportunity sites, the city should rezone as follow:
i. Rezone R3, R4, R4-D, R5, R5-D, R6-D; all C1, C2, and C3 districts; and all E zoning districts to allow:

1. 85 feet height and 8 stories

2. Eliminate density cap

3. Eliminate minimum lot size

4. Increase FAR to 5
ii. Rezone CBD, CBD/S, TOD, and all C4 districts to allow:

1. 125 feet height and 12 stories
4 Gov. Code, § 65583(c)(10)(A)(v): “Strategies and actions to implement [AFFH] priorities and goals, which may include, but are not limited to, enhancing mobility strategies and encouraging development of new affordable housing in areas of opportunity, as well as place-based strategies to encourage community revitalization, including preservation of existing affordable housing, and protecting existing residents from displacement.
3 Gov. Code, § 65583(c)(3): “Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels.”
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2. Eliminate density cap

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

4. Eliminate maximum lot coverage

5. Eliminate private open space requirement

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

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

Thank you for your consideration,
Jeremy Levine
Policy Manager, Housing Leadership Council of San Mateo County 5 Community Opinion Survey: Summary Report, p. 12
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1169 of 2271
Stephen A. Finn
Principal and Founder
RE Management, LLC
160 Bovet Rd., Suite 408
San Mateo, CA 94402
San Mateo City Council
330 West 20th Avenue
San Mateo, California 94403
August 13, 2019
Re: General Plan Analysis of Borel Square / Hayward Park Station Area Dear Mayor Papan and Honorable Members of the City Council:

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

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

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

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

Second, I look forward to collaborating with your team and providing input on the future land use alternatives to be evaluated for Borel Square and the Hayward Park Station area. I believe there are positive opportunities available to strengthen the connection between Hayward Park and Borel Square, improve the streetscape along Bovet Road and 17th Avenue, and encourage greater walkability, bikeability, and use of public transit. I applaud the City’s goal of encouraging greater 1170 of 2271
Mayor Papan and
Honorable Members
of the San Mateo City
Council
August 13, 2019

Page 2 ends

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

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

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

Thank you for making the General Plan Update a priority and for thoughtfully considering the input you are receiving from the community.
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-1-
April 15, 2022
Via Electronic Mail
Christina Horrisberger, Community Development Director
Zach Dahl, Deputy Community Development Director
City of San Mateo
330 West 20th Avenue
San Mateo, CA 94403
RE: Hillsdale Shopping Center—Preferred Land Use Scenario Dear Ms. Horrisberger and Mr. Dahl,
We are writing on behalf of the Bohannon Development Company and our joint venture partner, Northwood Investments Corporation, the owners of the Hillsdale Shopping Center (the “Owners”) located at 60 31st Avenue in San Mateo, CA (the “Site”). Thank you for the opportunity to submit our preferred land use map for the City Council’s consideration on April 18, 2022.

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

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

Therefore, as you can see on the attached “Preferred Alternative” exhibit, we are proposing the Mixed-Use High designation for the parcels closest to the Hillsdale Caltrain Station and along El Camino Real, while proposing Mixed-Use Medium for the interior of the Site, with a Transitional Buffer zone to the adjacent neighborhood. We also would like to adjust thethe boundary of the Study Area to include parcel 042-121- 090 currently a portion of the Hillsdale Garden Apartments. The exclusion of this parcel, contiguous to the Hillsdale Mall parcel (South Block),creates a mid-block transition that we think hinders the flexibility necessary to plan for the site in the future. This site is 1172 of 2271
-2-
currently occupied with aging housing stock that will be in need of investment in the coming years. Inclusion of this land in the study area will allow greater flexibility in how we answer the community’s call for adding housing, especially affordable housing, in reimagining Hillsdale. Inclusion of this parcel, provides an opportunity to think holistically about the future of Hillsdale and avoids having awkward mid-block transitions that can be an impediment to good design and planning.

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

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

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

Thank you for your consideration.

