Scotts Valley City Council
December 20, 2023

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Racially Concentrated Areas of Affluence (RCAA)
R/ECAPs are a long-standing, contributing factor to segregation. Patterns of segregation in the United States show that of all racial groups, the White population is the most separated from other racial groups. Research also identifies segregation of affluence to be greater than the segregation of poverty. Racial and economic segregation can have significant effects on respective communities, including, but not limited to, socioeconomic disparities, educational experiences and benefits, exposure to environmental conditions and crime, and access to public goods and services.

Data used in the analysis of Racially Concentrated Areas of Affluence (RCAAs) comes from the 2015-2019 American Community Survey and measured at the census tract level. HCD has created an RCAA metric to reflect California's relative diversity and regional conditions, and to aid local jurisdictions in their analysis pursuant to AB 686 and AB 1304. HCD's RCAA metric is first calculated using a Location Quotient (LQ) for each census tract that represents the percentage of total White population (White Alone, Not Hispanic or Latino) per census tract compared to the average percentage of total White population for all census tracts in a given Council of Governments (COG). For example, a census tract with an LQ of 1.5 has a percentage of total White population that is 1.5 times higher than the average percentage of total White population in the given COG region. To determine RCAAs, census tracts with an LQ of more than

1.25 and a median income 1.5 times higher than the COG Area Median Income (AMI), or 1.5 times the State AMI, whichever is lower, are assigned a numeric score of 1. A score of 1 indicates that a census tract is an RCAA. Census tracts that did not meet this criterion are assigned a score of 0.

The nationwide RCAA analysis identifies the following:
 RCAA tracts have more than twice the median household income of the average tract in their metro area.
 Poverty rates in RCAAs are significantly lower and are, on average, about 20 percent of a typical tract.
 RCAAs tracts are more income homogenous than R/ECAPs.  The average RCAA is about 57 percent affluent, whereas the average R/ECAP had a poverty rate of 48 percent.

The typical RCAA tract has a rate of affluence 3.2 times that of a typical tract, whereas R/ECAPs on average had a poverty rate 3.2 times of that of a typical tract. Overall, RCAAs may represent a public policy issue to the extent that they have been created and maintained through exclusionary and discriminatory land use and development practices.

Table E-2 below displays the RCAA data for the City. The data shows these RCAAs have significantly higher percentage of white residents and median household incomes. Table E-3 displays the data of median household income by race for the City compared to Sanat Cruz

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County. All households in Scotts Valley had a relatively higher median income compared to the County ($108,289 and $89,986, respectively). This trend is also similar for those who identify as White (Not Hispanic or Latino). The City’s median income is approximately $7,000 more than the County’s White population.

It can be concluded that White households in Scotts Valley Typically have higher household income than all households and those of the White households in the County. It is difficult and expensive to develop housing on hilly terrain, making affordable housing infeasible in these areas. Because development of housing in these areas can be costly, typically only households with higher incomes can afford to buy or rent, establishing a concentration of affluence. Lower income housing sites have been identified throughout the city and are within areas considered RCAAs.

Table E-2: Median Household Income and White Population of RCAAs Census Tract Percent White Population Median Income
06087121200 85.28% $112,877
06087120900 78.12% $105,020
06087120800 85.21% $107,014
Source: (U.S. Census Bureau) from HCD AFFH Data Viewer, Accessed December 6, 2022.

Table E-3: Median Household Income by Race and Geography Race Scotts Valley Santa Cruz County
Median Income Population Median Income Population
White (Not Hispanic
or Latino) $107,971 88.8% $100,259 56.9%
All Households $108,289 -- $89,986 --
Notes: Median income in the past 12 months (in 2019 inflation-adjusted dollars) Source: American Community Survey, 5-Year Estimates, 2019.

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Figure E-4: Racially Concentrated Areas of Affluence
Source: California Department of Housing and Community Development – AFFH Data Viewer

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Census Tract 1
As stated above, there are no R/ECAPs in the City. Similarly, as shown in Figure E-4, there are no R/ECAPs identified in this area. Census Tract 1 has a variety of new housing opportunities to accommodate a variety of housing for different income categories.

Census Tract 2
Table E-2 shows that Census Tract 2 has the lowest percentage of white population and the lowest median income compared to the other two census tract (78.21 percent and $105,020).

Figure E-4 also shows that Census Tract 2 has RCAAs in the area. All of the candidate sites located in this area are classified under residential rezone projects. There are a few moderateincome units. Majority of the units are for above-moderate and low-/very-low-income units. In total, there are 54 units, with 22 low-/very-low-income units, 5 moderate-income units, and 27 above-moderate-income units.

Census Tract 3
As shown in Figure E-4, census tract 3 also has RCAAs in the area. New housing opportunities in this census tract are developed through a variety of projects such as pipeline projects, mixeduse rezone, and existing residential capacity projects. Majority of the units were dedicated to above-moderate-income in this area due to the high median income of the area. However, new housing in census tract 3 also includes 95 units for low-/very-low-income and 23 units for moderate-income households. This would allow for some opportunities for diversity in incomegroups and people of different backgrounds to live in this area.

Hate Crimes
Hate crimes are violent acts against people, property, or organizations because of the group to which they belong or identify. The Federal Fair Housing Act makes it illegal to threaten, harass, intimidate, or act violently toward a person who has exercised their right to free housing choice.

As shown in Table E-4, between 2015 and 2021, only two hate crimes were reported in Scotts Valley. The hate crimes reported were based on Race/Ethnicity/Ancestry and Sexual Orientation. The city has a rather low number of hate crimes compared to the local jurisdictions. Comparatively, Santa Cruz City and Watsonville reported a total of 52 and 8 hate crimes, respectively.

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Table E-4: FBI Hate Crimes by Bias (2015-2021)
Year
Race/
Ethnicity/
Ancestry
Religion Sexual
Orientation Disability Gender Identity
Multiple
Bias Total
2015 1 0 0 0 0 0 1
2016 0 0 0 0 0 0 0
2017 0 0 0 0 0 0 0
2018 0 0 1 0 0 0 1
2019 0 0 0 0 0 0 0
2020 0 0 0 0 0 0 0
2021 0 0 0 0 0 0 0
Total 1 0 1 0 0 0 0
Source: Federal Bureau of Investigation, Crime Data Explorer, 2015-2021.

Income
Household income level plays a significant role in housing choice. The City has experienced a relatively small increase in median income over the past decade. Census data reports a 2.1 percent increase in median income between 2010 and 2020, with the largest growth occurring in the last five years. In comparison, the County experienced a 37.9 percent increase, and the State experienced a 29.2 percent increase from 2010 to 2020 in median income.

Table E-5: Median Income by Year and Geography
Median Income
by Year City of Scotts Valley Santa Cruz County California 2020 $103,783 $89,986 $78,672
2015 $101,475 $67,256 $61,818
2010 $101,673 $65,253 $60,883
Percent Change 2.1% 37.9% 29.2%
Source: American Community Survey, 5-Year Estimates, 2010, 2015, 2020.

Regarding household income, the City had a higher median household income than the County and the State from 2010 to 2020. As Table E-6 shows, a large portion of the City’s households are higher earning; in total, over 51 percent of households in Scotts Valley earn more than the State median-income. Additionally, 23 percent of households in Scotts Valley earn $200,000 or more annually. Just under 22 percent of the City residents earn less than $50,000 annually, compared to 28.6 percent and 32.6 percent for the County and State, respectively.

Comparatively, Scotts Valley has the highest median income of the surrounding jurisdictions.

Behind Scott Valley, Santa Cruz County and the City of Santa Cruz have the second and third highest median income of the nearby jurisdictions by $89,986 and $86,618, respectively.

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Table E-6: Households by Median Income by Geography
Households Income City of Scotts Valley Santa Cruz County California Less than $10,000 5.6% 4.4% 4.7%
$10,000-$14,999 0.8% 3.6% 3.9%
$15,000-$24,999 4.0% 6.3% 6.9%
$25,000-$34,999 5.9% 5.5% 7.1%
$35,000-$49,999 5.7% 8.8% 10.0%
$50,000-$74,999 11.2% 12.8% 15.3%
$75,000-$99,999 15.6% 12.9% 12.3%
$100,000-$149,999 12.9% 16.9% 17.1%
$150,000-$199,999 15.2% 12.1% 9.4%
$200,000 or More 23.0% 16.8% 13.3%
Source: American Community Survey, 5-Year Estimates, 2020.

To calculate projected housing needs for extremely low-income (ELI) households, the City assumed 50 percent of its very low-income RHNA are ELI households. As the City was allocated 392 very low-income units, approximately 192 units are projected for ELI households. Some ELI households could face other housing challenges depending on the age of the householder, tenure status, or household characteristics (mental or physical disabilities, household size, language proficiency, etc.) that could exacerbate housing problems.

Figure E-5 shows the median income change from 2014 to 2019 for Scotts Valley and the surrounding region. In 2014, all block groups in the City had a median income range greater than $125,000. Median income has diversified in 2019 through Block Groups 1 and 3. Block Group 1/Census Tract 12081, located west of Whispering Pines Drive and south of Mount Hermon Road, had a median income of less than $125,000, while Block Group 3/Census Tract 1209, located west of Scotts Valley Drive, had a median income of less than $87,100. 1 Block groups are a subdivision of a census tract – it is the smallest geographic unit for which the Census Bureau tabulates sample data. Census tracts are a small subdivision of a county delineated by a local committee of census data users for the purpose of presenting data.

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Figure E-5: Median Income (2014-2019)
Source: California Department of Housing and Community Development – AFFH Data Viewer 2014
2019

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There is a significant concentration of high-income levels in areas of high concentration of White population. As shown in Figure E-3b, areas with higher percentage of white population are in areas with a higher median income. As Scotts Valley continues to diversify in its demographics, it is important to address any issues that may exacerbate conditions in these areas and areas of lower household income.

Disability
In 1988, Congress added protections against housing discrimination for persons with disabilities through the Federal Housing Administration (FHA), which protects against intentional discrimination and unjustified policies and practices with disproportionate effects. The FHA also includes the following unique provisions to persons with disabilities: (1) prohibits the denial of requests for reasonable accommodations for persons with disabilities, if necessary, to afford an individual equal opportunity to use and enjoy a dwelling; and (2) prohibits the denial of reasonable modification requests. With regards to fair housing, persons with disabilities have special housing needs because of the lack of accessible and affordable housing, and the higher health costs associated with their disability. In addition, many may be on fixed incomes that further limit their housing options.

Table E-6 displays the data for persons with disabilities in the City, County, and State. Overall, about 10.6 percent of the California population reported having at least one disability. In the City, about 12.6 percent of persons reported at least one disability. The City reported higher than the County at 11.5 percent. Of the 12.6 percent of Scotts Valley residents who reported a disability, the most common disabilities were ambulatory difficulties and independent living, which could be tied with the City’s senior population. Ease of reasonable accommodation procedures and opportunity for accessible housing can provide increased housing security for the population with disabilities.

Table E-6: Population by Disability Type, Compared by Geography, 2020 Disability City of Scotts Valley Santa Cruz County California Total with a Disability 12.6% 11.5% 10.6%
Hearing Difficulty 3.5% 3.4% 2.9%
Vision Difficulty 4.9% 2.4% 2.0%
Cognitive Difficulty 3.4% 4.9% 4.3%
Ambulatory Difficulty 6.3% 5.0% 5.8%
Self-care Difficulty 3.5% 2.3% 2.6%
Independent Living 6.2% 5.0% 5.5%
Source: American Community Survey, 5-Year Estimates, 2020.

The data in Figure E-6 below displays data for disability status in Scotts Valley by census tract.

The data shows that in the City, all three of the census tracts report 10 to 20 percent of the population to have at least one disability. This is consistent with the surrounding region.

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Figure E-6: Population with a Disability
Source: California Department of Housing and Community Development – AFFH Data Viewer

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Appendices A, C and D provide detailed descriptions of services and resources for persons with disabilities. Furthermore, new housing opportunities throughout the City are available to people with disabilities. This is facilitated through the Federal Fair Housing Amendment Act (FHAA) and the California Fair Employment and Housing Act which require governments to make reasonable accommodations in their zoning laws and other land use regulations to afford persons with disabilities an equal opportunity to housing. Scotts Valley’s Municipal Code includes Chapter 17.60 Requests for Reasonable Accommodation which complies with these legal requirements.

Overall, Scotts Valley has a slightly higher percentage of population with a disability than the State and County at 12.6 percent. Comparatively, the City of Santa Cruz had a lower percentage of 9.7 percent and Watsonville had a higher percentage of 12.9 percent. As shown in Figure E-6, there is no concentration of the population with a disability in the city. Although there is no significant concentration of the population to have at least one disability, it is the policy and practice of the City to take all reasonable steps to ensure its services, programs and activities are accessible to all members of the public including persons with disabilities.

Familial Status
Under the FHA, housing providers (e.g., landlords, property managers, real estate agents, or property owners) may not discriminate because of familial status. Familial status refers to the presence of at least one child under 18 years old, pregnant persons, or any person in the process of securing legal custody of a minor child (including adoptive or foster parents).

Examples of familial status discrimination include refusing to rent to families with children, evicting families once a child joins the family (through birth, adoption, or custody), enforcing overly restrictive rules regarding children’s use of common areas, requiring families with children to live on specific floors, buildings, or areas, charging additional rent, security deposit, or fees because a household has children, advertising a preference for households without children, and lying about unit availability.

Families with children often have special housing needs due to lower per capita income, the need for affordable childcare, the need for affordable housing, or the need for larger units with three or more bedrooms. Single parent households are also protected by fair housing law. Of particular consideration are female-headed households, who may experience greater housing affordability challenges due to typically lower household incomes compared to two-parent households. Often, sex and familial status intersect to compound the discrimination faced by single mothers.

Table E-7 displays household type for the State, County, and City. Overall, Scotts Valley has the largest percentage of married-couple households (55.4 percent) in comparison to the County and State. The City also has the largest percentage (49.2 percent) of households with at least one person over the age of 60. This trend has been largely consistent for the City of Scotts Valley for more than 20 years.

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Different household types have varying housing needs – senior households may benefit from reasonable accommodation procedures and being located near medical facilities, single-parent households may benefit from affordable housing options due to limited income, and family households may benefit from larger housing units located near community areas and schools.

Table E-7: Population by Familial Status by Geography
Familial Status City of Scotts Valley Santa Cruz County California Total Households 4,799 96,275 13,103,114
Married-Couple Family
Households 55.4% 48.1% 49.7%
With Children 17.5% 17.8% 17.8%
Non-Family Households 32.5% 36.8% 31.4%
Households with one or more
people 60 years+ 49.2% 44.3% 39.9%
Female Headed Households, No
Spouse Present with Children 5.5% 10.1% 12.9%
Source: American Community Survey, 5-Year Estimates, 2020.

Scotts Valley has a relatively diverse familial status. Comparatively, Scotts Valley has the lowest percentage of female headed households, no spouse present with Children compared to the surrounding jurisdictions such as the City of Santa Cruz and Watsonville (7.4 percent and 7.5 percent, respectively). The percentage of children in married-couple family households rank the second highest between the two cities. This population is located west of the Highway 17.

Scotts Valley has a high percentage of households with one or more people 60 years or older compared to the surrounding jurisdictions, which can be tied to Scotts Valley’s senior population.

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3. Access to Opportunities
Access to opportunity is a concept to approximate the link between place-based characteristics (e.g., education, employment, safety, and the environment) and critical life outcomes (e.g., health, wealth, and life expectancy). Ensuring access to opportunity means both improving the quality of life for residents of low-income communities, as well as supporting residents’ mobility and access to ‘high resource’ neighborhoods.

Mobility
Access to public transit is of paramount importance to households affected by low-incomes and rising housing prices, especially because lower income households are often transit dependent.

Public transit should strive to link lower income persons, who are often transit dependent, to major employers where job opportunities exist. Access to employment via public transportation can reduce welfare usage and increase housing mobility, which enables residents to locate housing outside of traditionally low-income neighborhoods.

Transportation opportunities are depicted by two indices: (1) the transit trips index and (2) the low transportation cost index. The transit trips index measures how often low-income families in a neighborhood use public transportation. The index ranges from 0 to 100, with higher values indicating a higher likelihood that residents in a neighborhood utilize public transit. The low transportation cost index measures cost of transportation and proximity to public transportation by neighborhood. It too varies from 0 to 100, and higher scores point to lower transportation costs in that neighborhood.

AllTransit explores metrics that reveal the social and economic impact of transit, specifically looking at connectivity, access to jobs, and frequency of service. According to the data shown in Table E-8 and Figure E-9, Scotts Valley scored a 4.4 AllTransit performance score, illustrating a low combination of trips per week and number of jobs accessible that enable a moderate number of people to take transit to work. In total, 29,207 jobs are accessible within a 30-minute trip from Scotts Valley, and 1.42 percent of commuters use transit. Additionally, AllTransit identified the following transit related statistics for Scotts Valley:
 45.1% of jobs in Scotts Valley are located within a half-mile of transit.  44.8% of low-income households (earning less than $50,000) live within a half-mile of transit.
 1.17% of workers who commute by walking live within a half-mile of transit.  0.34% of workers who commute by bicycle live within a half-mile of transit.

By comparison, Scotts Valley scored lower than neighboring jurisdictions of Watsonville (6.1) and Santa Cruz (7.0). Overall, Scotts Valley has a lower AllTransit score than the Santa Cruz County average (4.4 in Scotts Valley and 4.8 in the County).

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Table E-8: AllTransit Index
Jurisdiction
AllTransit
Performance
Score
Transit Trips
Per Week
within ½ Mile
Jobs Accessible
within 30-
minute trip
Commuters
Who Use
Transit
Transit Routes
within ½ Mile
Scotts Valley 4.4 1,147 29,207 1.42% 3
Santa Cruz County 4.8 1,269 33,599 2.99% 6
Source: AllTransit, Transit Scores. Accessed November 29, 2022.

Figure E-9: AllTransit Performance Score (2022)
Source: AllTransit Face Sheet, 2022.

Most of Scotts Valley has poor transit accessibility, but the areas with higher concentrations of all protected characteristics exhibit higher transportation scores in the City. Residents with protected characteristics may exhibit a disproportionate need for reliable public transportation.

It is important to increase access to transportation throughout Scotts Valley to improve access for all protected classes. There is a correlation between low transit scores area and areas with RCAAs, so it is important to prevent such concentration by allocating units in areas with higher access to transportation and economic opportunities. The candidate housing sites in Appendix F show they are dispersed throughout the community with an emphasis on locating units where there is a high level of access to public services and transit. The distribution of potential units provides increased opportunities for low-income housing in areas with higher rates of low transportation access.

Census Tract 1
The AllTransit Map identified Census Tract 1 as an area with higher connectivity, access to jobs, and frequency of service. The Santa Cruz Metro service serves Census Tract 1 with various bus routes and the Cavallaro Transit Center is located in the southern portion of this tract. Scotts

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Valley Drive bisects this area and connects to Highway 17, which connects the City to the County and the San Francisco Bay Area.

Census Tract 2
Census Tract 2 has lower connectivity, access to jobs, and frequency of services as identified in the AllTransit Map (Figure E-9). There are no identified transit routes in the area. Highway 17 is located on the western boundary of this area. This area offers less services as it is predominantly single-family neighborhoods. Hence, this area has the least number of units allocated; however, it does provide for some variety of housing options at varying costs. Census Tract 2 will continue to develop through planned residential rezoning as described in this Housing Element.

Census Tract 3
The AllTransit Map identified Census Tract 3 as an area with moderate connectivity, access to jobs, and frequency of service. Similar to Census Tract 2, the Santa Cruz Metro service serves this tract with bus routes and eight stops along Mount Hermon Road. This road forms the northern boundary of the tract and connects to Scotts Valley Drive and Highway 17.

Economic and Employment Opportunities
The TCAC/HCD Opportunity Maps illustrates opportunity levels based on the following five economic factors:
 Poverty – Percent of population with income above 200 percent of federal poverty line.
 Adult Education – Percent of adults with a bachelor's degree or above.  Employment – Percent of adults aged 20-64 who are employed in the civilian labor force or in the armed forces.
 Job Proximity – Number of jobs filled by workers with less than a Bachelor of Arts degree that fall within a given radius (determined by the typical commute distance of low-wage workers in each region) of each census tract population-weighted centroid.
 Median Home Value - Value of owner-occupied units.

Figure E-10 shows economic opportunity scores for Scotts Valley and the surrounding region.

Overall, the City has a more positive economic outcome rating of 0.75 to 1 compared to the surrounding region.

When comparing economic opportunity scores to proximity to jobs (Figure E-11), Scotts Valley residents generally live near employment opportunities. Scotts Valley residents that live closer to the City limit line have further proximity to jobs than those who live in the center. However, the economic opportunity score is positive for all census tracts in the City. Overall, Scotts Valley residents have moderate access to positive economic opportunities.

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Future housing development will increase economic opportunities for existing and future residents. The candidate sites inventory includes various strategies to meet the City’s RHNA targets including plans for mixed use development at higher densities for select sites along Scotts Valley Drive and Mount Hermon Road, and in the Town Center Specific Plan Area. The Cavallero Transit Center (Metro Parcel), also located in the Town Center Specific Plan Area, will continue to provide access to transit services such as the Highway 17 Express and other routes that provide access throughout Santa Cruz County. Additionally, the candidate sites inventory includes plans for residential development within a half mile of transit and job opportunities along Scotts Valley Drive and Mount Hermon Road.

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Figure E-10: Economic Opportunity Scores
Source: California Department of Housing and Community Development – AFFH Data Viewer

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Figure E-11: Jobs Proximity Index
Source: California Department of Housing and Community Development – AFFH Data Viewer

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Education Opportunities
The TCAC/HCD Opportunity Area Maps include education data, as illustrated in Figure E-12. This data represents opportunity levels based on the following four factors:
 Math proficiency – Percentage of fourth graders who meet or exceed math proficiency standards.
 Reading proficiency – Percentage of fourth graders who meet or exceed literacy standards.
 High school graduation rates – Percentage of high school cohort that graduated on time.
 Student poverty rate – Percentage of students not receiving free or reduced-price lunch.

Figure E-12 shows educational scores for the City and the surrounding region. As shown, the City scored the highest positive education outcomes. This is consistent with the surrounding region, as the surrounding region scored most positive to second most positive education outcomes. Overall, Scotts Valley provides good opportunities for education achievement and in return Scotts Valley residents show high educational achievements and successes in achieving college degrees. Overall, future housing developments within the City will benefit from access to high levels of resources, bringing additional opportunities for existing and future residents.

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Figure E-12: Education Opportunity Scores
Source: California Department of Housing and Community Development – AFFH Data Viewer

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Census Tract 1
Census Tract 1 has a total of three schools. The following schools located in this area are the Scotts Valley High School, Vine Hill Elementary School, and the Scotts Valley Middle School, School Technology Resources, Scotts Valley Unified School District, and Baymonte Preschool.

This area provides good opportunities for education. Hence, Census Tract 1 scored the highest positive education outcomes in the TCAC/HUD Opportunity Area Maps. Development will continue along Scotts Valley Drive through the various pipeline projects and mixed-use rezones.

These developments will be in close proximity to the existing and future stock of schools.

Census Tract 2
Census Tract 2 has a variety of schools located in this area. This includes the Montessori Scotts Valley, Circle of Friends Preschool, and Baymonte Christian School. These schools are located near existing residential and future development. Parcels in between the three schools have been identified as a candidate residential rezone site. In total, 54 new units are proposed in this area. In general, new housing opportunities throughout Census Tract 2 will have access to positive levels to economic opportunities.

Census Tract 3
Census Tract 3 has only one school in the area. The Coast Redwood Montessori is located along Mount Hermon Road. Development will continue along Mount Hermon Road through pipeline projects, mixed-use rezone, and existing residential capacity strategies. These developments will be in close proximity to this school and other schools in neighboring Census Tracts 1 and 2.

Actions under Program H-3.2 address RCAAs on a City-wide level. Actions include establishing specific incentives for the development of affordable units including, but not limited to, permit streamlining and reduced fees. In general, new housing opportunities throughout the City would have access to positive levels to economic opportunities.

Environmental Health
The California Office of Environmental Health Hazard Assessment (OEHHA) developed a screening methodology to help identify California communities disproportionately burdened by multiple sources of pollution, called the California Communities Environmental Health Screening Tool (CalEnviroScreen). In addition to environmental factors (pollutant exposure, groundwater threats, toxic sites, and hazardous materials exposure) and sensitive receptors (seniors, children, persons with asthma, and low birth weight infants), CalEnviroScreen also takes into consideration socioeconomic factors. These factors include educational attainment, linguistic isolation, poverty, and unemployment. Research has shown a heightened vulnerability of people of certain ethnicities and lower socioeconomic status to environmental pollutants.

The CalEnviroScreen 4.0 Model is made up of a suite of 20 statewide indicators of pollution burden and population characteristics associated with increased vulnerability to pollution’s health effects. The model uses the following analysis and calculation to identify areas of health risk:

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 Uses a weighted scoring system to derive average pollution burden and population characteristics scores for each census tract.
 Calculates a final CalEnviroScreen score for a given census tract relative to the other tracts by multiplying the pollution burden and population characteristics components together.
 Measures the relative pollution burdens and vulnerabilities in one census tract compared to others; the score is not a measure of health risk.

Figure E-12 displays mapped results of the CalEnviroScreen 4.0 for the City and surrounding region. The City has low levels of pollution burdens. As shown on Figure E-12, Census Tract 1 reports a higher pollution burden than the other two census tracts due to a higher number of vehicles along Scotts Valley Drive, Mount Hermon Road, and Highway 17, but is still considered a low CalEnviroScreen 4.0 score. Similarly, majority of the neighboring jurisdiction show low levels of pollution burdens, which are mountainous, and sparsely populated. In general, new housing opportunities throughout the City would have access to low levels of pollution burdens.

