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CITY OF SAN MATEO
Agenda Report
City Hall
330 W. 20th Avenue
San Mateo CA 94403
www.cityofsanmateo.org
Agenda Number: 17 Section Name: {{section.name}} Account Number: File ID: {{item.tracking_number}} TO: City Council
FROM: Alex Khojikian, City Manager
PREPARED BY: Community Development Department
MEETING DATE: May 20, 2024
SUPPLEMENTAL CONTENT ADDED: May 20, 2024 (Highlighted in Attachments Section) SUBJECT:
General Plan Amendment to Adopt San Mateo's Revised 2023-2031 Housing Element RECOMMENDATION:
Adopt a resolution to approve a General Plan Amendment to adopt the Revised Housing Element for the Sixth Housing Cycle (2023-2031) that is compliant with State law, provides a plan for at least 10,286 new housing units, and affirmatively furthers fair housing, and is exempt from review under the California Environmental Quality Act, based on the identified findings.
BACKGROUND:
The City of San Mateo (City) has prepared an update to the Housing Element of the General Plan to affirmatively further fair housing and accommodate the City’s 7,015-unit Regional Housing Needs Allocation (RHNA) for the Sixth Housing Element Cycle (2023-2031). The content of the 2023-2031 Housing Element is structured for consistency with the requirements set forth in State law. In addition to responding to requirements of State law, the Housing Element also demonstrates the City’s strategy to meeting its housing needs as determined by local and regional growth projections through identification of sites as well as policies and programs that promote housing development in the City.
This staff report provides a summary of the Housing Element requirements and an overview of the review and engagement process with the California Department of Housing and Community Development (HCD). On January 19, 2024, HCD determined that the City’s draft Housing Element was in substantial compliance with Housing Element law (Government Code Section 65580 et seq.).
Since 1969, California has required that all local governments (cities and counties) adequately plan to meet the housing needs of their community. Local governments meet this requirement by adopting housing elements, which in the ABAG area are updated every 8 years. The housing element is a "chapter” of a city’s General Plan, which is also required by State law. However, it is the only element of the General Plan subject to State requirements for content, and HCD makes a determination regarding whether it is consistent with state law. State funding programs for transportation, infrastructure, and housing often require or consider a local jurisdiction’s compliance with housing element law and whether HCD has approved the housing element. In addition, non-compliance with housing element requirements could potentially affect a local jurisdiction’s ability to impose local zoning and land use controls over housing development and receive certain types of State funding and grants.
For the current eight-year housing cycle (2023-2031), HCD has identified the nine-county Bay Area region’s housing need to be 441,176 units, with this number broken down into four income categories, from very low-income households (which includes extremely low) to market rate housing. This Regional Housing Needs Determination (RHND) is based on
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population projections produced by the California Department of Finance (DOF) as well as adjustments that incorporate the region’s existing housing need in 2020 and 2021 and other factors. The City of San Mateo’s Regional Housing Needs Allocation (RHNA) for this housing cycle is 7,015 new housing units distributed across the four income groups as outlined in Table 1.
Table 1: San Mateo RHNA Targets Summary
Income Category Very Low
50% AMI
Low
80% AMI
Moderate
120% AMI
Above
Market Rate Total
2023-31 Allocation 1,777 1,023 1,175 3,040 7,015
The Housing Element identifies how the City can accommodate its RHNA of 7,015 new units over the next eight years, and establishes goals, policies and programs to help address the City’s current and future housing needs. The draft City Council resolution to adopt the Revised Housing Element is included as Attachment 1. The findings included in the Resolution outline how the Revised Housing Element is compliant with State law, provides a plan for to accommodate 10,286 new housing units, and affirmatively furthers fair housing, and is exempt from review under the California Environmental Quality Act (CEQA). The CEQA Exemption Technical Memorandum, which provides information to support the finding that the Housing Element is exempt from further environmental review, is included in Attachment 2. The HCD letter finding that the Revised Housing Element will substantially comply with State Housing Element Law is included as Attachment 3.