Sincerely,
David Bohannon
Attachment 1: Preferred Land Use Map
cc: Drew Corbett, City Manager
Rick Bonilla, Mayor
Diane Papan, Vice Mayor
Eric Rodriguez, Council Member
Joe Goethals, Council Member
Amourence Lee, Council Member
Margaret Williams, Planning Commission Chair
John Ebneter, Planning Commissioner
Adam Nugent, Planning Commissioner
Seema Patel, Planning Commissioner
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[1 of 1]

VIA EMAIL
2745 El Camino, LLC
5042 Wilshire Blvd #39799
Los Angeles, CA 90036
October 24, 2022
Zachary Dahl
Deputy Director
City of San Mateo
Community Development Department
330 West 20th Avenue
San Mateo, CA 94403
RE: 2745 S. El Camino, San Mateo (APN 039-351-070) - Development Capacity Dear Mr. Dahl:

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

Sincerely,
Yosef Tahbazof, Esq.

Principal
CC:

Eloiza Murillo-Garcia
Christina Horrisberger





  







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Nicholas Hamilton <[email protected]>
FW: Meeting Followup and Commentary on RWC Housing Element Nicholas Hamilton <[email protected]> Fri, Dec 23, 2022 at 3:23 PM To: Nicholas Hamilton <[email protected]>
From: Jeremy Levine
Sent: Tuesday, December 20, 2022 9:31 PM
To: Manira Sandhir ; Eloiza Murillo-Garcia ; Zachary Dahl ; Diana Elrod - D.R. Elrod and Associates/Solutions for Affordable Housing
Cc: Evelyn Stivers
Subject: Meeting Followup and Commentary on RWC Housing Element Good evening Manira, Eloiza, Diana, and Zach--Manira and Eloiza, it was a pleasure to talk with you last week. Thank you for taking the time to help me better understand staff's perspective. We're all working to get San Mateo the best housing element possible, and I appreciate the opportunity to share HLC's perspective on what that looks like.

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

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

RWC also rezoned single-family neighborhoods along a number of dimensions to allow smaller units on smaller lots. And they cut parking requirements in half throughout the city. (Not just in the 1/2 mile around transit required by state law, but EVERYWHERE.) 1176 of 2271
It also really helps that RWC is donating city-owned land to support affordable homes. We are looking for subsidy of some form, land, money, or ideally both!
And the good policies continue. Redwood City is making big commitments to follow through on implementing its anti-displacement plan; streamline permit processing for 100% affordable housing developments; entirely eliminate a cap on new units in the downtown; and revise the city's affordable housing ordinance to remove city discretion over AH projects.

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

As we discussed, HLC does not see theoretical upzoning in the general plan in the future equivalent to upzoning in the housing element today, as the housing element is a legally binding contract with the state and the general plan is, well, not. Considering its past track record of development and the constraints to housing present in the city, San Mateo may need to make commitments within the housing element to upzone opportunity sites in order to justify its site inventory. HLC has argued that the city in fact must rezone, but we are willing to wait and see what HCD requires. 1177 of 2271
However, I continue to believe that San Mateo staff should be prepared to undergo a potentially long period of housing element noncompliance if HCD finds that the city's opportunity sites cannot be justified under current zoning, which would require new rezonings and a time-consuming housing element EIR. HLC would have preferred that the city study the potential environmental impacts of upzoning earlier in this process so that the council would have had the option to rezone now if necessary, but the city did not take that prudent course of action at an earlier time, and so we are faced with the present high-risk circumstances. If possible, HLC wants to help the city satisfy HCD, but we are reluctant to support a housing plan that includes so few incentives for development on the proposed opportunity sites. We look forward to seeing the city's new draft at the end of the month, hopefully with more policies that we can support wholeheartedly.

