Cities Index.
Agenda packet

San Ramon City Council
January 30, 2023

Document
Agenda packet
Meeting
January 30, 2023
Body
San Ramon City Council
Pages
9
Original file
30.8 MB
Text extracted from the city's file for reading and search. Open the original on sanramonca.iqm2.com. That file is the official record.

requirements for single‐family detached dwellings, except for four‐bedroom units.

Three parking spaces are required for a four‐bedroom multi‐family unit but only two spaces are required for a four‐bedroom single‐family unit. This requirement may potentially constraint the development of large multi‐family units. The City will amend the ZO to reduce the parking requirement for large multi‐family units (four bedrooms) from three spaces to two spaces. Guest space requirements for multi‐family developments are reasonable because these types of developments do not have private driveways for each unit to accommodate parking for guests as is required for new single‐family homes. The City offers flexible or alternative parking arrangements to facilitate multi‐family housing and mixed use construction. These may include tandem parking and shared parking.  For example, the City Walk project utilizes shared parking between residential and commercial uses.

Furthermore, parking standardsforsingle‐family homes with more than four bedrooms are higher than other cities. Given that the City has a large proportion of families with children and extended/multi‐generation family members, there is a demand for larger homes. The City will revise the parking standards for large single‐family homes to be consistent with regional trends.

Because the increased cost of off‐street parking can make financing the development of housing affordable to lower and moderate income households more difficult, reduced parking and other incentives, concessions, or waivers and modifications of development standards are available for developers of affordable projects that are eligible for a density bonus. However, for projects not eligible for a density bonus, the City’s parking standards may constrain development due to the cost of parking construction. This Housing Element includes a program action to amend the ZO to utilize the State Density Bonus parking standardsfor all projects. As part of the rezoning of sites to meet the City’s RHNA, the City will establish appropriate development standards, including parking, to ensure maximum densities can be achieved.

Furthermore, the City will amend the ZO to reduce parking standards for large single‐ family and multi‐family units as discussed above.

3. Other
Local
Ordinances
: Should
establish
measures;
should
commit to
streamline
approvals
and other
mechanis
ms to
address
the
constraint,
including
taking an
initiative
Added to Program 14 on Page H.5‐16:

Program 14: Growth Management (Measure G)
Land use decisions triggering Measure G require a four‐fifth super‐majority vote of the Council. This requirement can potentially hinder the City’s ability to address the need for new housing opportunities. The City will conduct an education program to educate the public regarding the impact of Measure G and compliance with State law.

Responsible Agency: City of San Ramon, Community Development Department, Planning Division
Financing: General Fund
Objectives/Timeframe:
• Annually evaluate housing proposal processed under Measure G, to determine if the super majority requirement delayed approval. • By 2026, conduct an education program to educate the public regarding the impact of Measure G and compliance with State law.

2.1.e
Packet Pg. 400 Attachment: A: Planning Commission Resolution 01-23, Recommending City Council approval of the General Plan Amendment for the 2023-

Page 3 of 4 ends

to the
voters to
modify or
remove
the 4/5ths
requireme
nt.

Provided
suggested
language
to amend
Program
14 • By 2028, review and determine pursue and establish opportunities to streamline Measure G approvals and if necessary, pursue and complete other mechanisms to ensure the process does not constraint development, including a ballot measure.

AFFH Themes: New Opportunities in High Resource Areas
Housing Mobility
Targeted Neighborhoods: Not applicable

4. Concurrent
Rezoning:

Commit to
appropriat
e
developme
nt
standards
and to
meet all by
right
requireme
nts
Added to Program 13 on page H.5‐14 and 5‐15:
 Six sites: 20 to 60 du/ac
The rezoned sites will meet the requirements of Government Code 65583.2, including but not limited to a minimum density of 20 units per acre, minimum site size to permit at least 16 units on site, and zoned to allow ownership and rental housing by right in which at least 20 percent of the units are affordable to lower income households (see also Program 14). As part of the rezoning, appropriate development standards (including but not limited to setbacks, lot coverage, height, and parking, among others) will be established to ensure the allowable maximum density of each zone can be achieved.

Overall, rezone sites will provide an estimated capacity of 5,287 units (1,477 very low income; 711 low income; 593 moderate income; and 2,506 above moderate income units), adequate to fulfill the City’s RHNA shortfall of 2,190 units. To ensure that the City complies with SB 166 (No Net Loss), the City will monitor the consumption of residential and mixed use acreage to ensure an adequate inventory is available to meet the City’s RHNA obligations.  To ensure sufficient residential capacity is maintained to accommodate the RHNA, the City will develop and implement a formal ongoing (project‐by‐project) evaluation procedure pursuant to Government Code Section 65863.  Should an approval of development result in a reduction of capacity below the residential capacity needed to accommodate the remaining need for lower income households, the City will identify and if necessary, rezone sufficient sites to accommodate the shortfall and ensure “no net loss” in capacity to accommodate the RHNA.

Responsible Agency: City of San Ramon, Community Development Department, Planning Division
Financing: General Fund
Objectives/Timeframe:
•    Complete redesignation/rezoning of 55 sites as outlined in Appendix D to fully accommodate the RHNA by the end of 2023. As part of the rezoning, establish a procedure to provide by‐right approval of projects on reuse sites (identified in the previous Housing Elements) and rezone sites that include 20 percent of the units as housing affordable to lower income households (see also Program 14). •    Maintain an inventory of the available sites for residential development and make it available on City website. Update sites inventory annually.

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Packet Pg. 401 Attachment: A: Planning Commission Resolution 01-23, Recommending City Council approval of the General Plan Amendment for the 2023-

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5. Large Sites:

Add Large
Sites
Program
Add New Program Number 20; renumber programs 20 and after to reflect addition of new Program 20:

Program 20:  Development of Large Sites
The sites inventory for meeting the RHNA includes four large sites (larger 10 acres) that are expected to offer affordable housing opportunities for lower income households. To facilitate the development of these large sites, the City will:
 Provide site planning tools such as clustered development, allowing flexibility for the transferring of densities within the property.
 Meet with property owners and developers to encourage the development of mixed income housing with a mix of unit sizes, types, and prices.  Allow the development in phases within eight years of the Housing Element Planning period.

Responsible Agency: City of San Ramon, Community Development Department Financing: General Fund
Objectives/Timeframe:
 Meet with developers/property owners at least semi‐annually beginning 2023 to facilitate development of sites.
 By 2024, establish objective development standards for clustered development to facilitate large‐site development.

AFFH Themes: New Opportunities in High Resource Areas Housing Mobility Targeted Neighborhoods:   Not applicable

6. AFFH:

Increase
missing
middle
objectives
to 200
units; set
parameter
s for
evaluation
and
response.

Provided
suggested
edits to
Program
18 Modified Program 18, page H.5‐15 as follows:
• A waiver system to ensure development standards do not preclude the maximum allowable density.

The City shall evaluate the effectiveness of meeting missing middle housing targets of these strategies in 2027 year and if half of the objective is not achieved, the City will pursue and establish additional measures, including but not limited to further increasing development intensity and additional measures as appropriate such as fee mitigation (in‐lieu or other) single family zones within the following year to achieve more inclusive neighborhoods throughout City.

2.1.e
Packet Pg. 402 Attachment: A: Planning Commission Resolution 01-23, Recommending City Council approval of the General Plan Amendment for the 2023- STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
October 18, 2022
Debbie Chamberlain, Director
Community Development Department
City of San Ramon
7000 Bollinger Canyon Road
San Ramon, CA 94583
Dear Debbie Chamberlain:

RE: City of San Ramon’s 6th Cycle (2023-2031) Draft Housing Element Thank you for submitting the City of San Ramon’s (City) draft housing element update received for review on July 20, 2022. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. In addition, HCD considered comments from East Bay for Everyone, South Bay YIMBY, Greenbelt Alliance and YIMBY Law, Ralph Ballart and TransForm pursuant to Government Code section 65585, subdivision (c).

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

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

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

For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if a local government fails to adopt a compliant housing element within 120 days of the statutory deadline (January 31, 2023), then any rezoning to make sites available from prior planning periods or accommodate the regional housing needs allocation (RHNA), including for lower-income households, shall be completed no later than one year from the statutory deadline. Otherwise, the local government’s housing element will no longer

2.1.f
Packet Pg. 403 Attachment: B: HCD Comment Letter, dated October 18, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing Debbie Chamberlain, Director

Page 2 ends

comply with State Housing Element Law, and HCD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i).

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

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

Sincerely,
Paul McDougall
Senior Program Manager
Enclosure

2.1.f
Packet Pg. 404 Attachment: B: HCD Comment Letter, dated October 18, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon’s 6th Cycle (2023-2031) Draft Housing Element Page 1 October 18, 2022

APPENDIX

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

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

A. Housing Needs Resources and Constraints

1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).) Fair Housing Enforcement and Capacity: The housing element must include a summary of fair housing enforcement and outreach capacity. The analysis must address how the City complies with state and federal fair housing laws, including regulations, lawsuits, and related enforcement actions. For more information, see HCD’s affirmatively furthering fair housing (AFFH) Guidance Memo at https://www.hcd.ca.gov/planning-andcommunity-development/affirmatively-furthering-fair-housing.

Local to Regional Patterns of Income and Concentrated Areas of Affluence (RCAA):

The element briefly mentions a concentrated area of affluence (p. H.E-47) and that the City has a much smaller proportion of lower-income households compared to the County and Bay Area region (p. H.E-35). However, the element should include specific analysis of these areas to guide an appropriate policy response. The analysis should at least address evaluating trends, conditions, comparisons to other neighborhoods and cities beyond the I-680 corridor, effectiveness or absence of past strategies, local data and knowledge and other relevant factors related to equitable quality of life. The element must add or modify meaningful programs based on the outcomes of this analysis.

Local Data and Knowledge: The element must include local data, knowledge, and other relevant factors to discuss and analyze any unique attributes about the City related to fair housing issues. The element should complement federal, state, and regional data with local data and knowledge where appropriate to capture emerging trends and issues, including utilizing knowledge from local and regional advocates and service providers, City staff and related local and County planning documents.

Other Relevant Factors: The element must include other relevant factors that contribute to fair housing issues in the City. For instance, the element can analyze historical land use, zoning and barriers to housing choices, investment practices, seeking investment

2.1.f
Packet Pg. 405 Attachment: B: HCD Comment Letter, dated October 18, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon’s 6th Cycle (2023-2031) Draft Housing Element Page 2 October 18, 2022
or lack of seeking investment to promote affordability and inclusion, information about redlining/greenlining, restrictive covenants and other discriminatory practices, land use related lawsuits, local initiatives, demographic trends, or other information that complements the state and federal data.

Contributing Factors to Fair Housing Issues: Based on the outcomes of a complete analysis, the element should re-assess contributing factors and particularly prioritize those factors then formulate appropriate policies and programs.

2. Include an analysis of population and employment trends and documentation of projections and a quantification of the locality's existing and projected needs for all income levels, including extremely low-income households. (Gov. Code, § 65583, subd. (a)(1).)
Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)
Extremely Low-Income (ELI) Households: The element does include some data on the number of existing and projected ELI households, but it must also analyze their housing needs. The analysis should evaluate tenure, overpayment, resources, and strategies available and the gap and magnitude of housing needs to better formulate policies and programs.

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

This analysis should also address elderly by tenure (renters and owners).

3. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
Entitled Projects: While the element may utilize pending, approved or under construction projects toward the Regional Housing Needs Allocation (RHNA), it must also demonstrate their affordability and availability in the planning period. Affordability must be demonstrated based on actual sales price, rent level or other mechanisms ensuring affordability (e.g., deed restrictions). Availability should account for the likelihood of project completion in the planning period and should address the status, necessary steps to issue permits, any barriers to development and other relevant factors.

Realistic Capacity: Where zoning allows 100 percent nonresidential uses, the calculation of residential capacity should account for the likelihood of 100 percent

2.1.f
Packet Pg. 406 Attachment: B: HCD Comment Letter, dated October 18, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon’s 6th Cycle (2023-2031) Draft Housing Element Page 3 October 18, 2022
nonresidential development. For example, the element could analyze all development activity in nonresidential zones allowing 100 percent nonresidential uses, how often residential development occurs and adjust residential capacity calculations, policies, and programs accordingly. This analysis may incorporate any proposed policies such as residential performance standards, prohibition of commercial uses and should clarify that all zones allow residential uses, particularly 100 percent residential uses.

Suitability of Nonvacant Sites: The element must include an analysis demonstrating the potential for additional development on nonvacant sites. While the element includes parcel by parcel descriptions intended to demonstrate potential for redevelopment, it should complement these descriptions with a discussion of existing uses and recent trends or expressed interest to support various factors (e.g., age, improvement to land value, lot coverage) utilized to identify nonvacant sites. • Existing Uses: The element must address the extent existing uses impede additional development such as market demand for the existing use and existing leases, contracts or other conditions that would perpetuate the existing use or prevent additional residential development. For example, many sites are parking lots, offices, San Ramon Visitor Conference Center, and similar uses. The element could generally describe these typologies and whether the existing uses impede additional development. Finally, the City should consider and address public comments regarding the potential of redevelopment on some identified sites.
• Recent Trends: Many sites utilize factors such as age, improvement to land value and lot coverage to demonstrate the potential for redevelopment. The element should evaluate recent trends or expressed interest in redevelopment to support the validity of these factors. For example, the element could list recent redevelopment or expressed interest in redevelopment by the existing use and factors then evaluate the similarities to identified sites.

In addition, if relying upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower income households, the housing element must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period. (Gov. Code, § 65583.2, subd. (g)(2).) Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA.

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

Electronic Sites Inventory: Pursuant to Government Code section 65583.3, subdivision (b), upon adoption of the housing element, the City must submit an electronic version of the sites inventory with its adopted housing element to [email protected]. HCD has not received a copy of the electronic inventory. Please note, the City must utilize standards, forms, and definitions adopted by HCD when preparing the sites inventory.

2.1.f
Packet Pg. 407 Attachment: B: HCD Comment Letter, dated October 18, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon’s 6th Cycle (2023-2031) Draft Housing Element Page 4 October 18, 2022
Please see HCD’s housing element webpage at https://www.hcd.ca.gov/communitydevelopment/housing-element/index.shtml#element for a copy of the form and instructions. The City can reach out to HCD at [email protected] for technical assistance.

Zoning for a Variety of Housing Types
• Emergency Shelters: The element mentions emergency shelters are permitted in the Thorough Fare Commercial district with capacity to accommodate the need for emergency shelters but should also discuss proximity to transportation and services and any conditions inappropriate for human habitability. The analysis should also list and evaluate development standards and add or modify programs if necessary.
• Accessory Dwelling Units (ADU): After a cursory review of the City’s ordinance, HCD discovered some areas which are not consistent with State ADU Law. HCD will provide a complete listing of ADU non-compliance issues under a separate cover. As a result, the element should modify Program 16 (ADU) to update the City’s ADU ordinance and comply with state law.

4. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).)
An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2... (Gov. Code, § 65583, subd. (a)(6).) Land Use Controls: The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types. While the element lists various development standards, it should also evaluate those development standards for impacts on housing supply (number of units), cost, feasibility, and the ability to achieve maximum densities.

In addition, the element should include a discussion of compliance with State Density Bonus Law. (Gov. Code, § 65915.), including whether the City has an ordinance and implementing mechanisms such as application requirements, granting of density bonuses, concession and incentives, waivers and modifications and parking reductions.

Based on the outcomes of this discussion, the element should add or modify programs if necessary.

Building Codes: The element should identify and evaluate any local amendments to the building code for impacts on housing costs.

2.1.f
Packet Pg. 408 Attachment: B: HCD Comment Letter, dated October 18, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon’s 6th Cycle (2023-2031) Draft Housing Element Page 5 October 18, 2022
Local Processing and Permit Procedures: While the element mentions typical timeframes and that developments are subject to various reviews; it should also describe the procedures for a typical single family and multifamily development complying with zoning. The analysis should address the approval body, the number of public hearing if any, approval findings and any other relevant information. The analysis should evaluate approval findings for impacts on approval certainty and timing.

In addition, the element must clarify whether there are written procedures for the SB 35 (Chapter 366, Statutes of 2017) Streamlined Ministerial Approval Process and add a program to address these requirements, if necessary.

Constraints on Housing for Persons with Disabilities: The element indicates group homes for seven or more persons are allowed in all residential zones and subject to a conditional use permit (CUP). The element also indicates these uses are subject to parking requirements of one space per three beds plus guest and employee parking.

The element should analyze the CUP and parking requirements for impacts on housing for persons with disabilities including approval certainty, objectivity, feasibility, timing and cost and add or modify programs to address the constraint.

Other Local Ordinances: The element must analyze any locally adopted ordinances that directly impact the cost and supply of residential development (e.g., inclusionary requirements, short term rentals, growth controls). While the element (p. H.3-2) explains Measure G is primarily a growth management requirement related to the Urban Growth Boundary, coordinating infrastructure and promoting infill development, it also explains that any general plan amendment is subject to four fifths voting requirements (p. H.E-92).

The element should analyze the impacts of requiring a four-fifths vote for any general plan amendment on housing supply, cost, timing and feasibility and add or modify programs as appropriate to address identified constraints.

Potential Nongovernmental Constraints: The element must be revised to identify the price of land (vacant or nonvacant) and analyze requests to develop housing at densities below those anticipated in the sites inventory, including hinderance on the construction of a locality’s share of the regional housing need. The element notes projects are often approved below the maximum allowable densities but should also discuss requests of densities below the realistic capacity assumptions in the sites inventory.

B. Housing Programs

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

2.1.f
Packet Pg. 409 Attachment: B: HCD Comment Letter, dated October 18, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon’s 6th Cycle (2023-2031) Draft Housing Element Page 6 October 18, 2022
To have a beneficial impact in the planning period and address the goals of the housing element, programs must be revised with specific commitment and discrete timelines (e.g., at least annually or month and year). Examples include:
• Program 1 (Neighborhood Preservation): The Program should commit to how often outreach will be conducted in targeted areas and consider additional outreach methods, beyond updating a website.
• Program 2 (City Rehabilitation Grants): The Program should commit to annually explore and pursue additional funding.
• Program 6 (Housing Choice Vouchers): The Program should commit to how often the City will work with fair housing service providers to educate the community on source of income protections (SB 329 and SB 222). • Program 5 (Preservation of Existing Affordable Housing Stock): The Program could commit to proactively work with non-profit and public agencies early in the planning period to develop a strategy, seek funding and other resources to preserve at-risk units and support tenants.
• Program 9 (Below Market Rate Home Ownership Program): The Program should commit to how often the City will promote the availability of the program and consider distribution at a broader regional level.
• Program 10 (Affordable and Special Needs Housing Development): The Program commits to annual outreach at community events and seeking grants to defray outreach costs. However, the Program should also specifically commit to annually contact affordable housing developers to identify development opportunities, including assisting with funding or supporting funding applications, for lower-income households, including extremely low-income and special needs households.
• Program 21 (Regional Partnerships for Affordable Housing): The Program could commit to support and assist with pursuing funding such as past efforts related to the Homeless Emergency Aid Program (HEAP) as noted on page H.C-12.

2. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).)
As noted in Finding A3, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised as follows:

2.1.f
Packet Pg. 410 Attachment: B: HCD Comment Letter, dated October 18, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon’s 6th Cycle (2023-2031) Draft Housing Element Page 7 October 18, 2022
• Concurrent Rezoning: HCD understands the City will be completing rezoning prior to the start of the planning period (January 31, 2023) to accommodate the RHNA, including for lower-income households. Please be aware, if rezoning is not completed by January 31, 2023, the element must include a program(s) to rezone sites with appropriate zoning and development standards pursuant to Government Code section 65583, subdivision (c)(1), and meet all the requirements of Government Code section 65583.2, subdivisions (h) and (i). • Large Sites: The element should include a program to encourage the development of housing for lower-income households on sites greater than ten acres. Actions could include coordination with property owners and developers to facilitate appropriate parceling or site planning (e.g., one to five acres), establishing incentives, priority processing and fee reductions.

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 and housing for persons with disabilities... (Gov. Code, § 65583, subd. (c)(3).)
As noted in Finding A4, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints.

4. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics... (Gov. Code, § 65583, subd. (c)(5).)
As noted in Finding A1, the element must include a complete analysis of AFFH. The element must be revised to add goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically respond to the analysis and identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have specific commitment, discrete timing or milestones, geographic targeting and metrics or numerical targets toward AFFH outcomes. As appropriate, actions must address housing mobility, new housing choices and affordability in higher resource or higher income areas throughout the City (e.g., a variety of choices and affordability such as missing middle housing types in lower density single family areas), place-based strategies for community preservation and revitalization and displacement protection.

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

2.1.f
Packet Pg. 411 Attachment: B: HCD Comment Letter, dated October 18, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon’s 6th Cycle (2023-2031) Draft Housing Element Page 8 October 18, 2022
While the element includes quantified objectives for new construction, rehabilitation, and conservation by income group; it could consider quantified objectives for conservation beyond at-risk preservation. Examples of programs that could be utilized include Programs 3 (Green Building), 4 (Code Enforcement), 6 (Housing Choice Vouchers), 7 (Condominium Conversions) and 15 (Replacement Housing).

D. Water Sewer Priority
The element shall be immediately delivered to all public agencies or private entities that provide water or sewer services for municipal and industrial uses, including residential, within the territory of the legislative body. Each public agency or private entity providing water or sewer services shall grant a priority for the provision of these services to proposed developments that include housing units affordable to lower income households. (Gov.

Code, § 65589.7.)
The element should discuss or commit to immediately deliver the housing element to all public agencies that provide water and sewer service.