DISCUSSION:
2023-2031 Housing Element
The City’s Housing Element is included as Attachment 4, and contains the following eight sections:
1.Introduction and Background - Includes the history of San Mateo, the legislative framework for housing, consistency and relationship with other General Plan Elements, and a discussion on water/sewer capacity.
2.Housing Needs and Sites Inventory - Describes the City’s housing needs summary, RHNA allocation, sites inventory methodology, an overview of the adequate sites list and focused discussions on various areas that will support increased housing production (i.e. Accessory Dwelling Units, City Properties and Projects, the General Plan Update and Missing Middle Housing). A capacity of up to 10,286 housing units could be accommodated on the properties listed in the Sites Inventory under the City’s existing land use and zoning designations.
3.Other Required Housing Element Components - Provides an overview of the City’s governmental and non- governmental constraints to meet its housing goals, summarizes existing and potential housing resources, and describes the climate change context and energy conservation requirements for new housing developments.
4.Public Participation - Summarizes the City’s efforts to engage with the community, including under-represented groups, key accomplishments of the outreach efforts over the past two years, critical take-aways from the community input, and how this input was incorporated into the Housing Element’s goals, policies and programs.
5.Affirmatively Furthering Fair Housing (AFFH) Assessment - Provides an overview of AFFH requirements, a history of segregation in the region, and an assessment of San Mateo’s AFFH issues with primary findings, contributing factors, and the AFFH action plan.
6.Housing Plan - Describes the policies, programs, implementing actions, and timelines associated with the City’s five goals for production and preservation of housing, protection of its residents, promotion of outreach and education, and affirmatively furthering fair housing.
7.Quantified Objectives - Includes an estimate of actual housing units that could be achieved via preservation and production, given available resources, as well as projected pipeline projects anticipated for completion over the eight-year housing cycle.
8.Review of Prior Housing Element - Highlights key accomplishments, challenges and opportunities from the previous housing cycle (2015-2022).
The Housing Element includes six technical appendices that provide detailed analysis and information that support the findings and conclusions in the main document. These technical appendices are included in Attachments 5 to 11.
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Goals, Policies and Programs
Housing needs in the City are significant, especially for very low-, low-, and moderate-income households. These needs affect the entire community, but disproportionately impact underrepresented, special needs, and ethnically diverse populations. Therefore, the Housing Element specifically focuses on the need to affirmatively further access to housing and promote fair housing policies and programs. Over the past two years, Staff conducted extensive community outreach, including 19 public meetings, four surveys, and numerous pop-up events, to inform the approach for addressing these needs in the Housing Element.
Based on the City’s RHNA allocation, constraints analysis, AFFH issues, and input from the community, consultant team, and decisionmakers, the Housing Element articulates the following five goals to shape policies and programs:
Goal 1 – Production. Facilitate and support the production of new housing at all income levels, but especially affordable housing. Twenty policies with 52 implementing actions have been identified to support this goal. Goal 2 – Preservation. Preserve existing housing that is affordable to lower- and middle-income residents. Six policies with 13 implementing actions have been identified to support this goal. Goal 3 – Protection. Protect current residents to prevent displacement. Seven policies with 17 implementing actions have been identified to support this goal.
Goal 4 – Promotion. Promote social resilience through public education and community outreach to make information more available and accessible. Five policies with 12 implementing actions have been identified to support this goal.
Goal 5 – Affirmatively Furthering Fair Housing. Address the issues of fair housing, equity and access while reinforcing the objective that affirmatively furthering fair housing is both a stand-alone priority and decisively inseparable from achieving the Housing Element’s other goals. Fifteen policies with 22 quantified objectives have been identified to support this goal.
To support attainment of the five goals, each policy identifies the lead department, funding source if known, target work plan or program measure(s), implementation action(s), and a timeline, to provide an adequate level of specificity and accountability. Many of the polices also include metrics with specific targets or quantified objectives.