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

Regards,
Jeremy
--
Jeremy Levine (he • him)
Policy Manager
Housing Leadership Council of San Mateo County
2905 El Camino Real
San Mateo, CA 94403
www.hlcsmc.org
650.242.1764
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THOMAS B. MAYHEW CHARLES J. HIGLEY
December 16, 2022
Via E-Mail
Planning Manager
City of San Mateo
Planning Division
330 W. 20th Avenue
San Mateo, California 94403
E-Mail: [email protected], and
Re: Draft Housing Element for City of San Mateo 2023-2031 Comments of Housing Action Coalition
Dear Planning Manager:

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

Below, we identify two significant issues to be addressed as San Mateo continues to work on formulating an acceptable Housing Element. First, San Mateo has included a number of sites that do not have a realistic likelihood of becoming housing during the next eight years, as required to meet the need for new housing. The inventory includes a major shopping center and a regional mall and claims that these are housing sites that will redevelop in the next eight years, despite busy stores, new long-term leases, and even multimillion dollar improvements that conclusively demonstrate that the current retail uses will continue. Second, San Mateo’s methodology for identifying how much of the regional need will be met by the sites on the inventory appears both unprincipled and inconsistently applied. In order to properly evaluate whether the site inventory will meet the needs of San Mateo’s anticipated population growth, San Mateo needs to formulate a proper methodology and then apply it consistently, and explain 1 The Housing Action Coalition is a nonprofit that advocates for building more homes at all levels of affordability to alleviate the Bay Area and California’s housing shortage, displacement, and affordability crisis.
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how it evaluates site-specific information, other potential uses of the property, and market evidence on what is likely to actually be built.

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

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

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

Government Code § 65583.2(g)(1).

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

1. The Bridgepointe Shopping Center
(APN 035-466-010, -070, -080, -090, -100, -110)
The City’s sites inventory lists several parcels that together make up the Bridgepointe Shopping Center, a popular regional mall described by owner CBRE as “one of the premier power centers in the Bay Area.” Together, the parcels comprising Bridgepointe account for 1,188 total housing units in the site inventory. Of these, 241 units would be for Very Low income residents, and 180 would be Low income residents. 1183 of 2271
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The bulk of the units the City identifies for the Bridgepointe property would be contained on parcel 035-466-100, which the City describes in Appendix C, Table A as a “large parking lot, larger than .5 acre, potential for structured parking.” As an initial matter, HCD’s guidance for conducting the sites analyses provides that “[a] parcel smaller than one half acre or over 10 acres is considered inadequate to accommodate housing affordable to lower income households, unless the housing element demonstrates development of housing affordable to lower income households on these sites is realistic or feasible.” At 12 acres, this parcel is presumed to be inadequate without more specific information demonstrating feasibility. Aside from a vague mention on page H-34 of “a variety of discussions” with the owner of the shopping center, we have not found any such information in the City’s draft Housing Element or in the public discourse that demonstrates the feasibility of re-developing the site for housing. Nor does the City show that there is a history of successful developments of this size by affordable housing developers. For this reason, parcel 035-466-100 should be excluded from the sites inventory.

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

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

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

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

One possible explanation for the City’s inclusion of the Bridgepointe parcels, despite clear evidence the existing retail uses on the site are likely to continue for the foreseeable future, is that the City’s analysis seems to rely heavily on the availability of the parking lots associated with the shopping center. Presumably the logic here is that, because they are surface parking lots that aren’t occupied by other existing structures, they could theoretically accommodate construction of housing, while the requisite parking to serve the retail uses could be 1184 of 2271
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accommodated in one or more newly constructed parking garages. While this is theoretically true and makes sense as a matter of spatial arrangement, nothing in the City’s draft demonstrates that redevelopment of this nature is likely or would be legally feasible under the retailers’ leases.

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

2. Hillsdale Mall
(APN 042-121-040, -060, -080; 039-490-050, -170; 039-353-010, -020, -030, - 040)
The site of the Hillsdale Shopping Center, including surrounding parking lots and buildings (listed as Consolidated Site X on the draft Housing Element), is projected to provide 912 lower income units towards the RHNA. The assumption is that 100% of the acreage will redevelop at 100% of the maximum density for the site: 50 dwelling units per acre.