2.1.f
Packet Pg. 412 Attachment: B: HCD Comment Letter, dated October 18, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing 1 Cindy yee
From: East Bay for Everyone <[email protected]> Sent: Friday, December 23, 2022 1:42 PM
To: Cindy yee
Cc: Finney, Connor@HCD; McDougall, Paul@HCD
Subject: Re: Extension for San Ramon's comment period
Attachments: IMG_6519.jpg
Further this page on San Ramon’s website describing the Housing Element contains no instructions about how to “request notification” and no email sign up option.
https://www.sanramon.ca.gov/our_city/departments_and_divisions/community_development/planning_services /general_plan_and_housing_element_update
On Fri, Dec 23, 2022 at 13:03 East Bay for Everyone <[email protected]> wrote:

I subscribed on May 11 and submitted multiple comments and did not receive any emails. I checked my spam folder as well.

A cynical person would say that the timing is designed to reduce the amount of comment that San Ramon receives about the Housing Element.

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Packet Pg. 413 Attachment: C: Public Comments received on the revised Draft 2023-2031 Housing Element dated December 2022 (3867 : General Plan 2 2.1.g
Packet Pg. 414 Attachment: C: Public Comments received on the revised Draft 2023-2031 Housing Element dated December 2022 (3867 : General Plan 3 On Fri, Dec 23, 2022 at 13:00 Cindy yee <[email protected]> wrote:

Hi Kevin and John,
Thank you for your email.  I appreciate you taking the time to contact the City regarding the Housing Element update. Our 2nd draft was released on December 20th and the draft was posted and emailed to all individuals and organizations that have requested notification. The City is committed to receiving and reviewing public comments on the draft for at least 7‐days before submitting to the State for their review in accordance with AB 215. After the revised draft is submitted to HCD, the City will continue to compile any comments received and provide these comments to the Planning Commission and City Council for their consideration before the updated Housing Element is adopted.

If I can be of further assistance, please feel free to contact me.

Cindy M. Yee, AICP | Senior Planner | City of San Ramon | Planning Services Division 7000 Bollinger Canyon Rd. ꞏ San Ramon, CA 94583 ꞏ www.ci.san-ramon.ca.us T: 925.973.2562 direct ꞏ F: 925.830.0100 ꞏ E: [email protected] The public counter at the San Ramon Permit Center is now open, with social distancing and hygiene measures in place.

Please visit www.bit.ly/CityServices for the latest information regarding City services.

From: East Bay for Everyone <[email protected]> Sent: Friday, December 23, 2022 8:49 AM
To: Joe Gorton <[email protected]>; Planning Services (public) <[email protected]>; Finney, Connor@HCD <[email protected]>; McDougall, Paul@HCD <[email protected]>; Cindy yee <[email protected]>
Subject: Extension for San Ramon's comment period

San Ramon released their 2nd draft on December 20th.

We both submitted public comments on the first draft and I believe that means we are supposed to receive an email from San Ramon letting us know the second draft is available. Neither John Minot nor myself received emails from San Ramon; we only found out the draft was available because we read a news story about it.

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Packet Pg. 415 Attachment: C: Public Comments received on the revised Draft 2023-2031 Housing Element dated December 2022 (3867 : General Plan 4 The 7 day comment period spans Christmas Eve, Christmas, and the day after Christmas. We are an all volunteer group, I am hosting family, daycare is closed and it is unlikely we will be able to submit a comment on time.

Further, we may have questions about the draft and we find it unlikely that Planning staff will be responsive during this window.

We'd like our comments to be considered even if they are submitted after the deadline.

Thanks very much,
Kevin

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Packet Pg. 416 Attachment: C: Public Comments received on the revised Draft 2023-2031 Housing Element dated December 2022 (3867 : General Plan 1 Cindy yee
From: Claire Mailhiot <[email protected]>
Sent: Tuesday, December 27, 2022 9:43 AM
To: Planning Services (public)
Subject: Draft Housing Element Comment
I believe the massive parking lots at Bishop Ranch 1 would be a great location for more housing.

Build a parking structure for the employees of the businesses there and then use the rest of the parking lots for apartments or condos that would enable workers to live near their offices.

I have been living in San Ramon since 1989. It is ostensibly a "city" but I see it turning into more of a "bedroom community" with more housing than jobs.

I don't understand the rationale for tearing down office space to build homes if we hope to get people out of their cars. But I would rather see that than having more houses built on undeveloped land (such as the ironically-named "Preserve" which destroyed so much of the wildlife habitat and natural ecosystem).

I also object to putting housing at the Marketplace, unless there is a grocery store or retail on the ground floor and an attempt is made to preserve the architectural integrity of the buildings, and the same applies to the Chevron property. I hope it can be converted to housing without destroying the campus and landscaping.

Additionally, I have concerns about the capacity of our roads to handle such an increase in population density. If there is a massive earthquake on the Calaveras fault, there will be no way to evacuate the city. Even now when there is a major accident on Bollinger or Crow Canyon, the traffic backs up for ages.

Finally, I really don't want to see San Ramon turn into Dublin.

Claire Mailhiot
San Ramon resident

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Packet Pg. 417 Attachment: C: Public Comments received on the revised Draft 2023-2031 Housing Element dated December 2022 (3867 : General Plan 1 Cindy yee
From: Ryan Driscoll
Sent: Tuesday, December 27, 2022 10:00 AM
To: Cindy yee
Subject: FW: Revised Draft 2023-2031 Housing Element (dated December 2022) Available for a 7-day Public Review Period
Cindy,
I received the following comment on the revised HE from a previous commenter, Penny Wolfsohn, regarding water concerns. Also, has  question on where to comment for the upcoming meeting. Want me to respond? ‐Ryan
Ryan Driscoll – Associate Planner
Direct Phone: (925) 973‐2568 – Fax: (925) 830‐0100 – [email protected] City of San Ramon – Planning Services Division – 7000 Bollinger Canyon Rd., San Ramon, CA 94583 From: Penny Wolfsohn <[email protected]>
Sent: Tuesday, December 27, 2022 9:30 AM
To: Ryan Driscoll <[email protected]>
Subject: Re: Revised Draft 2023‐2031 Housing Element (dated December 2022) Available for a 7‐day Public Review Period
I’m not sure how to comment or where to comment on this upcoming meeting but my concerns continue to be about water issues for any new development that plan for our community.

Sincerely Penny Wolfsohn.

On Wed, Dec 21, 2022 at 4:28 PM Ryan Driscoll <[email protected]> wrote:

All PlanSanRamon.com E-mail List Contacts:

On October 18, 2022, the California Department of Housing and Community Development (HCD) provided the City of San Ramon comments on the Draft 2023‐2031 Housing Element along with a list of revisions necessary to comply with State Housing Element Law. In consultation with HCD, the City has prepared an update to the Draft Housing Element using “tracked changes” that show revisions to the document in underlined and/or highlighted yellow text.

The Revised Draft 2023‐2031 Housing Element (dated December 2022) is available for a 7‐day public review period, from December 21, 2022 through December 27, 2022. The link to the Revised Draft 2023‐2031 Housing Element is available below, on the City webpage, and on the PlanSanRamon.com website:
 Revised Draft 2023-2031 Housing Element, dated December 2022  HCD Comment Letter on Draft 2023-2031 Housing Element, dated October 18, 2022

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Packet Pg. 418 Attachment: C: Public Comments received on the revised Draft 2023-2031 Housing Element dated December 2022 (3867 : General Plan 2 To provide comments on the Revised Draft 2023‐2031 Housing Element, please email [email protected] or send written communication to the City of San Ramon Planning Services Division at 7000 Bollinger Canyon Road, San Ramon, CA 94583 during the 7‐day public review period, from December 21, 2022 through December 27, 2022.

Ryan Driscoll – Associate Planner
Direct Phone: (925) 973-2568 – Fax: (925) 830-0100 – [email protected] City of San Ramon – Planning Services Division – 7000 Bollinger Canyon Rd., San Ramon, CA 94583

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Packet Pg. 419 Attachment: C: Public Comments received on the revised Draft 2023-2031 Housing Element dated December 2022 (3867 : General Plan Debbie Chamberlain and Cindy Yee
Planning Services Division
7000 Bollinger Canyon Rd.

San Ramon, CA 94583
December 28, 2022
Dear Mrs. Chamberlain and Mrs. Yee:

East Bay for Everyone writes to help ensure San Ramon's second draft Housing Element will meaningfully help those who need housing in San Ramon. Our major concerns with this new draft are:
- San Ramon did not meaningfully commit to reducing parking minimums despite evidence from property owners that they serve as a constraint.
- San Ramon is using unrealistic development assumptions for its largest parcels, without substantial evidence that existing uses will discontinue.

11.5.5 Housing Programs
Program 18
We are very excited by this program and hope San Ramon will implement it to the fullest. We encourage San Ramon to target a higher number of units than 50 units, which amounts to about three acres of land. San Ramon should target 200 units under this program instead of 50.

We are also concerned that the upper density level proposed of 15 units/acre will not increase zoned capacity significantly compared to SB 9,
1 corresponding to only 2 or 3 units in the standard
range of San Ramon single-family lot sizes. 3 units are already possible with SB 9 and ADUs, which will also be more attractive through ministerial approvals; the addition of a single attached unit is not likely to be attractive enough to justify the expense of high local land values plus demolition cost. Consider amending the program to ensure missing middle projects are feasible on mostlots in practice. For example, the city could permit a fourplex on any parcel between 6-10,000 square feet (~17 DUA), and permit a triplex on any parcel smaller than 6000 square feet (22 DUA), with development standards applied only to the extent they do not bar such projects. 1 Typical lot sizes of single-family homes in San Ramon, based on 16 lots selected by eye from a range of neighborhoods on CCMAP, average about 8,000 square feet. With a maximum 15 du/a, the 25th percentile lot we found of 6,975 s.f. would hold 2.4 (two) units, the median of 7,675 would hold 2.6 (three) units, and the 75th percentile of 9,925 would hold 3.4 (three) units.

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Packet Pg. 420 Attachment: C: Public Comments received on the revised Draft 2023-2031 Housing Element dated December 2022 (3867 : General Plan We also recommend studying off-street parking standards to the list of development standards for Program 18 and consider moving to 0.5/unit ratios, as one-to-one ratios are likely to hurt the feasibility of missing middle projects.
2 We encourage San Ramon to include Program 18 units toward its above moderate income RHNA allocation, using an expected yield formula similar to the one used for ADU's.

Parking minimums
The parking changes specified in Program 19 appear to be minimal, those required only to comply with state law. Parking will continue to likely be a constraint needing reduction, as shown by multiple studies.

The draft also notes the passage of AB 2097 without noting no site in San Ramon is likely to be affected by this law: the MTC map of major transit stops is blank between Walnut Creek and Dublin.

San Ramon presents a comparison to other nearby cities for parking requirements for a hypothetical 100 unit apartment complex (Table 11.3-4). Not only does San Ramon have the highest parking minimums included in the list, none of the comparison cities met their 5th Cycle RHNA allocation, suggesting that parking minimums constrain development in all of these cities and need to be reduced in all of them.

San Ramon should eliminate guest parking minimums, eliminate parking minimums entirely in the City Center core where many amenities are within walking or cycling distance, and set minimums to 1 space/unit for all other projects in the city.

Program 13
This program only commits to additional rezoning "if the buffer is diminishing" which leaves wide latitude. San Ramon should provide a specific number or percentage that qualifies as "diminishing," and clarify what it will increase the buffer to if it falls below that amount.

Sites Inventory
Because San Ramon is meeting more than 50% of its lower income RHNA on nonvacant parcels, San Ramon must include substantial findings that the existing use will be discontinued during the planning period. We find that evidence lacking.

Likelihood of nonresidential development
2 The most prominent historical model of missing middle housing consistent with 1:1 parking ratios is the dingbat, parking tucked under the homes, which presumably San Ramon does not want to foster; it may already be banned by objective design standards.

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Packet Pg. 421 Attachment: C: Public Comments received on the revised Draft 2023-2031 Housing Element dated December 2022 (3867 : General Plan HCD's October 2022 letter asked San Ramon to analyze the likelihood of nonresidential development on sites included in the inventory based on past trends. We do not find evidence in the draft that this analysis was completed or included for all sites.

PG&E conference center site
The inventory continues to place reliance on PG&E selling or redeveloping the SRV Conference Center entirely. Adding up multiple parcels, this appears to account for 439 total"realistic" units.

Although it now notes that PG&E consolidated to leave a nearby parcel to be redeveloped, it continues to provide no evidence that it will leave this site in full, which would be required for this capacity.

Toyota site
The inventory also rates the Toyota site at 2451 Bishop Ranch as fitting 1,066 units. Although more text has been added to the notes column, it continues to provide no evidence that the owner intends to turn part of the site to residential use, merely elaborating on speculations that it would make sense. Page H.A-14 has the same notes from a Toyota representative we drew attention to in our previous letter, saying no change in status was anticipated. (It also does not discuss whether building over 60% of the site while keeping the existing use on the remaining 40% would be compatible with maintaining required off-street parking for the existing use.) Bishop Ranch
The inventory newly indicates that Bishop Ranch sites 7, 8, and 11, accounting for a total of 2,084 realistic zoned units, were added for rezoning at the request of the property owner. While this is more evidence of redevelopment intention than exists for PG&E and Toyota, it still seems unrealistic given that the same Bishop Ranch owner has been approved to build 1,472 units in the planning period and has thousands more scheduled in later periods—does the developer have such capacity to balloon their own project in the first third of their 25-year plan? 2400 Old Crow Canyon
Our previous letter
3 noted that similar language about this site was present in the 2015 Housing Element draft. San Ramon added a lot of words to the notes for this site without providing any evidence that the use will discontinue or that the property owner is interested in adding housing on this site.

Other sites
It is unclear why larger parcels are assessed to realistically produce 75% of their maximum zoned capacity while many others are assumed at 100%. 75% across the board would be more realistic, founded in experience.
3 Sent to HCD on June 10, available at
https://eastbayforeveryone.org/wp-content/uploads/2022/06/2022-06-09-san-ramon-housing-element-dr aft.pdf

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Packet Pg. 422 Attachment: C: Public Comments received on the revised Draft 2023-2031 Housing Element dated December 2022 (3867 : General Plan

11.3 Constraints
Development Standards (Church of the Valley)
In June 2022 San Ramon received a letter from a pastor interested in building housing on church land.
4 To make onsite affordable housing feasible, the pastor asked for increases in density (to 14-22 DUA), reductions in parking minimums, and less intense creek standards. The second draft lowers creek standards but does not increase density or lower parking minimums.

San Ramon should take feedback from property owners, especially those interested in building affordable housing, more seriously. We share the pastor's concerns about low densities and large parking minimums. San Ramon should rezone this site to meet the pastor's criteria.

On page 165 San Ramon notes the church can receive waivers in response for density bonuses, however, per HCD guidance the Housing Element is not supposed to include density bonuses in site feasibility calculations. Any density bonus should be a true "bonus"in addition to feasible base zoning."The analysis of “appropriate zoning”should not include residential buildout projectionsresulting from the implementation of a jurisdiction’sinclusionary program or potential increase in density due to a density bonus."
https://www.hcd.ca.gov/community-development/housing-element/docs/sites_inventory_memo_f inal06102020.pdf
Political and community opposition
A developer interviewed by San Ramon describes the experience of proposing 248 apartments on a parcel near downtown, which was met with opposition from residents and the Planning Commission. Instead they proposed 40 single family townhomes, which will not be as affordable, will not provide as much in tax revenue or impact fees, and will not help San Ramon meet its RHNA allocation nearly as much.

Community and political opposition serves as a significant constraint on development in San Ramon and this should be analyzed as part of the Housing Element, including the total number of units that were proposed vs. actually permitted after "community feedback."

11.1.3 Public Outreach
We received no email notification of San Ramon's second draft, even though we subscribed on May 11 to a San Ramon city listserv labeled "General Plan Housing Element Update." We also provided several comments on San Ramon's first Housing Element draft.

San Ramon released the draft for comment in the 7 day period including Christmas Eve, Christmas and the day after Christmas which is a federal holiday. It is difficult for our volunteers to turn 4 See attachment from EB4E to HCD,"San Ramon pastor asking for higher density, lower parking minimums" dated December 29, 2022.

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Packet Pg. 423 Attachment: C: Public Comments received on the revised Draft 2023-2031 Housing Element dated December 2022 (3867 : General Plan around comments in seven days let alone when several of those days are part of the biggest holiday of the year, and daycares are closed.

If San Ramon submits subsequent drafts, we hope they will do a better job of notifying the public.

Conclusion
We look forward to continuing to engage with the City of San Ramon throughout the Housing Element Update and General Plan process.

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Packet Pg. 424 Attachment: C: Public Comments received on the revised Draft 2023-2031 Housing Element dated December 2022 (3867 : General Plan From: plansanramon <[email protected]>
Sent: Monday, June 27, 2022 1:28 PM
To: [email protected]; [email protected]; [email protected]; [email protected]; Cindy yee; Debbie Chamberlain; Lauren Barr; Ryan Driscoll
Subject: [#20220627202758] Comment from plansanramon Website San Ramon General Plan

Ticket: [#20220627202758]
Name: Kraig Whitney
e-mail: [email protected]
General Plan Comment:

I would like to see the general plan to change the zoning of the San Ramon golf course (south San Ramon, off Fircrest) back to golf course zoning from it's current recreational zoning. This was done 20+ years ago with little south San Ramon residents feedback. If you were to poll this group again, I'm positive you'd get a concensus to rezone the golf course back to a golf course only zone.

Page title: Home

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Packet Pg. 425 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: plansanramon <[email protected]>
Sent: Monday, October 24, 2022 5:15 PM
To: [email protected]; [email protected]; [email protected]; [email protected]; Cindy yee; Debbie Chamberlain; Lauren Barr; Ryan Driscoll
Subject: [#20221025001447] Comment from plansanramon Website San Ramon General Plan

Ticket: [#20221025001447]
Name: John Ochoa
e-mail: [email protected]
Housing Element Comment:

Not in my backyard
Page title: Home

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Packet Pg. 426 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Harvey McKeon <[email protected]>
Sent: Wednesday, August 10, 2022 8:47 AM
To: Cindy yee; Ryan Driscoll
Cc: Planning Services (public); City Clerk (Public); Kyle Swarens; Jacob Adiarte; Dan Calamuci
Subject: Carpenters Local 152 Comments Re Housing Element Attachments: LU152_Comments_Housing_Element_SanRamon_8_10_2022.pdf Importance: High
Dear Ms. Cindy Yee,
Please find attached a letter with comments regarding the Draft San Ramon Housing Element Update.

This is a submission on behalf of Carpenters Local Union 152.

Thank you to your colleague Ryan Driscoll for discussing some of our comments over the phone this week in advance of this letter.

We look forward to discussing these proposals further with you, and to collaborating on this issue of great importance for the people of San Ramon.

Yours faithfully,
Harvey McKeon
Harvey McKeon
Field Representative
Research
Nor Cal Carpenters Union
265 Hegenberger Rd. Ste 200
Oakland, CA 94621
(M) 510 414-5371

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Packet Pg. 427 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing

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Packet Pg. 428 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing

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Packet Pg. 429 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing

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Packet Pg. 430 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing

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Packet Pg. 431 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: East Bay for Everyone <[email protected]> Sent: Monday, July 11, 2022 2:35 PM
To: Planning Services (public); Joe Gorton; City Clerk (Public) Cc: [email protected]
Subject: Comment on San Ramon Housing Element
We have been in discussion with members of SRVEA (a union of SRVUSD employees) about the urgent need for teacher housing throughout the district. SRVUSD owns a number of parcels that could become workforce housing, or could be leased to help support school operations.

SRVEA may or may not send a formal letter by the time comments are due; my understanding is that their leadership is on summer vacation right now.

All parcels owned by SRVUSD that are in San Ramon should be rezoned as part of the Housing Element so that a base density of 40 homes/acre can be built by right.

While SRVUSD does not have plans to build teacher housing at the moment, changing the base zoning will help make financing and planning a future housing application cheaper and more predictable. Changing the zoning will give a potential project the protections embedded in the Housing Accountability Act, which will help insulate it from community and political opposition. We also believe that this will help San Ramon meet its RHNA goals.

Here are two sites that we think could be feasible - there may be more but these jumped out initially.

This vacant area at Bollinger Canyon Elementary is about two acres, which would be enough for 80 homes at 40 du/ac.

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Packet Pg. 432 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing Country Club Elementary (which I attended in 4th grade) has an unusually large playground.

This space is over one acre and has road access from May Way.

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Packet Pg. 433 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing

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Packet Pg. 434 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: East Bay for Everyone <[email protected]> Sent: Thursday, December 29, 2022 11:26 AM
To: Debbie Chamberlain; Cindy yee; Planning Services (public); Housing Elements@HCD; Finney, Connor@HCD; McDougall, Paul@HCD
Subject: Comment on San Ramon's second Housing Element draft Attachments: 2022-12-29-san-ramon-housing-element-draft.pdf We apologize for sending this feedback two days late. As noted in a previous email, Christmas was four days ago, and we did not receive email notification about the draft despite signing up for a listserv on San Ramon's website titled "General Plan Housing Element Update." We also provided a comment on the first draft. We hope you will consider our comment even though we missed the deadline.

If there is a more appropriate listserv to sign up for to receive notification of new drafts or public meetings about the Housing Element or General Plan update, please let us know.

Thanks,
Kevin

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Packet Pg. 435 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing Debbie Chamberlain and Cindy Yee
Planning Services Division
7000 Bollinger Canyon Rd.

San Ramon, CA 94583
December 28, 2022
Dear Mrs. Chamberlain and Mrs. Yee:

East Bay for Everyone writes to help ensure San Ramon's second draft Housing Element will meaningfully help those who need housing in San Ramon. Our major concerns with this new draft are:
- San Ramon did not meaningfully commit to reducing parking minimums despite evidence from property owners that they serve as a constraint.
- San Ramon is using unrealistic development assumptions for its largest parcels, without substantial evidence that existing uses will discontinue.

11.5.5 Housing Programs
Program 18
We are very excited by this program and hope San Ramon will implement it to the fullest. We encourage San Ramon to target a higher number of units than 50 units, which amounts to about three acres of land. San Ramon should target 200 units under this program instead of 50.