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Figure E-12: CalEnviroScreen 4.0
Source: California Department of Housing and Community Development – AFFH Data Viewer

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4. Disproportionate Housing Need and Displacement
The analysis of disproportionate housing needs within Scotts Valley evaluated existing housing need, need of the future housing population, and units within the community at-risk of converting to market-rate.

Disproportionate housing needs refer to disparities in cost burden, overcrowding, substandard housing, and displacement risk for special needs populations in comparison to the rest of the population. Housing needs are assessed by the HUD Comprehensive Housing Affordability Strategy (CHAS), based on ACS data. Housing problems and severe housing problems include the following elements:

Housing Problems
 Incomplete kitchen facilities
 Incomplete plumbing facilities
 1+ person per room
 Cost burden greater than 30
percent
Severe Housing Problems
 Incomplete kitchen facilities
 Incomplete plumbing facilities
 1.5+ person per room
 Cost burden greater than 50
percent
Overcrowding
Table E-9a displays data for household tenure (owner vs. Renter) for the State, County, and City of Scotts Valley. Homeownership is a crucial foundation for helping families with low incomes build strength, stability, and independence. The opportunity for transition into the homebuyer’s market is important for persons and households in different communities, homeownership allows for increased stability and opportunity to age in place. As shown in Table E-9a, Scotts Valley has a higher rate of homeownership compared to the County and State.

Table E-9a: Households by Tenure, Compared by Geography, 2020 Overcrowding and Tenure City of Scotts Valley Santa Cruz County State of California Owner Households 73% 60.3% 55.3%
Renter Households 27% 39.7% 44.7%
Total Occupied Housing Units 4,779 96,275 13,103,114
Source: American Community Survey, 5-Year Estimates, 2020 Additionally, Table E-9b displays data for overcrowding in the State, County, and City over time.

Overcrowding is defined as between 1.01 and 1.5 persons per room in a household, and severe overcrowding is defined as more than 1.51 persons per room. Overcrowding often occurs when nonfamily members combine incomes to live in one household, such as college students and roommates. Overcrowding also occurs when there are not enough size appropriate housing

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options for large or multigenerational families. The City experiences a lower rate of overcrowding In comparison to the County and the State. According to the data, overcrowding occurs more frequently in renter households than in owner households. Similarly, the City of Santa Cruz showed similar rates of severely overcrowded at 0.2 percent for owners and renters.

Other nearby jurisdictions had much higher rates such as Watsonville which had overcrowded rates at 3.2 percent for owners and 9.2 percent for renters.

In Scotts Valley, owner households that are overcrowded represent 0.5 percent of all households, and overcrowded renter households represent 0.2 percent. In Scotts Valley, owner households have seen a slight increase in overall overcrowding while renter households have seen a drop in overcrowding and a slight increase in severe overcrowding since 2010. In general, new housing opportunities in census tracts 1 through 3 will help alleviate overcrowding in both owner and renter households. In particular, actions under Program H-3.1 in the Housing Plans will aid low-income households extend rental subsidies. Overall, Scotts Valley showed lower rates of overcrowding compared to the local and state rates. Both the homeowners and renters with high overpayment rates were concentrated west of Highway 17 (40 percent to 60 percent).

Table E-9b: Overcrowding Change Over Time by Geography
Overcrowding and Tenure City of Scotts Valley Santa Cruz County State of California 2010 2020 2010 2020 2010 2020
Owner Households
Overcrowded
(1.01 to 1.5 persons per room) 0.0% 0.5% 1.5% 1.7% 1.8% 1.7% Severely Overcrowded
(1.51+ persons per room) 0.0% 0.0% 0.5% 0.4% 0.5% 0.6%
Renter Households
Overcrowded
(1.01 to 1.5 persons per room) 0.8% 0.2% 2.3% 2.5% 3.5% 3.5% Severely Overcrowded
(1.51+ persons per room) 0.0% 0.4% 1.6% 2.3% 2.2% 2.4%
Source: American Community Survey, 5-Year Estimates, 2010 and 2020.

Cost Burden
Housing cost burden, or overpayment, is defined as households paying 30% or more of their gross income on housing expenses, including rent or mortgage payments and utilities. Renters are more likely to overpay for housing costs than homeowners. Housing cost burden is considered a housing need because households that overpay for housing costs may have difficulty affording other necessary expenses, such as childcare, transportation, and medical costs.

Table E-10 and E-11 shows households that experience cost burden by tenure. In Scotts Valley,

37.2 percent of all households experience cost burden. Similar to Santa Cruz County, renters

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experience higher rates of cost burdens than owners (51.8 percent to 31.4 percent in Scotts Valley).

Table E-10: Households that Experience Cost Burden by Tenure in Scotts Valley Total Number of Households
Cost burden Percentage of Households that
Experience Cost Burden >30% to < 50% > 50%
Owners Only 3,165 625 370 31.4%
Renters Only 1,255 235 415 51.8%
All Households 4,420 860 785 37.2%
Source: HUD, 2015 - 2019
Table E-11: Households that Experience Cost Burden by Tenure in Santa Cruz County Total Number of Households
Cost burden Percentage of Households that
Experience Cost Burden >30% to < 50% > 50%
Owners Only 57,560 9,855 7,660 30.4%
Renters Only 38,255 9,140 11,460 53.8%
All Households 95,820 18,995 19,120 39.8%
Source: HUD, 2015 - 2019
Table E-12 displays data for households experiencing overpayment or cost burden in the State, County, and City for the years from 2016 to 2020. Housing Cost burden has a number of consequences for a household, mainly displacement from their existing living situation creating limited access essential goods and often employment by potentially increasing commute times.

The percentage of households that experience a cost burden greater than 30 percent is lowest in the City (40.4 percent) while the County and State reported about 38 percent. The City has a higher percentage (approximately 2.6 percent and 3.6 higher than the County and State) of households that have a high-cost burden over 50 percent. There are no households within the City that didn’t have the Cost Burden data available. Increased opportunity for affordable housing and housing assistance funds help to prevent cost burden on households. Compared to the previous two tables, the housing cost burden for both owner and renter households increased from the 2015 – 2019 to 2016 – 2020 analysis (325 owner households and 35 renter households, respectively). Similarly, the owner households in Santa Cruz County experienced an increase by 535 households. However, the number of renter households dropped by 75.

Table E-12: Households by Overpayment, Compared by Geography Overpayment/Cost Burden City of Scotts Valley Santa Cruz County State of California Cost Burden > 30% 40.4% 38.2% 38.3%
Cost Burden > 50% 22.0% 19.4% 18.4%
Cost Burden Not Available 0.0% 0.9% 1.3%
Source: HUD, 2016 - 2020

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Substandard Housing
Incomplete plumbing or kitchen facilities can be used to measure substandard housing conditions. Substandard housing is defined by the U.S. Census as:
 Housing without hot and cold piped water, a flush toilet and a bathtub or shower; and
 Households with kitchen facilities that lack a sink with piped water, a range or stove or a refrigerator.

Table E-13 below shows substandard housing within Scotts Valley, Santa Cruz County, and the State of California. The City of Scotts Valley has the highest percent of occupied housing units without complete kitchen facilities when compared to the County and State.

Table E-13: Substandard Housing
Jurisdiction Total Occupied Housing
Units
Without Complete Plumbing
Facilities
Without Complete Kitchen
Facilities
Scotts Valley 4,779 0.0% 1.9%
Santa Cruz County 96,275 0.35% 1.0%
California 13,103,114 0.41% 1.2%
Source: American Community Survey, 5-Year Estimates, 2020 Table E-14 below shows the substandard housing within the City compared to Santa Cruz County and California from 2010 to 2020. The City has seen an increase in occupied housing units in all substandard housing categories, except for housing units without complete plumbing facility. The number of housing units without a complete kitchen facility rose by 74 units and no telephone service available by 37 units within ten years. Both the County and State saw a decrease in occupied housing units without complete plumbing facilities, kitchen facilities, and no telephone service.

Table E-14: Substandard Housing Over Time by Geography
Factors City of Scotts Valley Santa Cruz County State of California 2010 2020 2010 2020 2010 2020
Total Occupied Housing Units 4,297 4,779 93,802 96,275 12,392,852 13,103,114 Without Complete Plumbing
Facilities 0 0 1,018 341 67,427 5,4342
Without Complete Kitchen
Facilities 16 90 1,191 988 132,424 151,660
No telephone service
available 58 95 1,863 901 305,058 184,117
Source: American Community Survey, 5-Year Estimates, 2020 Table E-15 below displays the County’s housing stock by year built. Older housing may generally require more upkeep and regular maintenance and can cause a cost burden on both renter and

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homeowners. Units over 30 years of age are considered older and more at-risk of requiring upgrades. Majority of the County’s housing stock was built prior to 1980 (65.6 percent). These units should be considered for major rehabilitation. Majority of these units were built between 1970 to 1979 (21.7 percent). Approximately 34.4 percent of the housing stock was built after 1980 indicating a relatively newer housing stock.

Table E-15: Age of Santa Cruz County Housing Stock
Year Built Number of Occupied Housing Units Percent
2014 or later 1,038 1.0%
2010 to 2013 1,332 1.3%
2000 to 2009 8,432 8.0%
1990 to 1999 9,659 9.1%
1980 to 1989 15,918 15.0%
1970 to 1979 22,962 21.7%
1960 to 1969 15,273 14.4%
1950 to 1959 11,530 10.9%
1940 to 1949 7,607 7.2%
1939 or earlier 12,068 11.4%
Source: American Community Survey, 5-Year Estimates, 2020 Table E-16 below displays the City’s housing stock by year built. Compared to the County’s housing stock, majority of the stock housing was built after 1980 (60 percent). 40 percent of the occupied housing units were built prior to 1980 (40 percent). Majority of these units were built between 1990 to 1999 (22.1 percent).

Table E-16: Age of Scotts Valley Housing Stock
Year Built Number of Occupied Housing Units Percent
2014 or later 118 2.2%
2010 to 2013 165 3.1%
2000 to 2009 771 14.7%
1990 to 1999 1,159 22.1%
1980 to 1989 938 17.9%
1970 to 1979 1,101 21.0%
1960 to 1969 495 9.4%
1950 to 1959 235 4.5%
1940 to 1949 163 3.1%
1939 or earlier 107 2.0%
Source: American Community Survey, 5-Year Estimates, 2020 The current distribution of the age of homes in Scotts Valley also indicates that a majority of homes in the City were built prior to the 1990 Americans with Disabilities Act (ADA), which may result in a lack of accessible homes for those residents experiencing a disability. As the City’s

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existing housing stock ages, it will be rehabilitated consistent with current building regulations which could represent a barrier to some residents who have a lower or fixed income.

Displacement Risk
Displacement occurs when housing costs or neighboring conditions force current residents out and rents become so high that lower-income people are excluded from moving in. UC Berkeley’s Urban Displacement Project (UDP) states that a census tract is a sensitive community2 if the proportion of very low-income residents was above 20 percent in 2018 and the census tracts meets two of the following criteria: (1) Share of renters above 40 percent in 2018; (2) Share of Non-White population above 50 percent in 2018; (3) Share of very lowincome households (50 percent AMI or below) that are also severely rent burdened households above the county median in 2018; or (4) Nearby areas have been experiencing displacement pressures.

The potential for economic displacement risk can result from a variety of factors, including large-scale development activity, neighborhood reinvestment, infrastructure investments, and changes in local and regional employment opportunities. Economic displacement can be an inadvertent result of public and private investment, where individuals and families may not be able to keep pace with increased property values and market rental rates.

The U.C. Berkeley Urban Displacement Project developed a neighborhood change database to map neighborhood transformations and identify areas vulnerable to gentrification and displacement. This data was developed to assist local decision makers and stakeholders better plan for existing communities and provide additional resources to areas in need or at-risk of displacement and gentrification.

Figure E-13 shows the City has lower displacement risk. Overall, the City is surrounded by areas that are at lower displacement risk. Communities are considered sensitive communities if the neighborhoods with a high proportion of residents are vulnerable to displacement in the case of rising housing costs and market-based displacement pressures present in and/or near the community. Low displacement risk means that the population isn’t vulnerable to increased redevelopment and drastic shifts in housing cost.

In addition to displacement and gentrification data, the UC Berkeley Urban Displacement Project also analyzes the occurrence of anti-displacement policies, as defined below:
 Just Cause Eviction Ordinance. Just cause eviction statutes are laws that allow tenants to be evicted only for specific reasons. These “just causes” can include a failure to pay rent or violation of the lease terms.
2 Sensitive communities are vulnerable communities concerned about exacerbated displacement pressures as “sensitive communities” – place that would receive five years for community planning to guide potential up zones towards more equitable outcomes.

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 Rent Stabilization or Rent Control. Rent Control ordinances protect tenants from excessive rent increases, while allowing landlords a reasonable return on their investments. Such ordinances limit rent increase to certain percentages, but State law allows landlords to raise rents to the market rate once the unit becomes vacant.  Rent Review Board and/or Mediation. Rent review boards mediate between tenants and landlords on issues related to rent increases and encourage them to come into voluntary agreement. As mediators, the board normally does not make binding decisions.
 Mobile Home Rent Control. Mobile home rent control places specific rent increase restrictions on the land rented by mobile homeowners, or the mobile homes themselves.
 SRO (Single-Room Occupancy) Preservation. Single room occupancies, also called residential hotels, house one or two people in individual rooms. Tenants typically share bathrooms and/or kitchens. These are often considered a form of permanent residence affordable for low-income individuals. SRO Preservation Ordinances help to preserve or create new SRO units.
 Condominium Conversion Regulations. In addition to state laws regulating the conversion of multi-family rental property into condominiums, many cities have enacted condominium conversion ordinances. These impose procedural restrictions and/or substantive restrictions on the ability to convert apartment units into condominiums to protect the supply of rental housing.
 Foreclosure Assistance. Many cities and counties have local programs that assist homeowners when they are at risk of foreclosure. These programs may be funded with federal grants.
 Jobs-Housing Linkage Fee or Affordable Housing Impact/Linkage Fee. Affordable housing impact/linkage fees are charges on developers of new market-rate, residential developments. They are based on the square footage or number of units in the developments and are used to develop or preserve affordable housing.  Commercial Linkage Fee/Program. Commercial linkage fees are charged to developers per square foot of new commercial development. Revenues are used to develop or preserve affordable housing.
 Housing Trust Fund. A housing trust fund is a designated source of public funds— generated through various means—that is dedicated to creating affordable housing.  Inclusionary Zoning/Housing (Below Market Rate Housing). Inclusionary housing policies require market-rate developers of rental or for-sale housing to rent or sell a certain percentage of units at affordable prices. Some policies include a provision for developers to pay “in-lieu fees” in place of building the housing; this revenue is used to develop affordable units elsewhere.

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 Density Bonus Ordinance. Density bonuses allow developers of market-rate housing to build higher-density housing, in exchange for having a certain portion of their units offered at affordable prices. In this inventory, we only include a city as having this policy if they allow an additional density bonus beyond that mandated by the State.
 Community Land Trusts. Community land trusts are nonprofit, community-based organizations (supported by the city or county) whose mission is to provide affordable housing in perpetuity by owning land and leasing it to those who live in houses built on that land.
 First Source Hiring Ordinances. First Source hiring ordinances ensure that residents are given priority for new jobs created by municipal financing and development programs
Table E-17 identifies which of these policies the City has adopted, according to the Urban Displacement Project as specified as above. The City is at a low risk for displacement as a result of the anti-displacement policies in place. Furthermore, new housing opportunities throughout the City would not be at risk for displacement. The actions under Program H-3.2 in the Housing Plan create opportunities for increased diversity and access to a variety of affordable housing options. These actions will also help to protect the City’s existing lower-income population from possible displacement.

Table E-17: Anti-Displacement Policies
Anti-Displacement Measures Scotts Valley
Policy Measure
Just Cause Eviction Ordinance No
Rent Stabilization or Rent Control No
Rent Review Board and/or Mediation No
Mobile Home Rent Control Yes
SRO Preservation No
Condominium Conversion Regulations Yes
Foreclosure Assistance No
Jobs-Housing Linkage Fee No
Commercial Linkage Fee No
Housing Trust Fund No
Inclusionary Zoning Yes
Density Bonus Ordinance Yes
Community Land Trusts No
First Source Hiring No
Source: Urban Displacement Project, University of California Berkeley (2018), and the City of Scotts Valley.

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Figure E-13: Displacement Risk
Source: California Department of Housing and Community Development – AFFH Data Viewer

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Affordable Units at Risk of Converting to Market Rate
Jurisdictions are required by State Housing Element Law to analyze government-assisted housing that is eligible to convert from lower income to market rate housing over the next ten years. State law identifies housing assistance as a rental subsidy, mortgage subsidy or mortgage insurance to an assisted housing development. Government assisted housing may convert to market rate housing for several reasons, including expiring subsidies, mortgage repayments, or expiration of affordability restrictions. Affordable covenants help to ensure that certain housing units remain affordable for an extended period of time. Covenants help balance the housing market in a community and provide lasting affordable options to low and very low-income households. This section will provide:
 An inventory of assisted housing units that are at risk of converting to market-rate housing,
 An analysis of the costs of preserving and/or replacing these units,  Resources that could be used to preserve at-risk units,  Program efforts for preservation of at-risk housing units, and  Quantified objectives for the number of at-risk units to be preserved during the Housing Element planning period.

Table E-18 below identifies deed-restricted, assisted rental properties within Scotts Valley, of which 22 units are at-risk of converting from affordable to market-rate units between 2023 and 2033. Consistent with the requirements to analyze impacts of potential conversion of these units to market-rate units, this section provides an analysis to preserve these at-risk units. The City is committed to working with property owners and utilizing appropriate funds, as available, to review covenants set to expire for renewal.

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Table E-18: Assisted Affordable Housing and At-Risk Units in Scotts Valley Project Name Assisted
Units Type Funding Source
Agreement
Executed Term Units At-Risk
Rental Units
Acorn Court
Apartments 4 4 - 2 bed 10/20/1999 30 years – 2029 4
Bay Tree Apartments 9 8 - 2 beds
1 - 1 bed
RDA monthly
subsidy 4/7/1999 30 years – 2029 9
Brookdale 20 All studios 6/3/1987 Indefinite 0
Emerald Hill
Apartments 46
1 - 1 bed
7 - 2 bed
13 - 3 bed
1 - 4 bed

CDBG, HOME,
City 11/22/1996 55 years – 2051 0
Markell Mixed-Use
Apartments* 3 3 - 1 bed RDA monthly subsidy 7/20/2005 55 years – 2060 0 Oak Lane
Apartments 1 1 - 2 bed 11/17/2004 55 years – 2059 0
San Augustine Way
Apartments 1 1 - 2 bed Silent Second 11/20/1996 33 years - 2029 1 Rental Units At-Risk 14
For-Sale Units
Acorn Commons 6 2 - 2 bed
4 - 3 bed 3/20/2019 55 years - 2074 0
Blue Bonnet Lane 5 5 - 2 bed 11/4/2003 45 years – 2048 0 Cathy Lane Condos 8 8 - 2 bed 10/16/1996 33 years - 2029 8 Kelly Court 1 1 - 3 bed 4/16/2003 50 years - 2053 0
2 MacLeod Way 1 1 - 3 bed 5/18/2005 45 years - 2050 0
Torrey Oaks Condos 2 2 - 3 bed 4/24/2003 33 years - 2036 0 Town Center 5 4 - 4 bed
1 - 3 bed RDA 11/7/2012 45 years - 2057 0
The Cove 3 3 - 3 bed 5/25/2018 55 years - 2073 0
The Grove 7 7 - 3 bed Silent Second 6/28/2016 45 years - 2061 0 The Manor 1 1 - 3 bed 4/22/2015 45 years - 2060 0
The Terrace 2 2 - 3 bed 3/20/2018 45 years - 2063 0
Windward Place 2 2 - 2 bed 9/3/2003 45 years - 2048 0
Woodside 7 7 - 4 bed 6/20/2012 45 years - 2047 0
Ownership Units At-Risk 8
TOTAL AT-RISK UNITS 22
*1-bedroom units rented at studio-level rents.

Source: City of Scotts Valley, Affordable Housing Action Plan Brochure While there are many options to preserve at-risk units including providing financial incentives to property owners to extend lower income use restrictions, purchasing affordable housing units by a non-profit or public agency, or providing local subsidies to offset the difference between the affordable and market rate units, the strategy considered below, for analysis purposes, is to provide local rental subsidy to residents. Rent subsidy would provide financial assistance to residents if their affordable units converted to market-rate units. To determine the subsidy needed, fair market rents were compared to market-rate rents. Table E-19 below

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outlines an estimated monthly subsidy that would be required to preserve these at-risk units.

This analysis is not suggestion the City will provide rental subsidy, but it is used to assess the difference in cost between potential subsidy and direct replacement of lost affordable units.

The analysis in Table E-19 shows that it would cost about $1,524 annually to subsidize the at risk-units.

Table E-19: Estimated Monthly Subsidy to Preserve At-Risk Units Unit Size
Monthly Rents Number of
Units
At-Risk*
Difference Monthly
Subsidy
Annual
Subsidy Fair Market
Rents1
Market Rate
Rents 2
Efficiency $2,212 $1,900 0 - - -
1-Bedroom $2,502 $2,375 1 ($127) N/A N/A
2-Bedroom $3,293 $3,300 21 $7 $127 $1,524
3-Bedroom $4,077 $2,800 0 - - -
4-Bedroom $4,568 $3,698 0 - - -
Total $1,524
Source: HUD FY 2023 Fair Market Rent Documentation System – Santa Cruz-Watsonville, CA HUD Metro FMR Area.

Kimley-Horn and Associates Analysis.

In comparison, if the at-risk units are converted to market rate, they would need replacing with new construction. Construction cost estimates include all hard and soft cost associated with construction in addition to per unit land costs. The analysis assumes the replacement units are apartments with concrete block with steel frame buildings and parking provided on-site. Square footage estimates are based on estimated size of units to be replaced and assume housing units are developed on multi-family zoned properties. Land costs have been determined on a per unit basis. Table E-20 below estimates that approximately $3,455,863 would be required to replace the at-risk units.

Table E-20: Replacement Cost of At-Risk Units
Unit Size Cost per
Square Foot1
Average
Square Foot
per Unit2
Replacement
Cost per Unit
Number of
Units At-Risk*
Total
Replacement
Cost
Efficiency $160.35 N/A N/A - -
1-Bedroom $160.35 699 $112,084.65 1 $112,084.65
2-Bedroom $160.35 993 $159,227.55 21 $3,343,778.55
3-Bedroom $160.35 1,199 $192,259.65 - -
4-Bedroom $160.35 1,737 $278,527.95 - -
Total $3,455,863.20
Source: International Code Council – August 2022; Kimley-Horn and Associates Analysis.

A variety of programs exist to help cities acquire, replace, or subsidize at-risk affordable housing units. The following summarizes financial resources available:
 Community Development Block Grant (CDBG) - CDBG funds are awarded to cities on a formula basis for housing activities. The primary objective of the CDBG program is the development of viable communities through the provision of decent housing,

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a suitable living environment and economic opportunity for principally low- and moderate-income persons. Eligible activities include administration, fair housing, energy conservation and renewable energy sources, assistance for economic development, public facilities and improvements, and public services.  HOME Investment Partnership - Local jurisdictions can receive funds by formula from HUD to increase the supply of decent, safe, sanitary, and affordable housing to lower-income households. Eligible activities include housing acquisition, rehabilitation, development, homebuyer assistance, and rental assistance.  Section 8 Rental Assistance Program - The Section 8 Rental Assistance Program provides rental assistance payments to owners of private, market-rate units on behalf of very low-income tenants, senior citizens, disabled persons, and other individuals for securing affordable housing.
 Section 202/811 Program - Non-profit and consumer cooperatives can receive nointerest capital advances from HUD under the Section 202 Program for construction of very low-income rental housing with the availability of supportive services for seniors and persons with disabilities. These funds can be used in conjunction with Section 811 funds, which can be used to develop group homes, independent living facilities, and immediate care facilities. The capital advance funding can also provide project rental assistance for the properties developed using the funds. Eligible activities include acquisition, rehabilitation, new construction, and rental assistance.  California Housing Finance Agency (CalHFA) Multifamily Programs - CalHFA’s Multifamily Programs provide permanent financing for the acquisition, rehabilitation, and preservation of new construction of rental housing that includes affordable rents for low- and moderate-income families and individuals. One of the programs is the Preservation Loan program which provides acquisition/rehabilitation and permanent loan financing designed to preserve or increase the affordability status of existing multifamily housing projects.
 Low-Income Housing Tax Credit (LIHTC) - This program provides tax credits to individuals and corporations that invest in low-income rental housing. Tax credits are sold to those with high tax liability and proceeds are used to create housing.

Eligible activities include new construction, rehabilitation, and acquisition of properties.
 California Community Reinvestment Corporation (CCRC) - The California Community Reinvestment Corporation is a multi-family affordable housing lender whose mission is to increase the availability of affordable housing for low-income families, seniors, and residents with special needs by facilitating private capital flow from its investors for debt and equity to developers of affordable housing. Eligible activities include new construction, rehabilitation, and acquisition of properties.

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The following organizations have the experience and capacity to potentially assist in preserving future at-risk units:
 Eden Housing
 Mercy Housing
 Habitat for Humanity
 Mid-Peninsula Housing Coalition
 Housing Authority of the County of Santa Cruz
State law requires that jurisdictions establish the maximum number of units that can be preserved over the planning period. The City’s objective is to preserve the 22 affordable units at-risk of converting to market-rate units as outlined in the Housing Plan.

F A I R H O U S I N G E N F O R C E M E N T A N D O U T R E A C H

C A P A C I T Y

1. Fair Housing Enforcement and Outreach
Fair housing enforcement and outreach capacity refers to the ability of a locality and fair housing entities to disseminate information related to fair housing laws and rights and provide outreach and education to community members. Enforcement and outreach capacity also includes the ability to address compliance with fair housing laws, such as investigating complaints, obtaining remedies, and engaging in fair housing testing.