Sites Inventory and RHNA Strategy
The purpose of the adequate sites list (Sites Inventory) is to evaluate whether there are sufficient sites with appropriate zoning capacity (density) to meet the City’s RHNA goal. The Sites Inventory analysis was established based on a methodology consistent with state law and accepted by HCD that identifies sites likely to redevelop during the planning period. The methodology included a review of factors required by statute, including the extent to which existing uses may be an impediment to additional residential development, the City’s past experience with converting existing uses to higher density residential development, market demand for the existing uses and for residences, leases (where information was available), development trends in the City over the past five years, regulatory incentives (especially the use of state density bonus law), and expressed interest or applications from developers and letters from property owners. However, the Housing Element does not dictate where residential development will actually occur or what owners must do with their property.
In determining whether sites were likely to redevelop in the planning period and whether existing uses would constitute impediment to redevelopment, the City used a conservative methodology to estimate the development potential of each property included on the Sites Inventory. The methodology considered sites individually and determined whether they were likely to redevelop in the planning period based on ten specific factors, as described in Appendix C: owner or developer interest; developer ownership; previous proposals for development; vacant sites; sites containing limited improvements, such as parking lots; and sites meeting three of the following five factors: uses similar to those redeveloped in the past; structure age; single-story buildings; improvement to land value; and lot coverage. Other factors considered on a site-by-site basis included floor area ratio, location and context, local knowledge, and environmental and infrastructure constraints. The City’s conservative assumptions for unit-type distributions for most sites between 0.5 and 10 acres assumed an income distribution that is aligned with the City’s RHNA distribution and much lower than the 100% lower income allocation that is allowed by State law. The Sites Inventory in Appendix C of the Housing Element was updated to
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create site specific data sheets for some of the larger sites to adequately demonstrate their suitability for housing development and to provide additional information and analysis to support inclusion on the Sites Inventory. Based on this analysis, the City has capacity for potential development of up to 10,286 housing units, or 146% of the City’s RHNA. This development capacity exists within the City's current zoned densities and does not require any rezoning to achieve. Table 2, on the following page, provides a summary breakdown of the properties included on the Sites Inventory by income category and opportunity area.
Table 2 - San Mateo Sites Inventory Breakdown
Housing Opportunity
Areas
Total Units Very Low Low Moderate Above Moderate
(Market Rate)
San Mateo RHNA 7,015 1,777 1,023 1,175 3,040
ADUs 440 132 132 132 44
Pipeline Projects* 3,110 562 14 2,534
Remaining RHNA 3,465 1,974 1,029 462
Fashion Island Area 817 167 121 109 418
Hillsdale Mall 1,200 0 180 180 840
Downtown 1,213 177 305 85 646
Other Sites 3,528 1,290 721 1,520
Total Sites 6,758 2,240 1,095 3,424
Buffer Over
Remaining RHNA
3,271
(94%)
329
(17%)
103
(10%)
2,840
(484%)
Grand Total** 10,286 3,129 1,278 5,880
General Plan Buffer 10,000 3,991 1,675 4,334
* The pipeline project numbers are based on information as of December 31, 2023. The number of pipeline units may change over time based on project applications.
** Includes ADUs and Pipeline Projects.
Most of the properties listed on the Sites Inventory are located within one of the ten General Plan Study Areas in the City’s recently adopted General Plan 2040. However, the Housing Element does not rely on the adopted 2040 General Plan densities to meet the RHNA requirements. The land use map in the 2040 General Plan increases land use densities within the Study Areas from 35-50 units per acre to 50-130 units per acre and adds capacity for over 19,700 new housing units, which will add significant capacity to the City’s RHNA buffer. However, because the City’s voter-approved growth limits (Measure Y) cap density at 50 units per acre, this increased capacity in the General Plan cannot be achieved until the measure is amended by the voters or sunsets in 2030. If the amendment is approved by the voters, capacity for up to 19,764 additional housing units by 2040 would be created.