We are also concerned that the upper density level proposed of 15 units/acre will not increase zoned capacity significantly compared to SB 9,
1 corresponding to only 2 or 3 units in the standard
range of San Ramon single-family lot sizes. 3 units are already possible with SB 9 and ADUs, which will also be more attractive through ministerial approvals; the addition of a single attached unit is not likely to be attractive enough to justify the expense of high local land values plus demolition cost. Consider amending the program to ensure missing middle projects are feasible on mostlots in practice. For example, the city could permit a fourplex on any parcel between 6-10,000 square feet (~17 DUA), and permit a triplex on any parcel smaller than 6000 square feet (22 DUA), with development standards applied only to the extent they do not bar such projects. 1 Typical lot sizes of single-family homes in San Ramon, based on 16 lots selected by eye from a range of neighborhoods on CCMAP, average about 8,000 square feet. With a maximum 15 du/a, the 25th percentile lot we found of 6,975 s.f. would hold 2.4 (two) units, the median of 7,675 would hold 2.6 (three) units, and the 75th percentile of 9,925 would hold 3.4 (three) units.

2.1.h
Packet Pg. 436 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing We also recommend studying off-street parking standards to the list of development standards for Program 18 and consider moving to 0.5/unit ratios, as one-to-one ratios are likely to hurt the feasibility of missing middle projects.
2 We encourage San Ramon to include Program 18 units toward its above moderate income RHNA allocation, using an expected yield formula similar to the one used for ADU's.

Parking minimums
The parking changes specified in Program 19 appear to be minimal, those required only to comply with state law. Parking will continue to likely be a constraint needing reduction, as shown by multiple studies.

The draft also notes the passage of AB 2097 without noting no site in San Ramon is likely to be affected by this law: the MTC map of major transit stops is blank between Walnut Creek and Dublin.

San Ramon presents a comparison to other nearby cities for parking requirements for a hypothetical 100 unit apartment complex (Table 11.3-4). Not only does San Ramon have the highest parking minimums included in the list, none of the comparison cities met their 5th Cycle RHNA allocation, suggesting that parking minimums constrain development in all of these cities and need to be reduced in all of them.

San Ramon should eliminate guest parking minimums, eliminate parking minimums entirely in the City Center core where many amenities are within walking or cycling distance, and set minimums to 1 space/unit for all other projects in the city.

Program 13
This program only commits to additional rezoning "if the buffer is diminishing" which leaves wide latitude. San Ramon should provide a specific number or percentage that qualifies as "diminishing," and clarify what it will increase the buffer to if it falls below that amount.

Sites Inventory
Because San Ramon is meeting more than 50% of its lower income RHNA on nonvacant parcels, San Ramon must include substantial findings that the existing use will be discontinued during the planning period. We find that evidence lacking.

Likelihood of nonresidential development
2 The most prominent historical model of missing middle housing consistent with 1:1 parking ratios is the dingbat, parking tucked under the homes, which presumably San Ramon does not want to foster; it may already be banned by objective design standards.

2.1.h
Packet Pg. 437 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing HCD's October 2022 letter asked San Ramon to analyze the likelihood of nonresidential development on sites included in the inventory based on past trends. We do not find evidence in the draft that this analysis was completed or included for all sites.

PG&E conference center site
The inventory continues to place reliance on PG&E selling or redeveloping the SRV Conference Center entirely. Adding up multiple parcels, this appears to account for 439 total"realistic" units.

Although it now notes that PG&E consolidated to leave a nearby parcel to be redeveloped, it continues to provide no evidence that it will leave this site in full, which would be required for this capacity.

Toyota site
The inventory also rates the Toyota site at 2451 Bishop Ranch as fitting 1,066 units. Although more text has been added to the notes column, it continues to provide no evidence that the owner intends to turn part of the site to residential use, merely elaborating on speculations that it would make sense. Page H.A-14 has the same notes from a Toyota representative we drew attention to in our previous letter, saying no change in status was anticipated. (It also does not discuss whether building over 60% of the site while keeping the existing use on the remaining 40% would be compatible with maintaining required off-street parking for the existing use.) Bishop Ranch
The inventory newly indicates that Bishop Ranch sites 7, 8, and 11, accounting for a total of 2,084 realistic zoned units, were added for rezoning at the request of the property owner. While this is more evidence of redevelopment intention than exists for PG&E and Toyota, it still seems unrealistic given that the same Bishop Ranch owner has been approved to build 1,472 units in the planning period and has thousands more scheduled in later periods—does the developer have such capacity to balloon their own project in the first third of their 25-year plan? 2400 Old Crow Canyon
Our previous letter
3 noted that similar language about this site was present in the 2015 Housing Element draft. San Ramon added a lot of words to the notes for this site without providing any evidence that the use will discontinue or that the property owner is interested in adding housing on this site.

Other sites
It is unclear why larger parcels are assessed to realistically produce 75% of their maximum zoned capacity while many others are assumed at 100%. 75% across the board would be more realistic, founded in experience.
3 Sent to HCD on June 10, available at
https://eastbayforeveryone.org/wp-content/uploads/2022/06/2022-06-09-san-ramon-housing-element-dr aft.pdf

2.1.h
Packet Pg. 438 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing

11.3 Constraints
Development Standards (Church of the Valley)
In June 2022 San Ramon received a letter from a pastor interested in building housing on church land.
4 To make onsite affordable housing feasible, the pastor asked for increases in density (to 14-22 DUA), reductions in parking minimums, and less intense creek standards. The second draft lowers creek standards but does not increase density or lower parking minimums.

San Ramon should take feedback from property owners, especially those interested in building affordable housing, more seriously. We share the pastor's concerns about low densities and large parking minimums. San Ramon should rezone this site to meet the pastor's criteria.

On page 165 San Ramon notes the church can receive waivers in response for density bonuses, however, per HCD guidance the Housing Element is not supposed to include density bonuses in site feasibility calculations. Any density bonus should be a true "bonus"in addition to feasible base zoning."The analysis of “appropriate zoning”should not include residential buildout projectionsresulting from the implementation of a jurisdiction’sinclusionary program or potential increase in density due to a density bonus."
https://www.hcd.ca.gov/community-development/housing-element/docs/sites_inventory_memo_f inal06102020.pdf
Political and community opposition
A developer interviewed by San Ramon describes the experience of proposing 248 apartments on a parcel near downtown, which was met with opposition from residents and the Planning Commission. Instead they proposed 40 single family townhomes, which will not be as affordable, will not provide as much in tax revenue or impact fees, and will not help San Ramon meet its RHNA allocation nearly as much.

Community and political opposition serves as a significant constraint on development in San Ramon and this should be analyzed as part of the Housing Element, including the total number of units that were proposed vs. actually permitted after "community feedback."

11.1.3 Public Outreach
We received no email notification of San Ramon's second draft, even though we subscribed on May 11 to a San Ramon city listserv labeled "General Plan Housing Element Update." We also provided several comments on San Ramon's first Housing Element draft.

San Ramon released the draft for comment in the 7 day period including Christmas Eve, Christmas and the day after Christmas which is a federal holiday. It is difficult for our volunteers to turn 4 See attachment from EB4E to HCD,"San Ramon pastor asking for higher density, lower parking minimums" dated December 29, 2022.

2.1.h
Packet Pg. 439 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing around comments in seven days let alone when several of those days are part of the biggest holiday of the year, and daycares are closed.

If San Ramon submits subsequent drafts, we hope they will do a better job of notifying the public.

Conclusion
We look forward to continuing to engage with the City of San Ramon throughout the Housing Element Update and General Plan process.

2.1.h
Packet Pg. 440 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Penny Wolfsohn <[email protected]>
Sent: Friday, June 24, 2022 12:56 PM
To: Planning Services (public)
Subject: Density with regard to housing
It’s impossible for me to read this plan and understand what it means so I am asking you. Are you aware that we cannot take in more people then we have water and environmental concerns to care for.?
I have written you about my concerns in the past and I hope they are still being considered. Before you add more housing you must plan for water needs. We don’t have enough water as it is now and to add more housing with more demand for water would not be a wise plan. You need to know that and take that into consideration.

A concerned San Ramon resident,
Penny Wolfsohn
130 Neptune Pl.

2.1.h
Packet Pg. 441 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Claire Mailhiot <[email protected]>
Sent: Tuesday, December 27, 2022 9:43 AM
To: Planning Services (public)
Subject: Draft Housing Element Comment
I believe the massive parking lots at Bishop Ranch 1 would be a great location for more housing.

Build a parking structure for the employees of the businesses there and then use the rest of the parking lots for apartments or condos that would enable workers to live near their offices.

I have been living in San Ramon since 1989. It is ostensibly a "city" but I see it turning into more of a "bedroom community" with more housing than jobs.

I don't understand the rationale for tearing down office space to build homes if we hope to get people out of their cars. But I would rather see that than having more houses built on undeveloped land (such as the ironically-named "Preserve" which destroyed so much of the wildlife habitat and natural ecosystem).

I also object to putting housing at the Marketplace, unless there is a grocery store or retail on the ground floor and an attempt is made to preserve the architectural integrity of the buildings, and the same applies to the Chevron property. I hope it can be converted to housing without destroying the campus and landscaping.

Additionally, I have concerns about the capacity of our roads to handle such an increase in population density. If there is a massive earthquake on the Calaveras fault, there will be no way to evacuate the city. Even now when there is a major accident on Bollinger or Crow Canyon, the traffic backs up for ages.

Finally, I really don't want to see San Ramon turn into Dublin.

Claire Mailhiot
San Ramon resident

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Packet Pg. 442 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Khanh Russo <[email protected]>
Sent: Friday, August 26, 2022 11:49 AM
To: Planning Services (public)
Cc: Aysha Pamukcu; Evita Chávez; [email protected]
Subject: Equity Focused Input for Housing Elements
Attachments: PBF Priority Policies 082022.pptx; PBF HE priorities - San Ramon.pdf Dear City of San Ramon:

Thank you for the opportunity to provide input on the city of San Ramon’s housing element. The Partnership for the Bay’s Future (“PBF”) is a public-private-nonprofit partnership working to create a more livable Bay Area in which diverse people of all walks of life can afford to live and thrive. To do so, we address the challenges of housing and protecting tenants through the support of equitable policy change as well as investing in the production and preservation of affordable housing.

In consultation with government leaders, housing policy experts, and communities, we have compiled a list of equitable housing priorities that we hope San Ramon will consider incorporating into the new housing element. We are including the following resources for your review and consideration:
• a slide deck covering each priority policy idea, with template language for your jurisdiction to consider,
• examples of places where the policy has been adopted, and • additional links and resources.

We believe that your current efforts already include many of the listed policies, which we applaud. In addition to the attached equitable policy resources, we are offering technical assistance from Baird + Driskell Community Planning if your jurisdiction is interested in exploring or developing some of these policies even further. If you have any questions, please contact me ([email protected]) and our colleagues at Baird + Driskell (Kristy Wang, [email protected], and Joshua Abrams, [email protected]). We will follow up with you shortly to see if we can provide further support.

Thank you again for the opportunity to provide input into San Ramon’s housing element.

We appreciate all your efforts to address the housing needs of Bay Area and California residents.

Sincerely,

Khanh Russo
Vice President of Policy and Innovation
San Francisco Foundation

2.1.h
Packet Pg. 443 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing Khanh Russo
Vice President of Policy and Innovation
One Embarcadero Center, Suite 1400 | San Francisco, CA 94111 T: (415) 733-8570 |
[email protected] | www.sff.org
Pronouns: He, Him, His
Please follow the Partnership for the Bay's Future on Twitter Facebook LinkedIn

2.1.h
Packet Pg. 444 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing PBF’s Priorities for 6th Cycle
Housing Elements
August 2022

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Packet Pg. 445 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Priority Policies and Actions

1. Favorable Zoning and Land Use
• Make multifamily infill easier to develop
• Allow, require or encourage multifamily housing in
more places
• Allow or encourage missing middle housing in singlefamily neighborhoods • Provide incentives for affordable housing
development
• Provide incentives for affordable ADUs and "missing
middle" housing

2. Accelerating Production Timeframes
• Streamline development approvals and
environmental review process for multifamily housing
• Streamline permitting process for multifamily housing

3. Reducing Construction and Development Costs
• Ensure local requirements are not making
development more expensive without requisite
benefits
• Actively support the use of modular and factory-built construction methods

4. Providing Financial Subsidies: Generate new or dedicate existing revenue for affordable housing

5. Advocating for Rent Control and Just Cause for Eviction Policies
• Adopt or update rent stabilization policies
• Adopt or update just cause eviction policies

6. Advocating for Community Land Trusts (CLTs): Support the formation and operation of community land trusts (CLTs)

7. Advocating for Inclusionary Zoning and Impact Fees:

Create or review/update inclusionary housing (including inlieu fees) and commercial linkage fee requirements

8. Inventory of Sites: Ensure that land is equitably zoned for multifamily housing, especially in high-opportunity areas

2.1.h
Packet Pg. 446 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan

EXAMPLES
San Francisco, Berkeley and San Diego
have eliminated minimum parking
requirements in new housing
development. San Francisco also has
parking maximums.

Redwood City's Downtown Precise Plan
links adherence to development
standards with a streamlined approvals
process.

Make multifamily infill easier to develop
3 • Revise development codes: Review multifamily
development standards to allow greater density, including floor area ratio, height limits, minimum lot or unit sizes, setbacks, lot coverage and/or allowable dwelling units per acre.
• Reduced parking requirements: Adopt policies that reduce parking minimums, establish parking maximums and
encourage other practices that reduce cost and the amount of space dedicated to cars.
• Eliminate design standards: Eliminate or replace
subjective development and design standards with objective standards that simplify zoning clearance and improve
approval certainty and timing.
• Form-based codes: Establish form-based codes that can be paired with by-right approvals
Explore the following policies and programs:

2.1.h
Packet Pg. 447 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan

EXAMPLES
Redwood City's Mixed-Use
Neighborhood District allows greater
height and FAR for residential-only and
mixed-use buildings than for
commercial-only buildings.

In 2019, San Jose revised its planning
regulations to allow for co-living housing
types.

Allow, require or encourage multifamily housing in
more places
4 In mixed-use zones where commercial uses outcompete
residential uses, cities could:
• Change zoning standards: Offer greater FAR, height and other zoning standards for residential developments in
mixed use zones.
• Encourage mixed-use: Require applicants to build housing when applying to build commercial developments in mixed use zones
Cities can also ensure their regulations don't preclude the development of microunits, single room occupancy (SRO)
buildings.

Explore the following policies and programs:

2.1.h
Packet Pg. 448 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan

EXAMPLES
Portland has established a strong missing
middle policy, including their Better Housing by
Design work, focused on design guidelines and
related zoning code changes in multi-family
zones, and the Residential Infill Project
development standards focused on single family
neighborhoods.

Eugene, Oregon approved Middle Housing
Code Amendments to comply with state law. The
amendments include smaller minimum lot sizes,
lot size reductions for affordable units, parking
reductions for housing built near transit, and
other changes.

Allow or encourage missing middle housing in singlefamily neighborhoods 5 • Rezoning: Rezone in single-family neighborhoods to allow additional ADUs, duplexes, triplexes and other small-scale multifamily ("missing middle") housing
• New standards and guidelines: Establish design and
development standards and guidelines that support missing middle housing types
• SB 9 ordinances: Develop local SB 9 implementing
ordinances that encourage and support the creation of
small-scale multifamily housing rather than merely comply with state requirements.

Explore the following policies and programs:

2.1.h
Packet Pg. 449 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan

EXAMPLES
Menlo Park's Affordable Housing Overlay
Zone
Foster City's Affordable Housing Overlay
Zone
Oakley’s Affordable Housing Overlay Zone
Sunnyvale's waiver of parking
requirements
Half Moon Bay's waiver of development
standards
Provide incentives for affordable housing development
6 • Overlay zones: Establish an affordable housing overlay zone to encourage the production of below-market-rate
affordable housing with targeted incentives or relaxed
requirements that go beyond state density bonus law
• Incentives for developers: Offer zoning concessions and fee exemptions as incentives to developers of multifamily housing projects which meet [JURISDICTION]’s housing
needs, in exchange for an agreement that more than [#%] of the total number of units constructed will be affordable to lower-income households
Explore the following policies and programs:

2.1.h
Packet Pg. 450 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan

EXAMPLES
San Diego allows an extra ADU on a site that
has reached the maximum ADU limit if the extra
one is deed-restricted affordable.

Piedmont has flexibility built into their ADU
ordinance where larger ADUs are permitted if
they are deed restricted affordable for low- income households.

Pasadena incentivizes the creation of ADUs
affordable to Section 8 voucher holders with
incomes below 80% of AMI. The city offers
comprehensive assistance (with financing,
designing, permitting, and constructing) and low- interest construction loans.

LA ADU Accelerator matches homeowners with
older renters, providing landlord support and
reliable rent in return for affordability.

LA Mas's Backyard Homes Project
Provide incentives for deed-restricted affordable ADUs
and "missing middle" housing
7 • Lot splits: Allow nonprofits and community land trusts (CLTs) to sell deed restricted affordable ADUs separately from the main house.
• Increase ADUs per lot: Allow nonprofits/CLTs to build two detached, deed restricted, affordable ADUs per property. • Community partnerships: Develop zoning standards that provide additional flexibility to nonprofits/CLTs that want to build ADUs, including 2-story ADUs.
• Upzoning partnerships: Allow nonprofits/CLTs to convert single family homes into deed restricted, affordable duplexes, triplexes or quads (more permissive than SB 9)
• Density bonuses: Develop rules that extend the density bonus to 100 percent affordable projects smaller than 5 units.

Explore the following policies and programs:

2.1.h
Packet Pg. 451 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan

EXAMPLES
Redwood City's Downtown Precise Plan
allows for the ministerial approval of
certain multifamily infill projects.

Streamline development approvals and environmental
review process for multifamily housing
8 In locations that have not yet met their housing targets, SB 35 pairs a streamlined approval process with objective design standards for infill projects that provide a certain level of affordability and comply with existing residential and mixed-use zoning and other requirements.

Localities could take it further by:
• Establishing by-right zoning and local systems/dedicated staff for more types of housing beyond SB 35-eligible
projects
• Establishing by-right zoning in certain areas or
neighborhoods
Explore the following policies and programs:

2.1.h
Packet Pg. 452 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan

EXAMPLES
San Diego has an expedited permitting process
for affordable, infill and sustainable buildings.

Seattle has a expedited approvals program for
new construction projects that meet certain
sustainability requirements.

San Francisco's Mayoral Executive Directives
on ADUs and setting timelines for approvals
have sped up permitting processes by providing
a rationale to create a sense of urgency and
focus city staff.

San Jose had "ADU Tuesdays" at the city's
permit counter in order to streamline ADU permit
processing.

Streamline permitting process for multifamily housing
9 • Improve application processes: Review application review and approvals process to identify improvements (convene stakeholders, hire an outside firm).
• Pre-application checks: Establish pre-application checks to ensure that applications are complete before submission. • One-stop-shops: Establish one-stop-shop permitting
process and/or a single point of contact for coordinating permitting across city approval functions (e.g., planning, public works, building) from entitlement application to certificate of occupancy.
• Special expedited permits: Establish priority permit
processing or reduced plan check times for specific
categories of housing (ADU/JADUs, multifamily housing,
affordable housing, etc.)
Explore the following policies and programs:

2.1.h
Packet Pg. 453 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Ensure local requirements do not make
development more costly without requisite benefits
10 Explore the following policies and programs:
• Flexible standards: Provide additional
flexibility on development standards,
including parking standards, for
affordable housing
• Reduce construction costs: Review
current local construction requirements
and building standards for excessive and
costly terms

EXAMPLES
Half Moon Bay’s zoning code allows for
flexibility in the application of
development standards for affordable
housing projects.

2.1.h
Packet Pg. 454 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Actively support the use of modular and factorybuilt construction methods 11 Explore the following policies and programs:
• Expedited permits: Establish a clear and expedited approval and permitting process for modular and manufactured homes.
• Pre-fab trainings: Conduct or require a training for building officials and relevant staff to ensure they are aware of current state processes and requirements and how they intersect with local authority/responsibilities.

2.1.h
Packet Pg. 455 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan

EXAMPLES
In 2016, Santa Clara County voters and
Alameda County voters approved general
obligation bonds for affordable housing through
Measure A ($950 million in Santa Clara County)
and Measure A1 ($580 million in Alameda
County).

In 2018, Oakland voters approved a vacant
property tax that generates revenue for
homeless services.

By resolution, San Mateo County's Board of
Supervisors established funding priorities – including affordable housing uses – for 2016's Measure K half-cent sales tax extension.

In 2012, San Francisco established its Housing
Trust Fund through a set-aside in the General
Fund.

Generate new revenue and/or dedicate existing
revenue towards affordable housing
12 • Explore new or increased taxes: Generate new dedicated revenue for affordable housing. This could include:
• Sales tax increases
• General obligation bonds
• Transient occupancy taxes
• Parcel taxes
• Head taxes
• Business license (landlord) taxes
• Real estate transfer taxes
• Vacant property and vacancy taxes
• Prioritize existing revenue: Establish priorities or set-aside existing local general funds for affordable housing.

Explore the following policies and programs:

2.1.h
Packet Pg. 456 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan

EXAMPLES
Several Bay Area jurisdictions have rent
stabilization policies that go beyond state
law (such as smaller allowed rent
increases), including:
• San Francisco
• San Jose
• Oakland
• Berkeley
• East Palo Alto
• Mountain View
• Richmond
Adopt or update rent stabilization policies
13 Under California’s Tenant Protection Act of 2019 (AB 1482):
• Rent cannot be increased more than 5% + your local CPI (Consumer Price Index) OR 10% annually – whichever of
these is lower.