California’s Department of Fair Employment and Housing (DFEH) has statutory mandates to protect the people of California from discrimination pursuant to the California Fair Employment and Housing Act (FEHA), Ralph Civil Rights Act, and Unruh Civil Rights Act (with regards to housing). The FEHA prohibits discrimination and harassment on the basis of race, color, religion, sex (including pregnancy, childbirth, or related medical conditions), gender, gender identity, gender expression, sexual orientation, marital status, military or veteran status, national origin, ancestry, familial status, source of income, disability, and genetic information, or because another person perceives the tenant or applicant to have one or more of these characteristics.

The Unruh Civil Rights Act (Civ. Code, §51) prohibits business establishments in California from discriminating in the provision of services, accommodations, advantages, facilities and privileges to clients, patrons and customers because of their sex, race, color, religion, ancestry, national origin, disability, medical condition, genetic information, marital status, sexual orientation, citizenship, primary language, or immigration status. The Ralph Civil Rights Act (Civ.

Code, § 51.7) guarantees the right of all persons within California to be free from any violence, or intimidation by threat of violence, committed against their persons or property because of

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political affiliation, or on account of sex, race, color, religion, ancestry, national origin, disability, medical condition, genetic information, marital status, sexual orientation, citizenship, primary language, immigration status, or position in a labor dispute, or because another person perceives them to have one or more of these characteristics.

2. Fair Housing Enforcement
The Consumer Affairs and Environmental Protection Division of the District Attorney’s Office provides a variety of fair housing services. These services include:
 Telephone counseling and referrals to other agencies that deal with consumer issues;
 Landlord- tenant information, assistance and mediation efforts; and  Information and referral service to other agencies.

Approximately 100 to 200 calls are received each month from tenants, landlords, and roommates. The most common complaints are about security deposits, evictions, and/or housing conditions. The Office primarily provides legal information and self-help advice to inquiring clients and makes referrals to other legal and nonprofit agencies. Because of a persistent lack of funding, the Office does not have a database that can provide more detailed information on the type of calls received. One volunteer is responsible for handling the majority of landlord-tenant questions and referrals; no paid staff members are involved in this effort.

The City refers fair housing discrimination activities to the Civil Rights Department (CRD); previously referred to as the State Department of Fair Employment and Housing. Violations of the anti-discrimination law include:
 Refusal to sell, rent, or lease rooms, apartments, condos or houses to protected individuals;
 Refusal to negotiate for the sale, rental, or lease of housing;  Representation that a housing accommodation is not available for inspection, sale, or rental when it is in fact available;
 Denial of a home loan or homeowner’s insurance;
 Cancellation or termination of a sale or rental agreement;  Policies, practices, terms, or conditions that result in unequal access to housing or housing-related services;
 Offering inferior terms, conditions, privileges, facilities or services in connection with the housing accommodation;
 Sexual harassment involving unwanted sexual advances or requiring sexual favors for housing rights or privileges;

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 Refusal to permit, at a disabled tenant’s expense, reasonable modifications when necessary to accommodate a disability;
 Refusal to make reasonable accommodations in housing rules, policies, practices, or services where necessary to afford a disabled person equal opportunity to use and enjoy a dwelling;
 Retaliation against someone filing a complaint; and,
 Overly restrictive rules limiting the activities of daily life for families with children, including where children are allowed to play.

Fair Housing and Civil Rights Findings, Lawsuits, Enforcement, Settlements, or Judgements The City’s Planning Department works closely with residents, property owners, outside agencies, and other City departments to resolve health, safety, and public nuisance conditions that adversely affect the quality of life in Scotts Valley. The Planning Department is primarily responsible for enforcing the provisions of the Zoning Ordinance and the Building Department is primarily responsible for enforcing the provisions of the California Building Codes, the Scotts Valley Municipal Code, and the Uniform Housing Code.

In 2021, the City processed 20 code enforcement complaints relating to housing. These complaints addressed issues relating to property maintenance, access to heating and air conditioning, construction without building permits, and complete kitchen and plumbing facilities. None of the code enforcement complaints received by the City related to fair housing issues. During the 5th Cycle Housing Element, the City was not involved in any fair housing lawsuits, settlements, or judgments.

Fair Housing Laws
According to the AFFH data viewer, two fair housing, enforcement, and outreach (FHEO) cases were submitted from January 2013 to November 2022. The cases were submitted based on disability, national origin, and retaliation. The City processed less cases than the City of Capitola but more than the City of Santa Cruz, which has no recorded cases. Nevertheless, the City is in compliance with existing fair housing laws and there have been no findings against the City of Scotts Valley from the U.S. Department of Housing and Urban Development (HUD), Office of Fair Housing and Equal Opportunity (FHEO), or from the CRD.

The following lists State and local fair housing laws and specifies how the City complies:

State
 California Fair Employment and Housing Act (FEHA): The City continues to implement and update programs that promote fair and equal access to housing. The City also continues to review standards and requirements that may constrain equal access to housing and the development of affordable housing.

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 Government Code Section 65008: The City continues to implement programs that encourage affordable housing development. The City’s Affordable Housing Committee provides guidance to new residential development regarding affordability and meets on an as-needed basis. Additionally, programs are included in the Housing Plan to ensure compliance with the State’s requirement for fair review of affordable housing development.
 Government Code Section 8899.50: The City’s website contains a general complaint report form that can be used to submit complaints regarding fair housing issues. The City continues to implement programs and actions in compliance with State law that affirmatively furthers fair housing. As detailed in the Housing Plan, the City administers programs to promote equal housing access and affordable resources.  Government Code Section 11135: The City promotes state-funded programs, such as the First-Time Homebuyer Loan Program, on the City’s website and at the public counter. The City continues to implement and encourages programs that promote full and equal access to all programs and activities.
 Density Bonus Law: The City has an adopted Density Bonus Ordinance consistent with State Density Bonus Law. The City provides incentives to developers to produce affordable housing to very low-income households, low-income households, moderate-income households, senior citizens, transitional foster youth, disabled veterans, and persons experiencing homelessness, as well as for the development of childcare facilities.
 No-Net-Loss Law: The Housing Plan and Appendix F detail how the City maintains adequate sites to meet its RHNA.
 Excessive Subdivision Standards: The City continues to update its Zoning Ordinance, waive certain development fees, and offer incentive packages to facilitate housing development.
 Housing Element Law: The City identifies and includes an analysis of existing and projected housing needs and a statement of goals, policies, quantified objectives, financial resources, and scheduled programs.

Local
 Local Ordinances: The City has multiple local ordinances (Chapter 9.16 - Mobile Home Park Rent Stabilization; Chapter 17.60 - Requests for Reasonable Accommodation) that establish procedures for rezoning, development permit processing, affordable housing fees, and other programs that encourage fair housing practices.
 Chapter 2: Housing Plan details the City’s goals, policies, programs, and objectives.

The City addresses the need to provide additional housing opportunities, remove

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constraints to affordable housing, improve the existing housing stock, and provide equal opportunities for current and future residents of Scotts Valley.

C O N T R I B U T I N G F A C T O R S
Locally derived knowledge and contributing factors were developed in response to community participation in outreach events and through analysis conducted in Affirmatively Furthering Fair Housing development and analysis of sites inventory and feedback and comments on the draft Housing Element’s data, analysis, and policy program. The contributing factors listed below were identified as creating, perpetuating, and/or increasing the severity of fair housing issues in Scotts Valley:
 Housing Conditions and Senior Housing. Affordability, design, and discrimination limit the supply of housing for persons with disabilities. Amendments to the Fair Housing Act, as well as State law, require ground-floor units of new multi-family construction with more than four units to be accessible to persons with disabilities.

Units built prior to 1989 are not required to be accessible to persons with disabilities.
 Access to Affordable Housing. Due to its proximity to Silicon Valley, the City’s average income is the highest in the County and median home prices are also high.

This may lead to lower income households being priced out. When paired with lower affordable housing options, lower income households and local employees may not be able to find adequate housing within the City and have to commute in from other jurisdictions.
 Housing Disbursement.

The City has two RCAAs, indicating a concentration of affluent White populations.

RCAAs may indicate historical exclusionary practices continue to affect the Scotts Valley community. More integrated, mixed-income housing is required to dissolve RCAAs.
 Location and Type of Affordable Housing. Scotts Valley community is generally affluent and has high housing costs. The manufacturing and education services, health care, social assistance sectors represent 33.7 percent of the City’s total workforce but earns less than the City’s median income. Persons working in these sectors, as well as other sectors earning below the City’s median income, may not have the opportunity to live in the City in which they work and must commute long distances.
 Housing Conditions and Senior Housing. Affordability, design, and discrimination limit the supply of housing for persons for persons with disabilities, Amendments to the Fair Housing Act, as well as State law, require ground-floor units of new multifamily construction with more than four units to be accessible to persons with

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disabilities. Units built prior to 1989 are not required to be accessible to persons with disabilities. As shown in Table E-16, 57.9 percent of the City’s housing stock was built prior to 1989. Aging housing units may have housing problems and require significant rehabilitation which may be costly for seniors and low-income residents.

The City recognizes the fair housing issues that exist within the community and is committed to reducing barriers to affordable housing to all persons. The Housing Plan includes goals, policies, and programs to increase housing opportunities, remove constraints to affordable housing, improve the existing housing stock, and provide equal opportunities for all current and future residents of Scotts Valley.

H I S T O R I C B A C K G R O U N D
Scotts Valley is located in north Santa Cruz County and bisected by Highway 17. The City is located just a short distance from Monterey Bay, nestled in the redwoods on the upland slope of the Santa Cruz Mountains. Scotts Valley was incorporated in 1966. The first Land Use Plan was adopted in 1968 and the first Scotts Valley General Plan was adopted in 1972. It has been updated three times subsequently in 1978, 1986, and 1994. The City is currently in the process of updating its General Plan.

Residential uses include both single family and multiple-family residences, apartments, condominiums and mobile home parks. Residential development has been guided by the topography, geology, vegetative cover, access to transportation and services facilities. Larger lots with low densities have been developed in the hillsides with single family detached homes in the Whispering Pines, Granite Creek and Hacienda/Cadillac neighborhoods. Higher densities are located on the valley floor close to local shopping, public services and transportation facilities such as the neighborhoods on Blake Lane, Jolley Way, Trammel Way, and along Bean Creek Road. Mobile home parks within the City include Montevalle, Spring Lakes and Mountain Brook are deed-restricted adult communities. The City’s development patterns have remained largely unchanged over the course of the City’s history, with single family residential uses developed along hillsides and higher densities residential/commercial/industrial uses located along the valley floor off Scotts Valley Drive and Mount Hermon Road.

As noted in the Land Use Element, 88 percent of the existing housing stock in Scotts Valley was constructed between 1960 and 2000. Most of these homes (56 percent) are detached, single family homes. The other 44 percent of the housing stock is made up of apartments and condominiums, attached houses, and mobile homes. A majority of Scotts Valley is designated for residential uses (72 percent), allowing for single and multiple-family residences, apartments, and condominiums. About 4 percent of land area is designated commercial, allowing for mixed use residential projects.

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1. Affordable Housing
In 1994, the City adopted an Inclusionary Housing Ordinance in the Redevelopment Project Area (RDA). The ordinance requires all residential developments in the redevelopment project area (RDA boundary) consisting of one or more units to contribute to the provision of housing units for very-low-, low-, and moderate-income households in the City. All new residential developments with six or fewer units are required to pay an in-lieu fee. All new residential developments with seven or more units can meet the affordable housing requirement by setting aside 15 percent of the total housing unit approved for very low-, low-, and moderateincome households on site or off-site in very limited circumstances. The inclusionary housing ordinance has generated the creation of 84 affordable rental units and 50 affordable ownership units. The in-lieu fees for smaller housing projects have allowed for the provision of subsidies for smaller housing projects.

A F F H S U M M A R Y
Beginning of 2023, the City conducted a variety of outreach and engagement efforts to connect with as many members of the community as possible regarding the 6th Cycle Housing Element update. Community engagements were meant to notify, educate, and engage the public. The City outreached to special needs groups and organizations and groups representing or serving special needs groups. In response to the feedback received and solicited, the City drafted a Policy Plan and Sites Inventory that responded to the unique needs of Scotts Valley residents in an effort to affirmatively further fair housing.

During community engagement events, the public expressed the need for affordable housing due to concerns about the high cost of housing and lack of housing choices. The public also expressed the need for a variety of housing types and multi-family housing such as townhomes, duplexes/triplexes, and housing for Persons with Disabilities. In direct response to the public’s desire for more affordable housing options, the City drafted policies and programs to encourage housing variety and affordability in Chapter 2 of this Housing Element.

In furtherance of fair housing, the City solicited feedback from populations that have historically experienced lower opportunities, lower incomes, and lower resources. Through a variety of community workshops and during the public comment period, the City engages residents in these areas to understand their unique needs and desires. In response to correspondence with affected groups in Scotts Valley, the City drafted a plan that will increase access to opportunities and resources for individuals who experience reduced access currently. The city’s response to each submitted letter are shown in Table G-1 of Appendix G.

A comprehensive summary of the above AFFH analysis is provided within this section for each of the City’s two planning areas, as shown in Figure E-14 below. The Planning Areas are: Scotts

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Valley Corridor and South Gateway. The planning areas provide a comparative analysis of how its RHNA and housing policies are affirmatively furthering fair housing. The Planning Areas were not established for zoning or regulatory purposes, but rather to assess the equitable distribution of RHNA sites throughout the City. The goal of the analysis is to ensure that the City’s housing policy approach is not intentionally worsening existing fair housing challenges.

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Figure E-14: City of Scotts Valley Planning Areas

Mt. Hermon Road Area
Scotts Valley Drive Area

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1. Scotts Valley Drive Area
Local Context
The Scotts Valley Drive Area is comprised of a variety of land uses with commercial parcels along Scotts Valley Drive, industrial parcels, and medium density residential parcels. Open space and rural residential parcels surround the main corridor along the City boundaries to the north, east, and west. Scotts Valley Drive is the main corridor that bisects the city parallel to Highway 17 and leads towards the city’s downtown area to the south. The commercial parcels are resident and visitor-serving that accommodate the needs of the neighborhood such as hotels/motels, auto repair shops, gas stations, home goods stores, banks, hair salons, and a variety of retail businesses.

AFFH Findings
The City identified commercial and industrial sites to rezone for residential and mixed uses as a prime solution to provide resident-serving needs and resources within proximity to housing.

According to TCAC Opportunity Maps, the planning area has high resource and lower displacement risks census tracts. The area experiences moderate to lower diversity rates and low disability rates. There is an RCAA census tract in the southern portion of the planning area south of Highway 17. The median income reduced in the northern portion of the planning area north of Scotts Valley Drive from 2014 to 2019; however, the area is still considered moderate income and a majority of the planning area consists of above moderate-income households earning greater than $125,000. There are high rates of positive economic outcomes with high rates of closest job proximity along the commercial corridor. CalEnviroScreen shows census tracts with lower scores of pollution burden throughout the planning area. As shown in Table E21 below, about a third of the sites are located in a high resource area, including 234 lower income sites. Mixed income housing projects are sited in this area to encourage pedestrian activity and potentially reduce infrastructure constraints by siting units in closer proximity to resources.

Candidate Sites
Candidate sites in the Scotts Valley Drive Area are predominantly located along Scotts Valley RoadDrive, where a majority of the commercial sites will be rezoned to allow residential and mixed uses. A few rezone parcels are scattered to the north in existing neighborhoods throughout the planning area. The planning area includes more challenging topographic conditions (as shown in Figure E-15) to the north and south of Highway 17. The analysis does not include projected ADUs, which account for approximately 2 percent of the total sites inventory, and is further discussed in Appendix F.

Table E-21: Scotts Valley Corridor Candidate Site Units by Affordability Lower Income Moderate- Income Above Moderate- Income TOTAL Units 234 60 310 604
Percent of Total Units 10.8% 2.8% 14.3% 27.9%

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Figure E-15: City of Scotts Valley Slopes Map

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2. Mt. Hermon Road Area
Local Context
The Mt. Hermon Road Area is located in the City’s Southwestern area and consists of areas north and south of Mount Hermon Road. The planning area is predominantly made up of single-family neighborhoods, with open space, and commercial uses along Mount Hermon Road. The area also includes the Kings Valley shopping center, Scotts Valley’s top shopping destination. The Mt. Hermon Road was identified as a prime location for its location to major streets and variety of land uses. North of Mount Hermon Road is a variety of commercial, open space, and professional uses. This area serves as the main service area to the city and surrounding area. South of Mount Hermon Road is a wide variety of low- and high-density residential areas. The area offers close access to a number of restaurants, auto repair shops, gymnasiums, and grocery stores. The main arterial roads that bisect through this planning area include Scotts Valley Drive, Highway 17, and Mount Hermon Road. These roads offer access to jobs and connectivity to the County and San Francisco Bay Area.

AFFH Findings
The City identified existing residential capacity in the area to encourage residential development on vacant and non-vacant sites. The Town Center Specific Plan area is also located in the planning area. The City is working with developers to redevelop City-owned parcels and privately owned retail developments as a key strategy to provide affordable housing within the planning area. According to TCAC Opportunity Maps, the area contains census tracts with highest resource and lower displacement risk. The area experiences low disability rates, lower diversity rates, mostly white, and is an RCAA area. From 2014 to 2019, the median income among block groups remained relatively the same with some decrease but remain wealthy with moderate- to above-moderate median income households. The area has a higher positive economic outcomes score, moderate to low job proximity index, and low pollution burden scores.

Table E-22 shows that about a third of the lower-income units are provided within the area.

The availability of lower income units throughout the City aims to spread its availability throughout the City and reduce impacts of concentrated income levels. Additionally, it is important to note that 100 percent affordable housing projects are sited on vacant and nonvacant commercial/retail parcels in the Town Center Specific Plan area along Mount Hermon Road. This strategy aims to address the planning area’s low job proximity index and site affordable units in close proximity to resident-serving uses, public transit, and community resources in a generally affluent census tract. Furthermore, siting mixed use developments in the area complements the Specific Plan’s intent to integrate residential and commercial/retail uses while taking advantage of the proximity to civic uses and transit centers. As mentioned in the Contributing Factors section above, poor housing conditions and access to affordable housing are described as some of the key contributors to fair housing issues.

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Candidate Sites
The identified candidate sites are located along Mount Hermon Road, where the majority of the existing commercial and open space sites will be rezoned into mixed use and residential uses. A bulk of the candidate sites are located east of Scotts Valley Road. A few sites scattered in areas identified as open space west of the planning area. As shown in Table E-22, there are 1,521 units located in the Mt. Hermon Road Area. The analysis does not include projected ADUs, which account for approximately 2 percent of the total sites inventory and is further discussed in Appendix F.

Table E-22: Mt. Hermon Road Candidate Site Units by Affordability Lower Income Moderate-Income Above Moderate-Income TOTAL Units 638 96 786 1,521
Percent of Total Units 29.5% 4.4% 36.3% 70.2%

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The Housing Element is required to identify a
Candidate Sites Inventory by income category to
meet the City’s Regional Housing Needs Allocation
(RHNA). The sites identified within the 2023-2031
Housing Element represent the City’s ability to
accommodate housing at the designated income
levels during the 6th Cycle. All sites have been
assessed for the highest potential for residential
development during the Planning Period.

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A . C A N D I D A T E S I T E S I N V E N T O R Y
The Housing Element is required to identify sites by income category to meet the City’s Regional Housing Needs Allocation (RHNA). The sites identified within the 2023-2031 Housing Element represent the City’s ability to accommodate housing at the designated income levels during the 2023-2031 planning period. For the 6th Cycle, the City of Scotts Valley was allocated a total of 1,220 units to plan for, as detailed in Table F-1.

Table F-1: City of Scotts Valley 6th Cycle RHNA by Income Category Income Category Percent of Area Median Income
(AMI) RHNA
Very Low-Income 0-50% AMI 392
Low-Income 51-80% AMI 257
Moderate-Income 81-120% AMI 154
Above Moderate-Income >120% AMI 417
TOTAL RHNA 1,220
*The Santa Cruz County AMI is $119,300 for a family of four, according to 2022 HCD Income Limits.

Table F-2 shows the City’s ability to accommodate the 6th Cycle RHNA by income category through a variety of methods, including those listed below. Figure F-1 illustrates the location of the sites throughout Scotts Valley.
 Current capacity on residentially-zoned sites;
 Projects currently in the City’s review pipeline;
 Accessory dwelling unit (ADU) projections; and,
 Rezone strategies to accommodate the remaining RHNA.

Table F-2: 6th Cycle RHNA Sites Inventory Analysis
Strategies Very Low
Income
Low
Income
Moderate
Income
Above
Moderate
Income
TOTAL
6 th Cycle RHNA 392 257 154 417 1,220
Existing Residential Capacity 11 6 66 83
Pipeline Projects 51 13 353 417
Projected ADUs 24 12 4 40
Town Center Specific Plan 427 39 191 657
Rezones
Residential 65 14 89 168
Mixed Use 318 84 399 801
TOTAL 896 168 1,102 2,166
Percent Over RHNA 38% 9% 164% 78%

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Figure F-1: 6th Cycle Housing Element Sites Inventory – All Sites

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1. General Plan Consistency
The City’s current General Plan was adopted in 1994. As of May 2023, efforts are currently underway to update the General Plan. The City will ensure that other Elements of the General Plan are consistent with the Housing Element as they are updated.

2. Zoning Consistency
Candidate housing sites identified in this Appendix propose rezoning options. The City’s Zoning Code will, as such, be amended accordingly. The Chapter 2: Housing Plan establishes programs and actions to guide these rezones.

3. CEQA Streamlining
Candidate housing sites that are consistent with the existing zoning and the City’s objective design standards are exempt from review under the California Environmental Quality Act (CEQA). Candidate housing sites that require discretionary review (e.g., a rezone) are subject to CEQA and will be evaluated concurrent with each development application.

4. Access to Transportation
Current transportation programs, services, and improvements support the proposed units of this 6th Cycle Housing Element. The City will continue to work with Santa Cruz METRO to ensure that new residential developments are adequately served.

5. Infrastructure and Public Services Capacity
Candidate housing sites identified in this Appendix are located in areas that adequately served by existing and planned infrastructure and public services. The Policy Plan establishes requirements for adequate infrastructure and public services for developments that include affordable housing units.

6. Affirmatively Furthering Fair Housing (AFFH)
The City has identified candidate sites to accommodate future housing growth based on existing access to community resources, services, and public transportation, while also considering the availability of land, developer interest, and general likelihood the sites would develop residential uses over the next eight years. Appendix E details how the Candidate Sites Inventory affirmatively furthers fair housing.

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B . P R O J E C T E D D E V E L O P M E N T

1. Accessory Dwelling Units (ADUs)
The State Department of Housing and Community Development (HCD) has supported a strategy to estimate future ADU development based on the average number of ADUs permitted in recent years. Table F-3 displays the City’s past performance in permitting ADUs from 2018 through 2022. The average over these five years is 3; however, year-by-year, the applications submitted and approved have been on the rise. The City has reviewed 4 ADU building permit applications and has responded to 13 ADU inquiries from January to September of 2023.

The City recognizes ADUs as a cost-effective way of not only adding to the City housing stock, but also to provide affordable units in existing single-family neighborhoods. As such, a program is included in the Housing Plan with the goal of bolstering ADU development throughout the 6th Cycle. The program includes the following actions:
 Modify the current “Secondary Dwelling Unit Program” from the 5th Cycle Housing Element to comply with changes in State law regarding ADUs. This will include updating the City’s “Secondary Dwelling Unit” Ordinance in compliance with State ADU laws. Submit revised ordinance to HCD in compliance with State law.  Establish and promote permit-ready ADU plans to minimize design costs, expedite permit processing, and provide development certainty.
 Establish and maintain an ADU Manual guiding applicants through the permitting and construction of an ADU.
 Establish and maintain an ADU webpage informing the community on ADU related codes, processes, and incentives.
 Establish an incentive program for deed-restricted affordable ADUs such as waived permitting fees and/or priority processing.
 Establish an ADU monitoring program, and biennially review, for development trends for potential gaps. If gaps are identified, implement changes within one year.

Given these efforts and recent inquiries on ADU development, the City has applied a development projection of 150 percent of the average ADUs permitted since 2018. The City anticipates a total of 40 new ADUs between 2024 and 2031, with approximately 5 ADUs permitted annually. A percentage of ADUs are projected to develop at affordable rates based on the Using ADUs to Satisfy RHNA Technical Memo produced by the Association of Bay Area Governments (ABAG). ABAG’s analysis consisted of the following steps:

1. Calculated maximum rent limits for RHNA income categories for one-person and two-person households by county;

2. Surveyed rents for ADUs in the ABAG region;

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3. Used survey data to determine proportion of ADUs within each income category; and,

4. Created assumptions of how many persons will occupy each ADU.

While Scotts Valley is located in the Association of Monterey Bay Area Governments (AMBAG), this methodology from ABAG is comparable and can be used for projection purposes. Table F-4 shows the ADU projections by income category. As established in the Housing Plan’s ADU program, the City will establish an ADU monitoring program and will assess trends biennially; if gaps are identified between what is anticipated in this analysis and what is built, the City will implement changes within a year.

Table F-3: ADU Projections
Year ADUs Permitted
2018 1
2019 2
2020 1
2021 6
2022 4
2023 N/A
Projection Years 5 units per year
2024 5
2025 5
2026 5
2027 5
2028 5
2029 5
2030 5
2031 5
PROJECTED TOTAL 40
Table F-4: ADU Projections
Income Category Percentage Units
Low- and Very Low-Income 60% 24
Moderate-Income 30% 12
Above Moderate-Income 10% 4
TOTAL 40
Per Government Code section 65852.2, ADUs must be permitted in any residential or mixed-use zone – any zone where residential uses are permitted by-right or by conditional use.