Some comment letters have suggested that pipeline projects should not be counted at their proposed density because the City has a history of reducing densities and/or denying projects. However, based on a review of all of the pipeline projects, a majority (9 of 17) actually increased the number of housing units from initial submittal to project approval. Only one project (Peninsula Heights) had a decrease in number of units from initial submittal to approval (191 to 190 units). Staff updated Table 1 in Appendix C (Housing Resources) to show this information, as well as include additional data about the level of environmental review and approval discretion for each pipeline project. Overall, this information further supports the City’s position that densities in the pipeline projects from 2019 – 2023 are a reasonable and defensible basis for the Sites Inventory density assumptions.
Affirmatively Furthering Fair Housing
Affirmatively Furthering Fair Housing, or AFFH, means taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and fosters inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. California law, as established by AB 686 (2018), requires all public agencies to “administer programs and activities relating to housing and community development in a manner that affirmatively
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furthers fair housing, and take no action inconsistent with this obligation.” The law also requires housing elements to include an analysis of fair housing outreach and capacity, integration and segregation, access to opportunity, disparate housing needs, and current fair housing practices.
In collaboration with 21 Elements (a county-wide planning collaborative), Root Policy Research prepared a Fair Housing Assessment for the City, which the Lawyers Committee for Civil Rights Under Law peer reviewed. The Fair Housing Assessment describes fair housing enforcement and outreach capacity, integration and segregation, access to opportunity, and disparate housing needs as contributing factors that needed to be addressed in the City’s fair housing action plan. In response to this analysis, as well as community input, an Affirmatively Furthering Fair Housing Action Plan, which details how the City proposes to respond to the factors contributing to the fair housing challenges identified in this analysis, was developed. The Action Plan is included in Appendix D of the Housing Element (Attachment 8) and the policies and programs to implement the Action Plan are included in the Housing Plan under Goal 5.
The Housing Element includes an extensive narrative on a variety of topics, including information on the history of the City’s development; the prioritization of contributing factors; detail on fair housing legal cases and inquiries; data on changes in racial composition in the City; enhanced discussion of special needs groups; and greater analysis of Racially/Ethnically Concentrated Area of Poverty (R/ECAPs) and Racially Concentrated Areas of Affluence (RCAAs).
Public Outreach Summary
To support the preparation of the Draft Housing Element in 2021 and 2022, a robust and inclusive community outreach and engagement process was conducted over 18 months (June 2021 through December 2022). During this time, the City conducted 19 public and community meetings and workshops, five intercept/pop-up events, four surveys, and conducted additional community engagement through partnership with 21 Elements. This is in addition to the many General Plan Update related public outreach activities during this period and into 2023, which included significant discussions around housing related topics. The outreach efforts included an emphasis on connecting with community members for whom English was not spoken at home, renters, those under 45 years of age, low-income and very low-income households, people with disabilities, seniors, single female heads of household, people experiencing homelessness, and those from under-represented neighborhoods.
Themes that were incorporated into the Housing Plan included production of more missing middle housing, more outreach and education to tenants and landlords, streamlining and simplifying development review and permitting processes, establishing programs to address fair housing and equity, and ensuring that new housing is sustainable and addresses climate change. All public comments and input received as part of the Housing Element outreach and engagement activities are included in Appendix F - Public Participation (Attachment 10). Additional public comments that have been received during the most recent public review period, and since the beginning of 2023 are included in Appendix G - Public Review Comments (Attachment 11).
For organizations that raised specific issues/concerns about the Housing Element, staff prepared response letters to provide clarifications and correct the record. These response letters are included as a subsection within Appendix F (Attachment 10).