Localities could take it further by:
• Adopting a local ordinance with a smaller allowable annual rent increase
• Adopting a local ordinance that does not sunset in 2030 Localities could also dedicate funding and resources toward education and enforcement.

Explore the following policies and programs:

2.1.h
Packet Pg. 457 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan

EXAMPLES
Berkeley, East Palo Alto and
Oakland are some Bay Area
jurisdictions that have existing
permanent Just Cause evictions
ordinances.

Most rental units in Oakland and
Richmond are subject to their just
cause eviction ordinances.

Adopt or update just cause eviction policies
14 California’s Tenant Protection Act of 2019 (AB 1482) limits the reasons for which tenants can be evicted. This law does not cover all buildings or all tenants. It expires on Jan. 1, 2030.

Localities could take it further by:
• Applying protections on day 1 of a tenancy (instead of day 365) • Requiring landlords to have a permit in hand before evicting tenants using the "substantial remodel" provision
• Passing a local ordinance that is permanent
• Expanding just cause eviction policies to cover new construction, single-family homes and condominiums
Localities could also dedicate funding and resources toward education and enforcement.

Explore the following policies and programs:

2.1.h
Packet Pg. 458 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan

EXAMPLES
In 2018, New York City funded a
citywide CLT initiative to support the
incubation/expansion of 10 CLTs
Cities like Irvine and Chicago have city
sponsored/chartered CLTs that manage
the affordable ownership stock.

Support the formation and operation of community land
trusts (CLTs)
15 • Eligibility: Ensure CLTs are eligible for local housing funding. • Opportunity to Purchase: Establish a right of first
offer/refusal that gives nonprofits/CLTs enhanced ability to buy property
• CLT Incubation: Establish an initiative to support the incubation or creation of a new community land trust. Provide financial support to CLTs in the early stages of organizational development.
• CLT Pipeline Development: Study the feasibility of requiring new inclusionary ownership units to be stewarded by a CLT. • Extra Flexibility: Give CLTs extra flexibility to
develop/steward ADUs, allowing CLTs to sell ADUs to lowincome buyers and giving CLTs more flexibility with development standards (multiple ADUs, 2-story ADUs, etc.).

Explore the following policies and programs:

2.1.h
Packet Pg. 459 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan

EXAMPLES
Inclusionary housing requirements have
been widely, but not universally, adopted
by jurisdictions across the Bay Area.

San Mateo (city) and Boulder, CO are
two examples of small to midsized cities
that have set up strong inclusionary
programs that deliver affordable units
and maintain affordability over time.

Create or review/update inclusionary housing and
commercial linkage fee requirements
16 • Establish New Inclusionary Requirements: Require the provision of affordable housing by the private sector through an inclusionary requirement for market-rate housing
(including in-lieu fee options) and a commercial linkage fee paid by new commercial development.
• Regularly Update Inclusionary Requirements: Conduct an inclusionary housing feasibility study in [20XX] and develop policy recommendations on inclusionary zoning in [20XX].

Explore the following policies and programs:

2.1.h
Packet Pg. 460 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan

EXAMPLES
Los Angeles's 6th Cycle housing element
includes an objective to "Increase the utilization
of public land for affordable housing with
particular emphasis in high resource and
gentrifying areas."
Seattle has a development siting policy that
seeks to provide housing opportunities for the
lowest-income and the most vulnerable
populations across the city, including amenity- rich neighborhoods.

San Jose has begun a process to develop an
affordable housing siting process to ensure the
city meets its fair housing and affordable
housing goals, including providing affordable
housing in higher-opportunity neighborhoods.

Ensure that land is equitably zoned for multifamily
housing, especially in high-opportunity areas
17 • Zoning: Rezone sites for multi-unit housing in high resource areas.
• Public Land: Set-aside publicly owned land in high
opportunity areas for housing development.
• Affordable Housing Siting Policy: Develop an affordable housing siting policy to provide affordable housing equitably across a jurisdiction.
• Tax Credit Competitiveness: Conduct an analysis of a
jurisdiction's geography for tax credit amenity scoring. • Zone more land for multi-family in amenity-rich areas, and do land assembly/acquisition in places that score highly for tax credits • Address gaps in communities that do not score highly for tax credit amenities, especially if they are high resource areas
Explore the following policies and programs:

2.1.h
Packet Pg. 461 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Other equitable housing policies for further exploration 18 • Anti-tenant harassment policies (Oakland and Concord) • Preservation policies including acquisition/rehab models • Transit Oriented Communities (TOC) policies
Explore the following policies and programs:

2.1.h
Packet Pg. 462 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan baysfuture.org

2.1.h
Packet Pg. 463 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan August 24, 2022
Submitted by email to: [email protected]
RE: San Ramon’s 6th Cycle Housing Element Update
Dear City of San Ramon:

Thank you for the opportunity to provide input on the city of San Ramon’s housing element.

Your work supporting your community to meet its housing needs is critical in addressing the current housing affordability crisis. We understand that at this moment in the housing element process, your jurisdiction is waiting for comments from HCD. As such, we request that you incorporate additional equitable housing policies into your draft housing element during your next revision. We offer the attached equitable policy resources as well as potential technical assistance from Baird + Driskell Community Planning (“B+D”) if your jurisdiction is interested in this level of support.

The Partnership for the Bay’s Future (“PBF”) is a public-private-nonprofit partnership working to create a more livable Bay Area in which diverse people of all walks of life can afford to live and thrive. To do so, we address the challenges of housing and protecting tenants through the support of equitable policy change as well as investing in the production and preservation of affordable housing.

In consultation with government leaders, housing policy experts, and communities, we have compiled a list of equitable housing priorities that we request San Ramon incorporate into the new housing element. In some cases, these are policies that housing element law requires jurisdictions to address as a potential action or recommendation in their housing elements, but in other cases, these are suggested policies that we are raising up as PBF’s equitable planning priorities. We are including the following resources for your review and consideration:
● a slide deck covering each priority policy idea, with template language for your jurisdiction to consider,
● examples of places where the policy has been adopted, and ● additional links and resources.

We believe that San Ramon’s current efforts already include some of the listed policies, which we applaud. We also believe that all Bay Area communities can take more steps to make their housing elements more equitable. The attached summaries can be used as resources for staff as they communicate with both decision makers and the public, and we are happy to provide further assistance to incorporate these policies into your housing element as well as help draft talking points that can be tailored for local implementation.

We believe the following policies can play an important role in meeting the requirements of this housing element and supporting thriving communities, and we request that San Ramon include them in the next housing element draft:

2.1.h
Packet Pg. 464 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing

1. Favorable Zoning and Land Use
○ Make multifamily infill easier to develop
○ Allow, require or encourage multifamily housing in more places ○ Allow or encourage missing middle housing in single-family neighborhoods ○ Provide incentives for affordable housing development ○ Provide incentives for affordable ADUs and "missing middle" housing

2. Accelerating Production Timeframes
○ Streamline development approvals and environmental review process for multifamily housing
○ Streamline permitting process for multifamily housing

3. Reducing Construction and Development Costs
○ Ensure local requirements are not making development more expensive without requisite benefits
○ Actively support the use of modular and factory-built construction methods

4. Providing Financial Subsidies: Generate new or dedicate existing revenue for affordable housing

5. Advocating for Rent Control and Just Cause for Eviction Policies ○ Adopt or update rent stabilization policies
○ Adopt or update just cause eviction policies

6. Advocating for Community Land Trusts (CLTs): Support the formation and operation of community land trusts

7. Advocating for Inclusionary Zoning and Impact Fees: Create or review/update inclusionary housing (including in-lieu fees) and commercial linkage fee requirements

8. Inventory of Sites: Ensure that land is equitably zoned for multifamily housing, especially in high-opportunity areas
If you have any questions, please contact me ([email protected]) and our colleagues at Baird + Driskell (Kristy Wang, [email protected], and Joshua Abrams, [email protected]).

We will follow up with you shortly to see if we can provide further support, including technical assistance from the B+D team to further explore some of these policies.

Thank you again for the opportunity to provide input into San Ramon’s housing element. We appreciate your efforts to address the housing needs of Bay Area and California residents.

Sincerely,
Khanh Russo
Vice President of Policy and Innovation
San Francisco Foundation

2.1.h
Packet Pg. 465 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: East Bay for Everyone <[email protected]> Sent: Friday, December 23, 2022 8:49 AM
To: Joe Gorton; Planning Services (public); Finney, Connor@HCD; McDougall, Paul@HCD; Cindy yee
Subject: Extension for San Ramon's comment period
San Ramon released their 2nd draft on December 20th.

We both submitted public comments on the first draft and I believe that means we are supposed to receive an email from San Ramon letting us know the second draft is available. Neither John Minot nor myself received emails from San Ramon; we only found out the draft was available because we read a news story about it.

The 7 day comment period spans Christmas Eve, Christmas, and the day after Christmas. We are an all volunteer group, I am hosting family, daycare is closed and it is unlikely we will be able to submit a comment on time.

Further, we may have questions about the draft and we find it unlikely that Planning staff will be responsive during this window.

We'd like our comments to be considered even if they are submitted after the deadline.

Thanks very much,
Kevin

2.1.h
Packet Pg. 466 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Debbie Chamberlain
Sent: Wednesday, August 3, 2022 11:38 AM
To: RICHARD B MARKS; Eric Wallis
Cc: Cindy yee
Subject: FW: CAMPAD Comments on Mixed-Use Ad Hoc Committee Agenda Attachments: 2022-08-03 CAMPAD Comments on Ad Hoc Commitee Agenda.pdf Debbie Chamberlain |Community Development Director
City of San Ramon |Community Development Department
7000 Bollinger Canyon Road · San Ramon, CA 94583 · www.sanramon.ca.gov T: 925.973.2566 | F: 925 830.0100 | E: [email protected] The public counter at the San Ramon Permit Center is now open, with social distancing and hygiene measures in place, and face coverings required. Please visit http://www.bit.ly/CityServices for the latest information regarding City services.

From: [email protected] <[email protected]> Sent: Wednesday, August 3, 2022 11:16 AM
To: [email protected]
Cc: Dave Hudson <[email protected]>; Christina Franco <[email protected]>; Debbie Chamberlain <[email protected]>; Martin Lysons <[email protected]>; [email protected]; [email protected]
Subject: CAMPAD Comments on Mixed-Use Ad Hoc Committee Agenda Good morning Mixed-Use Ad Hoc Committee members:

Thank you for including Citizens Against Market Place Apartment/Condo Development’s (CAMPAD) July 18th letter in the agenda for today’s meeting. Attached, please find a letter on behalf of CAMPAD commenting on the agenda.

Please confirm that this letter has been circulated to all members.

Thank you,
Ariel Strauss
__________________________________________________________________________________________________________________ ____
510-900-9502 x 702
Greenfire Law, P.C.

P.O. Box 8055
Berkeley, CA 94707

PRIVILEGE AND CONFIDENTIALITY NOTICE
This communication constitutes an electronic communication within the meaning of the Electronic Communications Privacy Act, 18 U.S.C.

Section 2510, and its disclosure is strictly limited to the recipient intended by the sender of this message. This transmission, and any attachments, may contain confidential attorney-client privileged information and attorney work product. If you are not the intended recipient, any disclosure, copying, distribution or use of any of the information contained in or attached to this transmission is STRICTLY

2.1.h
Packet Pg. 467 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing PROHIBITED. Please contact me immediately by return e-mail or at 510-900-9502 x 2, and destroy the original transmission and its attachments without reading or saving in any manner.

2.1.h
Packet Pg. 468 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing 1 August 3, 2022
Via Electronic Mail
To: San Ramon Mixed Use Ad Hoc Committee
Committee Chair Councilmember Sabina Zafar ([email protected]) Mayor David Hudson ([email protected])
Commissioner Rick Marks (c/o [email protected])
Commissioner Eric Wallis (c/o [email protected])
RE: Comments on Agenda for August 3, 2022 Mixed Use Ad Hoc Committee Dear San Ramon Mixed Use Ad Hoc Committee:

As legal counsel to Citizens Against Market Place Apartment/Condo Development (CAMPAD), I am writing in response to items on the agenda for the August 3, 2022 Committee meeting.

CAMPAD is concerned that the proposed revisions to the North Camino Ramon Specific Plan Area (NCRSP) does not include adequate specificity necessary to ensure that the standards are objectively enforceable under SB 330 and that commercial development is prioritized rather than ignored. The need for objective mixed-use standards was a central topic in the prior Committee meeting and the subject of Commissioner Wallis and Commissioner Marks’ July 29, 2022 letter attached to the agenda.

CAMPAD is similarly concerned that a developer may challenge the validity of the Commissioners’ proposed new requirements as “actions that would individually or cumulatively reduce the site’s residential development capacity.” (Gov. Code, § 66300(b)(1)(A).) In general, such actions taken after 2018 are invalidated by SB 330 unless the City affirmatively re-allocates residential capacity to other parcels (see Gov. Code, § 66300(i)(1)) as described in CAMPAD’s previous letter of July 18th. Once the City makes this necessary reallocation, residential density should be affirmatively restricted to a predefined very low level on mixed-use parcels unless the Planning Commission finds that discretionary criteria are met to ensure maximization of the site’s retail potential and compatibility with the surrounding area. 1 1 Note: If density is reallocated to other sites, pursuant to Government Code, section 66300(i)(1), it would be lawful to apply subjective development criteria to mixed-use sites that are simultaneously down-zoned.

Ariel Strauss, Of-Counsel
P.O. Box 8055
Berkeley, CA 94707
510-900-9502 x 702
[email protected]
www.greenfirelaw.com

2.1.h
Packet Pg. 469 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing 2 CAMPAD is supportive of the design requirements in Policy 4 but, unless the City obtains an exception to SB 330 by simultaneously shifting residential development potential elsewhere, likewise recommends adding further detail to ensure that the requirements are “objective.” SB 330 defines objective standards as those that are “uniformly verifiable by reference to an external and uniform benchmark or criterion available and knowable by both the development applicant or proponent and the public official.” (Gov. Code, § 65589.5(h)(8).) Developers may contend that “attractive landscape materials (hardscape and plant materials) special features and amenities” does not conform to this definition.

CAMPAD is also concerned that part (c) of proposed Policy 1 will force all mixed-use sites to be high density (minimum two levels of housing) even if this degree of density is not appropriate to the setting or consistent with the Mixed Use Zone Redevelopment Guidelines in Appendix A of the Zoning Ordinance. Proposed Policy 1 may also be inconsistent with the current 0.7 FAR standard of Zoning Ordinance Section D2-12A.

The explanatory note describes the objective of Policies 1 and 2 is to avoid significant loss of retail potential. The Committee should be mindful that existing shopping malls suffer from antiquated layouts common approximately 40 years ago. (See, e.g., San Ramon: Retail Development Opportunities Analysis, Table III-3 “Existing Shopping Centers in San Ramon” (May 23, 2022) (showing centers were built in the 1980s).) As a result, sites may need to be reconfigured to make them attractive and productive destinations for current and future shoppers.

Building housing on parking lots will significantly constrain site development and may interfere with achievement of well-designed, walkable mixed-use developments that afford significant public amenities.

CAMPAD requests that staff and the Committee consider these issues at today’s meeting.

Sincerely,
__________________
Ariel Strauss
Cc: Community Development Director Debbie Chamberlain ([email protected]) City Attorney Martin Lysons ([email protected])

2.1.h
Packet Pg. 470 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Debbie Chamberlain
Sent: Monday, July 18, 2022 1:59 PM
To: Cindy yee; Ryan Driscoll
Cc: Lauren Barr; Christina Franco
Subject: FW: CAMPAD Recommendations for Mixed-Use Ad Hoc Committee Attachments: CAMPAD Letter to MU Ad Hoc Comm.pdf
Please include as part of the AdHoc Staff report.

Debbie
Debbie Chamberlain |Community Development Director
City of San Ramon |Community Development Department
7000 Bollinger Canyon Road · San Ramon, CA 94583 · www.sanramon.ca.gov T: 925.973.2566 | F: 925 830.0100 | E: [email protected] The public counter at the San Ramon Permit Center is now open, with social distancing and hygiene measures in place, and face coverings required. Please visit http://www.bit.ly/CityServices for the latest information regarding City services.

From: [email protected] <[email protected]> Sent: Monday, July 18, 2022 1:34 PM
To: [email protected]
Cc: Dave Hudson <[email protected]>; Christina Franco <[email protected]>; Debbie Chamberlain <[email protected]>; Martin Lysons <[email protected]>; 'Jessica Blome' <[email protected]>
Subject: CAMPAD Recommendations for Mixed-Use Ad Hoc Committee Dear Mixed-Use Ad Hoc Committee members:

Attached, please find a letter on behalf of Citizens Against Market Place Apartment/Condo Development (CAMPAD) with recommendations for preserving community-serving retail.

Please confirm that this letter has been circulated to all members.

Thank you,
Ariel Strauss
__________________________________________________________________________________________________________________ _____
510-900-9502 x 702
Greenfire Law, P.C.

P.O. Box 8055
Berkeley, CA 94707

PRIVILEGE AND CONFIDENTIALITY NOTICE
This communication constitutes an electronic communication within the meaning of the Electronic Communications Privacy Act, 18 U.S.C.

Section 2510, and its disclosure is strictly limited to the recipient intended by the sender of this message. This transmission, and any attachments, may contain confidential attorney-client privileged information and attorney work product. If you are not the intended recipient, any disclosure, copying, distribution or use of any of the information contained in or attached to this transmission is STRICTLY

2.1.h
Packet Pg. 471 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing PROHIBITED. Please contact me immediately by return e-mail or at 510-900-9502 x 2, and destroy the original transmission and its attachments without reading or saving in any manner.

2.1.h
Packet Pg. 472 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing 1 July 18, 2022
Via Electronic Mail
To: San Ramon Mixed Use Ad Hoc Committee
Committee Chair Councilmember Sabina Zafar ([email protected]) Mayor David Hudson ([email protected])
Commissioner Rick Marks (c/o [email protected])
Commissioner Eric Wallis (c/o [email protected])
RE: Recommendation to the Cap Residential Development on Core Commercial Sites Dear San Ramon Mixed Use Ad Hoc Committee:

As legal counsel to Citizens Against Market Place Apartment/Condo Development (CAMPAD), I am writing to provide recommendations to assist in preserving critical community-serving retail in mixed-use-designated shopping centers.

The Retail Opportunities Analysis discussed in the June 30th meeting identified the core issues facing the City:
• “San Ramon’s limited supply of developable land is likely the singe greatest constrain on future retail development[.]”
• “As old centers become less competitive, the City is likely to face increasing pressure to redevelop these properties with residential development (as is already reflected in the City’s draft 2023-2022 Housing Element).”
• The City must “Incentivize reinvestment in existing retail properties to maintain San Ramon’s retail footprint in response to market pressure to replace retail commercial space with residential development.”
The Analysis appendix actually understates future retail shortfall by neglecting to mention that TRC’s application for Market Place, if approved, demolishes approximately 50,000 square feet of commercial space.

Moreover, as Commissioner Wallis reflected, the post-2018 increase in commercial square footage is almost entirely attributable to City Center, which was approved years earlier and before the restrictions imposed by SB 330. Critically, there is no current pipeline of retail projects to meet the City’s needs. The Mayor correctly explained that massive “retail leakage,” described in the Analysis, also means increased vehicle miles traveled (VMT), with attendant environmental harm, traffic congestion and CEQA burdens.

Ariel Strauss, Of-Counsel
2001 Addison St. #300
Berkeley, CA 94704
510-900-9502 x 702
[email protected]
www.greenfirelaw.com

2.1.h
Packet Pg. 473 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing 2 TRC’s application for Market Place could be “Exhibit A” of what will happen if the City does not assert its authority. Emboldened by SB 330, the application flatly ignored the City’s mixed-use design requirements in the General Plan and Zoning Ordinance and proposes to permanently swap premier retail space for only 40 market-rate townhomes.

As Commissioner Marks and others Committee members stated, the City must plan for longterm needs, not cater to present developer trends. One suggestion was to institute “objective” mixed-use standards so that they will be more enforceable under SB 330. CAMPAD supports this effort. However, the City must not forget that applicants are still required to comply with current, arguably-subjective standards whenever the applicant has not demonstrated that the standard, as-applied, reduces residential square footage. (California Renters Legal Advocacy & Education Fund v. City of San Mateo (2021) 68 Cal.App.5th 820, 846, 850.) More importantly, this modest change does not answer the burning question of what should be done to preserve the City’s retail centers.

The answer is simple: The City must affirmatively prohibit residential development from cannibalizing scarce, critical retail supply and hamstringing the long-term growth of the City.

Staff must identify the maximum amount of residential housing compatible with optimizing existing commercial centers and strictly cap residential development at that level. Commercial sites should be first and foremost commercial, not only secondarily so as considered in the 25% commercial use minimum floated in the meeting.

Reducing residential intensity on commercial sites is explicitly permitted by SB 330 so long as the City “concurrently changes the development standards, policies, and conditions applicable to other parcels within the jurisdiction to ensure that there is no net loss in residential capacity.” (Gov. Code § 66300(i)(1).)
What this means is that the City Council must exercise the political courage to shift residential development to other parts of the City where it would be more suitable, and would not conflict with the City’s essential obligation to provide community-serving retail.

CAMPAD requests that staff and the Committee consider this shift and produce a proposal to increase residential development potential in other areas of the City under the General Plan amendment to protect the essential community-serving retail.