Additionally, State law states that local governments cannot preclude the creation of ADUs, and any limitations should be accompanied by detailed findings of fact explain why ADU limitations are required and consistent with these factors. The City has a total of 3,856 parcels which currently permit residential uses (C-S, C-SC, OS, P, R-1-10, R-1-20, R-1-40, R-H, R-M-6, R-M-8, RMT-5, R-R-2.5, R-VH) – this adds up to a total of 2,621.21 acres. As such, the City has an

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abundance of sites with potential to accommodate the total projected 40 ADUs over the following eight years.

2. Pipeline Projects
HCD guidance states that residential projects that are in review, approved, permitted, or receive a certificate of occupancy after the beginning of the RHNA period may be credited towards meetings the RHNA. Table F-5 provides a list of current pipeline projects (only projects with proposed affordable units are listed for the purposes of this analysis). The projects are also illustrated in Figure F-2. Projects listed do not have any known constraints or barriers which may hold-up or delay the entitlement and/or permitting process. As such, these sites are included for their anticipated development in the planning period.

Table F-5: Pipeline Projects
Pipeline
Project Acreage Net Units Lower Moderate Above Moderate Erba
Lane
(APN:
022-481-
18)

0.77 10 1 1 8
Currently a vacant parking lot near residential neighborhoods. Proposed 10-unit single-family development/duets. Project entitlements included a Planned Development Zoning Permit, Land Division, Design Review, and Environmental Review. The project includes deed restricted affordable units as required by the City’s 15% Inclusionary Ordinance. The City Council approved the project June 16, 2021, and granted a two year a time extension on June 21, 2023. Next steps include submitting a Final Map for adoption by the City Council. Once the Final Map is adopted, the applicant can submit for grading and building permits. The City continues to work with the developer on post-entitlement coordination efforts by providing technical assistance on the Final Map submission and grading/building permit submission processes.

Oak
Creek
Park
(APN:
022-162-
76)

3.56 52 6 2 44
Currently vacant parcel proposing a mixed-use development with 52 units and 25,000 square-feet of commercial space. Project entitlements included a General Plan Amendment, Zoning Change with a Planned Development Zoning Overlay, Minor Land Division, Design Review Permit and Environmental Review. The project was approved by the City Council on December 7, 2022. The project includes deed restricted affordable units as required by the City’s 15% Inclusionary Ordinance, including three very low-income units, two low income, and two moderate income units.

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Pipeline
Project Acreage Net Units Lower Moderate Above Moderate Next steps include submitting a Final Map for adoption by the City Council. Once the Final Map is adopted, the applicant can submit for grading and building permits. The City continues to work with the developer on post-entitlement coordination efforts by providing technical assistance on the Final Map submission and grading/building permit submission processes.

Valley
Gardens
(APNs:
021-231-
07, 021-
221-02,
021-231-
08, 021-
231-04,
021-231-
02)

18.36 171 25 0 144
The parcels currently include an old, unused, golf course. The mixed-use project currently proposes 171 units with 12,000 square-feet of commercial space. Project entitlements include a General Plan Amendment, Zone Change, Planned Development, Tentative Parcel Map, Design Review, Use Permit, and Environmental Review. While the project is not located in the City’s Inclusionary Ordinance Boundary, the developer has proposed 15% of the total units be deed restricted as affordable. The project is currently under review by City staff. The project requires review by the Planning Commission who will forward to the City Council for approval of project entitlements. The City issued a Notice of Preparation to prepare an Environmental Impact Report and is in the process of completing an EIR for the project. City staff continue to meet with the developer on a frequent basis to provide technical assistance on City requirements and entitlements.

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Pipeline
Project Acreage Net Units Lower Moderate Above Moderate La
Madrona
–
Gateway
South
(APN:
021-141-
05)

17.6 184 19 10 155
Currently vacant parcel zoned open space proposing a mixed-use development with 184 units, a hotel, and 3,500 square-feet of commercial space. Project entitlements include General Plan Amendment, Zone Change, Planned Development, Specific Plan Amendment, Use Permit, Design Review, Minor Land Division, and Environmental Review. While the project is not located in the City’s Inclusionary Ordinance Boundary, the developer has proposed 15% of the total units be deed restricted affordable. The City issued a Notice of Preparation for an Environmental Impact Report and is in the process of completing an EIR for the project. The project requires review by the Planning Commission and approval of entitlements by the City Council. City staff continue to meet with the developer to provide technical assistance on City requirements and entitlements.

PIPELINE PROJECTS UNIT
TOTAL: 417 51 13 353

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Figure F-2: Pipeline Projects

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C . E X I S T I N G R E S I D E N T I A L C A P A C I T Y

1. Residentially Zoned Land
The City has identified five parcels currently zoned for residential with the capacity to accommodate additional housing units. Four of these sites are considered underutilized and have a land value that is higher than the improvement value; the sites also have common ownership and are considered due to their ability to consolidate to develop a multi-family housing development with affordable units. The fifth parcel is a mostly vacant site with a structure previously used for a flooring company that is no longer open.

The projecting out development of these sites, the City assumes a realistic capacity of 70 percent. This capacity assumption is based on past projects density yields in comparison to what the site could permit at the maximum. On average, a sample size of six past projects noted an average density yield of 83 percent (with the highest yield at 123 percent and lowest yield at 67 percent each). Additionally, this capacity assumption accounts for development standards, sets a reduction to avoid a no-net loss scenario, and follow HCD guidance.

These conservative assumptions result in a development capacity of 72 potential units – 12 affordable to lower income households, 2 to moderate-income households, and 58 to above moderate-income households.

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Figure F-3: Existing Residential Capacity

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2. Town Center Specific Plan
The Town Center Specific Plan is designed to be the heart of the city and offer convenient proximity between commercial and residential uses near community resources. The Plan area encompasses approximately 58 acres, including 15 acres of vacant land, and is surrounded by a mix of retail and civic uses. The Plan area is made up of multiple parcels with multiple property owners. Currently, the Specific Plan allows residential uses within the Town Center Specific Plan Area. In order to develop residential within that area, a Planned Development permit is required. However, residential uses are limited to certain areas and permitted densities are vague. The Specific Plan will be amended to increase the amount of residential uses allowed in the Specific Plan Area, to apply objective design standards to those uses to facilitate development and to designate additional areas for residential development. Subsequent to the adoption of the Specific Plan Amendment, necessary rezonings or zoning code amendments will be completed in accordance with the terms of the Specific Plan. It is anticipated that the Specific Plan Amendment will be adopted by December 2025 and the associated zoning changes will be implemented by December 2026. The City intends to sell the City owned properties in accordance with the requirements of the Surplus Lands Act and issue RFPs to interested developers.

Soil contamination has previously been an impediment to development; however, it is in the process of being eliminated and will not continue to pose a constraint to residential development during the planning cycle. The City is currently in contract with Weber Hayes to remediate the surface soil contamination on the effected City-owned properties. In addition, the City of Santa Cruz is expected to enter into a similar agreement with Weber Hayes on the parcels they own within Town Center. The surface soil remediation is expected to be completed by December 2023 (the remediation efforts have begun as of October 2023). An additional impediment to the development of the Town Center has been the amount of residential uses permitted under the Specific Plan. During prior attempts to develop the area, many developers expressed a need for additional residential development in order to ensure a successful project.

This amendment will allow increased density of residential development in the Specific Plan Area.

Programs H-1.1 and H-1.10 in the Chapter 2 Housing Plan establish the actions and timelines the City commits to regarding the development of Town Center.

Historically, project applications have been submitted for the Plan, but development was not successful. Interest in developing the Town Center area has increased over recent years. Figure F-4 shows new developments within the Plan area.

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Figure F-4: Town Center Specific Plan – Recent Developments As part of the candidate housing sites analysis, the City has identified three City-owned parcels, one METRO-owned parcel (the transit center), and one privately-owned parcel part of the Kings Village Shopping Center. The goal in identifying the City-owned parcels is to directly ensure affordable housing development – the City will coordinate the development of the parcels with affordable housing developers. Regarding the METRO- and privately-owned parcel, the City will coordinate with both to facilitate and promote affordable housing development. Table F-6 provides details on each parcel identified. The City intends to sell the City-owned parcels to a developer for a mixed use project in accordance with the Surplus Lands Act once the Specific Plan Amendment and Rezonings are complete. This is anticipated to occur by December 2027.

New Faultline
Brewing Company
New Starbucks Coffee
New Theatre and
renovated City
Library

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Table F-6: Town Center Specific Plan
Town
Center SP
Parcels
Acreage Density Realistic
Capacity Net Units Lower Moderate Above Moderate
022-721-06 2 40 80% 64 64 0 0
This vacant, City-owned parcel currently covers the Skypark Dog Park and the Scotts Valley Pump Track, as well as part of the Skypark Skate Park parking lot. The City anticipates developing the property in coordination with an affordable housing developer to create a fully-affordable housing development centrally located near public transit, community resource, and open space.
022-212-19 1.07 40 80% 32 32 0 0
This vacant, City-owned parcel is adjacent to the Scotts Valley Public Library and the new theatre. The City anticipates developing the property in coordination with an affordable housing developer to create a fullyaffordable housing development centrally located near public transit, community resource, and open space. 022-601-01 2.9 40 80% 92 92 0 0
This non-vacant, City-owned parcel is adjacent to the post office and vacant land, and it is currently being used for trailer storage. The City anticipates developing the property in coordination with an affordable housing developer to create a fully-affordable housing development centrally located near public transit, community resource, and open space.

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Town
Center SP
Parcels
Acreage Density Realistic
Capacity Net Units Lower Moderate Above Moderate
022-212-16 2.77 40 80% 86 86 0 0
This parcel contains the METRO Cavallero transit center and the Scotts Valley Park and Ride center. The City has been in discussions with METRO about converting the site to affordable residential units with workforce components. Redevelopment of the site would result in parking being moved underground or provided through a parking structure. This would allow for Transit-Oriented Development (TOD) to occur in partnership with the transit center. As mentioned above, the area offers much for community resources, open space, and commercial needs.
022-601-18 13.69 40 80% 383 153 39 191
This parcel contains the Kings Village shopping center and is owned by the Ow family. The center includes a Goodwill Thrift Store, CineLux, Nob Hill Foods, Ace Hardware, UPS Store, Walgreens, various restaurant, smaller retail stores, and surface parking. The site has been identified as a candidate site with the vision of

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Town
Center SP
Parcels
Acreage Density Realistic
Capacity Net Units Lower Moderate Above Moderate
redeveloping the northern portion of the sites into residential uses. While a large site, the City’s Zoning Ordinance does not require parcelization to redevelop the site with affordable housing. The Specific Plan and Zoning Ordinance allow for mixed use development. Additionally, a program is included In the Housing Plan for the City to facilitate redevelopment of the property. Development is anticipated to include a mix of affordable and market rate units.

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D . R E Z O N E S T R A T E G I E S
The City cannot fully accommodate the entirety of its RHNA through existing capacity. As such, two rezone strategies have been identified to expand the City’s existing mixed-use zoning on identified sites and rezone particular parcels to accommodate high density residential development.

The intent of these rezones are to create additional residential development opportunities along Scotts Valley Drive and Mount Hermon Road – in areas that provide convenient access to community resources and public transportation, and in areas that have development interest.

The City of Scotts Valley covers a small 4.61 square-miles in the Santa Cruz Mountains with steep hillsides and creeks. As such, adequate land suitable for higher density developments are minimal and result in more feasible sites requiring redevelopment of existing parcels. The following sections detail the City’s plan to accommodate the remaining RHNA.

1. Residential Rezones
The City has identified six parcels totaling 4.23 acres to be rezoned to allow high density residential at an expected density of 40 dwelling units per acre. In total, the parcels identified for rezoning have potential to accommodate 65 very low- and low-income units, 14 moderateincome units, and 89 above moderate-income units. Projected development of these sites, the City assumes a realistic capacity of 80 percent. This capacity assumption is based on past projects density yields in comparison to what the site could permit at the maximum. On average, a sample size of six past projects noted an average density yield of 83 percent (with the highest yield at 123 percent and lowest yield at 67 percent each); see Table C-13b in Appendix C for a comprehensive list of recent development examples. Additionally, this capacity assumption accounts for development standards, sets a reduction to avoid a no-net loss scenario, and follow HCD guidance.

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Figure F-5: Residential Rezones

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2. Mixed-Use Rezones
The City currently allows for mixed-use developments with a maximum residential component of 50 percent. The City has identified 29 parcels totaling 36.6 acres to be rezoned to allow for higher density, mixed-use residential at an expected density of up to 40 dwelling units per acre and a commercial requirement lowered down to 30 percent. The City assumes a realistic capacity of 70 percent on these sites to account for the commercial component. This capacity assumption is based on past projects density yields in comparison to what the site could permit at the maximum. On average, a sample size of six past projects noted an average density yield of 83 percent (with the highest yield at 123 percent and lowest yield at 67 percent each); see Table C-13b in Appendix C for a comprehensive list of recent development examples.

Parcels identified for mixed-use rezoning have potential to accommodate 318 very low- and low-income units1, 84 moderate-income units, and 399 above moderate-income units.

These sites were identified for a variety of reasons, including being considered underutilized (the land value exceeds the development value), property owner/developer stated interest, potential for lot consolidation with adjacent parcels, and/or the site was in an appropriate location in comparison to community resources.

Increasing the residential components of these sites will create additional opportunities for the properties to develop. Property owners along Scotts Valley Drive voiced interest in developing residential uses along the corridor and also noted the current 50 percent residential maximum was too low and restrictive to allow for worthwhile development. Specifically, it was noted that residential development is a key component for the financing of commercial development in mixed use projects, with an increase in residential development potential and a decrease in the commercial requirements needed for worthwhile development. During the 5th Cycle, the only solely commercial project reviewed in approved in the City was The Hangar development off Mount Hermon Road. More recently, the development trends along Scotts Valley Drive have typically included a mixed use approach to providing in-fill housing opportunities. Given the size of Scotts Valley and the importance of its two main corridors (Scotts Valley Drive and Mount Hermon Road), the City believes it remains important to allow for commercial development to benefit existing neighborhoods. As such, increasing the density and allowable residential percentage was considered the most appropriate solution.

Figure F-5 below maps the mixed-use rezone areas in the City. 1 A total of 49 percent of lower income units identified to meet the RHNA are located on mixed-use sites.

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Figure F-5: Mixed-use Rezones

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E . A D E Q U A C Y O F S I T E S

1. Availability of Water, Sewer, and Dry utilities
The City has existing and planned water, sewer, and dry utilities that can accommodate potential residential development identified for the 2023-2031 Housing Element. More information on utilities is provided in Appendix C.

Each candidate housing site has been evaluated to ensure there is adequate access to utility services and connections, including water, sewer, and dry utilities. Each site is situated with a direct connection to a public street that has the appropriate water and sewer mains and other infrastructure services.

2. Larger and Smaller Parcels
AB 1397 identifies parcels measuring between half-an-acre and 10 acres to be appropriate for the development of affordable housing. Parcels that are less than half-an-acre (“smaller”) or above 10 acres (“larger”) are not deemed adequate to accommodate lower income housing units unless past performance shows a tendency for affordable housing projects to develop on these types of parcels. The candidate sites inventory includes affordable units on sites that fall outside the size requirements.

Smaller Parcels
A total of 15 smaller parcels have been identified with assumed potential to develop lower income units. These sites were identified as they are adjacent to other candidate sites – the candidate sites inventory identifies which parcels could be consolidated – and have shared access. Additionally, some parcels that are located next to one another are under common ownership – facilitating their consolidation. These small sites may be consolidated into a parcel greater than 0.5 acres allowing for the development of a higher density residential project. The Housing Plan includes a program to facilitate lot consolidation for these parcels. Program H-2.8 facilitates the development of lots that are less than a half-an-acre in size for the development of affordable housing development. Through this program, the City shall establish and implement this program to facilitate lot consolidation for these parcels, as well as adopt and promote incentives for the development of these smaller sites.

Larger Parcels
A total of two parcels have been identified with assumed potential to develop lower income units. One of these parcels includes the Lockhart Gulch storage center. This site covers a total of

12.05 acres; however, only 4 acres are developable as the parcel has split zoning and topography make residential development impossible. The City would not require any subdivisions to facilitate development of this site as the portion of the site that is not

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developable is zoned as Open-Space (OS). As such, the parcel has a realistic development capacity of approximately 33 percent and is not proposing to develop low-income units on a site that is 10 acres or greater in size. The second parcel is the Kings Village Shopping Center.

The property is currently zoned in the Town Center Specific Plan to allow for mixed-use residential development and does not require any subdivisions to facilitate its development.

The Housing Plan includes a program to facilitate development of these two larger sites (Program 2.6). As the list of pipeline project shows, the City is currently reviewing two projects on sites that are over 10 acres (18.36 and 17.6 acres, respectively). As such, the City is able to show development interest in these types of parcels.

3. City-Owned Parcels
Three parcels identified in the candidate site inventory are owned by the City of Scotts Valley.

All three of these parcels are part of the Town Center Specific Plan and have been identified at fully affordable assumptions. The City anticipates selling the properties to affordable housing developers to create opportunity for fully affordable housing projects. In total, these Cityowned parcels would allow for 188 total affordable units over 5.97 acres. The City will comply with the Surplus Lands Act.

4. Vacant Parcels
A total of 6 vacant parcels have been identifies as part of the candidate sites inventory with potential to accommodate 70 lower income units. This represents 10.8 percent of the lower income RHNA for Scotts Valley.

5. Non-Vacant Parcels
The City has identified 43 non-vacant parcels. These sites were identified for a variety of reasons including property owner and developer interest, underutilized uses, and appropriateness of the site location in relation to other uses and community resources.

Lease Analysis
Existing lease agreements on infill and non-vacant parcels may present potential impediments that may prevent residential development, particularly affordable residential development, within the planning period. The City made diligent efforts to review existing lease terms in evaluating the uses on non-vacant parcels; however, the City does not have access to private party lease agreements or other contractual agreement amongst private parties. While the City does not have access to lease structures, only sites that showed characteristics indicating they are likely to redevelop within the planning period were included. This includes sites that are considered underutilized and have not had recent structural improvements. Sites with property owner interest were also included.

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Likelihood of Non-Residential Development
During and prior to the 6th Cycle Housing Element Update, the City has experienced an increase in development applications and inquiries focusing on solely residential redevelopment projects or seeking to increase residential capacity. As noted in Appendix G – Community Engagement, the development community has expressed interest in increased residential development with a lower commercial square footage requirement for mixed use projects than currently required by the City’s General Plan and Zoning Ordinance. As noted in Program H-1.1, Mixed Use Rezones will be eligible for a reduced commercial square footage requirement (from 50 percent to 30 percent of total project square footage) and an increase in allowable residential square footage (from 50 percent to 70 percent of total project square footage). Out of the six recent development projects discussed in Appendix C, two of the development projects involved were mixed use projects which included commercial and residential uses (Oak Creek Park and The Cove). In order to increase the residential density in those projects, the Oak Creek Park and The Cove entitlements included Zoning Amendment and Zoning Change requests to allow for additional residential development on site. Additionally, the City of Scotts Valley has only seen one solely commercial development project during the last Housing Element Cycle. The Hangar project within the Town Center Specific Plan Area involved the construction of a drive-through facility and a multi-tenant commercial building.

The EIR for the Town Center Specific Plan (2008) analyzed 300 dwelling units and 310,000 square feet of commercial space, emphasizing commercial development versus residential development. Despite this, numerous responses to requests for proposals (RFPs) between 2012 and 2018 revised this mix, emphasizing residential development over commercial development.

At least two of the proposals submitted included approximately 27,000 square feet of commercial space instead of the previously contemplated 310, 000 square feet.

The City’s assumptions for increased residential development are based on current market conditions, developer feedback, and past development trends proving that non-residential development is unlikely and will not pose a constraint to the development of residential uses.

Redevelopment Factors
Given the size, location, and topography of the City, opportunities for development are limited.

As such, the City has identified a greater percent of non-vacant sites to be rezoned and redeveloped throughout the planning period. These parcels were identified for a number of factors listed below. The candidate sites inventory refers to this list to further detail the likelihood of redevelopment.

1. Land value is greater than the improvement value
77 percent of non-vacant sites have land values that exceed the improvement values.

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2. Existing structure was built prior to 1990 (it was built over 30 years ago) 95 percent of non-vacant sites have structures built at least 30 years ago, with the majority being well over 30 years.

3. Existing uses do not include housing units
51 percent of non-vacant sites have no existing units.

4. City-owned
5 percent of non-vacant sites are City-owned.

5. Development interest from a housing developer and/or property owner 9 percent of non-vacant sites have stated developer or property owner interest.

All but four of 43 total parcels have at least two identified redevelopment factors and 17 have at least three. Sites listed in the inventory were individually assessed for their likelihood to redevelop but also for their suitability to include residential units. This considers their location in comparison to neighboring uses, access to the two corridors that run through Scotts Valley, walkability potential to community and commercial resources and services, as well as parcel size and shape.

Furthermore, and as stated above, the City is very limited due to its topography. Figure F-6 shows that the City is located in a small valley and entirely encircled by steep slopes. The figure begins at 15 percent but ahead of that are smaller slopes that may still make development impossible or difficult, particularly for higher density residential projects. Given these limitations, the City must rely heavily on non-vacant parcels, while still ensure adequate opportunities for commercial and employment resources for residents and community amenities.

The Housing Plan includes programs to further support and facilitate the development of nonvacant sites, as well as programs which include development incentives which may be applied to non-vacant sites. These all include:
 Program H-1.11: Non-Vacant Sites Development
 Program H-1.2: By-Right Development Program
 Program H-1.3: Sites Inventory Monitoring Program
 Program H-1.6: Removal of Residential Development Constraints  Program H-1.7: Mixed-Use Development
 Program H-1.8: Facilitation of Affordable Housing Development  Program H-2.6: Development of Large Lots
 Program H-2.8: Lot Consolidation
 Program H-3.10: Density Bonus Ordinance

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Figure F-6: City of Scotts Valley Slopes Map

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6. 5
th and 4th Cycle Housing Element Parcels
State law limits a jurisdiction’s ability to re-use sites from the prior RHNA cycle. Vacant sites identified in the last two Housing Element cycles and non-vacant sites identified in the last Housing Element cycle may not be counted towards the lower income RHNA unless the sites are zones at the “default density” of 20 dwelling units per acre and the sites allow residential use by-right for housing developments in which at least 20 percent of the units are affordable to lower income households. A “by-right” use in this case refers to permitted residential development which does not require a conditional use permit, planned unit development permit, or any other discretionary local government review or approval.

A total of ten parcels were identified in this 6th Cycle inventory which were also identified in the 4 th and 5th Cycles. Two of these sites are pipeline projects, three are City-owned parcels in the Town Center Specific Plan area, and five are considered existing residential capacity parcels.

The Housing Plan includes a program to facilitate the appropriate rezones and permit “by-right” development of these sites (Program H-1.2). The program meets the standards established in AB 1398 and 1397 which states the State law on rezone properties and “by-right” Development.

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Table F-8: Scotts Valley 6th Cycle Candidate Sites
APNS Address Property Owner Acreage Zoning GPLU Vacancy Existing Units
Realistic
Capacity
Expected
Density
Potential Units 4
th/5th
Cycle Existing Use and Additional Information Total Low Mod. Above Mod.

Existing Residential Capacity
021-321-04 27 Mt Hermon Rd Coast 1031
Exchange Inc

2.03 R-VH Very
High
NonVacant 1 70% 20 28 4 2 22 Yes This site is developed with a single-family dwelling unit. The site is considered underutilized, the land value exceeds the
improvement value of the single-family dwelling unit on the parcel. Approximately 70% of the lot is vacant. This parcel is adjacent to other residential units/residentially zoned parcels.

Redevelopment Factors: 1,2
022-151-03 78 Mt Hermon Rd 1 Jaeger Theodore L
& Garnet L H/W Jt

1.12 R-VH Very
High
NonVacant 2 70% 20 15 2 1 12 Yes This site is developed with five dwelling units. This site is considered underutilized, the land value exceeds the
improvement value of the residential structures on the parcel.

Approximately 70% of the lot is vacant. This parcel is adjacent to other residential units/residentially zoned parcels enabling the possibility of consolidation and can feasible be redeveloped into higher intensity residential use.

Redevelopment Factors: 1, 2
022-151-04 68 Mt Hermon Rd Donato Jamie
Quinn

0.57 R-M-8 Med
High
NonVacant 2 70% 7 2 0 0 2 Yes This site is developed with two dwelling units. This site is considered underutilized, the land value exceeds the
improvement value of the residential structures on the parcel.

Approximately 70% of the lot is vacant. This parcel is adjacent to other residential units/residentially zoned parcels enabling the possibility of consolidation and can feasibly be redeveloped into higher intensity residential use.

Redevelopment Factors: 1, 2
022-151-05 58 Mt Hermon Rd Ward Jonathan Z 1.69 R-VH Very High
NonVacant 1 70% 20 23 3 2 18 Yes This site is developed with a single-family dwelling unit. The site is considered underutilized, the land value exceeds the
improvement value of the residential structures on the parcel.

Approximately 80% of the lot is vacant. This parcel is adjacent to other residential units/residentially zoned parcels enabling the possibility of consolidation and can feasibly be redeveloped into higher intensity residential use.

Redevelopment Factors: 1, 2
022-151-11 3535 Glen Canyon
Rd
Green Valley
Corporation

1.11 R-VH Very
High
NonVacant 1 70% 20 15 2 1 12 Yes This is developed with a single-family dwelling unit. The site is considered underutilized, the land value exceeds the
improvement value of the residential structures on the parcel.

