Below Market Rate
Program: Alternative
Compliance
1700 S. El Camino Real PA-2026-0025
October 5, 2026
Van Diggans, Housing Specialist II
Community Development Department
Objective
1. Review applicant-proposed alternative under BMR Guidelines Section VIII(d)
• Recommendation: adopt a resolution to approve an alternative means of compliance with the City's Below Market Rate Housing Program, pursuant to Section VIII(d) of the Below Market Rate Guidelines for the proposed 441- unit housing development project located at 1700 S. El Camino Real (PA2026-0025).
2. Limited Procedural Scope
• Council action applies strictly to the Applicant’s Affordable Housing Plan • Project entitlements remain subject to Planning Commission review Site Context
1700 South El Camino Real Overview
• Site Context
• Building A – Market Rate
• 253 market rate rental units
• Building B – Senior Affordable
• 188 deed-restricted rental units
dedicated to low-income seniors
Baseline Requirement vs. Proposed Plan
38 BMRs
188
Senior
Units
+ 395%
Net housing gain:
+395% gain in affordable units
150 additional units
Proposed Alternative:
188 senior units
for lower income households
in Building B
Baseline Requirement:
38 dispersed BMR units
for lower income households
Section VIII(d) Applicant-Proposed Alternative:
An applicant may propose other ways to comply with the on-site BMR requirement in Section III of these Guidelines if City Council determines, based on substantial evidence provided by the applicant, that it will provide as many or more BMR units at the same or lower income levels, or will otherwise provide greater public benefit than that provided under the on-site requirement in Section III of these Guidelines. The proposed alternative compliance option must be identified in an Affordable Housing Plan that is submitted as part of the Planning Application. A Planning Application shall not be deemed complete until the Affordable Housing Plan is approved. The applicant shall bear all costs associated with demonstrating that the compliance option meets the BMR requirements.
Section VIII(d) Findings
Section VIII (d) Findings
1. The number of affordable units provided by the ApplicantProposed Alternative equals or exceeds that required by the on-site requirement in Section III of these Guidelines;
188 senior units exceed the standard inclusion of
38 units by 395%
2. The level of affordability provided by each of the BMR units meets the affordability threshold or lower affordability threshold(s) as required under the on-site requirement in Section III of these Guidelines; All units in Building B will be affordable to LowerIncome Seniors (80% or less of AMI)
3. If the Applicant-Proposed Alternative does not meet the requirements in (i) and (ii) (i.e., 1 and 2 above), it will provide greater public benefit than that provided under the on-site requirement in Section III of these Guidelines; The Applicant-Proposed Alternative does meet the
requirements in (i) and (ii), but even if it did not,
the Project still provides a greater public benefit by
providing 5x the number of required BMR units in a
high resource area
4. Financing or a viable financing plan, which may include public funding, is in place for the Applicant-Proposed Alternative; and
Developer proposes to use private-activity taxexempt bonds and low-income housing tax credits
5. The Applicant-Proposed Alternative is consistent with the General Plan and Housing Element and the provisions of this Guidelines.
Developer proposal is consistent with the General
Plan, Housing Element and BMR Guidelines as
specified in the staff report
Recommendation
Adopt a Resolution to approve an alternative means of compliance with the City's Below Market Rate Housing Program, pursuant to Section VIII(d) of the below Market Rate Guidelines for the proposed 441-unit housing development project, located at 1700 S. El Camino Real (PA-2026-0025).
Next Steps for 1700 S. El Camino Real
• Approval of this alternative applies to the Affordable Housing Plan only and does not constitute approval of the Project
• Consistency letter dated September 28, 2026 sent to applicant • When CEQA review is complete, the project will be scheduled for a Planning Commission hearing
• A condition of approval will be recorded that Building A will not receive a certificate of occupancy until Building B has received a building permit