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

As the comment by Housing Leadership Council of San Mateo County has previously noted, the Hillsdale Mall recently rebuilt a significant portion of the retail mall at Hillsdale. The single largest parcel at the site (APN 039-490-170, comprising 39.91 acres) was significantly redeveloped for retail and entertainment uses. Known as the “Hillsdale North Block,” it was a massive project involving the demolition, redesigning, and reconstructing of existing buildings, and constructing two new ones, on 12.5 acres of the site.2 The construction loan for the project
was $240 million.3
Opened in November 2019, Hillsdale North Block has new stores, restaurants, a new multiscreen movie theater, and even a new upscale bowling alley. The remodeled structure ties into existing retail structures on the same parcel, including a two-story parking garage used to provide parking for the new retail and entertainment spaces, and a food court built over 31st Avenue, extending over to the Nordstrom’s building on the other side of 31st (in the older portion of the mall, which includes Nordstrom’s and Macy’s as anchor tenants). The food 2 Details on this project are available on the City Planning Department’s website at:
https://www.cityofsanmateo.org/DocumentCenter/View/47652/Hillsdale_Shopping_Center_Nort h_Block_Initial-Study--Mitigated-Negative-Declaration?bidId 3 HAC Appendix Tab 7. This January 2022 article also quotes the new co-owner of Hillsdale Mall as stating: “We are confident that Hillsdale Shopping Center will continue its meaningful presence in the city for years to come.” See also HAC Appendix Tab 8. 1185 of 2271
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court/pedestrian bridge, remodeled as part of the Hillsdale North Block improvements, shows that the retail uses to the south of 31st Street also continue to be part of the owner’s long-range plans.

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

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

A proper analysis under Government Code section 65583.2(g)(1) would preclude the City from making the required finding that this site is suitable, available, and realistic for affordable housing under 65583.2(g)(2), because existing uses are not likely to discontinue during the next eight years. A site of this size is also presumed to be insufficient to meet the needs for affordable housing, absent evidence of successful affordable housing developments of this size or special reason to believe that one would be successful here. Government Code § 65583.2(c)(2)(B). San Mateo shows neither.
4 These businesses are on APNs 039-490-050, and 042-121-040, -060, and -080, an area labeled as “Hillsdale South.” They are on the south side of West Hillsdale Boulevard from the main mall site on APN 039-490-170. Building permits indicate that $1.7 million in renovations was done in the 2009-2010 time frame when Trader Joe’s and other businesses were moving in; more recently, $150,000 of work was done on the interior in 2021, when Sleep Number opened a store there. BD-2021-279007; BD-2009-233895; BD-2009-34436; SG-2021-279679. Publicly available information shows that Sleep Number has a lease running into 2028. HAC Appendix Tab 10. Other building permits show substantial renovations and construction work done for the current tenants. When DSW (a shoe store) moved in, over $600,000 of improvements were done. BD-2011-240083, BD-2011-240152. When AT&T moved in next door to DSW, at 31 West Hillsdale Boulevard, over $1.8 million of construction was done; a Macaroni & Grill restaurant on the site was demolished and the AT&T building was constructed at the same location. BD-2016-260718, BD-2016-260255, BD-2017-263360. The AT&T construction was completed relatively recently: permits were signed-off and closed in 2018. It is not “likely” that these existing uses will discontinue in the next eight years. 1186 of 2271
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3. The Atrium: 1900 South Norfolk Street
(APN 035-391-090)
The executive office building located at 1900 South Norfolk Street is currently used by a large number of office tenants. The draft Housing Element does not perform any analysis of the current use, including whether existing leases would create obstacles to residential development of the site during the next eight years. Publicly available information indicates that a number of leases continue to be signed or renewed for this three story office building, with at least one lease publicly reported to extend until 2030. HAC Appendix Tab 9. The City should perform the required analysis under Government Code section 65583.2(g)(1), and evaluate whether it has substantial evidence to make the finding that existing uses are “likely to discontinue” during the next eight years, as required by section 65583.2(g)(2). If not, it should not be claimed to meet the need for 99 lower income affordable housing units, even if the owner has expressed a longterm interest in redevelopment.