Sincerely,
__________________
Ariel Strauss
Cc: Community Development Director Debbie Chamberlain ([email protected]) City Attorney Martin Lysons ([email protected])

2.1.h
Packet Pg. 474 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Christina Franco
Sent: Tuesday, September 13, 2022 5:58 PM
To: Cindy yee
Subject: FW: Comment on City Council 9/13/22 Agenda item 10.3 (Feedback re Mixed Use Land Use Designations)
Attachments: 2022-08-03 CAMPAD Comments on Ad Hoc Commitee Agenda.pdf; 2022-07- 18 CAMPAD Letter to MU Ad Hoc Comm.pdf
From: [email protected] <[email protected]> Sent: Tuesday, September 13, 2022 5:28 PM
To: City Clerk (Public) <[email protected]>
Cc: City Council <[email protected]>; Debbie Chamberlain <[email protected]>; 'Jim Blickenstaff' <[email protected]> Subject: Comment on City Council 9/13/22 Agenda item 10.3 (Feedback re Mixed Use Land Use Designations)
Good afternoon City Clerk:

On behalf of Citizens Against Market Place Apartment/Condo Development (CAMPAD), I want to ask that the attached letters previously submitted to the Mixed Use Ad Hoc Committee, the Mayor, Community Development Director and City Attorney are included in the record for this meeting.

As explained in the attached letters and as warned in the City’s Retail Analysis, if the City does not take immediate aggressive and legally supportable steps to preserve existing commercial opportunity sites, residential developers will, for short-term gain, irretrievably eviscerate the City’s stock of suitable retail sites. SB 330 makes reductions in residential density unenforceable unless accompanied by a concurrent increase in residential density potential elsewhere in the City. The Staff Report recommendations fail to address or implement this condition. As a result, the MU Commercial Emphasis zone and Mixed Use South’s stated intention to have “primarily commercial uses adjacent to the freeway” and commercial uses “encouraged along major streets” amounts to nothing more than aspirational preferences that developers will be free to ignore.

In response to the Staff Report, the Council should do two things: (1) ask Planning Staff whether the proposed change to mixed use zones are actually calibrated and assessed to accomplish the goals of the Retail Analysis to preserve the premium commercial locations and sufficient quantity of square footage necessary to serve the long-term needs of the City’s growing population, and (2) ask the City Attorney to opine on the enforceability of the mixed use standards in the face of SB 330. While the state court of appeal has explained that subjective conditions that do not reduce residential density are entirely enforceable under SB 330, and the City has a duty to demand compliance with enforceable conditions, my interpretation of the proposal is that it does not afford the City legal authority to protect the prime retail locations that the proposal purport to preserve and encourage.

Sincerely,
Ariel Strauss
Legal counsel for CAMPAD

2.1.h
Packet Pg. 475 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing __________________________________________________________________________________________________________________ _____
510-900-9502 x 702
Greenfire Law, P.C.

P.O. Box 8055
Berkeley, CA 94707

PRIVILEGE AND CONFIDENTIALITY NOTICE
This communication constitutes an electronic communication within the meaning of the Electronic Communications Privacy Act, 18 U.S.C.

Section 2510, and its disclosure is strictly limited to the recipient intended by the sender of this message. This transmission, and any attachments, may contain confidential attorney-client privileged information and attorney work product. If you are not the intended recipient, any disclosure, copying, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. Please contact me immediately by return e-mail or at 510-900-9502 x 2, and destroy the original transmission and its attachments without reading or saving in any manner.

2.1.h
Packet Pg. 476 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing 1 August 3, 2022
Via Electronic Mail
To: San Ramon Mixed Use Ad Hoc Committee
Committee Chair Councilmember Sabina Zafar ([email protected]) Mayor David Hudson ([email protected])
Commissioner Rick Marks (c/o [email protected])
Commissioner Eric Wallis (c/o [email protected])
RE: Comments on Agenda for August 3, 2022 Mixed Use Ad Hoc Committee Dear San Ramon Mixed Use Ad Hoc Committee:

As legal counsel to Citizens Against Market Place Apartment/Condo Development (CAMPAD), I am writing in response to items on the agenda for the August 3, 2022 Committee meeting.

CAMPAD is concerned that the proposed revisions to the North Camino Ramon Specific Plan Area (NCRSP) does not include adequate specificity necessary to ensure that the standards are objectively enforceable under SB 330 and that commercial development is prioritized rather than ignored. The need for objective mixed-use standards was a central topic in the prior Committee meeting and the subject of Commissioner Wallis and Commissioner Marks’ July 29, 2022 letter attached to the agenda.

CAMPAD is similarly concerned that a developer may challenge the validity of the Commissioners’ proposed new requirements as “actions that would individually or cumulatively reduce the site’s residential development capacity.” (Gov. Code, § 66300(b)(1)(A).) In general, such actions taken after 2018 are invalidated by SB 330 unless the City affirmatively re-allocates residential capacity to other parcels (see Gov. Code, § 66300(i)(1)) as described in CAMPAD’s previous letter of July 18th. Once the City makes this necessary reallocation, residential density should be affirmatively restricted to a predefined very low level on mixed-use parcels unless the Planning Commission finds that discretionary criteria are met to ensure maximization of the site’s retail potential and compatibility with the surrounding area. 1 1 Note: If density is reallocated to other sites, pursuant to Government Code, section 66300(i)(1), it would be lawful to apply subjective development criteria to mixed-use sites that are simultaneously down-zoned.

Ariel Strauss, Of-Counsel
P.O. Box 8055
Berkeley, CA 94707
510-900-9502 x 702
[email protected]
www.greenfirelaw.com

2.1.h
Packet Pg. 477 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing 2 CAMPAD is supportive of the design requirements in Policy 4 but, unless the City obtains an exception to SB 330 by simultaneously shifting residential development potential elsewhere, likewise recommends adding further detail to ensure that the requirements are “objective.” SB 330 defines objective standards as those that are “uniformly verifiable by reference to an external and uniform benchmark or criterion available and knowable by both the development applicant or proponent and the public official.” (Gov. Code, § 65589.5(h)(8).) Developers may contend that “attractive landscape materials (hardscape and plant materials) special features and amenities” does not conform to this definition.

CAMPAD is also concerned that part (c) of proposed Policy 1 will force all mixed-use sites to be high density (minimum two levels of housing) even if this degree of density is not appropriate to the setting or consistent with the Mixed Use Zone Redevelopment Guidelines in Appendix A of the Zoning Ordinance. Proposed Policy 1 may also be inconsistent with the current 0.7 FAR standard of Zoning Ordinance Section D2-12A.

The explanatory note describes the objective of Policies 1 and 2 is to avoid significant loss of retail potential. The Committee should be mindful that existing shopping malls suffer from antiquated layouts common approximately 40 years ago. (See, e.g., San Ramon: Retail Development Opportunities Analysis, Table III-3 “Existing Shopping Centers in San Ramon” (May 23, 2022) (showing centers were built in the 1980s).) As a result, sites may need to be reconfigured to make them attractive and productive destinations for current and future shoppers.

Building housing on parking lots will significantly constrain site development and may interfere with achievement of well-designed, walkable mixed-use developments that afford significant public amenities.

CAMPAD requests that staff and the Committee consider these issues at today’s meeting.

Sincerely,
__________________
Ariel Strauss
Cc: Community Development Director Debbie Chamberlain ([email protected]) City Attorney Martin Lysons ([email protected])

2.1.h
Packet Pg. 478 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing 1 July 18, 2022
Via Electronic Mail
To: San Ramon Mixed Use Ad Hoc Committee
Committee Chair Councilmember Sabina Zafar ([email protected]) Mayor David Hudson ([email protected])
Commissioner Rick Marks (c/o [email protected])
Commissioner Eric Wallis (c/o [email protected])
RE: Recommendation to the Cap Residential Development on Core Commercial Sites Dear San Ramon Mixed Use Ad Hoc Committee:

As legal counsel to Citizens Against Market Place Apartment/Condo Development (CAMPAD), I am writing to provide recommendations to assist in preserving critical community-serving retail in mixed-use-designated shopping centers.

The Retail Opportunities Analysis discussed in the June 30th meeting identified the core issues facing the City:
• “San Ramon’s limited supply of developable land is likely the singe greatest constrain on future retail development[.]”
• “As old centers become less competitive, the City is likely to face increasing pressure to redevelop these properties with residential development (as is already reflected in the City’s draft 2023-2022 Housing Element).”
• The City must “Incentivize reinvestment in existing retail properties to maintain San Ramon’s retail footprint in response to market pressure to replace retail commercial space with residential development.”
The Analysis appendix actually understates future retail shortfall by neglecting to mention that TRC’s application for Market Place, if approved, demolishes approximately 50,000 square feet of commercial space.

Moreover, as Commissioner Wallis reflected, the post-2018 increase in commercial square footage is almost entirely attributable to City Center, which was approved years earlier and before the restrictions imposed by SB 330. Critically, there is no current pipeline of retail projects to meet the City’s needs. The Mayor correctly explained that massive “retail leakage,” described in the Analysis, also means increased vehicle miles traveled (VMT), with attendant environmental harm, traffic congestion and CEQA burdens.

Ariel Strauss, Of-Counsel
2001 Addison St. #300
Berkeley, CA 94704
510-900-9502 x 702
[email protected]
www.greenfirelaw.com

2.1.h
Packet Pg. 479 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing 2 TRC’s application for Market Place could be “Exhibit A” of what will happen if the City does not assert its authority. Emboldened by SB 330, the application flatly ignored the City’s mixed-use design requirements in the General Plan and Zoning Ordinance and proposes to permanently swap premier retail space for only 40 market-rate townhomes.

As Commissioner Marks and others Committee members stated, the City must plan for longterm needs, not cater to present developer trends. One suggestion was to institute “objective” mixed-use standards so that they will be more enforceable under SB 330. CAMPAD supports this effort. However, the City must not forget that applicants are still required to comply with current, arguably-subjective standards whenever the applicant has not demonstrated that the standard, as-applied, reduces residential square footage. (California Renters Legal Advocacy & Education Fund v. City of San Mateo (2021) 68 Cal.App.5th 820, 846, 850.) More importantly, this modest change does not answer the burning question of what should be done to preserve the City’s retail centers.

The answer is simple: The City must affirmatively prohibit residential development from cannibalizing scarce, critical retail supply and hamstringing the long-term growth of the City.

Staff must identify the maximum amount of residential housing compatible with optimizing existing commercial centers and strictly cap residential development at that level. Commercial sites should be first and foremost commercial, not only secondarily so as considered in the 25% commercial use minimum floated in the meeting.

Reducing residential intensity on commercial sites is explicitly permitted by SB 330 so long as the City “concurrently changes the development standards, policies, and conditions applicable to other parcels within the jurisdiction to ensure that there is no net loss in residential capacity.” (Gov. Code § 66300(i)(1).)
What this means is that the City Council must exercise the political courage to shift residential development to other parts of the City where it would be more suitable, and would not conflict with the City’s essential obligation to provide community-serving retail.

CAMPAD requests that staff and the Committee consider this shift and produce a proposal to increase residential development potential in other areas of the City under the General Plan amendment to protect the essential community-serving retail.

Sincerely,
__________________
Ariel Strauss
Cc: Community Development Director Debbie Chamberlain ([email protected]) City Attorney Martin Lysons ([email protected])

2.1.h
Packet Pg. 480 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Lauren Barr
Sent: Wednesday, August 3, 2022 4:44 PM
To: [email protected]; RICHARD B MARKS
Cc: Debbie Chamberlain; Cindy yee
Subject: FW: COMMENTS TO AD HOC C. > Wed., Aug. 3 > [Market Place], Public Comment
Lauren
From: Jim Blickenstaff <[email protected]>
Sent: Wednesday, August 3, 2022 4:02 PM
To: '@sabinazafar' <[email protected]>; Dave Hudson <[email protected]>; Christina Franco <[email protected]>; Martin Lysons <[email protected]>; Alicia Poon <[email protected]>; Debbie Chamberlain <[email protected]>; Lauren Barr <[email protected]>; Lisa Schlotz <[email protected]>; Lucas Haase <[email protected]>; Martin Lysons <[email protected]>; Salmana Shah <[email protected]>; City Council <[email protected]>; [email protected]; [email protected]; 'Susie Ferris-Inderkum' <[email protected]>; [email protected] Subject: COMMENTS TO AD HOC C. > Wed., Aug. 3 > [Market Place], Date : Aug. 3, 2022
To : Mixed Use Ad Hoc Committee
From : Jim Blickenstaff
Re : Market Place , as it is affected by Housing Element and Mixed Use Zoning decisions
Note : This is a follow up to a July 2 comment letter .

Greetings :

I wanted to reiterate here, some concerns I raised at
an earlier meeting.

In particular, the proposal by staff to have a small
acreage retail site at the Market Place, surrounded on
3 sides by Housing Opportunity Sites – North, West and
South. These sites would constrict, or even render moot, any ‘Opportunities’ for viable and sustainable retail --an essential component of Mixed Use Zoning.

This happens in 4 ways: 1) The limited acreage available

2.1.h
Packet Pg. 481 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing for a functional retail center, 2) The reduced visibility of the retail area , 3) The limiting of convenient access, to the center, and 4) Reducing the prospects for an
‘Anchor Store’ to draw a steady customer base.

The Southern HOS suggested by staff, is especially
problematic regarding all 4 of these categories. It
pre-maturely and un-necessarily re-enforces a TRC
housing concept. A concept that represents the ‘Poster
Child’ for what not to do in a Mixed Use Zoning site.

A concept that requires the elimination of a key location and structure for the current retail, replacing it with housing , while in the process, among several other
negatives, constricts the available space needed for a
functional retail center.

In terms of the 5,000u RHNA numbers, it would be short
sighted, and a bad trade off, to degrade future prospects for a long standing, community serving retail center, in pursuit of a small fraction of the needed RHNA housing
numbers. While ideally, for now, all 3 HOS’s should be
taken off the table, at a minimum, the Southern HOS
needs to be remove from consideration at this time, and until such time that it can be looked at in the context of a detailed study for compliance with future mixed use
at the Market Place A Master Plan is not only required, but vert much needed for this purpose. This would assure proper implementation of the Mixed Use Zoning, and in
so doing, coordinate a successful integration/placement/ connectivity of the 40u Application housing request, and a viable retail center at this --now and future– strategic City location.

The City should also be aware of how approval of TRC’s
housing plans for Market Place , as they are currently
proposed, would not only marginalize retail, and over
time eliminate it at this site, but would set a precedent for similar mixed use sites being overwhelmed by

2.1.h
Packet Pg. 482 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing housing , further magnifying the impediments’ to the
City’s long term planning, and strategically locating,
critically needed retail shopping sites.

Thank You, Jim Blickenstaff

2.1.h
Packet Pg. 483 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Christina Franco
Sent: Thursday, June 30, 2022 2:50 PM
To: Cindy yee; Ryan Driscoll
Subject: FW: Public Comment 6/21/2022
From: Ralph Ballart <[email protected]>
Sent: Tuesday, June 21, 2022 3:37 PM
To: City Clerk (Public) <[email protected]>
Cc: Keith Diggs <[email protected]>; John Minot <[email protected]> Subject: Public Comment 6/21/2022
Thank you for the opportunity to comment again on San Ramon’s Housing Element Plan and some of the associated planned developments. I appreciate the hard work being done by the planning commissioners and city staff to build a better San Ramon.

It was only after the Planning Commission meeting of June 7 that I discovered that San Ramon had a web site “Marketplace: Proposed Development.” I subscribe to Planning Commission emails but didn’t receive notification about this posting. The site shared that instead of the apartments discussed by the Planning Commission a year ago, there would be a townhouse development instead. So instead of 15 affordable units, there will effectively be none. Moreover, the city is advertising the townhouse development before it has even been introduced to the Planning Commission.

This raises several questions about what will actually happen to the Marketplace. First, as the city divides the Marketplace into retail and residential zoning areas, has it already been decided that no apartments will be permitted? Second, on June 7 the Mayor essentially promised that a new supermarket will be built in the Marketplace; has a deal for a supermarket already been made and the details will be shared on the Marketplace website soon? I respect the traditional planning process that has made San Ramon a wonderful place to live. But we risk veering into Soviet style central planning with the judgement of private developers replaced by some secret city process involving undisclosed participants.

On a more positive note, I wanted to reiterate my support for the Deerwood and Omega Development Plan Concept that was discussed on June 7. This looks like a great opportunity to have 160 affordable units which will be subsidized by state funding. I was pleased with the reception this concept received from the planning commissioners and noted the relatively quick timeline required to ensure state funding. Let’s make this happen! Also, I wanted to give you feedback on some of comments you received on the Housing Element plan. - Some commenters said that the housing unit margin built into the plan to meet the targeted number of units appears insufficient. It was also noted that the current rate of development is insufficient to meet the target. I share these concerns. The city should have a sense of urgency in meeting our 5, 111 target reflecting the housing crisis we face. - There were comments that it would be desirable to reduce parking minimums to increase housing. I agree with this, especially in areas that will be developed in downtown San Ramon. - I agree with the comments from Church of the Valley that higher density be allowed on the site.

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Packet Pg. 484 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing Finally, I wanted give feedback to the General Plan Ad Hoc Committee with respect to Mixed Use Land Use Policies and Standards. Is the purpose of these discussions to limit residential development in areas currently zoned for Mixed Use? After replacing mixed use zoning with separate retail and residential zoning, will then FAR (floor area ratio) requirements be imposed to further limit development? I would simply prefer that we let the market decide some of these issues.

Respectfully,
Ralph Ballart, 28 Cree CT

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Packet Pg. 485 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Salmana Shah
Sent: Wednesday, June 29, 2022 4:49 PM
To: Cindy yee
Subject: FW: Public Comment 6/29/2022 - Mixed-use Ad Hoc Committee - Retail Development Opportunities Analysis
Attachments: the-marketplace-at-san-ramon-plan.jpg
Salmana Shah - Assistant Planner
City of San Ramon | Planning Services
7000 Bollinger Canyon Rd., San Ramon, CA 94583
Direct: (925) 973-2571 | Main: (925) 973-2560
From: Susie Ferris-Inderkum <[email protected]>
Sent: Wednesday, June 29, 2022 2:33 PM
To: planningcommission <[email protected]>; Dave Hudson <[email protected]>
Cc: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]
Subject: Public Comment 6/29/2022 - Mixed-use Ad Hoc Committee - Retail Development Opportunities Analysis
June 29, 2022

David E. Hudson, Mayor,
Sabina Zafar, Councilmember,
Rick Marks, Planning Commissioner,
Eric Wallis, Planning Commissioner,

I wish to make the following statements regarding agenda item 2.1 Mixed Use Land Use Policies and Standards Staff Report by: Cindy Yee, Senior Planner, and specifically ATTACHMENTS A. 2022 San Ramon Retail Development Opportunities Analysis.

I cannot stress enough how important it is that the Retail Development Opportunities Analysis is complete, accurate and thorough. Important portions of this report are not.

Given the growing number of Housing Opportunity Sites (HOS’s) now identified within our existing shopping centers, it is critical that this information is correct and current. Especially, given the number of commissions, committees and groups that will base future decisions upon that data.

I have attached a map of the Market Place Shopping Center area where the owner, TRC, has filed an application to Demolish approx. 55,636 sq. ft. of existing commercial tenant space and then Construct 40 single-family detached condominium units.

TABLE III-3. EXISTING SHOPPING CENTERS IN SAN RAMON (page 43) lists,

#3 The Marketplace at San Ramon as RBA = 180, 217, Available SF = 6,446 and Vacancy at 3.6%

The following shops/stores are closed and vacant:

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Packet Pg. 486 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing Market Place Cleaners, Nob Hill Foods, Fitness 19/Crunch Gym, Salon X, LP Jewelers, Café Tandoor, Roundtable Pizza, Hop Yard Bar & Grill, Space 160 (A3), Jimmy John’s, Space 179 (D12), Space 490 (H20), Space 409 (H8), and Buffalo Wild Wings.

Using the map, I am not able to calculate the RBA or SF (square feet) those 14 spaces equate to, but I can calculate the Vacancy @ 14/38 = 36.84 %. This percentage is reflective of the owner’s neglect of the property and increased rental rates. Such data should prompt the city to take action to understand what is happening in any retail shopping center that has such a dramatic change in less than a 5-year period.

It is also unclear if the report took into account the 7 lots and 8 satellite businesses that are technically part of the Market Place Shopping Center. As Sports Basement (4 bay area locations) is not listed in Appendix C.

Another compelling reason why there must be a Master Plan for any mixed-use development of the Market Place.

APPENDIX C Prospective Retail Tenants (pages 83-87) lists, a “Y” for yes there is one, but numbers would be much more helpful for decision making purposes. For example: there are 5 Starbuck’s locations in San Ramon. So, the loss of one in a particular shopping center may not be dramatic. But Roundtable Pizza, which at one time had 3 locations in San Ramon, has been reduced to a single location due to the Market Place rent increases.

Further the list has the following issues:

• Raley’s/Nob Hill Foods is listed as a San Ramon business. This is closed in the Market Place.

There are no other Raley's in San Ramon.
• Fails to list the AT&T Store in San Ramon (Shops @ Bishop Ranch), yet lists Sprint & Verizon as services in San Ramon, when in fact they are not. Closest locations are Dublin and Pleasanton. • Fails to list 24HR Fitness as a San Ramon fitness business (their corporate headquarters are located in San Ramon).
• Lists In-N-Out burgers but fails to list Habit Burger (with 327 locations in the US). • Lists Orange Julius in San Ramon, when there isn’t one. • Fails to list Inchin’s Bamboo Garden in San Ramon (part of a major US food chain). • The report mentions Trader Joe’s as an anchor tenant in #3 above but fails to list Trader Joe’s as a retail tenant, supermarket (with 569 stores in the US). • Fails to list Whole Foods as a supermarket in San Ramon (with 500 locations in the US). • Fails to list Roundtable Pizza as an eating and drinking establishment (with 400 locations in the US).

My analysis is cursory at best for shopping centers other than Market Place, but I have identified enough problems which renders the report useless for most decision-making purposes. Certainly, for deciding which businesses to solicit to come to San Ramon.

I encourage the Planning Commission and the City Council to ask for a complete analysis of the existing retail in our San Ramon shopping centers, so that all necessary agencies have a solid bases for approving mi project applications in shopping areas designated as mixed-use.