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APNS Address Property Owner Acreage Zoning GPLU Vacancy Existing Units
Realistic
Capacity
Expected
Density
Potential Units 4
th/5th
Cycle Existing Use and Additional Information Total Low Mod. Above Mod.

Approximately 90% of the lot is vacant. This parcel is adjacent to other residential units/residentially zoned parcels enabling the possibility of consolidation and can feasibly be redeveloped into higher intensity residential use.

Redevelopment Factors: 1, 2
Pipeline Projects
022-481-18,
022-481-22
- SV Housing LLC 0.77 R-H High Vacant - - - 10 1 1 8 Yes Currently vacant land near residential neighborhoods. Proposed 10-unit single-family development/duets. Project entitlements included a Planned Development Zoning Permit, Land Division, Design Review, and Environmental Review. The project includes deed restricted affordable units as required by the City’s 15% Inclusionary Ordinance. The City Council approved the project June 16, 2021, and granted a two year a time extension on June 21, 2023. Next steps include submitting a Final Map for adoption by the City Council. Once the Final Map is adopted, the applicant can submit for grading and building permits.
022-162-76 3640 Glen Canyon
Rd
NMSBPCSLDHB 3.56 C-S C-S Vacant - - - 52 6 2 44 Yes Currently vacant parcel proposing a mixed-use development with 52 units and 25,000 square-feet of commercial space. Project entitlements included a General Plan Amendment, Zoning Change with a Planned Development Zoning Overlay, Minor Land Division, Design Review Permit and Environmental Review. The project was approved by the City Council on December 7, 2022. The project includes deed restricted affordable units as required by the City’s 15% Inclusionary Ordinance, including three very lowincome units, two low income, and two moderate income units.

The applicant can submit for grading and building permits once a Final Map is reviewed by the City Council.
021-231-07,
021-231-02,
021-231-04,
021-231-08,
021-221-02
263 Mt Hermon Rd Valley Gardens
Golf Course

18.36 C-P C-P NonVacant - - - 171 25 0 146 - The parcels currently include an old, unused, golf course. The mixed-use project currently proposes 171 units with 12,000 square-feet of commercial space. Project entitlements include a General Plan Amendment, Zone Change, Planned Development, Tentative Parcel Map, Design Review, Use Permit, and
Environmental Review. While the project is not located in the City’s Inclusionary Ordinance Boundary, the developer has proposed 15% of the total units be deed restricted as affordable.

The project is currently under review by City staff. The project requires review by the Planning Commission who will forward to the City Council for approval of project entitlements. The City

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APNS Address Property Owner Acreage Zoning GPLU Vacancy Existing Units
Realistic
Capacity
Expected
Density
Potential Units 4
th/5th
Cycle Existing Use and Additional Information Total Low Mod. Above Mod.
issued a Notice of Preparation to prepare an Environmental Impact Report and is in the process of completing an EIR for the project.
021-141-05 - Le Garden House
LLC

17.60 C-S C-P Vacant - - - 184 19 10 155 - Currently vacant parcel zoned open space proposing a mixed-use development with 184 units, a hotel, and 3,500 square-feet of commercial space. Project entitlements include General Plan Amendment, Zone Change, Planned Development, Specific Plan Amendment, Use Permit, Design Review, Minor Land Division, and Environmental Review. While the project is not located in the City’s Inclusionary Ordinance Boundary, the developer has proposed 15% of the total units be deed restricted affordable.

The City issued a Notice of Preparation for an Environmental Impact Report and is in the process of completing an EIR for the project. The project requires review by the Planning Commission and approval of entitlements by the City Council.

Town Center Specific Plan
022-721-06 - Scotts Valley City
Of

2.00 C-S C-S NonVacant - 80% 40 64 64 0 0 Yes This City-owned parcel currently covers the Skypark Dog Park and the Scotts Valley Pump Track, as well as part of the Skypark Skate Park parking lot. The City anticipates developing the property in coordination with an affordable housing developer to create a fully-affordable housing development centrally located near public transit, community resource, and open space.

Redevelopment Factors: 1, 2, 3, 4
022-212-19 209 Bean Creek Rd Scotts Valley City
Of

1.07 C-S C-S Vacant - 80% 40 32 32 0 0 Yes This vacant City-owned parcel is adjacent to the Scotts Valley Public Library and the new theatre. The City anticipates developing the property in coordination with an affordable housing developer to create a fully-affordable housing
development centrally located near public transit, community resource, and open space.
022-601-01 - City Of Scotts
Valley

2.90 C-S C-S NonVacant - 80% 40 92 92 0 0 Yes This nonvacant, City-owned parcel is adjacent to the post office and vacant land, and it is currently being used for trailer storage.

The City anticipates developing the property in coordination with an affordable housing developer to create a fully-affordable housing development centrally located near public transit, community resource, and open space.

Redevelopment Factors: 1, 2, 3, 4

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APNS Address Property Owner Acreage Zoning GPLU Vacancy Existing Units
Realistic
Capacity
Expected
Density
Potential Units 4
th/5th
Cycle Existing Use and Additional Information Total Low Mod. Above Mod.
022-212-16 - Santa Cruz
Metropolitan
Transit District
Etal

2.77 P P NonVacant - 80% 40 86 86 0 0 - This parcel contains the METRO Cavallero transit center and the Scotts Valley Park and Ride center. The City has been in discussions with METRO about converting the site to affordable residential units with workforce components. Redevelopment of the site would result in parking being moved underground or provided through a parking structure. This would allow for Transit-Oriented Development (TOD) to occur in partnership with the transit center. As mentioned above, the area offers the opportunity to locate fully affordable housing development near community resources, open space, and commercial areas.

Redevelopment Factors: 1, 2, 3, 5
022-601-18 216 Mt Hermon Rd
A
Ow David L
Trustee Etal

13.69 C-SC C-SC NonVacant - 70% 40 383 153 39 191 - This parcel contains the Kings Village shopping center and is owned by the Ow family. The center includes a Goodwill Thrift Store, CineLux, Nob Hill Foods, Ace Hardware, UPS Store, Walgreens, various restaurant, smaller retail stores, and surface parking. The site has been identified as a candidate site with the vision of redeveloping the northern portion of the sites into residential uses. While a large site, the City’s Zoning Ordinance does not require parcelization to redevelop the site with affordable housing. The Specific Plan and Zoning Ordinance allow for mixed use development. Additionally, a program is included In the Housing Plan for the City to facilitate redevelopment of the property. Development is anticipated to include a mix of affordable and market rate units.

Redevelopment Factors: 2, 3
Rezones – Residential
024-152-30,
024-152-25,
024-152-27,
024-152-28,
024-152-29
- Bergman Marlyn J 1.32 R-1-10 Medium NonVacant 1 80% 40 43 17 4 22 - Four of the parcels are vacant with one parcel (024-152-25) is developed with single family dwelling unit. The parcels are located in a single family neighborhood. The five parcels are under common ownership and the property owner has expressed interest in consolidating the lots to allow for higher density residential development.

Redevelopment Factors: 1, 2, 3 (applicable to 4 parcels), 5 022-491-24 4556 Scotts Valley
Dr A
Shaffer Wayne &
Jo H/W Cp Rs As
Tc Etal

1.11 C-S C-S NonVacant 8 80% 40 35 14 3 18 - The site is currently developed with 8 residential dwelling units.

The structures were built in the 1940s to 1960s. The parcel is adjacent to other candidate sites in the 6th Cycle and adjacent to a site that is under common ownership. This enables the possibility of consolidation and can be feasibly redeveloped into a

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APNS Address Property Owner Acreage Zoning GPLU Vacancy Existing Units
Realistic
Capacity
Expected
Density
Potential Units 4
th/5th
Cycle Existing Use and Additional Information Total Low Mod. Above Mod.
higher intensity residential use. Property will be rezoned to allow for 100% residential development, up from the currently allowed 50% residential development.

Redevelopment Factors: 1, 2
022-491-23 4600 Scotts Valley
Dr
Shaffer Wayne &
Jo H/W Cp Rs As
Tc Etal

0.75 C-S C-S Vacant - 80% 40 24 9 2 13 - The site is currently vacant. The site is considered underutilized, the land value exceeds the improvement value. This parcel is also adjacent to other candidate sites in the 6th Cycle and adjacent to a site that is under common ownership. This enables the possibility of consolidation and can feasibly be redeveloped into higher intensity residential use. Property will be rezoned to allow for 100% residential development, up from the currently allowed 50% residential development.

Redevelopment Factors: 1, 2
022-491-12 4602 Scotts Valley
Dr 1
San Lorenzo
Homes LLC

0.56 C-S C-S NonVacant 8 80% 40 17 6 1 10 - The site is developed with two existing apartment buildings with a total of 8 units. The buildings were building in the 1940s and 1980s. Approximately 60% of the lot is vacant and majority of it is dedicated to surface parking. The site is considered underutilized, the land value exceeds the improvement value of the structures on the parcel. This parcel is also adjacent to other candidate sites in the 6th Cycle, enabling the possibility of consolidation and can feasibly be redeveloped into higher intensity residential use.

Property will be rezoned to allow for 100% residential
development, up from the currently allowed 50% residential development.

Redevelopment Factors: 1, 2
022-481-06 4425 Scotts Valley
Dr
Bowers Robert
Howard & Janice
Kathleen

0.89 C-S C-S NonVacant - 80% 40 28 11 2 15 - The site is currently developed as a landscaping materials yard.

The parcel is considered underutilized as the land value exceeds the improvement value of the yard. The parcel is adjacent to other residential uses, enabling the possibility of consolidation and can feasibly be redeveloped into a higher intensity residential use. Property will be rezoned to allow for 100% residential development, up from the currently allowed 50% residential development.

Redevelopment Factors: 1, 2, 3
022-031-14 5311 Scotts Valley
Dr
Bladat LLC 0.67 C-S C-S NonVacant - 80% 40 21 8 2 11 - The site is developed with a prefabricated building and landscape supply center constructed in the 1950s. This site is considered

H O U S I N G
A P P E N D I X F | F - 3 3
APNS Address Property Owner Acreage Zoning GPLU Vacancy Existing Units
Realistic
Capacity
Expected
Density
Potential Units 4
th/5th
Cycle Existing Use and Additional Information Total Low Mod. Above Mod.
underutilized, the land value exceeds the improvement value of the structures on the parcel. Approximately 50% of the lot is vacant. This parcel is adjacent to other residential units enabling the possibility of consolidation and can feasibly be redeveloped into higher intensity residential use. Property will be rezoned to allow for 100% residential development, up from the currently allowed 50% residential development.

Redevelopment Factors: 1, 2, 3
Rezones – Mixed-Use
022-801-17 4404 Scotts Valley
Dr
Markell Rodney E 0.24 C-S C-S NonVacant 3 70% 40 6 2 1 2 - There is an existing two-story mixed-use building with three residential units on this parcel constructed in 2007.

Approximately 60% of the lot is vacant and majority of it is dedicated to surface parking. The site is considered underutilized, the land value exceeds the improvement value of the mixed use structure on the parcel. This parcel is also adjacent to other residential units enabling the possibility of consolidation and can feasibly be redeveloped into a higher intensity residential use.

Potential consolidation for APNs: 022-491-27, 022-801-17, 022- 491-06, 022-491-04, 022-871-01, 022-491-09
022-031-13 5297 Scotts Valley
Dr
Lee James J &
Rella S Trustees

0.33 C-S C-S NonVacant - 70% 40 8 3 1 4 - The site is developed with a commercial building and parking lot area that was constructed in the 1960s. Approximately 60% of this parcel is vacant. This parcel is adjacent to other residential units enabling the possibility of consolidation and can feasibly be redeveloped into higher intensity residential use.

Redevelopment Factors: 2
022-031-16 5271 Scotts Valley
Dr
St Philip The
Apostle Episcopal
Church In Scotts
Valley

1.20 C-S C-S NonVacant - 70% 40 33 13 3 17 - The parcel is developed with a church and parking lot. l.

Approximately 70% of the site is dedicated towards surface parking. The site is adjacent to other residential uses and other candidate sites in the 6th cycle housing element. The site can feasible redeveloped into a higher residential use.

Redevelopment Factors: 2, 3
022-031-01 5163 Scotts Valley
Dr
Bfd Holdings 1 LLC 1.01 C-S C-S NonVacant - 70% 40 28 11 3 14 - The site is developed with a commercial building with parking lot area towards the front of the site. The building was constructed in the 1960s. The site is considered underutilized as the land value exceeds the improvement value. Approximately 60% of this parcel is vacant. The property owner has expressed interest in redeveloping this site at a higher intensity residential use. The site is also adjacent to another parcel held in common ownership.

H O U S I N G
F - 3 4 | A P P E N D I X F
APNS Address Property Owner Acreage Zoning GPLU Vacancy Existing Units
Realistic
Capacity
Expected
Density
Potential Units 4
th/5th
Cycle Existing Use and Additional Information Total Low Mod. Above Mod.

This parcel can feasibly be redeveloped into higher intensity residential use.

Redevelopment Factors: 1, 2, 3, 5
022-031-09 5215 Scotts Valley
Dr A
Bfd Holdings 1 LLC 0.48 C-S C-S NonVacant
7 70% 40 13 5 1 7 - The site is development with a mixed use building with commercial spaces on the first floor and four residential units on the second floor. The building was constructed in the 1970s.

Approximately 60% of this parcel is vacant. The property owner has expressed interest in redeveloping this site at a higher intensity residential use. The site is also adjacent to another parcel held in common ownership. The parcel can feasibly be redeveloped into a higher intensity use with the adjacent parcel.

Redevelopment Factors: 2, 5
022-031-12 5275 Scotts Valley
Dr
Perry Karen A 0.20 C-S C-S NonVacant 1 70% 40 5 2 1 2 - The site is developed with a commercial building and one dwelling unit. The buildings were constructed in the 1960s. The site is considered underutilized as the land value exceeds the improvement value. Approximately 50% of this parcel is vacant.

This parcel is adjacent to another candidate site identified for the 6th Cycle enabling the possibility of consolidation. The site can feasibly be redeveloped into higher intensity residential use.

Redevelopment Factors: 1, 2
022-491-06 4408 Scotts Valley
Dr
Double-O
Developments Inc

0.24 C-S C-S NonVacant - 70% 40 6 2 1 3 - This site is currently developed as part of parking lot for a commercial office center. The site was improved as a parking lot in the 1970s. The County Assessor’s Office notes that the site is classified as vacant commercial land. The parcel is adjacent to another candidate site under common ownership, enabling the possibility of consolidation. The site can be feasible be redeveloped into higher intensity residential use.

Potential consolidation for APNs: 022-491-27, 022-801-17, 022- 491-06, 022-491-04, 022-871-01, 022-491-09
Redevelopment Factors: 1, 2, 3
022-491-04 4444 Scotts Valley
Dr
Double-O
Developments Inc

0.90 C-S C-S NonVacant - 70% 40 25 10 3 12 - The site is currently developed as a commercial office building with surface parking. The site was built in the 1970s. T The parcel is adjacent to another candidate site under common ownership, enabling the possibility of consolidation. The site can feasibly be redeveloped into higher intensity residential use.

H O U S I N G
A P P E N D I X F | F - 3 5
APNS Address Property Owner Acreage Zoning GPLU Vacancy Existing Units
Realistic
Capacity
Expected
Density
Potential Units 4
th/5th
Cycle Existing Use and Additional Information Total Low Mod. Above Mod.

Potential consolidation for APNs: 022-491-27, 022-801-17, 022- 491-06, 022-491-04, 022-871-01, 022-491-09
Redevelopment Factors: 2, 3
022-491-27 4402 Scotts Valley
Dr
Fontana Family
Investments LLC

0.49 C-S C-S NonVacant - 70% 40 13 5 1 7 - The site is currently developed as a restaurant and surface level parking. The building was constructed in the 1960s. This parcel is considered underutilized, the land value exceeds the
improvement value of the structure on this parcel. This parcel is adjacent to other candidate sites listed in the 6th Cycle enabling the possibility of consolidation and can feasibly be redeveloped into higher intensity residential use.

Potential consolidation for APNs: 022-491-27, 022-801-17, 022- 491-06, 022-491-04, 022-871-01, 022-491-09
Redevelopment Factors: 1, 2, 3
023-113-31 257 Glenwood Dr Roman Catholic
Bishop Of
Monterey

4.44 P/QP P/QP NonVacant 1 80% 40 96 38 10 48 - The site is developed with an existing church with a surface level parking lot. Approximately 70% of the site is dedicated towards surface parking with the remaining 30% undeveloped. The site can feasibly be redeveloped into a higher residential use.

Redevelopment Factors: 2
022-491-07 4548 Scotts Valley
Dr
Luzzi Adrian J
Trustee Etal

2.40 C-S C-S NonVacant 1 70% 40 67 27 7 33 - The site is developed with a single family dwelling unit. The building was constructed in the 1910s. This site is considered underutilized, the land value exceeds the improvement value of the residential unit on the parcel. Approximately 80% of the lot is vacant. This parcel is adjacent to other candidate sites listed in the 6th Cycle enabling the possibility of consolidation and can feasibly be redeveloped into higher intensity residential use.

Potential consolidation for APNs: 022-491-07 and 022-491-05 Redevelopment Factors: 1, 2
022-491-05 4446 Scotts Valley
Dr
Hoffman Edward L
Trustee Etal

0.40 C-S C-S NonVacant 1 70% 40 6 2 1 3 - The site is developed with a structure that was constructed in 1977. Approximately 70% of the lot is vacant. This parcel is underutilized, the land value exceeds the improvement value of the structure on the parcel. This parcel is adjacent to other candidate sites listed in the 6th Cycle, enabling the possibility of consolidation and can feasibly be redeveloped into higher intensity residential use.

Potential consolidation for APNs: 022-491-07 and 022-491-05 Redevelopment Factors: 1, 2
022-871-01 - Shadow Oaks
Professional

1.32 C-S C-S NonVacant - 70% 40 36 14 4 18 - The site is developed with commercial condominiums and a common parking lot area. The commercial center was developed

H O U S I N G
F - 3 6 | A P P E N D I X F
APNS Address Property Owner Acreage Zoning GPLU Vacancy Existing Units
Realistic
Capacity
Expected
Density
Potential Units 4
th/5th
Cycle Existing Use and Additional Information Total Low Mod. Above Mod.

Center Owners
Assoc
in the 1980s. Approximately 60% of the parcel is vacant. This parcel is adjacent to another candidate site enabling the possibility of consolidation and can feasibly be redeveloped into a higher intensity use.

Potential consolidation for APNs: 022-491-27, 022-801-17, 022- 491-06, 022-491-04, 022-871-01, 022-491-09
Redevelopment Factors: 1, 2, 3
022-491-09 4402 Scotts Valley
Dr
Taylor Eric T &
Elaine M

0.12 C-S C-S NonVacant - 70% 40 2 1 0 1 - The site is currently developed as common open space for the adjacent property. The parcel is adjacent to other candidate sites in the 6th Cycle and adjacent to a site that us under common ownership, enabling the possibility of consolidation and can feasibly be redeveloped into a higher intensity residential use.

Potential consolidation for APNs: 022-491-27, 022-801-17, 022- 491-06, 022-491-04, 022-871-01, 022-491-09
Redevelopment Factors: 1, 2, 3
022-491-08 4550 Scotts Valley
Dr A
Taylor Eric T &
Elaine M

1.75 C-S C-S NonVacant 3 70% 40 50 20 5 25 - The site is developed with three dwelling units. The structures were constructed in the 1930s. This site is considered
underutilized, the land value exceeds the improvement value of the residential units on the parcel. The parcel is adjacent to other candidate sites in the 6th Cycle and adjacent to a site that is under common ownership. This enables the possibility of consolidation and can feasibly be redeveloped into a higher intensity residential use.

Redevelopment Factors: 1, 2
022-072-33 4865 Scotts Valley
Dr
Franich John
Anthony & Nancy
Katherine
Trustees

0.46 C-S C-S NonVacant - 70% 40 12 5 1 6 - The site is currently developed with a commercial building that was constructed in the 1940s and modified in the 1970s. The site is considered underutilized, the land value exceeds the improvement value of the existing commercial building. Parcel has a surface parking lot and the structure takes up
approximately 40% of the property. The parcel is adjacent to other candidate sites in the 6th Cycle and adjacent to a site that is under common ownership. This enables the possibility of consolidation and can feasibly redevelop into a higher intensity residential use.

Redevelopment Factors: 2

H O U S I N G
A P P E N D I X F | F - 3 7
APNS Address Property Owner Acreage Zoning GPLU Vacancy Existing Units
Realistic
Capacity
Expected
Density
Potential Units 4
th/5th
Cycle Existing Use and Additional Information Total Low Mod. Above Mod.
022-351-13 4901 Scotts Valley
Dr
Franich John
Anthony & Nancy
Katherine

0.47 C-S C-S NonVacant - 70% 40 13 5 1 7 - The site is currently developed with a commercial building that was constructed in the 1940s. The parcel is considered
underutilized; the land value exceeds improvement value of the commercial structure. Parcel has a surface parking lot and vacant land that take up approximately 50% of the property. The parcel is adjacent to other candidate sites in the 6th Cycle and adjacent to a site that is under common ownership. This enables the possibility of consolidation and can feasibly redevelop into a higher intensity use.

Potential consolidation for APNs: 022-072-41 and 022-351-13 Redevelopment Factors: 1, 2, 3
022-072-41 4859 Scotts Valley
Dr
Ross Lawrence A R
& Ruth J

0.29 C-S C-S NonVacant - 70% 40 8 3 1 4 - The site is currently developed with a commercial building that was constructed in the 1940s. The parcel is considered
underutilized as the land value exceeds improvement value of the commercial structure. Parcel is developed with a surface level parking and structure that takes up approximately 50% of the lot.

The parcel is adjacent to other candidate sites in the 6th Cycle, enabling the possibility of consolidation and can feasibly redevelop into a higher intensity use.

Potential consolidation for APNs: 022-072-41 and 022-351-13 Redevelopment Factors: 1, 2, 3
022-231-18 90 Lockhart Gulch
Rd
Storage Depot
LLC

12.05 I-L I-L NonVacant - 33% 40 159 64 16 79 - The site is currently developed as a mini-warehouse facility and was constructed in the 1990s. The parcel has a dual zoning designation of industrial and open space. Therefore, the developable area of the site is calculated at 4.35 acres. The City does not require the parcelization of this site as the
environmentally sensitive area of the parcel is held in an open space designation which prohibits development. The parcel is adjacent to residential uses, community amenities, and can feasibly be redeveloped into a higher intensity residential use.

Redevelopment Factors: 1, 3
021-271-04 75 Mt Hermon Rd
100
Kontoudakis John
& Barbara H/W Jt

1.90 C-S C-S NonVacant - 70% 40 53 21 5 27 - The site is currently developed as a commercial shopping center and was constructed in the 1970s. This parcel is considered underutilized, land value exceeds the improvement value of the commercial structures on the parcel. The parcel is adjacent to other candidate sites in the 6th Cycle and various residential uses.

This enables the possibility of consolidation and can feasibly redevelop into a higher intensity residential use.

H O U S I N G
F - 3 8 | A P P E N D I X F
APNS Address Property Owner Acreage Zoning GPLU Vacancy Existing Units
Realistic
Capacity
Expected
Density
Potential Units 4
th/5th
Cycle Existing Use and Additional Information Total Low Mod. Above Mod.

Redevelopment Factors: 1, 2, 3
021-281-07 Lexertus LLC 0.54 C-S C-S Vacant - 70% 40 15 6 2 7 - This parcel is vacant. The parcel is considered underutilized as the land value exceeds the improvement value. The site is adjacent to other candidate sites in the 6th Cycle, various residential uses, and sites under common ownership. These factors enable
consolidation. As such, the site can feasibly redevelop into a higher intensity residential use.
021-281-08 69 Mt Hermon Rd Lexertus LLC 0.30 C-S C-S NonVacant 1 70% 40 8 3 1 4 - The site is developed with a single dwelling unit. The site is adjacent to other candidate sites in the 6th Cycle, various residential uses, and sites under common ownership. These factors enable consolidation with other sites. As such, the site can feasibly redevelop into a higher intensity residential use.

Potential consolidation for APNs: 021-281-08 and 021-281-09 Redevelopment Factors: 2
021-281-09 69 Mt Hermon Rd Lexertus LLC 0.49 C-S C-S NonVacant - 70% 40 13 5 1 7 - The parcel is developed as an outdoor storage area. The site is considered underutilized as the improvement value of the lot is less than the value of the land. The site is adjacent to other candidate sites in the 6th Cycle, various residential uses, and sites under common ownership. These factors enable consolidation with other sites. The site can feasibly be redeveloped into a higher intensity residential use.

Potential consolidation for APNs: 021-281-08 and 021-281-09 Redevelopment Factors: 1, 2, 3
021-281-15 59 Mt Hermon Rd Bei-Scott
Company LLC

0.62 C-S C-S NonVacant - 70% 40 17 7 2 8 - This site is developed with a commercial building constructed in the 1980s. The site is adjacent to other candidate sites in the 6th Cycle, various residential uses, and a site under common ownership. These factors enable consolidation with other sites.

The site can feasibly be redeveloped into a higher intensity residential use.

Potential consolidation for APNs: 021-281-15 and 021-281-14 Redevelopment Factors: 2, 3
021-281-14 57 Mt Hermon Rd Bei-Scott
Company LLC

0.44 C-S C-S NonVacant - 70% 40 12 5 1 6 - The site is developed with a commercial building constructed in the 1970s. This site is considered underutilized, the land value exceeds the improvement value of the residential structures on the parcel. Approximately 60% of the lot is vacant. The site is adjacent to other candidate sites in the 6th Cycle, various

H O U S I N G
A P P E N D I X F | F - 3 9
APNS Address Property Owner Acreage Zoning GPLU Vacancy Existing Units
Realistic
Capacity
Expected
Density
Potential Units 4
th/5th
Cycle Existing Use and Additional Information Total Low Mod. Above Mod.
residential uses, and a site under common ownership. These factors enable consolidation with other sites. The site can feasibly be redeveloped into a higher intensity residential use.