HCD Reviews and Housing Element Revisions
Preparation of the City’s Housing Element initially started in 2020, with the community engagement process starting in the summer of 2021. The first Draft Housing Element was published at the beginning of April, 2022, with the 30-day Public Comment Period between April 6, 2022 and May 6, 2022. The Draft was reviewed by the Planning Commission at public meetings on April 26, 2022 and May 3, 2022, with City Council review and direction provided at a public meeting on May 23, 2022. Following revisions in response to Council direction, the Draft Housing Element was submitted to HCD on July 1, 2022, for its first review (90-day review period). HCD completed its review and provided a first review letter with their feedback and comments on September 28, 2022.
On November 7, 2022, the City Council held a study session to review and discuss HCD’s comments and provide staff with direction. The Council directed staff to take the necessary steps to strengthen the language and policies in the Housing
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Element to address HCD’s comments. On December 30, 2022, the Draft Housing Element (Version 2) was published for public review. Based on the statutory requirement to have an adopted housing element by January 31, 2023, Housing Element Version 2 was reviewed by the Planning Commission at a public hearing on January 12, 2023, where the Commission did not recommend adoption. On January 24, 2023, the City Council held a public hearing to consider Housing Element Version 2 and the Planning Commission’s recommendation, and voted unanimously to adopt the Housing Element. The Adopted Housing Element was submitted to HCD on January 27, 2023. HCD completed their review of the Adopted Housing Element and provided written comments to the City on March 27, 2023, stating that the adopted Housing Element addressed many statutory requirements described in HCD’s first review letter, but that additional revisions were necessary to fully comply with State Housing Element Law.
On April 17, 2023, and June 5, 2023, the City Council held study sessions to review HCD’s second comment letter, receive public input, and provide staff with direction on how to update the Housing Element. The Housing Element Version 3 was published for public review on July 26, 2023, and submitted to HCD on August 4, 2023. On August 30, 2023, a supplemental version of the third submittal was submitted to HCD to address some public comment letters and correct some data in the Sites Inventory. During the month of September, staff engaged with HCD and received preliminary comments that identified additional technical items that needed to be addressed and clarified. On September 20, 2023, Housing Element Version 3 submittal was rescinded to address the technical issues raised by HCD. During the month of October, staff continued discussions with HCD and updated the Housing Element to address HCD comments. On November 8, 2023, a revised Housing Element (Version 4) was published for public review, with Housing Element Version 4 submitted to HCD on November 22, 2023. In early January 2024, HCD met with staff and shared that there were five remaining technical issues that needed to be clarified. On January 17, 2024, the technical clarifications to Housing Element Version 4 were submitted to HCD, and on January 19, 2024, HCD provided a letter to the City finding that the draft Housing Element is in substantial compliance with State law. Once the Housing Element is locally adopted, it can be submitted to the State for formal approval.
Since January of 2023, various changes and revisions were made to the Housing Element (Revised Housing Element) in response to HCD comments and based on City Council direction. Key changes that have been incorporated since the Housing Element was originally adopted include:
1. Revised sites inventory methodology to implement a uniform approach for all sites based on size, zoning designation, and feasibility of redevelopment based on ten separate factors individually assigned to each site.
2. Updated Sites Inventory to reflect the current status/scope of pipeline projects, added/removed opportunity sites as new information became available, and removal of sites with lower potential for redevelopment during this housing cycle.
3. Updated AFFH narrative with additional background data and support information to justify findings.
4. Strengthened programs and implementation measures to address all identified constraints, add clear back-up plans and commitments for certain programs, including those related to Measure Y, ADUs, parking requirements and development streamlining, and the inclusion of metrics and target geographic areas for AFFH programs.
5. Technical corrections and revisions in response to comments received during the review periods.
To further analyze non-vacant site selection, leases as a barrier to redevelopment, and other assumptions applied in the Housing Element, the City hired Economic & Planning Systems, Inc. (EPS) to conduct a peer-review of the housing sites redevelopment assumptions and methodology used for the Sites Inventory. The EPS memorandum with summary findings is included as Attachment 12. Overall, EPS concluded that the methodology used for site selection is reflective of observed trends in redevelopment and site-specific conditions, and consistent with state law. While existing uses and leases can be constraints to redevelopment feasibility, market trends indicate that the housing opportunity sites in the Sites Inventory are reasonable to include. Findings that support the methodology and Sites Inventory composition include:
Since 2014, 88% of large multi-family projects built in San Mateo County were on land with previous commercial or office uses.