Sincerely,

Susie Ferris-Inderkum

Responsible Growth San Ramon & CAMPAD

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Packet Pg. 487 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing

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Packet Pg. 488 Attachment: D: Public Comments received since June 21, 2022 (3867 : General From: Lauren Barr
Sent: Wednesday, September 21, 2022 11:39 AM
To: Cindy yee; Ryan Driscoll
Subject: FW: Public Comment 9/21/2022 (CAMPAD Comment to MU Ad Hoc Committee on MU Proposal)
Attachments: 2022-09-21- Comments on MU Proposal.pdf
fyi
From: [email protected] <[email protected]> Sent: Wednesday, September 21, 2022 11:32 AM
To: planningcommission <[email protected]> Cc: Debbie Chamberlain <[email protected]>; Martin Lysons <[email protected]>; 'Jim Blickenstaff' <[email protected]>; 'Susie Ferris-Inderkum' <[email protected]>; 'Jessica Blome' <[email protected]> Subject: Public Comment 9/21/2022 (CAMPAD Comment to MU Ad Hoc Committee on MU Proposal) Dear members of the General Plan Mixed Use Ad Hoc Committee:

Attached, please find a comment on behalf of CAMPAD regarding the draft Mixed Use Development Standards.

Sincerely,
Ariel Strauss
__________________________________________________________________________________________________________________ _____
510-900-9502 x 702
Greenfire Law, P.C.

P.O. Box 8055
Berkeley, CA 94707

PRIVILEGE AND CONFIDENTIALITY NOTICE
This communication constitutes an electronic communication within the meaning of the Electronic Communications Privacy Act, 18 U.S.C.

Section 2510, and its disclosure is strictly limited to the recipient intended by the sender of this message. This transmission, and any attachments, may contain confidential attorney-client privileged information and attorney work product. If you are not the intended recipient, any disclosure, copying, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. Please contact me immediately by return e-mail or at 510-900-9502 x 2, and destroy the original transmission and its attachments without reading or saving in any manner.

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Packet Pg. 489 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing 1 September 21, 2022
Via Electronic Mail
To: San Ramon Mixed Use Ad Hoc Committee ([email protected]) RE: Comments on Mixed Use Development Standards Staff Report Dear San Ramon Mixed Use Ad Hoc Committee:

I am writing as legal counsel to Citizens Against Market Place Apartment/Condo Development (CAMPAD) to provide comments on the Mixed Use Development Standards Staff Report. This letter focuses on three issues: (1) preserving the City’s stock of prime retail opportunity spaces, (2) implementing objective high-quality mixed use design principles and (3) ensuring enforceability of new standards under SB 330.

CAMPAD’s prior letter of July 18th discussed the City’s Retail Opportunity Analysis and highlighted the urgent need to preserve San Ramon’s stock of premier retail sites, which are at immediate risk of permanent loss to low-value residential development such as is proposed to occur at the Market Place complex (demolishing 50,000 sf of prime retail to build 40 townhouses). As the Retail Opportunity Analysis concluded “San Ramon’s limited supply of developable land is likely the single greatest constraint on future retail development” and the City must “[i]ncentivize reinvestment in existing retail properties to maintain San Ramon’s retail footprint in response to market pressure to replace retail commercial space with residential development.” Given the current market conditions, developers can profit by rapidly maximizing the number of residential units and ignoring commercial development, creating projects that are not truly mixed use and do not serve the long-term needs of the City.

1. Preservation of Prime Community-Serving Retail
CAMPAD strongly supports the proposed establishment of minimum commercial FAR of

0.45 in the Mixed Use, Commercial Emphasis Zone.

CAMPAD suggests that staff assess the extent to which the new development standards provide adequate sites and square footage for the long-term commercial development needs identified in Table I-1 of the Retail Opportunity Analysis. Ultimately, any new standards should also be calibrated to reduce retail leakage/traffic impacts. For instance, how does the quantity of commercial-restricted area within the new districts compare with the amount of retail space that the City should support based on projected population growth (i.e., 800,000sf low scenario vs 1,400,000sf high scenario)?
Ariel Strauss, Of-Counsel
2001 Addison St. #300
Berkeley, CA 94704
510-900-9502 x 702
[email protected]
www.greenfirelaw.com

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Packet Pg. 490 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing 2 Taking Table III-3 of the Retail Opportunity Analysis as a starting point, staff should further identify at-risk high-value community-serving retail opportunity sites (similar to HOS) across the MU districts and consider how to subject these locations to preservation measures or incentives.

2. Developing Objective Design Standards
An issue that has been discussed at Committee meetings but not addressed in the proposed standards are more objective design criteria. Appendix A of the City’s Zoning Ordinance (attached for reference) sets out good design standards but may be challenged by developers under SB 330 as “subjective.”
1 Page 3 and 4 of the Staff Report bullets some relevant elements, such as to require “specialized paving, landscaping, and street furnishings to encouraging shoppers, employees, and residents to utilize the sidewalks” and “on and off-site active and passive recreational amenities as part of residential projects.” The policies and standards should ensure that projects provide significant community-serving amenities. CAMPAD urges the Committee to assist staff to take Appendix A and implement clearer, objective standards that ensure developments create high-quality community spaces that make the best use of this zoning designation.

3. Shifting Residential Density to Make the New Commercial Development Standards Enforceable
Finally, SB 330, generally forbids a city from taking actions that reduce the level of allowable residential development. However, the City can do this if it “concurrently changes the development standards, policies, and conditions applicable to other parcels within the jurisdiction to ensure that there is no net loss in residential capacity.” Gov. Code, § 66300(i)(1).

The new standards create barriers to residential development. If the City enacts these standards without shifting residential density, the standards will amount to nothing more than aspirational preferences that developers will be free to ignore. The City must explicitly shift residential density to more appropriate areas to ensure that commercial standards are actually enforceable.

CAMPAD appreciates the Committee’s focus on improving mixed use standards and looks forward to reviewing the next iteration of the proposal.

Sincerely,
__________________
Ariel Strauss
Cc: Community Development Director Debbie Chamberlain ([email protected]) City Attorney Martin Lysons ([email protected])
1 Note that even arguably-subjective standards are still enforceable when they do not reduce residential square footage. California Renters Legal Advocacy & Education Fund v. City of San Mateo (2021) 68 Cal.App.5th 820, 850.

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Packet Pg. 491 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing Referenced Tables from TNDG’s Retail Development
Opportunities Analysis (May 23, 2022)

2.1.h
Packet Pg. 492 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing

2.1.h
Packet Pg. 493 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon Zoning Ordinance D9
Appendix A - Mixed Use Zone Redevelopment Guidelines - Effective February 28, 2020 9-1 Appendix A
Mixed Use Zone Redevelopment Guidelines
The following guidelines illustrate a methodology for the redevelopment of existing commercial strip centers into pedestrian-oriented districts where applicable. The City will use these guidelines in reviewing proposals to change existing shopping centers in the MU zone.

Purpose. In order to illustrate the potential for redevelopment of commercial properties into vibrant, mixeduse centers, a hypothetical “strip mall” was created at the intersection of two arterial streets. This 10-acre property accommodates approximately 115,000 gross square feet (gsf) of commercial space and includes a 60,000 gsf retail anchor. It is served by approximately 815 surface parking spaces (a standard 8:1 ratio).

The following pages illustrate a series of design principles that may guide the redevelopment of similar properties, as well as a strategy for successful phasing such a project.

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Packet Pg. 494 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon Zoning Ordinance D9
Appendix A - Mixed Use Zone Redevelopment Guidelines - Effective February 28, 2020 9-2 Above: Existing conditions.

Principle One: Subdivide the property into an interconnected network of pedestrian-scaled streets and blocks.

Principle Two: Parking should be located along streets and in lots and garages oriented behind buildings.

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Packet Pg. 495 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon Zoning Ordinance D9
Appendix A - Mixed Use Zone Redevelopment Guidelines - Effective February 28, 2020 9-3 Principle Three: New buildings should be oriented towards streets and provide a scale and interest that is pedestrian friendly.

Principle Four: A comprehensive network of parks and open space should provide the community with a series of public places.

Principle Five: Built frameworks should provide pedestrian-friendly connections to neighboring properties and future redevelopment sites.

2.1.h
Packet Pg. 496 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon Zoning Ordinance D9
Appendix A - Mixed Use Zone Redevelopment Guidelines - Effective February 28, 2020 9-4 Above: Existing conditions within suburban context.

Phase I: A portion of the strip mall is demolished and redeveloped as a mixed-use “main street” fronting a linear park. A parking structure is built to accommodate lost parking and new residential uses. The existing anchor use is renovated to appropriately terminate this new axis.

Phase II: A second mixed-use address is introduced along with a parking structure serving new retail and residential uses, creating a nascent town center district.

2.1.h
Packet Pg. 497 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon Zoning Ordinance D9
Appendix A - Mixed Use Zone Redevelopment Guidelines - Effective February 28, 2020 9-5 Phase III: The remainder of the property is redeveloped with the addition of street-facing buildings along the site’s perimeter, as the arterial streets gradually evolve into avenues and boulevards that are more pedestrian-friendly.

The above drawing illustrates one way in which such a site could be redeveloped, integrating new and renovated commercial uses, residential uses in a variety of forms, and civic and open space. The redevelopment of one property can spur the redevelopment of adjacent underutilized sites, creating the long-term potential for the creation of a vibrant, mixed-use, pedestrian-friendly quarter.

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Packet Pg. 498 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon Zoning Ordinance D9
Appendix A - Mixed Use Zone Redevelopment Guidelines - Effective February 28, 2020 9-6 [Page intentionally left blank]

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Packet Pg. 499 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Ryan Driscoll
Sent: Tuesday, December 27, 2022 10:00 AM
To: Cindy yee
Subject: FW: Revised Draft 2023-2031 Housing Element (dated December 2022) Available for a 7-day Public Review Period
Cindy,
I received the following comment on the revised HE from a previous commenter, Penny Wolfsohn, regarding water concerns. Also, has question on where to comment for the upcoming meeting. Want me to respond?
-Ryan
Ryan Driscoll – Associate Planner
Direct Phone: (925) 973-2568 – Fax: (925) 830-0100 – [email protected] City of San Ramon – Planning Services Division – 7000 Bollinger Canyon Rd., San Ramon, CA 94583 From: Penny Wolfsohn <[email protected]>
Sent: Tuesday, December 27, 2022 9:30 AM
To: Ryan Driscoll <[email protected]>
Subject: Re: Revised Draft 2023-2031 Housing Element (dated December 2022) Available for a 7-day Public Review Period
I’m not sure how to comment or where to comment on this upcoming meeting but my concerns continue to be about water issues for any new development that plan for our community.

Sincerely Penny Wolfsohn.

On Wed, Dec 21, 2022 at 4:28 PM Ryan Driscoll <[email protected]> wrote:

All PlanSanRamon.com E-mail List Contacts:

On October 18, 2022, the California Department of Housing and Community Development (HCD) provided the City of San Ramon comments on the Draft 2023-2031 Housing Element along with a list of revisions necessary to comply with State Housing Element Law. In consultation with HCD, the City has prepared an update to the Draft Housing Element using “tracked changes” that show revisions to the document in underlined and/or highlighted yellow text. The Revised Draft 2023-2031 Housing Element (dated December 2022) is available for a 7-day public review period, from December 21, 2022 through December 27, 2022. The link to the Revised Draft 2023-2031 Housing Element is available below, on the City webpage, and on the PlanSanRamon.com website:
• Revised Draft 2023-2031 Housing Element, dated December 2022 • HCD Comment Letter on Draft 2023-2031 Housing Element, dated October 18, 2022

2.1.h
Packet Pg. 500 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing To provide comments on the Revised Draft 2023-2031 Housing Element, please email [email protected] or send written communication to the City of San Ramon Planning Services Division at 7000 Bollinger Canyon Road, San Ramon, CA 94583 during the 7-day public review period, from December 21, 2022 through December 27, 2022.

Ryan Driscoll – Associate Planner
Direct Phone: (925) 973-2568 – Fax: (925) 830-0100 – [email protected] City of San Ramon – Planning Services Division – 7000 Bollinger Canyon Rd., San Ramon, CA 94583

2.1.h
Packet Pg. 501 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Salmana Shah
Sent: Tuesday, July 19, 2022 7:51 PM
To: Cindy yee
Subject: Fwd: Public Comment 7/19/22
Attachments: SKM_C55822071916150.pdf
Begin forwarded message:

From: Stuart MacDonald <[email protected]>
Date: July 19, 2022 at 4:48:31 PM PDT
To: planningcommission <[email protected]> Subject: Public Comment 7/19/22
Please find our attached letter for the hearing tonight. Thanks.

Stuart MacDonald

VICE PRESIDENT, REGIONAL DEVELOPMENT
Federal Realty
d (408) 551-4673
356 Santana Row Suite 1005
San Jose CA 95128
[email protected]

Unless expressly stated otherwise, this message is confidential and may be privileged. It is intended for the addressee(s) only. Access to this email by anyone else is unauthorized. If you are not an addressee, any disclosure or copying of the contents of this email or any action taken (or not taken) in reliance on it is unauthorized and may be unlawful. If you are not an addressee, please inform the sender immediately. No discussion, offer or agreement regarding any potential lease or other contract is binding on Federal Realty Investment Trust, nor should it be relied on by any third party, unless it is documented in a final lease or other written (not electronic) agreement signed by our authorized representative.

The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.

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Packet Pg. 502 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing

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Packet Pg. 503 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing

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Packet Pg. 504 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing 1 Ryan Driscoll
Subject: To City of San Ramon: if it was up to me, I would develop San Ramon this way for the next 10 years this way that will satisfy the high density demand and a thriving retail that is compatible with our pedigree of a high(?) 💩🇨🇳🇮🇳 quality of life….. ‐‐‐‐‐Original Message‐‐‐‐‐
From: Debbie Chamberlain <[email protected]> Sent: Thursday, June 23, 2022 10:21 AM
To: Ryan Driscoll <[email protected]>; Cindy yee <[email protected]> Subject: FW: To City of San Ramon: if it was up to me, I would develop San Ramon this way for the next 10 years this way that will satisfy the high density demand and a thriving retail that is compatible with our pedigree of a high(?) 💩🇨🇳🇮🇳 quality of life…..

Debbie Chamberlain |Community Development Director City of San Ramon |Community Development Department 7000 Bollinger Canyon Road ∙ San Ramon, CA 94583 ∙ www.sanramon.ca.gov T: 925.973.2566 | F: 925 830.0100 | E:  [email protected] The public counter at the San Ramon Permit Center is now open, with social distancing and hygiene measures in place, and face coverings required. Please visit  http://www.bit.ly/CityServices for the latest information regarding City services.
‐‐‐‐‐Original Message‐‐‐‐‐
From: Helen Chernne <[email protected]>
Sent: Wednesday, June 22, 2022 5:41 PM
To: Keith Haase <[email protected]>; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Ryan Driscoll <[email protected]>; Virtual SRPD <[email protected]>; Debbie Chamberlain <[email protected]>; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Martin Lysons <[email protected]>; Rick Maria <[email protected]>; [email protected]; [email protected]; [email protected]; Robin Bartlett <[email protected]>; [email protected]; Amalia Kulczycki <[email protected]>; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Kathi Heimann <[email protected]>; [email protected]; [email protected]; [email protected]; Jennifer Gault <[email protected]>; Lisa Bobadilla <[email protected]>; Robin Bartlett <[email protected]>; [email protected]; [email protected]; [email protected]; Keith Haase <[email protected]>

2.1.h
Packet Pg. 505 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing 2 Cc: [email protected]; City Manager (Public) <[email protected]>; [email protected]; [email protected]; City Clerk (Public) <[email protected]>; [email protected]; Dave Hudson <[email protected]>; Sabina Zafar <[email protected]>; Sridhar Verose <[email protected]>; Scott Perkins <[email protected]>; Info <[email protected]>; Mark Armstrong <[email protected]>; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Craig Stevens <[email protected]>; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Christina Franco <[email protected]>; Cindy Fischer <[email protected]>; Martin Lysons <[email protected]>; [email protected]; [email protected]; [email protected]; Craig Stevens <[email protected]>; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Subject: To City of San Ramon: if it was up to me, I would develop San Ramon this way for the next 10 years this way that will satisfy the high density demand and a thriving retail that is compatible with our pedigree of a high(?) 💩🇨🇳🇮🇳 quality of life…..m...
8 floors of luxury living (for own as well as for rent) utilizing the vacant space left by Lennar on Bollinger Canyon that is dubbed as “hotel apartments” in 🇹🇼:

1.  Luxury 5 star‐ Hotel luxury high density living that will offer concierge service, 5 star award winning (satellite operations by quality and reputable restaurants from abroad, not 💩🇨🇳🐷 imposter run wannabes!) restaurants for residents, in house transportation service that includes luxury auto rental, intra‐city taxi, to inter‐city limo service available to residents/ owners on site.  Parking spaces for visitors to restaurants!

2.  Retail to the above include boutique couture for wedding dresses, prom dresses, etc.

3. Health and living center that will include credentialed massage service, swimming pool, racquet ball, table tennis, personal training, etc.

4.  Family oriented entertainment center like Dave and Buster

5.  Spaces for hobby clubs: floral arrangement, choir, sewing, cooking, planting, etc.

6.  Indoor Toddler and Children Learning Center
However, such is not for 💩🇨🇳🐷 Communist CA looking to turn the state into 💩🇨🇳 communes and 🇮🇳 Affordable living! So what am I talking about!  I will just retire in 🇹🇼 To live like this! https://youtu.be/EIQieolkCr4 <https://protect‐us.mimecast.com/s/S2KmC0RPBpsqK1MFwFaK6?domain=youtu.be> You guys can enjoy your affordable cheap housing here in San Ramon! If you guys are targeting high schoolers and young people, I don’t think we can outcompete cheap Dublin and shabby Oakland who come here to get lucky swiping our sheriffs!

2.1.h
Packet Pg. 506 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing 3 These days WOKE  young people have no taste for fashions and living, so put in a bunch used clothing recycle centers are your better bet!
And good,  all foods  are 💩🇨🇳🐷 cuisine anyways, so au revoir, audios, and bye‐bye! And education truly sucks!  Why waste time in school hearing 💩 all day? Get private tutors and graduate by 8th grade and enjoy life making money than complying with WOKE 💩! I cannot tell you how often I think the young people truly dress so ugly in San Ramon compared to when I was in high school, but oh well!
All in all, good luck living in 💩🇨🇳🐷🇮🇳 San Ramon, CA, 🇺🇸! Me in my teen years in 🇺🇸 ‐R Reagan CA:

This is a 💩🇨🇳🐷 committee!  No one in their right mind would want to live with these people!

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Packet Pg. 507 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: [email protected]
Sent: Tuesday, June 28, 2022 2:42 PM
To: Lisa Jackson
Subject: Letter About Building Electrification from 350 Contra Costa Attachments: 350 Bldg Elect Info to Local Govts 6-22Final.pdf; ATT00001.htm Attached please find a letter from our organization about suggested actions that local jurisdictions can take to phase out the use of fossil fuels (typically natural gas) in buildings. While GHG emissions from buildings are not as significant as those from the transportation and industrial sectors, they are significant enough to be critical in efforts to reduce global heating. And banning new natural gas heating systems is relatively easy to do because all-electric buildings are simpler to design and construct, and therefore are usually less expensive to build than those using gas heating systems.

Cordially,
Lisa Jackson [email protected]
Gary Farber [email protected]
350 Contra Costa

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June 2022
Members of the City Council
Sustainability Officer or Planning Director
CONSIDERATIONS: LOCAL REGULATIONS TO PHASE OUT FOSSIL FUELS IN BUILDINGS More than 50 cities and counties in CA have restricted or banned natural gas in new buildings.1 Why? Because climate scientists agree that the world cannot meet crucial GHG emission reductions without quickly phasing out the burning of fossil fuels, such as natural gas.2 Perhaps you have heard of the “reach code” framework for receiving state approval of local ordinances that ban the use of fossil fuel heating systems in all, or some, new buildings – and sometimes in certain building additions and building alterations as well. On April 21, I received a note from the CEC’s3 person in charge of reach code reviews and approvals - Danuta Drozdowicz4 - stating that the CEC will not be reviewing local ordinances that only ban certain types of heating equipment. Energy Reach Codes are defined as local ordinances that require greater energy efficiency than the state’s energy code. Ms. Drozdowicz stated that banning certain types of heating systems is not considered by the CEC to be an energy efficiency measure (as defined by the state’s energy code). The CEC has been carrying out this new policy, first rejecting So. San Francisco’s building electrification reach code application late last year, then rejecting Contra Costa County’s electrification reach code application this spring. Note: Ms. Drozdowicz of the CEC suggested that if a local jurisdiction has questions about whether a proposed local ordinance would require CEC review and approval, they are welcome to contact the CEC for guidance.

So where does that leave local jurisdictions wishing to ban fossil fuel heating systems?5 Several cities have adopted ordinances that restrict fossil fuel heating systems in buildings under their local health and safety code. Berkeley was the first CA city to write a natural gas ban, and last year won a legal challenge to it6. Oakland’s electrification code7 also uses this method. Their code went into affect in December 2020, prior to the positive court ruling on Berkeley’s ban. According to Alain Placido, the lead contact for Oakland’s electrification code, there have been no legal challenges to their natural gas 1 The Air Conditioning Heating Refrigeration News, Feb. 2022 2 IPPC Sixth Assessment Report 2021 https://www.ipcc.ch/ 3 CEC = California Energy Commission
4 Danuta Drozdowicz [email protected] (916) 805-7436 5 Heating Systems usually include the following: Space heating, water heating, cooking, clothes drying and pool heating. 6 Because Berkeley was apprehensive as to whether a natural gas ban would meet legal challenges, they also instituted a Reach code to achieve all-electric new buildings.
7 Oakland new buildings electrification code: https://cao-94612.s3.amazonaws.com/documents/13632-CMS.pdf

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ban.8 It applies to all new buildings (residential and nonresidential). And as described in Appendix 3:

Relationship Between Electrification Ordinances and Reach Codes (on page 4 of this letter), when Contra Costa County’s reach code application was rejected by the CEC (due to not including an energy efficiency component), the county just went ahead and adopted the ordinance. It became effective June 1, 2022 as originally planned.