Potential consolidation for APNs: 021-281-15 and 021-281-14 Redevelopment Factors: 1, 2
022-571-02 2 Bean Creek Rd Se-Camp Evers LLC 0.55 C-S C-S NonVacant 1 70% 40 15 6 2 7 - The site is developed with a single family residential dwelling unit that was constructed in the 1920s. The structure is in need of rehabilitation. The site is considered underutilized, the land value exceeds the value of the improvement value of the residential structure on the parcel. Approximately 70% of the parcel is vacant. The site is adjacent to other candidate sites in the 6th Cycle and sites under common ownership. These factors enable consolidation with other sites. The site can feasibly be redeveloped into a higher intensity residential use.

Redevelopment Factors: 1, 2
022-571-03 50 Mt Hermon Rd Se-Camp Evers LLC 0.98 C-S C-S NonVacant - 70% 40 27 11 3 13 - The site is developed with multiple commercial buildings that were constructed in the 1960s. This site is considered
underutilized, the land value exceeds the improvement value of the residential structures on the parcel. Approximately 50% of the parcel is vacant. The site is adjacent to other candidate sites in the 6th Cycle and sites under common ownership. These factors enable consolidation with other sites. The site can feasibly be redeveloped into a higher intensity residential use.

Redevelopment Factors: 1, 2, 3
022-571-05 3101 Scotts Valley
Dr
Se-Camp Evers LLC 1.49 C-S C-S NonVacant - 70% 40 41 16 4 21 - The site is developed with multiple commercial buildings that were constructed in the 1960s. This site is considered
underutilized, the land value exceeds the improvement value of the residential structures on the parcel. Approximately 50% of the parcel is vacant. The site is adjacent to other candidate sites in the 6th Cycle and sites under common ownership. These factors enable consolidation with other sites. The site can feasibly be redeveloped into a higher intensity residential use.

Redevelopment Factors: 1, 2, 3
022-571-01 6 Bean Creek Rd Se-Camp Evers LLC 0.55 C-S C-S NonVacant 1 70% 40 15 6 2 7 - The site is developed with a single family residential dwelling unit that was constructed in the 1930s. The structure is in need of rehabilitation. The site is considered underutilized, the land value exceeds the value of the improvement value of the residential structure on the parcel. Approximately 70% of the parcel is

H O U S I N G
F - 4 0 | A P P E N D I X F
APNS Address Property Owner Acreage Zoning GPLU Vacancy Existing Units
Realistic
Capacity
Expected
Density
Potential Units 4
th/5th
Cycle Existing Use and Additional Information Total Low Mod. Above Mod.
vacant. The site is adjacent to other candidate sites in the 6th Cycle and sites under common ownership. These factors enable consolidation with other sites. The site can feasibly be redeveloped into a higher intensity residential use.

Additionally, the site is market as a potential sandhill habitat; however, this is not considered a constraint to residential development as the City has a history of successful residential development on such parcels which has not resulted in prolonged CEQA review or entitlement. More analysis is provided in Appendix C.

Redevelopment Factors: 1, 2

HOUSING
Section 65583 of the Government Code states, “local
government shall make diligent effort to achieve
public participation of all economic segments of the
community in the development of the housing
element, and the program shall describe this effort.”
Meaningful community participation is also required
in connection with the City’s Assessment of Fair
Housing (AF). As such, a Summary of Community
Engagement is included within this Appendix.

HOUSING
G - 2 | APPENDIX G

SUMMARY OF COMMUNITY ENGAGEMENT
Beginning of 2023, the City conducted a variety of outreach and engagement efforts detailed in this Appendix. As required by government Code Section 65585 (b)(2), all written comments regarding the Housing Element made by the public have been provided to each member of the City Council.

1. Community Workshop #1
On January 26th, 2023, the City held its first virtual community workshop to introduce the Housing Element update process and provide details on how the community could stay engaged through adoption and certification. The workshop and presentation were made available in both English and Spanish, and the recordings for both are available on the City’s webpage. The workshop received a total of 30 attendees.

Participants were able to
provide thoughts and input in
real-time through live polling
activities and a Q&A. Feedback
received noted the high cost of
housing in Scotts Valley and the
lack of housing choices.

Additionally, participants
shared that the high cost of
rent and property costs makes
it too expensive to live in Scotts
Valley.

When it came down to the
selection of housing types,
workshop participants noted a
greater need for affordable
housing units and multi-family
housing. As shown below,
Townhomes, Duplex/Triplex,
and Housing for Persons with
Disabilities were also tied as a
need in housing types within
the City.

Lastly, workshop participants were asked about what they valued about Scotts Valley’s existing neighborhoods. They emphasized the importance of schools, walkability, proximity of resources, open space, parks, and low crime.

HOUSING
APPENDIX G | G - 3

2. Community Workshop #2
On May 30th, 2023, the City held a second virtual community workshop to inform the community of the Public Review Draft Housing Element, provide details on strategies to address RHNA, and solicit input and feedback. The presentation was made available in Spanish on the Housing Element Update webpage. The workshop received a total of 19 attendees.

In conjunction with the release of the Public Review Draft on May 19, 2023, the City also released an online Feedback Form to collect responses on the Draft. Workshop attendees received guidance on submitting responses through the form and contacting Staff for more indepth comments.

3. Joint City Council and Planning Commission Study Sessions On April 5th, 2023, Staff presented to City Council, Planning Commission, and members of the public during a joint Study Session. The presentation provided introductory information on the Housing Element Update process, details on the City’s RHNA allocation, and strategies for addressing the 6th Cycle RHNA. The Study Session was organized to solicit input and recommendations from Planning Commission, City Council, and members of the public.

Recordings of the meeting is available on the Housing Element Update webpage.

On June 28th, 2023, Staff presented to City Council, Planning Commission, and members of the public during a second joint Study Session. The presentation provided information on the status of the Element, including public comments received during the Public Review Draft comment period and revisions made in response to those public comments and guidance received during the first Study Session. Staff collected feedback and recommendations from Planning Commission, City Council, and members of the public; and also received approval to submit the Draft Housing Element to HCD for an initial review. Recordings of the meeting is available on the Housing Element Update webpage.

Members of the public who attended the Study Session in-person and virtually were given the opportunity to make comments and ask questions.

4. Engaging Special Housing Needs Populations
The City is engaging special housing needs organizations throughout the Housing Element update. This engagement included providing Spanish translation needs at the first community workshop.

The City has outreach to the organizations listed below to solicit input and feedback. This included direct emails and phone calls to request both general input on the state of housing in the City, opportunities, challenges, etc., as well as to notify them when drafts of the Housing Element were made available for review. These organizations were identified for their specialized services to special housing needs households in Scotts Valley and the region. The

HOUSING
G - 4 | APPENDIX G
City has heard back from Community Bridges and Senior Network Services to schedule a oneon-one meeting, but did not receive a response from Encompass Community Services.  Community Bridges – Provides a variety of services for children, adults, and seniors. This includes a food program, early education services, safe community space for women and children, family resources, senior day health care, door-to-door rides for seniors, and meals on wheels.
 Senior Network Services – Provides specialized services for senior residents throughout Santa Cruz County. This includes information and assistance, Medicare counseling, senior housing, respite, case management, and a grant program.  Encompass Community Services – Provides county-wide services in behavioral health, family and social well-being, early childhood education, housing, substance use recovery programs, reentry services, and health and financial services.

Additionally, the City also contacted the following organizations to notify them of the available draft for feedback. These organizations include more regional groups and affordable housing developers.
 Housing Santa Cruz County – Provides public advocacy, democratic accountability, and community education relating to affordable housing across Santa Cruz County.  Habitat for Humanity Monterey Bay – Builds affordable homes and provides home ownership opportunities in Santa Cruz and Monterey Counties.  Association of Faith Communities – Provides resources and services to persons experiencing homelessness across Santa Cruz County. This includes the following four programs: 1) Safe Spaces providing a place for persons to park with access to sanitary facilities and other amenities; 2) Shower Ministry providing hot showers; 3) Faith Community Shelter providing nightly shelter and food; and 4) SPIN which distributes socks to shelters and food pantries.
 Seniors Council – Operates several programs for seniors across Santa Cruz, San Benito, Monterrey, and Santa Clara Counties. Programs include Aging and Disability Resources Connection (ADRC), Area Agency on Aging, Falls Prevention, Foster Grandparent Program (FGP), Project SCOUT, and Senior Companion Program (SCP).  Eden Housing – Affordable housing developer
 MidPen Housing – Affordable housing developer
 Santa Cruz Co. Housing Authority – Operates the Housing Choice Voucher (HCV) Program and a number of additional programs for housing affordability, for farmworkers, and for prospective homeowners.

The City has received separate public comments from the organizations listed below regarding special housing needs populations. Letters and public comments are included within this Appendix and also detailed in Table G-1 with responses.  Affordable Housing NOW!
 Santa Cruz YIMBY

HOUSING
APPENDIX G | G - 5
 Housing Choices
 Santa Cruz Co. Housing Authority

5. Housing Element Update Webpage
The City maintains a Housing Element Update webpage that was created to provide background information and guide the public to outreach events and resources throughout the course of the update process. The website provides information about the update process, key features of the housing element, recorded meetings, a project timeline, resources, and contact information. The website is available at: https://tinyurl.com/th67rbyn All outreach materials, reports, and Drafts are available to the public through the Housing Element Update webpage.

HOUSING
G - 6 | APPENDIX G

PUBLIC COMMENTS
The following section contains all public comments submitted throughout the Housing Element Update process through June 23October 19, 2023, and Table G-1 provides a matrix of public comments received during the Public Review Draft Housing Element and responses noting how each have been considered or incorporated.

HOUSING
APPENDIX G | G - 7
Table G-1: Public Review Draft Comments and Responses
Public Comments City Response
Submitted Letters
Housing
Choices
Affirmatively Further Fair Housing by Producing More Extremely Low-Income Housing.

Not only is disability the highest-ranked source of Fair Housing complaints in Santa Cruz County, a growing body of Santa Cruz County data indicates that Black, Indigenous and other People of Color (BIPOC) with disabilities experience higher rates of severe rent burden than either BIPOC without disabilities or whites with disabilities. Such disparities in the experience of severe rent burden, housing instability and displacement from the City of Scotts Valley are attributable to the shortage of housing priced to be affordable to Extremely Low Income (ELI) households with incomes below 30% of Area Median Income. Multiple barriers including high land and construction costs and limited funding make it difficult for developers to produce Extremely Low Income units that would help to reduce such disparities. Local zoning and other policies that lead to increased production of Extremely Low Income units, as well as city staff dedicated to implementing and overseeing those policies, will Affirmatively Further Fair Housing in the City of Scotts Valley and decrease displacement and homelessness for the most at-risk residents, including people with developmental disabilities.

Sample Language: The City of Scotts Valley’s plans to Affirmatively Further Fair Housing for Black, Indigenous and other People of Color, particularly those with disabilities, shall include policies designed to increase the production of Extremely Low Income units, as well as adequate staff capacity to implement and monitor the impact of these policies.

An action has been added into Program H3.2.

Establish and monitor a quantitative goal.

Tracking the City’s success in housing people with developmental disabilities is essential to determine whether policies and programs are having an effect in overcoming historic patterns of discrimination and exclusion of people with developmental disabilities from affordable housing. A goal of 20 new Extremely Low-Income housing units for City of Scotts Valley residents with developmental disabilities over the period of the 2023-2031 Housing Element would represent meaningful progress towards the total unmet housing need of this special needs group.

Sample Language: The City of Scotts Valley shall monitor progress towards a quantitative goal of 20 new Extremely Low Income housing units that are subject to a preference for people with developmental disabilities needing the coordinated services provided by San Andreas Regional Center to live inclusively in affordable housing.

A metric has been added into Program H-3.2
Target City-Owned Land, Land Dedicated to Affordable Housing and City Housing Funds to Achieve City-Specific Priorities.

Comment has been noted.

HOUSING
G - 8 | APPENDIX G
Public Comments City Response
City-owned land, land dedicated to affordable housing development through a land trust or under an inclusionary housing ordinance, and city housing funds are often essential to the development of affordable housing that is financially feasible. In creating guidelines for the scoring of any competitive proposals for these scarce resources, the City should grant additional points to affordable housing projects that address the housing needs of the residents who are most difficult to house under existing state and federal housing finance programs--for example, by prioritizing proposals with a higher number of Extremely Low Income units or that make a percentage of units subject to a preference for identified categories of special needs people who would benefit from coordinated onsite services, including but not limited to people with developmental disabilities who benefit from services of the San Andreas Regional Center.

Example: City of San Jose Housing Department NOFA; San Mateo County Affordable Housing Fund NOFA
Sample Language: In publishing requests for competitive proposals for any city-owned land, land dedicated to affordable housing or city housing funds, the City of Scotts Valley shall grant additional points to proposals that address the city’s most difficult to achieve housing priorities, by, for example, providing a greater number of Extremely Low-Income units or committing to make a percentage of the units subject to a preference for people with special needs who will benefit from coordinated onsite services, such as people with developmental disabilities who receive services from the San Andreas Regional Center.

Amend Density Bonus Program.

Like many state and federal housing finance programs, the state density bonus program incentivizes the production of housing at the Low and Very Low Income level. But in counties like Santa Cruz County, with one of the highest Area Median Incomes in the state, these incentives have the effect of making much of the available affordable housing out of reach for residents on fixed incomes (including seniors and persons with disabilities) or who are working in low wage jobs and are thus unable to meet minimum income requirements to afford the rent assigned to the Very Low Income category. The City of Scotts Valley should update its density bonus program to conform with current state density bonus law which has increased the maximum density bonus allowed. In addition, the city should include in its updated density bonus program incentives which go above and beyond the state density bonus law to make it more responsive to the impact of Santa Cruz County’s high Area Median Income on the affordability of housing for Scotts Valley residents who are Extremely Low Income. The city should also include additional incentives for projects that make a percentage of units subject to a preference for identified categories of special needs populations who experience the greatest Program H-3.10 is included in the Housing
Plan to bring the existing Ordinance into
compliance with recent State law updates;
the program includes the following actions:
• Adopt a Density Bonus Ordinance
amendment to bring policies into
compliance with State density
bonus law.
• Promote the Density Bonus
Ordinance to multi-family
developers on a project-by-project
basis to promote affordable
housing unit development.

HOUSING
APPENDIX G | G - 9
Public Comments City Response
barriers to housing access including but not limited to people with developmental disabilities who benefit from services of the Golden Gate Regional Center.

Sample Language: In addition to implementing the California density bonus statute, the City shall provide an additional local density bonus, incentives, and/or concessions for housing projects that include at least 5% of the units for people at the Extremely Low-Income affordability level or commit to make a percentage of the units subject to a preference for people with special needs who will benefit from coordinated onsite services, such as people with developmental disabilities who receive services from the Golden Gate Regional Center.

Program H-3.2 aims to affirmatively further
fair housing. Two actions specifically relating
to special needs households include:
• Extend housing choice voucher
search times for particular groups,
such as larger families with children
or persons with disabilities. Aim to
assist 20 households with special
needs access housing choice
vouchers.
• Facilitate the development of
affordable housing units for special
housing needs population. This may
include, but is not limited to,
technical assistance, support for
funding applications, permitting fee
waivers, and development
standards concessions, and other
similar actions.

Amend Inclusionary Housing Ordinance to Apply Restrictions to Rental Housing.

California law (AB 1505, the “Palmer Fix”) explicitly allows cities to adopt inclusionary housing ordinances that address a range of income levels from moderate-income to extremely lowincome. The City should take advantage of this authority to make its ordinance more responsive to local needs by offering developers of rental housing a menu of options for including affordable units, for example, by setting a higher percentage of units priced for moderate income and a lower percentage of units priced for extremely low income or targeted to special needs populations. Such a menu would address a broader range of the City of Scotts Valley’s housing needs, while giving developers more options for meeting the inclusionary requirement.

Example: San Mateo County Inclusionary Affordable Housing Ordinance; Redwood City Affordable Housing Ordinance
Sample Language: The City of Scotts Valley shall revise its inclusionary housing ordinance to require developers of rental housing units to restrict some units to moderate, low, very low, and/or extremely low-income households. In addition developers will be offered a menu of options for achieving affordability, adjusting the percentage of units required to be affordable Program H-1.8 has been updated to include
some of the proposed language regarding
restricting some units to moderate, low,
very low, and/or extremely low-income
households.

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G - 10 | APPENDIX G
Public Comments City Response
depending on the degree of affordability achieved (moderate-income, low income, very low income, and extremely low income) or special needs groups targeted, including, for example, people with developmental disabilities who will benefit from coordinated onsite services provided by the San Andreas Regional Center.

Extremely Low-Income Accessory Dwelling Units. As part of a larger plan to increase the supply of Accessory Dwelling Units (ADUs), the City should consider creating a financing program for homeowners who build ADUs and rent them for at least 15 years at Extremely Low Income rent levels or that are subject to a preference for identified categories of special needs people who would benefit from coordinated onsite services, including but not limited to people with developmental disabilities who benefit from services of the San Andreas Regional Center.

Example: Portland System Development Charge Exemptions; LA Backyard Homes Project Sample Language: Subject to funding availability, the City shall devise a program of financing for Accessory Dwelling Units subject to rent restrictions for at least 15 years at Extremely LowIncome rent levels and/or that target special needs populations, such as people with developmental disabilities who will benefit from coordinated services provided by the San Andreas Regional Center.

Comment has been noted.

Reduce Parking Requirements for People with Developmental and Other Disabilities.

Because most adults with developmental disabilities do not drive or own a car, the City should revise its ordinances to limit parking required for affordable units for people with developmental disabilities to 0.5 space for each affordable studio or 1 bedroom unit and 1 space for an affordable 2 bedroom unit or larger. A similar reduction is recommended for affordable, physically accessible units. Example: Sunnyvale Parking Requirements for Special Housing Developments
Sample Language: The City of Scotts Valley shall encourage the inclusion of people with developmental and other disabilities in affordable housing by recognizing their transit dependence and establishing lower parking ratios for units targeted to people with developmental and other disabilities than would otherwise be required for affordable housing.

This comment has been noted.

As part of Program H-1.6 the City will be
conducting a study of residential
development standards to determine any
potential constraints to housing.

Affirmative Marketing of Physically Accessible Units:

Developers are allowed to affirmatively market accessible units to disability-serving organizations in Santa Cruz County (i.e. San Andreas Regional Center, Housing Choices Coalition for Persons with Developmental Disabilities, Central Coast Center for Independent Living and others) but rarely take this step. Affirmative marketing is particularly needed by people with developmental disabilities who, because of cognitive, communication and social impairment, often rely on housing navigation services funded by the San Andreas Regional Center to learn about and apply for affordable housing.

This comment has been noted. The City
encourages developers to affirmatively
market accessible units.

HOUSING
APPENDIX G | G - 11
Public Comments City Response
Sample Language: As a condition of the disposition of any city-owned land, the award of city financing, any density bonus concessions, or land use exceptions or waivers for any affordable housing project, the City of Scotts Valley shall require that the housing developer implement an affirmative marketing plan for state-mandated physically accessible units which, among other measures, provides disability-serving organizations adequate prior notice of the availability of the accessible units and a process for supporting people with qualifying disabilities to apply.

Letter from
Michael
Shulman
It is rather confusing that there is identical numbering for the Policies and the Programs, as (for example) Policy H-1.1 speaks to housing variety in general while Program H-1.1 is specific to the 6th cycle RHNA. Since this document will be used for the next 10 years, there could be some benefit to having some nomenclature distinction between these two classes (“PoH-1.1” v “PrH1.1”, for example).

Comment has been noted.

Program H-1.1 (RHNA): Table F-2 shows very encouraging numbers that bely publicly expressed concerns over the RHNA assigned to SV. Table F-6 takes an appropriately expanded view of the housing opportunities at the Town Center, recognizing the potential to redevelop certain existing parcels beyond their current singularly commercial purpose. The re-zoning opportunities along SV Drive, in addition to offering housing sites, can also generate longneeded economic revitalization along this corridor. But it is not clear why the rezoning is being proposed for only 33 identified parcels. An overlay zone that allows all property owners an ability to participate avoids the potential trap of the City attempting to pick winners-and-losers based on the ephemeral and potentially transient reasons offered on Page F-19. Identifying just these 33 parcels also creates unjustified inequitable development opportunities between adjacent parcels that may put the City on tenuous legal footing. We can’t know who will want to redevelop or who will constructively engage in lot consolidation; properties can change hands and zoning-based advantages can simply raise the perceived value of a parcel rather than necessarily lead to its prompt development.

There should also be more consideration given to allow 100% residential along at least some portions of this corridor rather than insist on minimum 30% commercial development. There simply may not be a viable market for commercial anytime soon and the encumbrance on all properties is counterproductive. The City’s economic viability no longer relies on the sales and business tax generation that was the basis for the non-residential legacy zoning of SV Drive. A high density residential overlay combined with PD (planned development) regulations along SV Drive, from Mt. Hermon all the way to Victor Square, could simplify and stimulate redevelopment, make great strides towards fulfilling our RHNA, and provide more resident wallets that will drive economic growth in our existing retail and employment centers.

Comment has been noted.

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G - 12 | APPENDIX G
Public Comments City Response
Program H-1.4 (ADU) – ADUs are perceived as an easy fix to affordable housing challenges because their small size makes them inherently more affordable, and by spreading them out within existing neighborhoods it can diffuse the opposition often associated with larger residential developments. But we should not overlook the adverse impacts they can have on fully developed neighborhoods by introducing more cars and traffics without any commensurate expansion of infrastructure, the loss of vegetation and open space (which matters, even when on individual parcels), and the crowding of structures and potential loss of privacy (depending on how the ADU is sited). ADUs should be accommodated where they work well in a particular neighborhood but we should be cautious about incentivizing them (as per H2.2, Design Review). We can achieve our RHNA through commercial rezoning and undeveloped residential properties without reliance on one-off ADUs that warrant selective support and individual consideration; they are essentially a neighborhood-level ‘remodel’ and the incentives should focus on retaining the positive qualities of that neighborhood rather than be driven by quantity of units. The total number of projected ADUs shown in Table F-2 (40) speak to their near irrelevance to meeting SV’s RHNA. Some actions proposed are contrary to good planning and pose enforcement challenges -- permit ready ADU plans may conflict with the character of a property or neighborhood, and affordability deed restrictions on individual property owners are intrusive, difficult to effectively regulate, and can generate conflict when the property changes hands.

Comment has been noted.

Program H-1.5 (removal of constraints) – This program needs more substance; it only says we’ll talk about it and conduct research. Yet despite this ambiguity, it seems to have concluded that parking requirements are a fair target. Everyone hates parking except when it is a challenge for them or their guests / customers to find a space. In MF and commercial developments, minimum parking requirements exist for clear and valid reasons. SV has other legacy development constraints (building heights, densities, commercial v residential percentages, etc.) that do not necessarily have such clear rationale, at least in a broad, one-size-fits-all sense; see also my comment on page C-3 below. The concept behind this program is worthwhile but the text is insufficiently ambitious. To say “if constraints are identified, adopt changes with(in) two years” will not lead to changes if those who have maintained the constraints are those who are now supposed to identify them. The Actions should identify both the process (who, how, and when) and specific objectives for the program. For example, the Planning Commission could be charged with identifying the nexus between the residential development standards and our planning objectives, and then making recommendations (within one year) for balancing these with our affordable housing goals.

Comment has been noted.

HCD considers a parking requirement of 2 or
more parking spaces per unit for multifamily developments as a constraint to affordable housing development. As part of
Program H-1.6 the City will be conducting a
study of residential development standards
to determine any potential constraints to
housing.

HOUSING
APPENDIX G | G - 13
Public Comments City Response
Program H-1.7 (affordable housing) – Applying the inclusion ordinance City-wide doesn’t change the financial realities associated with creating lower-cost housing from high-cost land. It simply creates a new constraint (see Program H-1.5) on hillside properties or existing neighborhoods whose development future is more likely to consist of replacement rather than additional housing. Instead, we might consider associating the inclusionary ordinance with zoning density and/or project scale, having it apply for all MF zones and developments exceeding 5 units where it is much more practical to create affordable units.

The expansion of the Inclusionary Ordinance
only refers to its boundary; the Ordinance
will continue to apply to projects that meet
the specified requirements.

Policy H-2.1 (property maintenance) – The Policy (and Program) statements refer to property maintenance standards, but it is not clear that local government has an enforceable role beyond issues associated with health and safety codes. Zoning and building codes are generally applied only during the permitting process. The H-2.1 Policy and Program (and its underlying actions) text may need clarification. The City does not want neighbors with different aesthetic preferences to drag the City into squabbles over paint colors, landscaping, and similar conflicts that can arise and really need to be resolved between the parties.

The City will continue to ensure quality
housing through compliance with health
and safety codes.

Policy H-3.1 (special needs groups) – It is not clear whether the expansive identification of these groups (as discussed on pages B-15 through B-24) is defined by the State or just reflects the opinion of the authors. Large families, single parents, and college students have housing affordability challenges that seem quite similar to those of the general population. Identifying them as a “special needs group” dilutes our ability to focus on the unique affordability challenges of those dependent on special housing accommodations (such as seniors, disabled, and extremely low income). While page B-23 cites 2020 ACS data showing 1,267 college or grad school students living in SV (a full 10% of our population), it is likely that most live in their family home and have simply not yet reached financial independence. That doesn’t make them a special needs group. This policy should perhaps be less ambitious so the associated programs and actions can have better focus.

State law requires the assessment of each of
these groups for special housing needs.

Policy H-3.3 (equal housing opportunity) – housing discrimination is blatantly illegal and the City should refer any such matters to the District Attorney rather than just “discourage” it. The City’s housing plan shouldn’t soft-pedal such behavior.