Shopping center conversions and phased residential development on commercial surface parking lots are increasingly common real estate industry trends; and tenants are increasingly open to negotiating with developers for phased projects that improve long-term benefits for a retail property.
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While some of the sites include longer-term leases, most commercial leases in San Mateo are expected to expire within the Housing Element cycle, which will relieve a constraint on redevelopment.
Planning Commission Recommendation
Pursuant to State law and the City’s Zoning Code, the Planning Commission is required to review and provide a recommendation to the City Council on all General Plan amendments. On April 23, 2024, the Planning Commission held a public hearing to consider the Revised Housing Element. During public comments, five members of the public provided input, which included concerns that the tenant protection and anti-displacement policies were not strong enough, that the Housing Element should include more affordable housing and higher densities in the highest resource areas of the City, that too many housing sites were near highways and exposed to poor air quality, and that the City should adopt an ordinance to allow for the sale of accessory dwelling units (ADUs). Following public comments, clarifying questions and deliberation, the Commission voted 4-1 to recommend adoption of the Revised Housing Element to the City Council.
The approving majority of the Commission noted that significant challenges still remain for the City to fully realize its RHNA production targets and to meet its AFFH obligations, but that the Revised Housing Element reflected significant improvements and included more robust policies and programs, which resulted in HCD’s finding of substantial conformance with state law. The dissenting commissioner expressed ongoing concerns with the Sites Inventory methodology, the feasibility of many of the opportunity sites redeveloping during this housing cycle, and the City’s ability to fully meet its AFFH requirements.
Findings for Adoption
Given HCD’s finding of substantial compliance and the Planning Commission’s favorable recommendation, staff recommends that the City Council adopt the Revised 2023-2031 Housing Element, based on the following key findings, and as expanded upon in the Draft Resolution in Attachment 1.
1. The Revised 2023-2031 Housing Element is internally consistent with the City’s recently adopted General Plan 2040.
2. State Law (Govt. 65580-65589.11) – To be in substantial compliance with state law, a housing element must contain all of the elements mandated by State housing element law . Based on HCD’s January 19, 2024 letter (Attachment 3) that found the Housing Element to be in substantial compliance, and further evidenced in the Compliance with Statutory Provisions table in Exhibit A of Attachment 1, the Revised 2023-2031 Housing Element adequately addresses and is consistent with each requirement and provision mandated by State law.
3. Based on substantial evidence and the methodology used to determine additional development potential, existing uses on non-vacant sites identified in the Housing Element are likely to be discontinued during the Housing Element planning period.
4. The City followed all required noticing and review procedures and timelines (Govt. 65580-65589.11) for various versions of the draft and final 2023-2031 Housing Element.
If the City Council takes action to adopt the Revised 2023-2031 Housing Element, it will be transmitted to HCD for formal certification following the action.
In addition, pursuant to Section 65583.2(c), and Program H 1.10 in the Housing Element, staff is working on a “by-right” ordinance that would allow ministerial approval (without Planning Application and CEQA review) for housing development projects on a site that was listed as a housing opportunity site in one of the City’s prior housing elements. A housing development project utilizing this ordinance must also provide at least 20% of its units as affordable for lower income households and have a density of at least 30 units per acre. There are approximately 40 such sites citywide that would be eligible for “by-right” approval. The ordinance will be reviewed by the Planning Commission on May 28 and is anticipated to be considered for adoption by the City Council in July. This ordinance is statutorily required and must be adopted before HCD can approve the Housing Element.