4. Borel Shopping Center (71-77 Bovet; 1750 El Camino Real) (Consolidated Site AH: APN 039-011-450, -460, -470, -480, -500, -510) This site is a busy shopping center anchored by a CVS Pharmacy, a 24 Hour Fitness,5 a
branch of Patelco Credit Union, a UPS store, and a separate restaurant building for Jack’s Restaurant and Bar. There is publicly available information showing that the lease for Jack’s extends well into the planning period. HAC Appendix Tab 11 (indicating Jack’s lease extends from 2013-2029). The City should do the required section 65583.2(g)(1) analysis of the existing leases, and current market demand for the retail uses at the location. The City currently lacks substantial evidence that the site’s existing use is “likely to be discontinued” during the next eight years. It should not count towards 85 units of housing affordable to lower income households.

5. The Elks and The Shriners – 229 W. 20th Street and 150 W. 20th Street (APN 037-052-350 and APN 039-030-220)
The Benevolent and Protective Order of Elks, Lodge 1112 (“San Mateo Elks Lodge”), has been located at 229 W. 20th Street since 1954. The San Mateo Elks Lodge has a membership of over 1,100 as of earlier this year. The Elks use their lodge to operate a popular swimming center for kids and families, hold crab feeds and other events in the meeting hall, and engage in fun activities and philanthropic works.

The only suggestion that the San Mateo Elks are not likely to continue their existing use of the Elks Lodge at 229 W. 20th Street is the statement on the site inventory that “Preliminary 5 In 2008, the 24 Hour Fitness substantially modified the building it occupies 2008 when it moved into a space formerly occupied by Albertson’s. It added locker rooms, a swimming pool, basketball courts, showers, and other tenant improvements at a cost exceeding $2.2 million. BD2007-230493; BD-2007-230029; BD-2008-230692. 1187 of 2271
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conversations with the owner to convert to residential have occurred.” That kind of statement might sometimes go unnoticed and unquestioned by the City Council, HCD, or a court. But here, no one should take it as an adequate answer to the question of whether the San Mateo Elks will stop using their lodge in the next eight years. The reason is that the 2015 Housing Element, when listing the same site, said the same thing, word-for-word: “Existing private member club.

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

Government Code § 65583.2(g)(2).

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

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

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

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

6 In order to rely on conversations purporting to express intent, the public needs to know much more. Who had the conversation cited by the City, and with whom did they have it? Has the Lodge taken any affirmative steps toward redevelopment beyond this conversation? Without more, the vague reference to “preliminary conversations” between unidentified speakers on an unidentified date does not constitute “substantial evidence.” 1188 of 2271
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6. Mollie Stone’s – Olympic Shopping Center
(Consolidated Site AD:

APN 042-242-050, -060, -070, -160, -180;
042-243-020, 042-244-040, -050;
042-245-040, -050, -060, -070, -080, -090, -100, -110, -120, -130; 042-263-010, 042-264-010)
This site, consisting of twenty parcels, is claimed to accommodate 161 units of housing affordable to those with lower incomes. The only basis for including it appears to be the claim that there is “ownership interest in specific plan redevelopment,” which does not indicate that all of the parcels would be redeveloped as housing at the maximum density, or indicate who said what to whom, and when.7
Meanwhile, and as discussed further in section B below, the draft Housing Element does not adequately analyze or demonstrate the realistic capacity of the site. Under section 65583.2(g)(1), for a nonvacant site like this, the city must “specify the additional development potential for each site within the planning period.” The required analysis is currently missing. A realistic assessment of the current uses and market conditions would preclude listing the entire site at maximum density. Mollie Stone’s is the only full service grocery store in the surrounding area. For households in the southwestern portion of town (for example, everyone near Laurel Elementary School and south to the Belmont border), closing Mollie Stone’s would more than double their travel times to the nearest grocery, and extend them well beyond the one-mile used to define a “food desert” – a condition no one expects to develop in this well-resourced city.8

Currently San Mateo’s land use pattern follows the predictable pattern: few, if any, households are more than one mile from a grocery. There is no reason to believe that the market need for grocery stores will make the need for Mollie Stone’s, or another grocery store, superfluous in this part of town. Particularly as San Mateo’s population grows, the need for grocery stores will increase, not diminish.
7 Here too, the concern about specificity is not idle. There are five separate owners.