Our organization, 350 Contra Costa, is very supportive of building electrification – for new buildings and for existing buildings – as an important step in reducing the use of fossil fuels. We are thankful to Contra Costa County, and the many cities who have taken this step – as well as those that are in the process of doing so.

ADDRESSING EXISTING BUILDINGS
The existing building stock constitutes a huge potential for GHG reductions, much greater than new buildings. But owners of most of those buildings have no plans to change out their gas systems for electric systems. Therefore, until such time as there is comprehensive public education on the benefits or replacing gas systems with electric systems, and government funding to subsidize the system retrofit costs, it will be challenging to get large numbers of buildings transformed from fossil fuel to electric systems. Local jurisdictions need to start planning for phasing out natural gas in the existing building stock, and lobby the state and federal governments for funding to ease the transition.

However, 350 Contra Costa urges you to consider addressing existing buildings in cases where building owners elect to make building system upgrades, as follow:
• Building Additions: Ban natural gas at additions where new heating equipment is installed that will serve the addition. (there would be no restrictions on using existing heating equipment to serve additions).
• Building Alterations: Ban natural gas for new heating equipment when the new heating equipment will be placed in a new location. Rationale: In cases where a new a furnace, water heater, stove or clothes dryer is being relocated to a new location, or where new heating equipment will be additional to existing heating equipment, that work scope signifies that the alteration is of such magnitude that changing to electric equipment is a reasonable policy imposition.

IMPACT OF 2022 CA BUILDING ENERGY CODE
Some news reports indicated that the upcoming 2022 building energy code (effective date 1/1/23) will do much to push buildings to use electric systems rather than fossil fuel systems. Our group has performed a comprehensive review of the 2022 energy code text as it pertains to space conditioning and water heating, and find large gaps to motivating building designers and owners to favor electric systems over fossil fuel systems. While there are new provisions which encourage the use of heat 8 Alain Placido, Supervising Civil Engineer. Communication on 4/22/22 [email protected] 510-238-7110

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pumps, these vary by climate zone, building type, and other factors. See Appendix A, below, for details.

As the next energy code will not result in favoring electric heating systems over fossil fuel systems to the extent that addressing the climate emergency dictates, we feel that enacting natural gas bans – for all new buildings, and for certain building additions and alterations (as described above under Addressing Existing Buildings) is essential to meeting GHG reduction goals necessary to deal with the existential threat of global heating.

Please feel free to contact me should you need any additional information.

Gary Farber, on behalf of 350 Contra Costa
[email protected]
cc: 350 Local Climate Policy Team
APPENDIX A – 2022 California Building Energy Code
Notes for the table below:
• Findings in the table below are based on a review of the Express Terms publication for the 2022 Energy Code (effective date: Jan. 1, 2023). The Express Terms are equivalent to the final draft of the energy code, the version that the commission approved for adoption). 2022 Energy Standards Express Terms are available at https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiency-standards/2022-buildingenergy-efficiency , Rulemakings, Final Express Terms, Parts 1 & 6 (this accesses a download of the document in PDF format).
• The Energy Code contains two compliance methods: “Prescriptive” and “Performance”. Prescriptive is the compliance method where requirements are prescribed. The “Performance” compliance method allows a wider choice of equipment and features – as long as the project meets an energy budget that is calculated by assigning Prescriptive requirements to the proposed design in the compliance program modeling. • Where Heat Pump space heating or water heating is a Prescriptive requirement (as noted below), gas heating would be allowed under Performance compliance – as long as the building complies with the Performance energy budget.

It is assumed that the Performance budget calculation program rules will assign an energy “penalty” to fossil fuel heating systems when conducting a Performance energy compliance budget calculation. 2022 Energy Code Prescriptive Compliance and Natural Gas Heating Systems Building Type Fossil Fuel Restrictions
New single-family residential, space
conditioning, Climate Zone (CZ) 3
(West County)
Heat pump space conditioning required under Prescriptive compliance.

New single-family residential, space
conditioning, CZ 12 (East County)
No gas restrictions
New single-family residential water
heating, CZ 3
No gas restrictions
New single-family residential water
heating, CZ 12
Heat pump water heating required under Prescriptive compliance.

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Packet Pg. 511 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing page 4 of 5
New multi-family building, common
area space conditioning, CZ 3 & 12
No gas restrictions
New multi-family building, dwelling
unit space conditioning, CZ 3 & 12
Heat pump space conditioning required under Prescriptive compliance.

New multi-family building, dwelling
unit water heating, CZ 3 & 12
No gas restrictions
New nonresidential building, space
conditioning, CZ 3 & 12
Prescriptive heat pump space conditioning mandate. However, it only applies to certain nonresidential buildings, and only where their HVAC systems are of a certain type and capacity.

New nonresidential building, water
heating, CZ 3 & 12
No gas restrictions
Residential and nonresidential
additions, CZ 3 & 12
No gas restrictions
Residential and nonresidential
alterations, CZ 3 & 12
No gas restrictions
APPENDIX B – Additional Building Electrification Information Building Decarbonization Coalition https://www.buildingdecarb.org/ Building Electrification Institute https://www.beicities.org/ The Switch is On https://www.switchison.org/
APPENDIX C – Relationship Between Electrification Ordinances and “Reach Codes” Short answer: Used to be relatively strong; now relationship between building electrification ordinances and reach codes is tenuous.

Long answer: An electrification ordinance can only be considered to be a reach code if the ordinance also requires building energy efficiency greater than the state’s energy code. Reach codes are defined in California as locally adopted codes that include stricter requirements than state codes. In the area of building energy, reach codes require greater energy efficiency than required by the CA energy code (Title 24 Part 6). Over the past couple of years, many advocating for local building electrification ordinances used the term “reach code” as if synonymous with “electrification ordinance”. There is a good story behind this terminology confusion.

Berkeley, the pioneer in building electrification, first drafted a “natural gas ban” for new buildings – under their Health & Safety Code. But lawyers advised that the courts could strike this down. So Berkeley, having experience with reach codes, decided to use the reach code format for a second track method to ban fossil fuel heating in new buildings. Berkeley submitted the proposed reach code ordinance to the CEC. With the CEC supportive of phasing out the use of fossil fuels, they decided to approve Berkeley’s electrification reach code. Subsequent to Berkeley’s example, many other jurisdictions also used the reach code format to enact restrictions on natural gas use, and the CEC

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Packet Pg. 512 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing page 5 of 5
continued to approve such applications. Support was such that the Investor Owned Utility’s Codes & Standards team assembled energy cost studies for building electrification, which were used in reach code application to the CEC.

I was one of several who questioned why the CEC was approving electrification ordinances as reach codes where there was no building efficiency component (as defined by the energy code). In the later part of 2021, the CEC decided to stop approving reach code applications that only banned certain building systems, and that had no efficiency component. Last December, they rejected So. San Francisoco’s application – the first rejected under this new policy. This spring, the CEC rejected the next building electrification ordinance submitted as a reach code – that of Contra Costa County.

The County’s lead staff on the electrification ordinance, Demian Hardman-Saldana, informed me on June 20 2022 that, because all ordinances that affect buildings must be referenced in the jurisdiction’s Health & Safety Code, the county was able to go ahead and adopt the ordinance without change.

It is unfortunate that So. San Francisco and Contra Costa County spent time putting together and submitting reach code applications to the CEC; hopefully the news will get out that local jurisdictions should not consider straight building electrification ordinances as reach codes, and can save the effort of submitting such ordinances to the CEC for approval.

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Packet Pg. 513 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Byron de Arakal <[email protected]>
Sent: Thursday, August 4, 2022 6:37 AM
To: Cindy yee
Cc: Debbie Chamberlain; Lauren Barr
Subject: MU ad hoc
Hello Cindy,
I continue to appreciate the difficult work you and the Planning team are managing with skill and patience relative to the Housing Element/GP update.

Can I trouble you to let me know when the recording of last night’s MU Ad Hoc Committee meeting is available on the City’s website and/or YouTube page?
Thanks so much!
Byron
Byron de Arakal
Consulting Director | Entitlement Planning TRC
c: 714.227.4720
[email protected]
Sent from Byron's iPhone

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Packet Pg. 514 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Penny Wolfsohn <[email protected]>
Sent: Thursday, July 7, 2022 1:15 PM
To: Ryan Driscoll
Cc: Planning Services (public)
Subject: Re: Density with regard to housing
Thank you for your response.

So happy to see that water availability and usage is a priority for you here in San Ramon, and absolutely needs to be for this whole state and especially here where we don’t have any other water sources available.

Thank you,
Penny Wolfsohn
On Thu, Jul 7, 2022 at 11:24 AM Ryan Driscoll <[email protected]> wrote:

Penny,
Thank you for your additional comment regarding the potential for future housing in San Ramon. Your comments will be considered by the City as part of the public review process for the ongoing Housing Element update.

Regarding water service for future housing, as part of the standard City review process for all proposed development projects, the City requests and considers comments from all responsible water service districts (e.g. EBMUD, DSRSD) on their ability to serve water for a proposed development project. For larger development projects (e.g. > 500 housing units), the City requests and considers the responsible water service district’s prepared water demand assessment for a proposed larger development project in accordance with State law and the California Environmental Quality Act (CEQA) Guidelines. Water availability continues to be a critical consideration by the City when reviewing future development projects.

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Packet Pg. 515 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing We appreciate your comments,
-Ryan
Ryan Driscoll – Associate Planner
Direct Phone: (925) 973-2568 – Fax: (925) 830-0100 – [email protected] City of San Ramon – Planning Services Division – 7000 Bollinger Canyon Rd., San Ramon, CA 94583 From: Penny Wolfsohn <[email protected]>
Sent: Friday, June 24, 2022 12:56 PM
To: Planning Services (public) <[email protected]> Subject: Density with regard to housing

It’s impossible for me to read this plan and understand what it means so I am asking you. Are you aware that we cannot take in more people then we have water and environmental concerns to care for.?
I have written you about my concerns in the past and I hope they are still being considered. Before you add more housing you must plan for water needs. We don’t have enough water as it is now and to add more housing with more demand for water would not be a wise plan. You need to know that and take that into consideration.

A concerned San Ramon resident,
Penny Wolfsohn
130 Neptune Pl.

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Packet Pg. 516 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Cindy yee
Sent: Tuesday, December 27, 2022 10:50 AM
To: Claire Mailhiot
Cc: Planning Services (public)
Subject: RE: Draft Housing Element Comment
Hi Claire,
Thank you for your email and taking time to provide comments on the revised Draft Housing Element. Your comments have been received and will be considered as part of the update to the Housing Element.

Sincerely,
Cindy Yee
Cindy M. Yee, AICP | Senior Planner | City of San Ramon | Planning Services Division 7000 Bollinger Canyon Rd. · San Ramon, CA 94583 · www.ci.san-ramon.ca.us T: 925.973.2562 direct · F: 925.830.0100 · E: [email protected] The public counter at the San Ramon Permit Center is now open, with social distancing and hygiene measures in place. Please visit www.bit.ly/CityServices for the latest information regarding City services.

From: Claire Mailhiot <[email protected]>
Sent: Tuesday, December 27, 2022 9:43 AM
To: Planning Services (public) <[email protected]> Subject: Draft Housing Element Comment
I believe the massive parking lots at Bishop Ranch 1 would be a great location for more housing.

Build a parking structure for the employees of the businesses there and then use the rest of the parking lots for apartments or condos that would enable workers to live near their offices.

I have been living in San Ramon since 1989. It is ostensibly a "city" but I see it turning into more of a "bedroom community" with more housing than jobs.

I don't understand the rationale for tearing down office space to build homes if we hope to get people out of their cars. But I would rather see that than having more houses built on undeveloped land (such as the ironically-named "Preserve" which destroyed so much of the wildlife habitat and natural ecosystem).

I also object to putting housing at the Marketplace, unless there is a grocery store or retail on the ground floor and an attempt is made to preserve the architectural integrity of the buildings, and the same applies to the Chevron property. I hope it can be converted to housing without destroying the campus and landscaping.

Additionally, I have concerns about the capacity of our roads to handle such an increase in population density. If there is a massive earthquake on the Calaveras fault, there will be no way to evacuate the city. Even now when there is a major accident on Bollinger or Crow Canyon, the traffic backs up for ages.

Finally, I really don't want to see San Ramon turn into Dublin.

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Packet Pg. 517 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing Claire Mailhiot
San Ramon resident

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Packet Pg. 518 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Cindy yee
Sent: Wednesday, October 19, 2022 5:05 PM
To: Preston Rutherford
Cc: Planning Services (public)
Subject: RE: Helping with your Housing Element Requirements Hi Preston,
Thank you for your email regarding your interest in the Housing Element. At this time, our draft has been submitted to the State Housing and Community Development Department for review. A copy of that draft can be found
here: https://plansanramon.com/images/media/San_Ramon_HE_HCD_Review_Draft_07-20- 2022.pdf
The City’s list of draft housing opportunity sites can be found in Appendix 11-D starting on Page H.D-1. These parcels have been identified as the housing sites the City intends to use to meet our Regional Housing Need. A map of the sites identified in Appendix 11-D can be found on page H.4-9.

If I can be of further assistance, feel free to reach out to me directly. Thank you.

Cindy M. Yee, AICP | Senior Planner | City of San Ramon | Planning Services Division 7000 Bollinger Canyon Rd. · San Ramon, CA 94583 · www.ci.san-ramon.ca.us T: 925.973.2562 direct · F: 925.830.0100 · E: [email protected] The public counter at the San Ramon Permit Center is now open, with social distancing and hygiene measures in place. Please visit www.bit.ly/CityServices for the latest information regarding City services.

From: Preston Rutherford <[email protected]>
Sent: Tuesday, October 18, 2022 6:36 PM
To: Planning Services (public) <[email protected]> Subject: Helping with your Housing Element Requirements I'd like to help you build more housing! I'm an entrepreneur turned local affordable housing developer. I understand that cities are putting together their Housing Element for the state. Do you have a spreadsheet of parcels you'd like to be developed into housing? Might you send it to me? I'd love to add great housing to our great city.

Thanks!
Preston Rutherford
520-409-8628
1000adu.com
Schedule a call with me
Learn more about our projects by viewing a 3 min intro video.

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Packet Pg. 519 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing Join our progress: Instagram | LinkedIn | YouTube

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Packet Pg. 520 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Steven Spedowfski
Sent: Friday, September 23, 2022 4:24 PM
To: [email protected]
Cc: Cindy yee
Subject: RE: San Francisco Business Times: NCRSP/Chevron campus rezoning Hello Sarah,
Thank you for reaching out to the City for additional comment regarding the NCRSP and Chevron campus. Our statement follows:

The City’s work on the General Plan Update and evaluating the land use designations in the core of the City began in Summer 2021. In addition to determine how the City will plan for new residential units as required by the State through the Regional Housing Need Allocation (RHNA) process, the City has an opportunity to set land use patterns for the next 20 years through the General Plan Update. The City’s vision for the core is a vibrant, integrated balance of residential and commercial uses. While the City has conducted a number of stakeholder interviews with property owners and held numerous community study sessions to receive feedback on land use, property owner approval is not required when the City is considering rezoning and Chevron has not specifically commented on their parcel’s land use. The City will continue to solicit input as part of our public review process as we move forward with the General Plan Update.

We hope the above statement provides some context to the decision making process moving forward. If you have any additional questions, please do not hesitate to call.

Thank you,
Steven Spedowfski / Deputy City Manager
[email protected] / 925-973-2632
City of San Ramon / 7000 Bollinger Canyon Road, San Ramon CA 94583

From: Sarah Klearman <[email protected]>
Sent: Thursday, September 22, 2022 4:50 PM

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Packet Pg. 521 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing To: Cindy Yee <[email protected]>
Subject: San Francisco Business Times: NCRSP/Chevron campus rezoning

Cindy,

I hope this message finds you well. I don’t think we’ve previously met – I cover commercial real estate for the San Francisco Business Times. I’m reaching out to ask if you might have a moment tomorrow to speak with me for a piece I’d like to do about the discussions San Ramon’s elected leaders are having regarding repealing the NCRSP and potentially rezoning the land that currently houses Chevron’s campus.

I understand both Planning Commission and City Council members have expressed their concern regarding the rezoning of Chevron’s campus and that it likely won’t move forward at this time. I do however have a few questions about that proposal – i.e. was that rezoning approved by Chevron and Sunset Development, which I understand has a say over how that property is used? I’m specifically wondering if the city could move forward with that rezoning without approval from Chevron and Sunset.

If you might have a moment to get in touch tomorrow (or this evening, though I know that’s last minute) I’d really appreciate it. Please feel free to reach me on my cell any time tomorrow – I have a 9a call but should be otherwise available.

Thank you for your time.

Best,
Sarah

--
Sarah Klearman
Commercial Real Estate Reporter
San Francisco Business Times
[email protected]
c. 415 288 4930

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Packet Pg. 522 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Cindy yee
Sent: Friday, October 14, 2022 4:29 PM
To: 'Michael Sacks'
Subject: RE: San Ramon Housing Element
Hi Michael,
Thanks for your follow up email. I note that the APNs provided are in unincorporated Contra Costa County, outside of the City limits. For more information on opportunities in CCC, you will want to contact their conservation and development dept. https://www.contracosta.ca.gov/3383/Conservation-Development In terms of opportunities within San Ramon, we have a draft housing element currently published awaiting HCD
review. https://plansanramon.com/images/media/San_Ramon_HE_HCD_Review_Draft_07-20- 2022.pdf A site inventory can be found in Appendix 11-D of the document where parcels are identified by APN and size. I would recommend using this list to narrow your search for a location that meets your criteria.

Feel free to follow up with me if you have any questions.

Thank you, Cindy
Cindy M. Yee, AICP | Senior Planner | City of San Ramon | Planning Services Division 7000 Bollinger Canyon Rd. · San Ramon, CA 94583 · www.ci.san-ramon.ca.us T: 925.973.2562 direct · F: 925.830.0100 · E: [email protected] The public counter at the San Ramon Permit Center is now open, with social distancing and hygiene measures in place. Please visit www.bit.ly/CityServices for the latest information regarding City services.

From: Michael Sacks <[email protected]>
Sent: Wednesday, October 12, 2022 4:53 PM
To: Cindy yee <[email protected]>
Subject: Re: San Ramon Housing Element
Hi Cindy,
We are not partial to any lot in particular, and would be happy to consider any lots 30 acres or greater.

APN 205-030-011 and APN 205-020-019 are on our radar.

Development would include 7 story buildings with retail on the ground floor and residential on floors 2-7.

Maybe this url will work for you?

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Packet Pg. 523 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing Best,
Michael
On Tue, Oct 11, 2022 at 4:18 PM Cindy yee <[email protected]> wrote:

Hi Michael,
Thank you for your email. The City of San Ramon is currently in the process of updating our Housing Element. Is there a particular site you have in mind for the new development proposal? I was not able to access your website as our City’s web server has blocked the address. Is there any information you can send me regarding your project proposal? Thank you.

Cindy M. Yee, AICP | Senior Planner | City of San Ramon | Planning Services Division 7000 Bollinger Canyon Rd. · San Ramon, CA 94583 · www.ci.san-ramon.ca.us T: 925.973.2562 direct · F: 925.830.0100 · E: [email protected] The public counter at the San Ramon Permit Center is now open, with social distancing and hygiene measures in place. Please visit www.bit.ly/CityServices for the latest information regarding City services.

From: Michael Sacks <[email protected]>
Sent: Monday, October 10, 2022 6:41 PM
To: Planning Services (public) <[email protected]> Subject: San Ramon Housing Element

Dear Planning Department,
Ancho Real Estate would like to build 2,000 housing units in San Ramon.

Our mixed use development would require residents forgo car ownership, meaning that San Ramon would see a negligible increase in traffic in exchange for 2,000 new units, taxpayers, and a range of additional retail spaces.

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Packet Pg. 524 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing You can find out more at liveancho.com
Best,
Michael Sacks

--
Michael Sacks
Director of Development
Ancho Real Estate Development
858 750 0172
[email protected]
www.liveancho.com

--
Michael Sacks
Director of Development
Ancho Real Estate Development
858 750 0172
[email protected]
www.liveancho.com

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Packet Pg. 525 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Corrina Gould <[email protected]>
Sent: Wednesday, October 12, 2022 5:36 PM
To: Cindy yee
Subject: Response to San Ramon General Plan update
Attachments: City of San Ramon General Plan Update.pdf; Copy of San Ramon Housing Element Concerns.docx (1).pdf
Dear Cindy,
Please find attached a letter and some comments from the Tribe. 'Uni (Respectfully),
Corrina Gould, Tribal Chair
Confederated Villages of Lisjan Nation

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Packet Pg. 526 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing Confederated Villages of Lisjan
(510) 575-8408 ⬨ 10926 Edes Avenue, Oakland CA 94603
City of San Ramon Planning Services Division
7000 Bollinger Canyon Road,
San Ramon, CA 94583
RE: City of San Ramon General Plan Update
Dear Planning Services Division,
I am writing on behalf of the Confederated Villages of Lisjan in response to your request for our input regarding the Housing Element of the City San Ramon. As people who have lived on this land for many generations before it was known as Contra Costa County, we are glad to continue to build a stronger County-Tribe relationship. We would like to eventually provide feedback that incorporates Native people into all general and specific plans proposed by the City.

We have reviewed several recent updates to housing elements proposed by various cities and counties in the larger Bay Area, but the City of San Ramon draft stands out because it fails to mention Native people in the narrative at all, with the exception of a few graphs in the Demographics Section. There is no mention of Ohlone people or Native people at all in the History section, despite information about Native occupation of the region being widely available.