Comment has been noted.

Program H-3.2 (fair housing) – The first sentence of the second paragraph is a bit garbled. The entire RCAA discussion (pages E-9 and E-10) tries to discuss patterns of discrimination but it just doesn’t work on the scale of SV. The data used here seems to have been gleaned from the 2015-2019 ACS which, as noted on B-24 (below), had some serious accuracy problems in this timeframe. The statement (page E-10) that “RCAAs may represent a public policy issue to the extent that they have been created and maintained through exclusionary and discriminatory Comment has been noted.

HOUSING
G - 14 | APPENDIX G
Public Comments City Response
land use and development practices” is a charged accusation that seems reflective of our fraught political environment but it does nothing to help SV meet its housing goals. Appendix E overall fails to identify “racially concentrated areas of affluence” in SV, and there’s no reason given to “establish specific incentives for the development of affordable units in the RCAAs” rather than just city-wide. While some of this content may be legally required, it reads as an unnecessary and pointless distraction that looks to sound politically correct but is indecipherable in practice.

Also under this program, the first action on page 2-15 suggests the City should “provide home repair and rehabilitation assistance for at least 20 households.” Any such assistance should be specifically targeted to those needing economic assistance and where the repair/rehab has a health or safety component; the City does not have the resources to just help everyone with their home improvement projects.

Program H-3.3 (childcare facilities) – The phrasing here is misleading as the City does not “make” these services available, affordable, or accessible. The first sentence should be rephrased to “The City shall continue to support the availability of high quality childcare services that are affordable and accessible …”.

This language correction has been made.

Program H-3.6 (housing for lower income households) – This is the core issue and it’s unfortunate to find it buried on page 27, with so little discussion and no tangible actions. “Coordinate” and “meet with” do not move the ball forward. Relevant actions that are cited elsewhere (such as rezoning, incentivizing lot consolidation, removal of development constraints, and density bonuses) should at least be referenced here.

Actions to address the needs of lower
income households are included through a
number of programs within Chapter 2; as
such, Program H-3.6 does not reiterate the
actions of other programs.

Program H-3.9 (emergency shelters) – the last bulleted action item may be overly ambitious and conflicts with our need to prioritize funding and incentives for affordable housing writ large. As noted in the Program text, the homeless population in Scotts Valley is quite small and prioritizing those housing needs will inherently deprioritize others. It should also be clarified as to whether the “projects” referred to in this action are separate emergency shelter facilities or programs to support emergency shelter functions at existing multi-purpose facilities.

Comment has been noted.

Program H-3.10 (density bonus) – Along with H-3.6, this program has a potentially large role to play in the City’s attainment of its RHNA. But it also can and should be coordinated with the otherwise underlying permitted zoning densities, proposed elsewhere (Program H-1.1) to permit up to 40 units per acre. Automatically applying PD zoning wherever density bonuses are offered can help address site and neighborhood compatibility.

Comment has been noted.

Program H-3.12 (condominium conversion) – Such an ordinance may have value for cities with centrally managed buildings full of condominiums; in SV, condominiums are individually owned and it is not practical or reasonable to prevent someone from selling their property when they Comment has been noted.

HOUSING
APPENDIX G | G - 15
Public Comments City Response
no longer wish to maintain it as a rental unit. There is no rational means for the city to establish “a maximum percent … that can be converted over a certain period of time” nor is there even a suggestion of evidence that this is a problem in need of a solution. Table B-29 in fact shows a significant increase (from 2010 – 2020) of multifamily homes being rented rather than owned.

The trend across the region is of wealthier individuals (and corporations) purchasing properties for investment and income generation purposes, and not taking them out of the rental market.

There is simply no need for this ordinance in SV.

Program H-4.3 (water and sewer service) – Since the City itself is the sewer provider, this text should be simplified by removing reference to providing coordination with the sewer service provider as if they are a separate entity.

Comment has been noted.

Page B-7 (economic characteristics) – This page has a typo where it states “The County of Santa Cruz’s median income for a household of four is $199,300, according to the 2022 State of California Income Limits for Santa Cruz County.” That correct number is $119,300 in accordance with https://www.hcd.ca.gov/docs/grants-and-funding/inc2k22.pdf.

Typo has been corrected.

Page B-24 (housing stock characteristics) – The acknowledged inaccuracy of the Table B-27 data, which suggests a significant decrease in housing units from 2010 (4661) to 2015 (4390) raises a question as to the accuracy of other estimates from the ACS surveys. It might be worthwhile for the City (or its consultant) to take careful stock of other numbers associated with these surveys to ensure that decisions and program choices are not being made based on bad or suspect data.

Comment has been noted.

Tables C-3 (permitted residential densities) and C-5 (development standards) – these are the key constraints impacting SV’s ability to meet its diverse and affordable housing needs. The ‘very high density residential’ cap of 20 units per acre, 2100 sq ft/unit, and 35 ft building height have been in place since prior to the 1994 General Plan, when land was cheap and the driving force behind increased density was developer profitability. These constraints on multifamily developments promote two story, nicely spaced structures with plentiful recreational and landscape amenities, which are very nice. But such developments are quite low density relative to what is otherwise possible and palatable. We can and should allow significantly higher unit densities along the SV Drive and Mt. Hermon corridors, recognizing their more urban aesthetic along transportation corridors, the different needs of today’s younger, older, and nontraditional households, and the financial realities of providing housing for those with lower incomes.

The City plans on allowing higher densities
through its rezoning program and will
establish development standards for the
new zones to appropriately match the
allowed density. Candidate sites for
rezoning were selectively chosen along
Scotts Valley Drive and Mount Hermon Road
to promote higher density development
along major corridors with access to
resources.

Page C-44 (water supply) – The top of page C-46 cites only the decreased amount of effluent flowing to Monterey Bay as a result of the water reclamation facility (WRF), but that fact has Comment has been noted.

HOUSING
G - 16 | APPENDIX G
Public Comments City Response
only a modest relationship to increasing our housing stock. It would be of more value for this document to mention the significant decrease in potable water demand since the WRF came online and the positive impacts of various water conservation measures that have been implemented (including building code requirements for water efficient appliances). A frequent concern cited by those opposed to more housing in SV is the potential adverse impact to our sole-source water supply. Presenting the data showing how aquifer water levels have recovered since the early 2000s and discussing the relative water use rates between SF (with landscaping) vs MF units would go a long way towards making those discussions more rational and factbased.

Letter from
C2G
Analysis included in the letter suggests that developers and property owners will not be able to meet the number of units assumed on each Mixed-Use Rezone parcel with the 30% commercial requirement given parking requirements for both commercial and residential. The letter suggests that an increase in the residential component at minimum to 90 percent, with 100% residential preferred, would be required for the development to be feasible.

Comment has been noted.

With Scotts Valley being a transit corridor, these [mixed-use rezone] properties would be able to implement the State’s Density Bonus Law. This could allow the density to increase by 35% with the affordable housing components required for these sites. This could increase the number of units to 54/Acre!
The Density Bonus Law also reduces the parking requirements. Instead of relying on the State Density Bonus Law, it would make more sense for the City to reduce the parking requirements for these mix-use zoning areas with the new Housing Element.

To the last topic, Residential Rezoning. When examining Table F-2 in the Housing Element, the RHNA hosing goal is almost achieved without the rezoning of the three (3) suggested properties. If the Density Bonus Law was encouraged for the mix-use sites, the residential rezoning would not be needed.

HCD does not allow jurisdictions to rely on
Density Bonuses in projecting development
growth. However, units added through
applied Density Bonuses will count towards
the City’s RHNA as projects develop.

Also, SB9 and ADU laws should be encouraged by the City Planning staff and proactively reach out to the community via social media, local newspapers and local service community meetings. This approach would look better (than randomly picking properties to rezone with higher density) for the City in our professional opinion.

Program H-1.5 includes a number of actions
the City is taking to proactively encourage
ADU development. The City cannot rely on
more ADUs than currently projected – the
projections must be based on past
performance and be supported with policy
programs per HCD. Additionally, HCD does
not allow jurisdictions to rely on housing
development through SB9 as there is not
enough evidence to support projections.

HOUSING
APPENDIX G | G - 17
Public Comments City Response
Letter from
Charlie
Eadie
Add to your mixed use inventory of potential sites two parcels at 4627 Scotts Valley Drive, APNs 022-082-34.35. This site consists of just under an acre and would be a prime candidate for high density and/or mixed use high density housing.

Comment has been noted.

Be explicit about the ratio of commercial to residential in mixed use projects in the Housing Element. The past policy in the General Plan (not the zoning ordinance) interpreted to require a 50/50 ratio (the "50 percent rule" so called), however well-intended, had the effect of killing numerous proposals for housing/commercial mixed use projects. Other jurisdictions are facilitating mixed use by either eliminating floor area ratio standards altogether, or setting the mix in a way that makes projects at least theoretically possible. For example, the County of SC now has proposed an 80/20 housing/commercial mix in their Housing Element.

Language specifying the increased ratio
between residential and commercial is
added in Program H-1.7
Address processing issues. In particular, SV processing times have been extraordinarily long, and the Housing Element consultants should look into the history of that for various projects.

One suggestion would be to reduce the high level of detailed engineering and other work now required by the City just to get to hearing on land use/design approval. This adds significant time and costs to getting a "complete" application, and can leave decision-makers frustrated because the project is essentially a "finished product" when they finally see it which inhibits their willingness/ability to make changes. Better to have the use and design considered and worked out before requiring the nth degree of detail in the plans.

Comment has been noted.

Letter from
Affordable
Housing
Now
While the HE must address housing needs for all income levels, one of the greatest challenges is meeting the goals for very-low and low-income housing units. The density bonus law provides developers with powerful incentives to build lower income housing units. In the City of Santa Cruz, incentivizing the density bonus system has facilitated housing production, especially for very-low and low units, as the State law intended. The HE recommends updating to AB 2345 requirements (raising maximum bonus from 35% to 50%) and increasing the concessions. The reality is that Scots Valley has to compete with other jurisdictions to attract developers to deliver units, so it should entice them with density bonus incentives. With very few empty large lots available for new housing projects, bonus density applications including concessions and incentives will be critically important to help the City meets its 6th cycle HE housing goals.

Comment has been noted. Program H-3.10
is included to update the Density Bonus
Ordinance in compliance with new State
requirements. Included in the program is an
action for the City to promote the use of
density bonuses for multi-family
developments as a way of promoting
affordable housing development.

One incentive successfully used in other jurisdictions that has not been formally used as an incentive in Scotts Valley is Section 8 Housing Vouchers. Since for years landlords have shunned using vouchers, the Housing Authority has been aggressive in securing dedicated voucher units in new projects and it is even doing its own project in the City of Santa Cruz. Both Santa Cruz and Watsonville allow for 5% of their inclusionary unit requirement to be met using housing vouchers, although at 20% their inclusionary rates are 5% higher than Scotts Valley's. This is a Section 8 Vouchers (now referred to as
Housing Choicer Vouchers) are addressed
through Programs H-3.1 and H-3.2.

HOUSING
G - 18 | APPENDIX G
Public Comments City Response
win-win as the developer gets market rate rents, but the voucher tenants who are the most needy, help deliver very-low and low housing units.

Affordable Housing NOW is concerned that too many of the RHNA units are tied to the Town Center. The HE indicates that 427 of the 649 very-low and low-income units would be built at the Town Center, and 657 of the total 1,220 units would be built there. Modifying the Town Center Specific Plan is vital. As we have argued before, standalone residential units are important, but for affordable housing units trading land for inclusionary requirements might yield more. However, the density bonus system would need to be employed for that and 100% affordable housing projects would have the highest bonuses and concessions.

Comment has been noted.

The programs and policies included in the HE makes the city well-positioned to pursue the California Department of Housing and Community Development's Pro housing Designation. The benefit to receiving the prohousing designation includes being given preference and additional points when pursuing state grant funds for affordable housing projects. Funding for affordable housing is one of the greatest challenges to overcome and this designation could give the city a competitive edge when pursuing state funding for Affordable Housing and Sustainable Communities and Infill Infrastructure Grants. Working to obtain the Prohousing designation will take time, but the payoff would be worth it for both funding and the increased production of affordable housing units.

Comment has been noted.

The city should also not overlook new state laws that have been enacted, or may be passed this year, to facilitate construction of affordable housing projects. Reduction of parking requirements, ministerial approvals, construction of projects on church property, and streamlining permitting and project approvals can all help move projects along and reduce the amount of time it takes to complete construction and make affordable units available to individuals and families in need of housing. Laws that allow ministerial approvals can help the city move forward with much needed larger housing projects that can provide workforce housing for our community and help the City reach its RHNA housing goals.

Comment has been noted. The Housing
Element is required to comply with all State
Housing laws.

We support the city's plan to meet annually with the development community, although more often might be better. Improved communication with developers can help the city identify regulations that constrain or create barriers to the construction of new affordable housing, especially for extremely low and low income units. Amending ordinances and regulations that impede projects from going forward will facilitate increased production of those much needed housing units. We also encourage working in collaboration with developers in the early stages of project development to maximize potential for housing units in the very-low and low-income categories.

Comment has been noted.

HOUSING
APPENDIX G | G - 19
Public Comments City Response
Letter from
Eli May
Requesting the 125 Bethany site be removed due to:

Current redevelopment efforts at this property.

We have been working toward obtaining approvals to redevelop this property for over 3 years.

We have applied for and paid for all application fees in excess of $40,000 as well as over $100,000 in additional reports requested by the city. We have been fully engaged in an ongoing and responsive exchange with city staff to move forward on the redevelopment of this property. This has involved serious and continuous community engagement. We have responded to over 100 items from public works and the planning department over the course of several redesigns and resubmittals. In fact, we will be entering environmental review for our redevelopment application this month. We have engaged in an incredibly lengthy, expensive, and involved process and we don’t feel it’s appropriate to include this property on a list to be rezoned for residential while in the middle of the application process to be redeveloped. This is particularly true when the “community engagement” process employed by consultants for the housing element has been seriously lacking in transparency and invalid by comparison to the process we have engaged in for a single redevelopment application and taken extensive time to seriously implement. We feel that we are legally entitled to proceed with processing our application under CEQA and welcome environmental review of our incredibly thoughtful and positive redevelopment plan. We are joined by our tenants and neighbors in looking forward to an approval for a new building that benefits the community and reduces - not increases - impacts.

Current Uses.

The current zoning of our property is commercial professional. It currently has ~ 14,000 gross sq ft, which is 100% occupied by businesses that serve the community. The current redevelopment plan would replace the existing amount of office space and create more opportunities for local businesses to operate and grow. As part of our resubmission in April 2022 we included half a dozen letters from businesses (existing and potential tenants) imploring the city to approve our redevelopment. These uses are an important part of the local economy and its loss would be a detriment to the community.

Neglected impacts of the draft designated use
In the process of applying to redevelop our property, the city asked us to perform a number of professional reports to study the impacts of the proposed redevelopment, which we did. This included extensive and expensive studies regarding noise, traffic and parking, as well as an The 125 Bethany Drive site has been
removed.

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G - 20 | APPENDIX G
Public Comments City Response
arborist study and an archeologist study. The results of the studies showed that our proposed redevelopment would actually reduce impacts; it does not appear any similar studies have been performed to study the impacts of 41 residential units for this draft report.

Parking & Traffic
The traffic studies we had completed for our redevelopment show a delicate balance of parking on this property. 41 residential units at this site would make trip generations skyrocket and it would simply not be possible to park all of these units at this site. Furthermore, the site is a relative island with a noisy freeway on one side with no other parking available in the immediate area, which would be a huge issue. It does not appear that our existing study has been reviewed or that a similar study has been conducted for the specific use designated in the draft housing plan. Also, this property is at the same intersection as Vine Hill Elementary, which already causes significant congestion at the intersection during school drop-off and pick-up times. A 41-residential unit site at this intersection would further exacerbate traffic in this area, Neighbors who live on Tabor and Bethany would face far worse congestion and traffic than they already do.

Noise
This site sits along HWY 17, which creates significant noise that would not be acceptable for the 41 units without significant noise-barrier walls, and the site simply does not have the space for this. It does not appear that a study has been performed on the noise at this site for residential use, as we have done for our proposed use.

Arborist
We performed an arborist study for our redevelopment and the city has mandated that we keep existing mature trees and add more shade trees to the parking area. This condition has further inhibited the number of parking spaces we can fit. It does not seem that an arborist study has been performed for the use of 41 residential units at this site as we had been tasked with doing, as it would show a lack of necessary parking and the consequent elimination of mature trees. These studies would show that the site is simply not equipped for this type of residential use.

Community Engagement
During the process of our redevelopment efforts, we held meetings with many stakeholders in the city including a comprehensive community engagement plan. We built a website detailing the redevelopment and sent direct mail to all of our neighbors to communicate with them about the project and point them toward the website along with contact information. It appears there has been very little community engagement around the process to create the

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APPENDIX G | G - 21
Public Comments City Response
housing element draft plan. I was not informed in writing as an owner of one of the three properties identified for rezoning. The Scotts Valley Press Banner noted the same issue in its article “Scotts Valley Housing Element workshop features little community input”.

Numerous opportunities elsewhere not identified
It is clear from the many public comments at the April 5th planning commission meeting that there are many property owners along Scotts Valley Dr that would be more than willing to build more dense residential projects, but are unable to because they would need to match 50/50 commercial to residential, which makes the projects not feasible. Allowing these property owners to build dense residential projects would create more foot traffic for the businesses along Scotts Valley Dr thus attracting more businesses and more revenue for the city. Instead, the Draft Housing Report identified only three parcels in the entire city for rezoning. We believe the city needs to look closer at other commercial parcels along Scotts Valley Dr and beyond to meet its plan. The draft housing element failed entirely to aggregate the 50/50 requirement on a larger basis - and did not assume anything for the assemblage of parcels. This is an abject failure on the part of the consultants to recognize and move on to an obvious solution.

Comment has been noted.

Furthermore, we believe the draft report missed multiple appropriate and obvious opportunities elsewhere. This includes ADUs. Last year, California passed SB9 which allows for any single-family residence to build at least one ADU and in many cases more than one. Scotts Valley is truly unique in that the city contains numerous older and larger residential parcels that can take advantage of SB9 - and do so appropriately within existing residential neighborhoods.

This would not only capitalize on existing infrastructure but will also significantly disperse any impacts from this incremental approach. Yet the public draft report used historic ADU origination numbers from the last 8 years of only 3 ADUs being built per year, without taking into account the tremendous growth in ADU construction which is just now occurring from this landmark legislation. There are also many other opportunities to account for more housing such as mobile home parks, which would be an obvious choice for more dense and affordable housing.

In conclusion, rezoning the property at 125 Bethany is not appropriate for a myriad of reasons, and I formally request this property be immediately removed from the draft plan.

Program H-1.5 includes a number of actions
the City is taking to proactively encourage
ADU development. The City cannot rely on
more ADUs than currently projected – the
projections must be based on past
performance and be supported with policy
programs per HCD. Additionally, HCD does
not allow jurisdictions to rely on housing
development through SB9 as there is not
enough evidence to support projections.

The 125 Bethany Drive site has been
removed.

Letter from
Santa Cruz
YIMBY
Probability of Meeting Low Income Targets
“The City of Scotts Valley has facilitated the building of market rate housing in recent years, but has made little effort to develop housing for low income workers.” According to the site inventory Scotts Valley is expecting that all sites identified for rezoning will set aside roughly Sites identified through the candidate sites
inventory have been identified as having
viable potential to be developed over the

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G - 22 | APPENDIX G
Public Comments City Response
50% of their units for very-low, low, or moderate income families, while providing little evidence that this level of affordability will be realistically produced. Meanwhile, the city’s four pipeline projects consist of only 18% affordable units. We would like the city to explain why it expects to achieve this 50% target, and how it will enable the development of additional housing if this target is not being met. For comparison, the City of Santa Cruz is projecting a 20% affordability rate for most parcels in its site inventory. If the city misses its target of 50% affordability, it faces the daunting task of identifying other sites to make up the difference under No Net Loss law. With nearly half of its very-low and low income units planned for through the Town Center Specific Plan, this single project not producing as many units as expected would subject the city to this law. Additionally, there is only a 9% buffer for moderate income units, HCD recommends a buffer of between 15 and 30 percent. In order for Scotts Valley to meet the needs of its most vulnerable residents, it is essential that plans for affordable housing not only sound good, but are workable and realistic. next eight years with supportive programs
included in the Housing Plan.

Through a number of Programs, the City will
provide incentives to development projects
that include affordable housing units in
order to meet its projections identified in
the Candidate Sites Analysis – see Programs
H-1.7, 1.8, and 3.6.

Pipeline Projects
A significant source of new units for the city during the 6th cycle will be from pipeline projects.

For jurisdictions relying heavily on pipeline projects, HCD recommends6 that “…the element should include programs with actions that commit to facilitating development and monitoring approvals of the projects, including the number of units and affordability (e.g., coordination with applicants to approve remaining entitlements, supporting funding applications, expediting approvals and monitoring of project progress, including rezoning or identification of additional sites, if necessary).” In order to meet this recommendation by HCD, the city should create policies to monitor the progress of pipeline projects. This could include automatic entitlement extensions until midway through the 6th cycle and proactively reaching out to all pipeline project developers to confirm that there is still development interest. In recent public meetings, local leaders said that they were contacting developers of existing pipeline projects to gauge their interest in resubmitting plans at a higher density or with additional units. The La Madrona and Valley Gardens projects together represent a vast majority of the city’s pipeline units. We urge the city to work with the project developers to increase the amount of multifamily and missing middle housing, especially in those areas of the project site closest to Mt Hermon Road.

The number of units in these two projects alone represents nearly 30% of the city’s RHNA, and could easily fulfill more if they were revised to have majority multifamily units. These sites offer an opportunity for Scotts Valley to demonstrate leadership in building mixed density neighborhoods that bring people of different income levels together.

Comment has been noted. The City is
actively coordinating with the developers
and property owners of the pipeline
projects.

Goal H-1 – Housing Production Comments have been noted.

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APPENDIX G | G - 23
Public Comments City Response
With the city’s RHNA increasing nearly tenfold from the 5th cycle, we see significant need for policies and programs which enable, not restrict, development. We applaud the city for identifying significant commercial and parking requirements as constraints to development but strongly disagree with the assertion that “...the City’s standards for lot size, setbacks, height, and site coverage are not considered [constraints]...”
As mentioned, the city has accurately identified its limit of 50% residential in mixed-use developments to be a constraint and is rezoning select parcels along main corridors to increase this cap to 70%. We would like to see the city go further and either remove this limitation entirely or allow for mixed-use development with an option for ground floor commercial only rather than as a percentage of total square footage. Additionally, granting this flexibility to all mixed-use projects in the city would incentivize development and allow developers to better respond to Scotts Valley’s housing shortage.

We would like to see the city commit to allowing more residential square footage in mixed-use developments if the proposed rezoning does not result in developer interest. With regards to parking requirements, the city should go much further in reducing or even eliminating requirements and the existing programs should have stronger language. Currently, program H1.5 does not commit to lowering parking requirements and has a timeline of 2027. We would like to see this timeline moved up and a commitment to lowering requirements to no more than half a space per unit, uncovered. Creation of missing middle housing isn’t mentioned within the policy plan - the city should adopt zoning regulations that would incentivize this form of housing. Examples include reducing minimum lot size, setbacks, and lot coverage restrictions.

In Redwood City’s compliant 6th cycle housing element amendments such as these are anticipated to result in an increase of at least 80 homes. Currently, duplexes are not conditionally or principally permitted in any of Scotts Valley’s zoning districts.12 The City of Scotts Valley should seek to allow a wide variety of housing types including duplexes, triplexes, fourplexes and other multifamily project types throughout the City. Much of this could be achieved without an EIR thanks to Senate Bill 10.

Unaddressed Constraints
Along with the commercial and parking constraints discussed in the prior section, there are other constraints that we believe the city should address to ensure that housing can be built.

We expect projects to make use of State Density Bonus law for feasibility of development of affordable housing. Currently, Scotts Valley zoning code includes constraints and limitations that could limit affordable multifamily or mixed-use housing from achieving assumed base Comment has been noted. As part of
Program H-1.6 the City will be conducting a
study of residential development standards
to determine any potential constraints to
housing. Program H-2.8 has been added to
facilitate lot consolidation.

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G - 24 | APPENDIX G
Public Comments City Response
densities. These include but are not limited to building height, FAR, and parking requirements.

The city should better explore to what extent its density restrictions are a constraint to development. With the city’s highest density residential zoning district capped at 20 du/acre, this is likely a significant barrier. We recommend the city expand its rezoning efforts to all ‘Very High Residential’ parcels at a minimum and allow up to 40 du/acre on such parcels. There are a number of small sites on the inventory which fall outside of the parcel size requirements set forth by AB 1397. These sites may still be included for a variety of reasons, in Scotts Valley’s case “…a program to facilitate lot consolidation.” There is no such program in the policy plan.

Town Center
One of the largest projects projected for Scotts Valley’s 6th cycle will be further development of the Town Center Specific Plan, encompassing 58 acres in the heart of the city. This area is well situated to accommodate a significant amount of housing and associated amenities. While we are pleased that the city anticipates 657 units to be built on these sites we would like to see more in the housing element to indicate that the city is determined to see this housing come to fruition. This plan has been in the works since at least 2008 and has not seen a significant amount of the proposed housing be built in that time. According to the city, “...project applications have been submitted for the Plan, but development was not successful. Interest in developing the Town Center area has increased over recent years.” Despite these failed developments and increased interest, there is no mention or analysis of the reasons for these failures or why development has not moved forward for this area in the housing element.