Carstens Realty owns most of the parcels, but CLC Investments, Sadigh Sassan, Shamco E LLC, and San Mateo Investment Co. each own one. The City does not discuss or address whether the five are willing or interested in a joint project, though it lists each of them as having expressed interest in a specific plan. Without evidence of what makes consolidation likely, the smaller sites are deemed insufficient to accommodate the need for lower income housing. See Government Code § 65583.2(c)(2)(A).
8 If Mollie Stone’s closed, and no grocery store was rebuilt in its place, it would create the unlikely situation where an affluent, urban community became a “food desert.” The United States Department of Agriculture has defined a “food desert” as an area where at least 500 people, or 33 percent of the tract population, reside more than one mile from a full service supermarket. https://www.ers.usda.gov/webdocs/publications/45014/30940_err140.pdf. 1189 of 2271
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This means that any redevelopment or specific plan of the Olympic Shopping Center will almost certainly include a substantial retail component, at least on the ground floor. Mixed use may be a responsible way to increase density, but it precludes listing the site at maximum density, particularly given the constraints of Measure Y. The City must conduct further analysis, including an analysis of existing leases, common ownership, and market conditions, before claiming that this site will meet the needs for construction of 161 units of housing affordable to lower income households. And, given the substantial demand for the existing use, the City may not be able to make the required finding under 65583.2(g)(2).

7. Site AN (4100 and 4142 El Camino Real)
(APN 042-242-170 and -080)
On the draft Housing Element site inventory, consolidated Site AN consists of a Cityowned vacant site and a neighboring parcel. In a recent staff report for the November 7, 2022 meeting, the chart responding to HCD comments indicated that the City had two city-owned sites: the “Talbot’s” site (APN 034-179-050 and -060), and APN 042-242-170, which it referred to as the “Ravioli” site. The chart indicated that staff recommended adding to the narrative about the Talbot’s site, but recommended removing the Ravioli site from discussion.

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

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

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

The draft Housing Element states that the site inventory “generally” calculates the realistic capacity of each site based on the maximum density, unless the site is smaller than 0.5 acres or has “characteristics similar to the outlier projects,” in which case a density of 18.2 units/acre is used. Draft Housing Element at H-30 to H-31. The HCD comment letter noted that the assumed densities are not sufficiently supported, and we understand that staff is working on a re-draft to take this comment into account. We offer the following comments about the existing draft to aid in this process.
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Under section 65583.2(c)(1) and (c)(2), a City that lacks a required minimum residential density for a site, like San Mateo, must “demonstrate how the number of units determined for that site will be accommodated.” Under (c)(2), “the number of units calculated pursuant to paragraph (1) shall be adjusted, as necessary, based on the land use controls . . ., the realistic development capacity for the site, typical densities of existing or approved residential developments at a similar affordability level in that jurisdiction, and on [availability of utilities].” Section 65583.2(g)(1) layers on additional requirements to analyze nonvacant sites: the city is required to “provide an explanation of the methodology used to determine the development potential,” and to consider a number of statutory factors.

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

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

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

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

Meanwhile, of those sites that did include some residential development, the development was not always 100% residential. Eight of the fifteen projects in table 15 were less than 100% residential. Combined with the five entirely nonresidential projects, 13 of 20 projects listed were not 100% residential. Under the HCD guidance and statutory mandate to consider typical experience with development, the City should apply a significant adjustment downward from maximum density to account for the very real probability that some of the sites may develop for 1191 of 2271
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