BUDGET IMPACT:
Although there are no direct budgetary impacts to taking this action, the preparation of the 2023-2031 Housing Element
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document has involved a significant amount of City staff time and the use of multiple consultants. The preparation of the Housing Element is primarily funded by the City’s Advanced Planning Fund (Fund 225), which is funded by a fee collected with each building permit, with some State grant funds also being used for the outreach component. To implement the Housing Element (52 policies with over 100 programs), a funding source is identified with each policy, and the Community Development Department will identify and allocate appropriate staff and budgetary resources to complete each effort in the coming years.
ENVIRONMENTAL DETERMINATION:
The Revised Housing Element is not subject to further review under CEQA because it can be seen with certainty that it will not cause a physical change in the environment, as there are no rezonings proposed. The proposed adoption of the 2023- 2031 Housing Element is considered exempt under the “common sense” exemption under state CEQA Guidelines Section 15061(b)(3) because the project involves policies, programs, and actions to meet the City’s RHNA and AFFH goals that would not have any potential for causing a significant effect on the environment, and identifies programs and actions to remove constraints and promote affordable housing development. Because the City does not have to rezone any sites or make any physical improvements to adopt the Revised Housing Element, it can be seen with certainty that there is no possibility that the approval of a General Plan Amendment to update the Housing Element would have a significant effect on the environment. Thus, the General Plan amendment to update the Housing Element for the Sixth Cycle (2023-2031) is exempt from CEQA under the common-sense exemption. The CEQA Determination with information to support this finding is included as Attachment 2.
NOTICE PROVIDED:
All meeting noticing requirements were met. A public hearing notice for consideration of the City’s Revised 2023-2031 Housing Element was published in the San Mateo Daily Journal on May 9, 2024. Notice of Housing Element availability was displayed on the home page of the City’s website, posted to the City’s Housing Element website and a physical copy was made available at City Hall and the Main Library. Notice of updated Housing Element publication was also included in the City’s E-Newsletter and sent out to various email distribution lists, including the Housing Policy, Housing Element and General Plan Update email distribution lists.
PUBLIC COMMENTS:
Appendix F (Attachment 10) of the Revised Housing Element includes community feedback, communications and documentation that supports the Housing Element preparation. All public comments submitted since the beginning of 2023 are included in Appendix G (Attachment 11). Since the publication of the Revised Housing Element on April 16, 2024, the City has received a total of six comment letters. The comments in these letters include concerns about the feasibility of the housing opportunity sites redeveloping with housing by 2031, and argue that that the Housing Element does not fully address AFFH requirements and that more affordable housing opportunities should be created in the High and Highest Resource areas of the City. The letters further contend that more affordable housing needs to be required with new development, that existing leases pose a significant constraint on new housing that has not been fully evaluated/considered, that the Constraints Analysis does not fully meet statutory requirements, and that the City should allow ADUs to be individually owned/sold pursuant to AB 1033. These comments are responded to in this staff report and in Attachment 10.
Public comments submitted after the publication of this agenda packet are posted to this item on the City’s Public Meeting Portal as “Post Packet Public Comments.”
ATTACHMENTS
Att 1 – Draft City Council Resolution – Housing Element Adoption Att 2 – Housing Element CEQA Exemption Technical Memorandum Att 3 – HCD Substantial Compliance Finding Letter
Att 4 – Revised 2023-2031 Housing Element
Att 5 – Appendix A - Needs Analysis
Att 6 – Appendix B - Constraints Analysis
Att 7 – Appendix C - Housing Resources and Sites Inventory
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Att 8 – Appendix D - Affirmatively Furthering Fair Housing Narrative Att 9 – Appendix E - Review of Prior Element
Att 10 – Appendix F - Public Participation
Att 11 – Appendix G - Public Review Period Comments
Att 12 – Housing Element Sites Inventory Review Memorandum, EPS Att 13 – Supplemental Information for Housing Element 2023-2031 Appendix C: Housing Resources and Sites Inventory
Appendix F: Public Participation
STAFF CONTACTS:
Zachary Dahl, Interim Director
(650) 522-7207
[email protected]
Manira Sandhir, Planning Manager
(650) 522-7203
[email protected]