In addition to the complete lack of any inclusion of Native people, past or present in the planning document, there is not a section devoted to a discussion regarding Tribal Cultural Resources or even historic resources. Our attorneys were asked to provide comments to the Public Review Draft and to markup the document, but it is not at all fair for the Tribe to be required to pay our attorneys to review the over 300 page document and edit it for the City.

In order to help aid the City in correcting the omissions, we have attached a document that both points out room for change in the current plan, as well as suggested language that would overall improve the document in regard to inclusion of tribal people.

We view this as a starting point and would also like to engage in more dialogue.

We would like a seat at the table throughout the entire process, as we have called this land home for generations.

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Packet Pg. 527 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing Confederated Villages of Lisjan
(510) 575-8408 ⬨ 10926 Edes Avenue, Oakland CA 94603
Thank you again for considering our comments, we look forward to working with you further.

Sincerely,
Corrina Gould
Chairwoman

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Packet Pg. 528 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon General Plan Update Comments from Confederated Villages of Lisjan Nation 10/22

1. Our primary concern is the fact the Tribe was not consulted with on the proposed Housing Element until the relative end of the process. There may be areas zoned for development of sensitivity to the Tribe, however, we would like to have access to the maps for proposed changed designations in a separate document that does not require us to sift through hundreds of pages and try to isolate the maps that are specifically recommending zoning changes.

We request access to the maps that set forth the proposed zoning changes in a format that is more user-friendly so that we can compare them with our knowledge base and provide site specific comments.

2. The primary purpose of the requirements set forth in SB18 (which require tribal consultation) is to help local governments identify areas where tribal cultural resources might be present and to avoid planning for development that would impact those places, wherever possible. The best way to prevent a grant of development entitlements that may have a significant impact on tribal cultural resources is to avoid changing the zoning that would allow development on parcels that contain tribal cultural resources. We would like to have time to review our maps and determine areas of major sensitivity in comparison with the maps that indicate proposed changes in land use in the Housing Element.

3. It is important that California Native American Tribes are consulted and involved at the earliest possible stage in decision-making regarding land use, cultural resources, and ways that tribal cultural resources may be impacted. Planning decisions today will impact our ancestral lands forever.

Our page specific comments follow:

4. Page H. 1-3 lists presentations that were given to various Committees and Commissions, however there was not a tribal specific consultation. In the future, there should be time set aside at the earliest possible date to consult with tribes that are culturally affiliated with San Ramon to determine areas of cultural importance and concern.

5. Page H. 1-4 and 1-5 list Stakeholder Interviews also lists various organizations for input but there is no reference to consultations with culturally affiliated tribes.

6. Page H. 2-1. Brief History of San Ramon. This section only has one sentence regarding the Native people: “The area of modern day San Ramon was once home to the Seunen and Ohlone/Costanoans Native Americans who lived adjacent to the valley creeks.” We believe that there should be more detail in the background of San Ramon because the planning document is reflective of a City’s vision of the place.

There is information online from a simple Google search that provides background at They Came First | The Indians of the San Ramon Valley | CCCHS Historical Essays (cocohistory.org) and Microsoft Word - Chapter 4.doc (museumsrv.org); I also direct

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Packet Pg. 529 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon General Plan Update Comments from Confederated Villages of Lisjan Nation 10/22 you to Milliken, Randall T., An Ethnohistory of the Indian People of the San Francisco Bay Area from 1770 to 1810 , Berkeley: Dissertation, 1991 and, A Time of Little Choice The Disintegration of Tribal Culture in the San Francisco Bay Area 1769-1810 , Menlo Park: Ballena Press, 1995

7. Page H. 2-5. Race/Ethnicity Characteristics. This section does not include any information about the Native tribal population or include data on American Indians who have relocated to San Ramon from other places.

8. Page H. 3-1. Land Use Controls. The narrative state that the “review of potential constraints is based on the existing General Plan 2035 and Zoning Ordinance.

However, the General Plan land use designations are being updated concurrently with the Housing Element Updated. Land use controls as presented in Table 11.3-1 will change with additional land use designations and zoning districts.” This language is very concerning because the Tribe has not been consulted with on an update to the San Ramon General Plan. As stated above, the primary purpose of the requirements set forth in SB18 (which require tribal consultation) is to help local governments identify areas where tribal cultural resources might be present and to avoid planning for development that would impact those places, wherever possible.

The best way to prevent a grant of development entitlements that may have a significant impact on tribal cultural resources is to avoid changing the zoning that would allow development on parcels that contain tribal cultural resources.

Clearly, there is more work to do for the Tribe and the City to identify areas of concern and potential impact to tribal cultural resources as soon as possible.

9. Page H. 3-19. Land Use Development Application Processing Timelines. This section references streamlining under SB 35, but it does not include language regarding tribal consultation prior to an application being submitted for streamlining.

We direct you to review the language of AB 168 and its counterparts, which require scoping consultation for streamlining applications prior to filing.

10. Page H. 3-19. Site Improvements, Development Fees and Exactions. This section could also include a provision for Tribal Cultural Resources: Mitigation Measures.

The new language could reference a policy of protection and avoidance of tribal cultural resources.

11. Page H. 3-37. Market Conditions. A new section regarding the protection of tribal cultural resources would be a natural addition after “Habitat Protection”. We can assist as needed. We would like to see goals on collaborating with Tribes and protecting resources woven into the document and this would be a good place for

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Packet Pg. 530 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon General Plan Update Comments from Confederated Villages of Lisjan Nation 10/22 such a policy statement and notification to the public about protective measure, including avoidance and re-design, similar to the habitat section.

12. Page H. 4-9. We would like to see a more specific map of the site inventory, with site specific layers and maps in order to determine if there are any conflicts in proposed use due to impact to tribal cultural resources.

13. Page H. 5-2. Variety of Housing Opportunities. Implementing Policies. We suggest adding a policy goal of “Identifying sites that contain sensitive tribal cultural resources and ensuring that they are not proposed for housing development or streamlining to avoid conflicts in land use.”

14. Page H. 5-16. Removal of Government Restraints. We propose an amendment to this section that notes that under Resource Management (p. H.5-17) “Tribal Cultural Resources found near historic watersheds will be identified for exclusion from any streamlined proposals for development. Such properties will be identified and preserved as Open Space.”

15. Appendix 11-A- There is no information about tribal consultation which is concerning and we hope that California Native American Tribes that are found on the Native American Heritage Commission’s list for Contra Costa County will be consulted as required in the future.

16. Page H. E-25, Table E-13. We note that the chart reflects that American Indian and Alaska Native alone indicates the highest percentage with disabilities (12.8%). There could be a greater analysis of the historical needs of Native people in San Ramon.

17. Page H. E-45, Table E-20 indicates that American Indian and Alaska Natives are reported as 3.4% in poverty. There could be a greater analysis of the historical needs of Native people in San Ramon.

18. Page H. E-95-98. We would like to see a more detailed discussion regarding a policy to protect tribal cultural resources utilizing open space. There is a significant amount of detail on this in the Tribal Consultation Guidelines that are published by the Governor’s Office of Planning and Research.

19. There is no discussion at all regarding the impact of housing on historic and tribal cultural resources, which is required by the CEQA guidelines. At a minimum we present the following language as a starting point:

SAMPLE LANGUAGE

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Packet Pg. 531 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon General Plan Update Comments from Confederated Villages of Lisjan Nation 10/22 In addition to these suggested changes to specific parts of the current General Plan, we have sample language regarding specific policy to address cultural resources and other issues.

CULTURAL AND ARCHAEOLOGICAL RESOURCES GOAL
Protection and Preservation of Native American Cultural Places. Policies

1. Consult with culturally-affiliated Native American tribes prior to amending the General Plan and adopting or amending specific plans, and when a tribal cultural site is to be placed in permanent open space, consistent with state law.

2. Work with culturally-affiliated tribes to identify and appropriately address cultural resources and tribal sacred sites through the development review process.

3. Avoid or mitigate to the maximum feasible extent impacts of development on Native American archaeological and cultural resources.

4. Encourage voluntary landowner efforts to protect cultural resources and tribal cultural sites consistent with state law.

Implementation Measures

1. The City shall refer proposals for projects that are not categorically-exempted from the California Environmental Quality Act for evaluation and a recommendation as to whether further study is required to determine the presence or absence of archaeological resources. If further study is required, the project applicant shall contract with a qualified professional to conduct the study and make recommendations designed to avoid or minimize adverse impacts on cultural or historic resources and indicate whether further investigation is needed. All studies shall be completed and submitted to the City prior to the completion of any environmental document for the project.

2. The City will refer draft environmental documents, including any studies and recommended mitigation measures, to the appropriate Native American tribes for review and comment as part of the public review process for such documents. Mitigation measures to avoid or minimize impacts on Native American cultural resources may include the execution of a cultural resources treatment agreement between the developer and the appropriate tribe(s) that address the treatment and disposition of cultural resources and human remains, and tribal monitoring during earth-disturbing activities.

3. Consult with culturally-affiliated tribes prior to designating open space in order to protect the identity of any cultural places that exist on the proposed open space and develop a treatment plan and management plan for any such cultural places.

4. Work with culturally-affiliated tribes to acquire and hold conservation easements on terms mutually satisfactory to the tribe and landowner for purposes of protecting tribal cultural places.

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Packet Pg. 532 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon General Plan Update Comments from Confederated Villages of Lisjan Nation 10/22 Archaeological and Cultural Resources

1. Any project that involves earth disturbing activities within previously undisturbed soils in an area determined to be archaeologically or culturally sensitive, shall require evaluation of the site by a qualified archaeologist retained by the project applicant. The applicant shall implement the recommendations of the archaeologist, subject to the approval of the City Planning Department.

2. Any project that involves earth disturbing activities in previously undisturbed soils that have been determined to be archaeologically or culturally sensitive shall require consultation by the applicant with California Indian Tribe(s) which have a traditional cultural affiliation with the project area and/or the resources affected by the project, for the purposes of determining archaeological and cultural resources impacts and creating appropriate mitigation to address such impacts. The applicant shall also arrange for monitoring of earth disturbing activities by Tribe(s) which have a traditional cultural affiliation with the project area and/or the resources affected by the project, if requested.

Human Remains

1. In the event of the discovery of a burial, human bone or suspected human bone all excavation or grading in the vicinity of the find shall halt immediately and the area of the find shall be protected and the project applicant immediately shall notify the County Coroner of the find and comply with the provisions of Cal. Health and Safety Code Section 7050.5, including Cal. Public Resources Code Section 5097.98, if applicable.

2. In the event that human remains are determined to be Native American human remains the applicant shall consult with the MLD to determine appropriate treatment for the Native American human remains as prescribed in Public Resources Code Section 5097 et seq..

OPEN SPACE ELEMENT GOAL
Protection and Preservation of Native American Cultural Places. Policies

1. Consult with culturally affiliated Native American tribes prior to amending the General Plan and adopting or amending specific plans, and when a tribal cultural site is to be placed in permanent open space, consistent with state law.

2. Work with culturally-affiliated tribes to identify and appropriately address cultural resources and tribal sacred sites through the development review process.

3. Avoid or mitigate to the maximum feasible extent impacts of development on Native American archaeological and cultural resources.

4. Encourage voluntary landowner efforts to protect cultural resources and tribal cultural sites consistent with state law.

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Packet Pg. 533 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing City of San Ramon General Plan Update Comments from Confederated Villages of Lisjan Nation 10/22 Sample Cultural Resources Mitigation Measures

1. Prior to the issuance of grading permits, the developer is required to enter into a cultural resources treatment agreement with the culturally affiliated tribe. This agreement will address the treatment and disposition of cultural resources and human remains that may be impacted as a result of the development of the Project, as well as provisions for tribal monitors.

2. If cultural resources are discovered during the project construction, all work in the area of the find shall cease, and a qualified archaeologist and representatives of the culturally affiliated tribe shall be retained by the project sponsor to investigate the find, and make recommendations as to treatment and mitigation.

3. A qualified archaeological monitor will be present and will have the authority to stop and redirect grading activities, in consultation with the culturally affiliated tribe and their designated monitors, to evaluate the significance of any archaeological resources discovered on the property.

4. Tribal monitors from the culturally affiliated tribe shall be allowed to monitor all grading, excavation and groundbreaking activities, including all archaeological surveys, testing, and studies, to be compensated by the developer.

5. The landowner agrees to relinquish ownership of all cultural resources, including all archaeological artifacts that are found on the Project area, to the culturally affiliated tribe for proper treatment and disposition.

6. All cultural sites within the Project area are to be avoided and preserved.

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Packet Pg. 534 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Kendra Ma <[email protected]>
Sent: Monday, October 3, 2022 4:23 PM
To: Planning Services (public)
Cc: [email protected]
Subject: San Ramon Draft Housing Element Comments
Attachments: San Ramon HE Comments_TransForm.pdf
Hi San Ramon Planning Department,
My name is Kendra and I am the Policy Analyst at TransForm. We are a nonprofit policy advocacy organization focusing on better land use and transportation policy at the local, regional, and state level. Thank you for releasing a draft of the City's Housing Element for review and public comment. I am aware that we're sending this past the 30-day comment deadline, but if you get the chance, our team has put together some feedback that we would like to see addressed in the Housing Element.

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

Feel free to reach out if you have any questions - we know this is a busy time of year and we thank you so much for your hard work around this! Thanks,
Kendra
--
Kendra Ma, Policy Analyst
(she/her/hers)
TransForm
560 14th Street, Suite 400, Oakland, CA 94612

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Packet Pg. 535 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing Sign up for our emails at www.TransFormCA.org. Follow us on Twitter, Instagram, Facebook, and Linkedin, too.

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Packet Pg. 536 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing October 3, 2022
Planning Department
San Ramon
7000 Bollinger Canyon Road
San Ramon, CA 945683
Re: Draft Housing Element Needs Ambitious Parking Updates Dear San Ramon Planning Department,
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 Ramon’s work to date on the Draft Housing Element. However, to meet housing, transportation, and climate goals, San Ramon needs to expand on its successful programs and initiate some new ones. In particular:
● Reducing the amount of parking mandated for housing and providing incentives and programs to drive less (Transportation Demand Management or TDM)
● Developing sufficient programs to meet affordable home targets of RHNA We appreciate the inclusion of Program 17 which promises a series of zoning code amendments by the end of 2023,including reduction of mandated parking spaces. However, the reduction only applies to single family homes and multi-family units of 2 bedrooms or more, with no mention of smaller unit sizes.

These policies are not enough of a change to eliminate parking’s constraint on development. After implementation the code will still require at least 1 space for units, with no change to guest parking, resulting in little improvement to San Ramon’s outdated parking standards.

San Ramon lists various reasons why their parking standards for multi-family are not excessive including that multi-family requirements are lower than single family dwellings, and they are not along a BART line like neighboring Dublin and Pleasanton. However cities like Alameda (which also lacks direct BART access) have eliminated parking requirements for all zoning districts, demonstrating that lowering excessive parking requirements is not only for BART-connected cities.

The need to eliminate or greatly reduce parking minimums is more important than ever. Each new parking space costs $30,000-$80,000. With inflation driving up construction costs since these 1 1 https://www.shoupdogg.com/wp-content/uploads/sites/10/2016/05/Cutting-the-Cost-of-Parking-Requirements.pdf 560 14TH STREET, SUITE 400, OAKLAND, CA 94612 | T: 510.740.3150 | WWW.TRANSFORMCA.ORG 1 2.1.h
Packet Pg. 537 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing estimates, two spaces may now cost up to $200,000. Beyond construction costs, parking takes up essential space that could provide more homes, services, or community amenities.

TransForm recommends that San Ramon 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.

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

3. Encouraging developments to subsidize transit passes in return for reduced parking provision.

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 2700 Hooper Drive. This site is identified in San Ramon’s draft Housing Element Site Inventory as a potential opportunity site this cycle and without a proposed development. 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 2700 Hooper Drive, GreenTRIP predicts:

1. By implementing unbundling and providing transit passes at this site, we saw a 28% decrease in parking and resident transportation savings of $840 per year.

2. With right-sized parking, incorporating the benefits of good location, unbundled parking, and free transit passes, the development would cost $6,045,000 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 County average.

4. If an affordable development with smart parking strategies were built on this site, each household would drive 6,858 fewer 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. One of the most important is Program 10 which provides incentives and expedited review for affordable developments. 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 Program 10. Not only do 560 14TH STREET, SUITE 400, OAKLAND, CA 94612 | T: 510.740.3150 | WWW.TRANSFORMCA.ORG 2 2.1.h
Packet Pg. 538 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing these households use transit more and drive much less than average, but success in this area can help provide homes for unsheltered individuals and families. A commitment to these programs will show that San Ramon is committed to planning for all levels of the 3,126 RHNA BMR units anticipated in this cycle.

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

Sincerely,
Kendra Ma
Housing Policy Analyst
[email protected]
560 14TH STREET, SUITE 400, OAKLAND, CA 94612 | T: 510.740.3150 | WWW.TRANSFORMCA.ORG 3 2.1.h
Packet Pg. 539 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Michael Sacks <[email protected]>
Sent: Monday, October 10, 2022 6:41 PM
To: Planning Services (public)
Subject: San Ramon Housing Element
Dear Planning Department,
Ancho Real Estate would like to build 2,000 housing units in San Ramon.

Our mixed use development would require residents forgo car ownership, meaning that San Ramon would see a negligible increase in traffic in exchange for 2,000 new units, taxpayers, and a range of additional retail spaces.

You can find out more at liveancho.com
Best,
Michael Sacks
--
Michael Sacks
Director of Development
Ancho Real Estate Development
858 750 0172
[email protected]
www.liveancho.com

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Packet Pg. 540 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing From: Byron de Arakal <[email protected]>
Sent: Tuesday, July 19, 2022 2:29 PM
To: planningcommission
Cc: Debbie Chamberlain; Lauren Barr; Cindy yee
Subject: TRC Comment Letter - Item 12.1 - Study Session - 07192022 Attachments: TRC Comment Letter_Retail Analysis_SRPC_07192022.pdf Please distribute the attached communication to members of the Planning Commission re: Item 12.1 on this evening’s agenda.

Thank you.

Byron de Arakal
Byron de Arakal
Consulting Director Entitlement Planning
4695 MacArthur Court | Suite 700
Newport Beach, CA 92660
C 714.227.4620
[email protected]

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Packet Pg. 541 Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing

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Attachment: D: Public Comments received since June 21, 2022 (3867 : General Plan Amendment (GPA 2021-0001) for the 2023-2031 Housing Element 1 Cindy yee
From: East Bay for Everyone <[email protected]> Sent: Thursday, January 19, 2023 3:15 PM
To: Finney, Connor@HCD; McDougall, Paul@HCD; Cindy yee; [email protected]; Ryan Driscoll
Subject: San Ramon Planning Commission wants to adjudicate objective standards, instead of staff
Hi,
I'm summarizing here and I am trying my best to get the facts right, apologies if I don't get anything right.

A developer proposed 284 homes at the site of the "Marketplace" in San Ramon which currently contains a Trader Joe's and CVS, at the corner of Alcosta and Bollinger Canyon. This was met with opposition from the Planning Commission and members of the public so they withdrew that proposal and instead are proceeding with 40 single family townhomes. https://www.danvillesanramon.com/news/2021/06/23/opposition-grows-to-5- story-284-unit-apartment-complex-project-at-san-ramonsmarketplace, https://www.danvillesanramon.com/news/2022/10/03/san-ramon-planning-commission-to-discusslatest-plans-for-marketplace-housing This is not the first time they have done this, in 2019 the Planning Commission rejected an application to a memory care home for seniors and a preschool building on church property. The applicant in 2019 (Church of the Valley) asked for looser development standards in June 2022, since they want to build housing again, and San Ramon is including their parcel in its Housing Element. San Ramon did not grant the pastor's requests for additional density and reduced parking minimums which we mentioned in our December 29th letter. https://www.danvillesanramon.com/news/2019/05/27/san-ramon-council-set-to-finalize-denial-of-church-ofthe-valley-project In our December 29 letter we asked San Ramon to analyze local, political and Planning Commission opposition to housing as a "Non-governmental constraint" since they did not discuss political opposition causing reductions in density as part of their December draft.

Now, even the 40 townhome project is too much. A local group "Citizens Against Marketplace Development" (CAMPAD) has retained attorneys to send threatening letters.

In October, the San Ramon Planning Commission got upset that staff made a determination that the project complied with objective standards without consulting the Commission, since they disagreed with staff and were hoping to use their own reading of objective standards to deny the project. This is covered here:
https://www.danvillesanramon.com/news/2022/12/01/around-the-valley-questionable-actions On Tuesday January 17th the Planning Commission reviewed a presentation from outside counsel about a proposal for the Planning Commission to review staff determination of completeness within 30 days of that judgment being reached. The outside counsel said this would basically be unprecedented in California and strongly recommended against it. http://sanramonca.iqm2.com/Citizens/FileOpen.aspx?Type=14&ID=3285 To be honest I am trying to read the transcript of that meeting and I think the Commission direction was to try to go ahead with Commission review of staff's objective standards determination, over and against the advice of the outside counsel and city attorney. Several of the public comments discussed traffic and the desire for the Council/Plancom to be the ones adjudicating objective standards which suggest that the basis for all of this

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Packet Pg. 553 Attachment: E: Public Comments received on the errata changes to the revised Draft 2023-2031 Housing Element (3867 : General Plan 2 effort is to try to find ways to deny housing applications in San Ramon. https://www.youtube.com/watch?v=homZQIFLHOE
To us it is very concerning that the San Ramon Planning Commission is attempting to meddle in staff's ability to apply an objective standard to housing applications. At very least San Ramon should include discussion of how this could impede their ability to meet their RHNA goal, and discussion of how projects may be watered down after they are initially proposed.

Best,
Kevin

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Packet Pg. 554 Attachment: E: Public Comments received on the errata changes to the revised Draft 2023-2031 Housing Element (3867 : General Plan

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