Additionally, we would like the city to provide more detail on the affordability projections for the Kings Village parcel as part of the Town Center plan. While the other four parcels are publicly owned (by METRO or the city) this shopping center is privately owned. The city estimates that this parcel will produce a 50% affordable project, but provides no indication that there is interest from the owner, a developer, or any other type of agreement that would be required for housing production to happen.

Comment has been noted. Previously,
surface soil contamination has been an
obstacle to development in the Town Center
Specific Plan area. The City is currently
under contract to remediate the soil, which
should be complete by Spring 2024.

Mid-cycle Review
To ensure the city makes appropriate progress towards its 6th cycle goals we would like to see a commitment to a mid-cycle review and adjustment (if needed). Tying this review to programs to increase housing production such as rezoning, ADU incentives, or removing development constraints would allow the city to quickly make up lost ground and minimize impacts of falling behind in the 6th cycle. This would also be a time to review pipeline projects which have not progressed.

Additional mid-cycle programs could include:

The City has included actions throughout
programs to review trends and progress
more often than once at mid-cycle.

Program H-1.5 includes an action to
establish an ADU monitoring program and
biennially review ADU development
progress.

HOUSING
APPENDIX G | G - 25
Public Comments City Response
• Ministerial approval process for all site inventory projects • SB10 upzoning of small sites to 10 units per parcel
Tracking commercial occupancy, and if vacancy is too high, relaxing commercial requirements in favor of more residential, including live/work units
Program H-1.6 includes an action to
annually review development trends and
biennially meet with the development
community to receive input and feedback,
and adopt changes if constraints are
identified.

Program H-1.2 has been added to establish
by-right development in compliance with AB
1398 and 1397.

Transit Oriented Development
Despite being home to the Cavallaro Transit Center (CTC), Scotts Valley lacks any current or planned high quality transit stops. In the 2040 MTP/SCS the CTC was identified as such a site, however, it was subsequently removed in the 2045 MTP/SCS19. We encourage the city to commit to working with AMBAG in the 2050 MTP/SCS (scheduled for June 2026) to designate the CTC as a planned high quality major transit stop. This designation would incentivise more sustainable, affordable, and equitable development in an area identified for a significant amount of new housing in the 6th RHNA cycle.

Scotts Valley is currently not a pedestrian and bike friendly community. The transit center is a key connector for jobs and opportunities for low income people that do not own cars. Further investment in housing around transit stops has been shown to increase ridership on public transit. Denser housing and investments in walking and biking infrastructure between the Valley Gardens, Town Center, and the CTC could together make great strides in helping Scotts Valley achieve its housing, climate, and safety goals while also making it easier for people of all ages, abilities, and incomes to access the city.

Comment has been noted.

Tenant Protections
As a city with a growing percentage of renters, it is important to have strong tenant protections. The housing element notes that “[a]bout 51.8 percent of renters are cost burdened, and 33.1 percent are severely cost burdened.” There are a number of programs we would like to see implemented or expanded in the city including:
• Elimination of or cap on rental application fees
• Creation of a rental registry. This was recently passed by both Salinas and Monterey Comment has been noted.

HOUSING
G - 26 | APPENDIX G
Public Comments City Response
• Local preference for people employed in the county COPA and TOPA programs Conduct a disparate impact analysis of non-high(est) resource areas and apply a live-work preference if if it matches county demographics
Online Feedback Form
Comment
from David
Duquette
This is regarding the mixed-use rezones.

I own a one acre parcel (5163 Scotts Valley drive) that is being considered for a rezone. The increase in the residential component from 50% to 70% is not enough to encourage development.

If I imagine a building with 28 units averaging 850 square feet per unit, that would amount to 23,800 square feet. Under the 70% rule I would need an additional 10,200 square feet of commercial space. Adding more commercial space to an already saturated market will only add more "FOR LEASE" signs to the existing ones up and down Scotts Valley Drive.

The parking requirements for the commercial space alone would be more than our lot could handle. At the standard 1 parking space for every 250 square feet for business/professional services, that would be 41 parking spaces for just the commercial. Relaxing the parking requirements won't help. I have owned commercial/retail buildings with inadequate parking and they are extremely difficult to rent.

Tastefully designing 28 units on one acre is going to be very difficult by itself.

This rezone makes Scotts Valley’s housing problem worse. By increasing the density to 40 units per acre, it forces the property owners to go all in with an unprofitable and much larger commercial/retail investment. To make matters worse, we are expected to provide 50% of the units for low income. I don't see how this formula will make sense for any property owner.

I strongly encourage the city to be more realistic about their needs regarding the amount of commercial space on Scotts Valley Drive, as well as the financial viability of asking property owners to shoulder such a large portion of affordable housing. Under this new zoning change, I will be unable to move forward on any future development.

Comments have been noted.

Comment
from
Jeanette
Cook
Chapter 2: I do not see environmental sustainability included in any of the policies. Given the amount of growth encompassed in this plan, there should be specific actions related to mitigating and adapting to climate change. For example, requiring solar panels for new buildings. Although covered somewhat by policy Policy H-3.1, given the large number of seniors in the City, perhaps a specific goal could be included for new over-55 communities that are not mobile homes. Some of the larger sites (Valley Gardens, Avisa) could be targeted for a higher end senior community like The Villages.

Comments have been noted.

HOUSING
APPENDIX G | G - 27
Public Comments City Response
Appendix B: The projected growth in population does not seem to be aligned with the increased number of residences. Increase of 1.5% in population by 2040 (175 people) compared to the proposed addition of 1220-2000 new residences. Is the goal to attract a lot of new residents to the City and if not would not these units be vacant? Some perspective on where the people to fill these residences would come from would be helpful in understanding the plan and goals. Is it likely that there would be increased numbers of people coming from "over the hill" who would purchase single family homes? Do you anticipate a growth in jobs with local workers residing in the multi-family rental properties?
The City is mandated by the State to plan for
its Regional Housing Needs Allocation
(RHNA) based on regional housing need. The
regional housing need for Scotts Valley is
determined by the Association for Monterey
Bay Area Governments (AMBAG)
Appendix F: Why is the former Avisa site not included in this plan? More ADU's could be included and encouraged. Most parcels have room for them. The sites that contain existing buildings/use seem unlikely to be converted. Taking half of the Nob Hill shopping center? Removing the parking from the Transit Center? What would be required to make this actually happen? Bank of America on Scotts Valley Drive has a huge underutilized site. Why was it not included along with the other unlikely sites? The Lockhart Gulch Storage Locker site is problematic from the perspective of the residents of Lockhart Gulch and associated roads.

Adding 139 new residential units to this already impacted intersection will require substantial upgrades to the infrastructure.

Program H-1.5 includes a number of actions
the City is taking to proactively encourage
ADU development. The City cannot rely on
more ADUs than currently projected – the
projections must be based on past
performance and be supported with policy
programs per HCD.

Sites identified through the candidate sites
analysis have been identified as having
viable potential to be developed over the
next eight years with supportive programs
included in the Housing Plan.

Additional comments: The fact that the state is requiring the City to plan for 1,220 new units is utterly ridiculous. It does not take into account environmental factors such as terrain, access to water, wildfire risk, etc. I haven't been able to read the entire plan, but would like to see more of a push back. This could be particularly important should it actually be impossible to implement what is in this plan. I do not see traffic issues addressed anywhere. What upgrades to roads will be required to accommodate this many new drivers and trips? This aggressive growth plan will change the character of the City profoundly. Lots of good things have been implemented over the past 40+ years that I have lived here. Could there be some explicit goals that aim to retain the positive aspects that we currently enjoy? For example, including some allocation for new parks (like Skypark) and green space.

Comment has been noted.

September HCD TA Public Review Comments
Letter from
John Swift
The property at 4850 Scotts Valley Drive, APN 022-091-12 is an appropriate site to be included in the list of Candidate Sites for Mixed Use Development in the 6th Cycle Housing Element.

Previously, the City reviewed this site for
inclusion in the candidate sites inventory.

Factors that precluded the site from its

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G - 28 | APPENDIX G
Public Comments City Response
The property owners are interested in pursuing a mixed use commercial/residential redevelopment of this 39,209 S.F.; .9acre parcel. Currently the property is zoned C-2, Service Commercial. There is a small retail convenience/liquor store located at the front of the property along Scotts Valley Drive. The majority of the property , roughly 80% or 32,000 SF is located behind the existing commercial use and has been largely vacant or used for marginal outdoor storage for decades.

A portion of the rear of the property is within the flood plain. Residential units could be elevated above the flood plain by designing parking and storage at grade with housing above.

The property is 100’ wide. This is sufficient width to provide access to a residential project in the rear of the property while maintaining a viable commercial use along the Scotts Valley Drive frontage. Additional access options to the rear of the property from Carbonero Way may be possible through the adjacent properties to the east and/or south which also appear to be underdeveloped .

There is a realistic potential for 30 or more residential units on this property in addition to maintaining a viable commercial use along Scotts Valey Drive. The land value of this property exceeds the current improvement/development value of the property. The property has excellent access to transportation and community resources. The owners of the property are interested and motivated to make a productive use of this land which has been underutilized for many years. Please consider incorporating this property in the list of Potential Candidate Sites for mixed use development in the 6th Cycle Housing Element, inclusion in the inventory include its
proximity to industrial land uses to the
South, commercial redevelopment on
adjacent properties to the east to west, and
its location near the “gateway” to the City’s
industrial core area. Additionally, the City
Council provided direction to Staff at the
Joint Study Session in April 2023 to avoid
inclusion of and properties adjacent to
industrial land in the sites inventory. Based
on these factors and Council/Planning
Commission direction, the sites inventory
does not include parcels near this industrial
“gateway” area.

October HCD Resubmittal Public Review Comments
Comment
from David
Duquette
Not that anyone will listen but I will reiterate what I have said all along. I have real concern and disapproval of the 30% requirement for commercial space on Scotts Valley Drive. With the expected larger footprint that 40 units per acre is going to bring, 30% is just not workable.

Given all the existing vacant commercial/retail space up and down Scotts Valley drive, more space is not only unprofitable but not needed. I have been at every meeting regarding this Housing element and I did not hear one comment from the public or any official that did not support relaxing the commercial requirement in order to promote housing. I don't know why the city is still pushing for such a large commercial requirement. Lastly, relaxing the parking requirement is no help. Whether we like it or not, Scotts Valley is a mountain town that requires a large number of its residents to commute. Not requiring enough parking is going to only hurt the surrounding neighborhoods and jeopardize the success of any housing project.

This is only magnified by the push for a larger amount of low income housing. Lower income households have a disproportionate larger number of cars. Lower income households typically have a larger number of working adults that require more cars to get to work and or school. I Analysis on the purpose of the mixed-use
requirement decrease and the purpose of
keeping a commercial requirement has been
added to Appendix C – Housing Constraints.

In addition, the section above it includes a
development example for a theoretical
mixed-use project using the average size of
the candidate sites identified for mixed-use
rezoning and the existing mixed-use
development standards. It should also be
noted that as part of the rezonings, the City
will adopt objective design standards –
these will not be more constrictive than

HOUSING
APPENDIX G | G - 29
Public Comments City Response
personally own a low income apartment and I say this from experience. Lowering the parking requirement will only result in a failed project.
existing standards, which the analysis shows
can currently be accommodate.

Letter from
John Swift
This letter is a follow up to my previous letter dated Sept 18,2023 regarding the property at 4850 Scotts Valley Drive, APN 022-091-12. This property is an appropriate site to be included in the list of Candidate Sites for Mixed Use Development in the 6th Cycle Housing Element.

In the City’s draft response to the HCD Oct. 3, 2023 comment letter, City staff describes the redevelopment factors that are considered in the selection of candidate sites as follows:

1. Land value is greater than the improvement value. 77 percent of non-vacant sites have land values that exceed the improvement values.

2. Existing structure was built prior to 1990 (it was built over 30 years ago). 95 percent of non-vacant sites have structures built at least 30 years ago, with the majority being well over 30 years.

3. Existing uses do not include housing units. 51 percent of non-vacant sites have no existing units.

1. City-owned. 5 percent of non-vacant sites are City-owned.

2. Development interest from a housing developer and/or property owner. 9 percent of non-vacant sites have stated developer or property owner interest.

All but four of 43 total parcels have at least two identified redevelopment factors and 17 have at least three.

The subject property at 4850 Scotts Valley Drive complies with 4 out of 5 of these factors. It is not a City owned property.

Interestingly only 9% of the candidate sites have owners that have indicated their interest in pursuing redevelopment of the property.

The owners of this property have clearly expressed their interest in redeveloping this property.

The land value clearly exceeds the improvement value.

The existing structure was built prior to 1990.

The existing uses do not include housing.

My understanding of the proposed Mixed-Use policies is that only Candidate sites will be eligible for the 70/30 mix of residential uses to commercial uses. If a property in the C-S zone, subsequent to the adoption of the General Plan/Housing Element, is proposed to be developed with a mixed-use project it will be subject to the City’s current ratio of 50/50. Clearly this requirement is a disincentive for the redevelopment of these properties. The market realities of Previously, the City reviewed this site for
inclusion in the candidate sites inventory.

Factors that precluded the site from its
inclusion in the inventory include its
proximity to industrial land uses to the
South, commercial redevelopment on
adjacent properties to the east to west, and
its location near the “gateway” to the City’s
industrial core area. Additionally, the City
Council provided direction to Staff at the
Joint Study Session in April 2023 to avoid
inclusion of and properties adjacent to
industrial land in the sites inventory. Based
on these factors and Council/Planning
Commission direction, the sites inventory
does not include parcels near this industrial
“gateway” area. The parcel has not been
included in this October 2023 Draft version.

However, the City will continue to evaluate
the site given the additional information
provided by the commenter.

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G - 30 | APPENDIX G
Public Comments City Response
commercial uses will continue to make mixed use projects that are not designated as candidate sites unfeasible.

There is no guarantee that candidate sites will be proposed for redevelopment. There are many complicated factors, such as taxes, estate issues, interest rates, etc. that can influence a property owner’s decision to move forward with redevelopment. The property owners of 4850 Scotts Valley Drive are prepared to move forward with a mixed-use project that is expected to yield 30 or more housing units.

Such a project could maintain the commercial use or allow for a modernization of the commercial structure that currently exists at the property frontage of Scotts Valley Drive.

This property is over 140’ removed from the commercial/industrial uses located to the south along El Pueblo Drive and is separated by a creek and a City Water District owned parcel of land. The presence of these industrial uses is not a realistic constraint to the redevelopment of this property with residential uses.

This property has excellent access to transportation and community resources. The owners of the property are interested and motivated to make productive use of this land which has been underutilized for many years. Please consider incorporating this property in the list of Potential Candidate Sites for mixed use development in the 6th Cycle Housing Element,

C2G 4444 Scotts Valley Drive, Suite 6, Scotts Valley, CA 95066-4529 831/438-4420 • Fax 831/438-5829 • [name]@c2gengrs.com • www.civilconsultantsgroup.com 6-9-23
City of Scotts Valley
Planning Department
1 Civic Center Drive
Scotts Valley, CA 95066
Subject: Infeasibility of 70/30 Residential Mix in Commercial Zone & impact on complying with Housing Element
C2G/Civil Consultants Group, Inc. (C2G) has reviewed the initial draft of the Housing Element for the City of Scotts Valley to address their Regional Housing Need Assessment (RHNA) mandate by State Housing Law required by the State of California Department of Housing and Community (HCD). It is clear the current draft will not meet the Housing Element’s intent and is what we believe City is trying to achieve.

To substantiate this claim, C2G has run a hypothetical analysis (shown below) to help show how the proposed 70/30 mix for Mix-Use development does not go far enough in incentive a property owner to proceed with developing their property with a high residential density mix. This will result in the City drastically falling short of the RHNA numbers required in the 6th cycle.

Below C2G has shown a hypothetically vacant 1-acre property along Scotts Valley Drive that is currently zoned Commercial Service (CS) per the City’s zoning standards. Since this lot is proposed to be adjacent to other mixed-use properties residential setbacks were used. This analysis also assumes a 50/50 split between residential and commercial per the city’s current General Plan and current Zoning Standards (maximum 20 dwellings per acre).

Infeasible Housing Element

C2G 4444 Scotts Valley Drive, Suite 6, Scotts Valley, CA 95066-4529 831/438-4420 • Fax 831/438-5829 • [name]@c2gengrs.com • www.civilconsultantsgroup.com The analysis for the 1-acre property on page 1 (with current zoning requirements) would result in the following:
15,000 SQ FT of Commercial Parking (1 stall/500 SQ Ft) = 30 stalls required 15,000 SQ FT of Residential (750 SQ. FT. Units) Parking (2.2 stalls per unit) x 20 = 44 stalls 30,000 SQ FT of Total Mix-Use
38 stalls are shown, but 44 can be achieved with minor reconfiguration of the building footprint. Also assumes, commercial use does not coincide with residential use so parking can be shared.

When performing the same analysis with the proposed modification in the Draft Housing Element, the density increases (40 units/acre) and the ability to increase the residential component of the site goes up to 70-percent. Below is an exhibit of what a potential layout would look like.

This analysis for the same 1-acre property creates the following results with the 70/30 mix:
12,857 SQ FT of Commercial (30 percent) Parking (1/500) = 25 stall required 30,000 SQ FT of Residential (750 SQ. FT. Units) Parking (2.2) x 40 = 88 Stalls required 42,857 SQ FT
Parking cannot be met. This is substantially short of the required parking per the City’s current parking standards for residential.

This layout would also require a 3-story building.

With the transition from the current zoning to the proposed Housing Element zoning, you will notice that the housing is currently dictated by the commercial size. The proposed Housing Element flips the scenario

Infeasible Housing Element

C2G 4444 Scotts Valley Drive, Suite 6, Scotts Valley, CA 95066-4529 831/438-4420 • Fax 831/438-5829 • [name]@c2gengrs.com • www.civilconsultantsgroup.com where the size of the commercial square footage is dictated by the new residential density. Though the site has increased the residential component to 70-percent, the reduction in commercial is only 14% when comparing square footage size from the current zoning of commercial space.

C2G’s professional experience with developers focusing on Scotts Valley understands this reduction is not enough to offset the increase in affordable housing associated with the density increase. In order for the City to entice a developer to proceed with a project with this type of density and still have a commercial component, the commercial reduction would need to be closer to 80-percent reduction.

In order to get a 780-percent reduction in commercial area the residential component would need to be 90%.

This would result in the following exhibit below:

This analysis for the same 1-acre property creates the following results with the 90/10 mix:
3,000 SQ FT of Commercial (10 percent) Parking (1/500) = 6 stall required 30,000 SQ FT of Residential (750 SQ. FT. Units) Parking (2.2) x 40 = 88 Stalls required 33,000 SQ FT
Parking is met in this scenario.

This layout would be a podium style building and probably 4-stories in height. This would exceed the current City height requirements.

The analysis shows the suggested 70/30 does not work. The percentages would need to be 90/10 to work.

Infeasible Housing Element

C2G 4444 Scotts Valley Drive, Suite 6, Scotts Valley, CA 95066-4529 831/438-4420 • Fax 831/438-5829 • [name]@c2gengrs.com • www.civilconsultantsgroup.com C2G suggest a better option would be allowing landowners to go 100-percent residential in these areas. This would make the most sense.

Also, it needs to be pointed out that with Scotts Valley being a transit corridor, these properties would be able to implement the State’s Density Bonus Law. This could allow the density to increase by 35% with the affordable housing components required for these sites. This could increase the number of units to 54/Acre! The Density Bonus Law also reduces the parking requirements. Instead of relying on the State Density Bonus Law, it would make more sense for the City to reduce the parking requirements for these mix-use zoning areas with the new Housing Element.

To the last topic, Residential Rezoning. When examining Table F-2 in the Housing Element, the RHNA hosing goal is almost achieved without the rezoning of the three (3) suggested properties. If the Density Bonus Law was encouraged for the mix-use sites, the residential re-zoning would not be needed. Also, SB9 and ADU laws should be encouraged by the City Planning staff and proactively reach out to the community via social media, local newspapers and local service community meetings. This approach would look better (than randomly picking properties to rezone with higher density) for the City in our professional opinion.

If you have any questions on our calculations or would like to discuss them in more detail. Please call my office. Thank you.

Very truly yours,
C2G/CIVIL CONSULTANTS GROUP, Inc.

David Dauphin Todd Creamer
Vice President / Associate Engineer President/Principal Engineer

Eli May
Co-Owner, 125 Bethany Dr. Scotts Valley, CA
[email protected]
831-419-9641
June 21th, 2023
City of Scotts Valley
Planning Department
1 Civic Center Drive
Scotts Valley, CA 95066
Re: Scotts Valley Housing Element Public Review Draft
I am a co-owner of 125 Bethany Dr in Scotts Valley, which was identified as one of three properties to be rezoned in the recently released Scotts Valley Housing Element Draft Plan. The draft plan calls for changing the general plan and zoning of our 1.35-acre property from its current commercial zoning to multi-family residential use of up to 41 units.

We were surprised to learn our property was included in the housing element plan as we were never officially notified in writing at any point in time that it was being considered for rezoning.

This shocking news was particularly surprising because our property is currently the subject of an active redevelopment application with the city and has been for several years. During this time we have been working very closely with the numerous and various planners who have come and gone during this process with city staff. We currently have a completed application with the city that is entering environmental review. We believe it is incumbent on the city to process our existing application for redevelopment and remove this property from the draft housing plan.

I am also very concerned about the lack of community engagement that has failed to occur with this process. Having never been officially notified, let alone consulted, regarding our property’s inclusion in the housing plan, there was no proper opportunity to engage in the process. In fact, the Scotts Valley Press Banner noted the same issue in its article “Scotts Valley Housing Element workshop features little community input”, which noted that the most recent public meeting “was cut off after less than an hour—before all comments could be aired verbally.” This article was in response to the May 30th community workshop, which was the first meeting since the draft plan was released on May 19th. Unfortunately, the lack of public input and community engagement seriously threatens to leave the plan open to invalidation by HCD.

For these reasons and the ones explained below, this site does not actually have any real potential to be developed into 41 residential units, and I am formally requesting our property at 125 Bethany be removed from consideration in the draft plan.

Current redevelopment efforts at this property
We have been working toward obtaining approvals to redevelop this property for over 3 years.

We have applied for and paid for all application fees in excess of $40,000 as well as over $100,000 in additional reports requested by the city. We have been fully engaged in an ongoing and responsive exchange with city staff to move forward on the redevelopment of this property.

This has involved serious and continuous community engagement. We have responded to over 100 items from public works and the planning department over the course of several redesigns and resubmittals. In fact, we will be entering environmental review for our redevelopment application this month. We have engaged in an incredibly lengthy, expensive, and involved process and we don’t feel it’s appropriate to include this property on a list to be rezoned for residential while in the middle of the application process to be redeveloped. This is particularly true when the “community engagement” process employed by consultants for the housing element has been seriously lacking in transparency and invalid by comparison to the process we have engaged in for a single redevelopment application and taken extensive time to seriously implement.

We feel that we are legally entitled to proceed with processing our application under CEQA and welcome environmental review of our incredibly thoughtful and positive redevelopment plan. We are joined by our tenants and neighbors in looking forward to an approval for a new building that benefits the community and reduces - not increases - impacts.

Current Uses
The current zoning of our property is commercial professional. It currently has ~ 14,000 gross sq ft, which is 100% occupied by businesses that serve the community. The current redevelopment plan would replace the existing amount of office space and create more opportunities for local businesses to operate and grow. As part of our resubmission in April 2022 we included half a dozen letters from businesses (existing and potential tenants) imploring the city to approve our redevelopment. These uses are an important part of the local economy and its loss would be a detriment to the community.

Neglected impacts of the draft designated use
In the process of applying to redevelop our property, the city asked us to perform a number of professional reports to study the impacts of the proposed redevelopment, which we did. This included extensive and expensive studies regarding noise, traffic and parking, as well as an arborist study and an archeologist study. The results of the studies showed that our proposed redevelopment would actually reduce impacts; it does not appear any similar studies have been performed to study the impacts of 41 residential units for this draft report.

Parking & Traffic
The traffic studies we had completed for our redevelopment show a delicate balance of parking on this property. 41 residential units at this site would make trip generations skyrocket and it would simply not be possible to park all of these units at this site. Furthermore, the site is a relative island with a noisy freeway on one side with no other parking available in the immediate area, which would be a huge issue. It does not appear that our existing study has been

reviewed or that a similar study has been conducted for the specific use designated in the draft housing plan. Also, this property is at the same intersection as Vine Hill Elementary, which already causes significant congestion at the intersection during school drop-off and pick-up times. A 41-residential unit site at this intersection would further exacerbate traffic in this area, Neighbors who live on Tabor and Bethany would face far worse congestion and traffic than they already do.

Noise
This site sits along HWY 17, which creates significant noise that would not be acceptable for the 41 units without significant noise-barrier walls, and the site simply does not have the space for this. It does not appear that a study has been performed on the noise at this site for residential use, as we have done for our proposed use.

Arborist
We performed an arborist study for our redevelopment and the city has mandated that we keep existing mature trees and add more shade trees to the parking area. This condition has further inhibited the number of parking spaces we can fit. It does not seem that an arborist study has been performed for the use of 41 residential units at this site as we had been tasked with doing, as it would show a lack of necessary parking and the consequent elimination of mature trees.

These studies would show that the site is simply not equipped for this type of residential use.

Community Engagement
During the process of our redevelopment efforts, we held meetings with many stakeholders in the city including a comprehensive community engagement plan. We built a website detailing the redevelopment and sent direct mail to all of our neighbors to communicate with them about the project and point them toward the website along with contact information. It appears there has been very little community engagement around the process to create the housing element draft plan. I was not informed in writing as an owner of one of the three properties identified for rezoning. The Scotts Valley Press Banner noted the same issue in its article “Scotts Valley Housing Element workshop features little community input”.

Numerous opportunities elsewhere not identified
It is clear from the many public comments at the April 5th planning commission meeting that there are many property owners along Scotts Valley Dr that would be more than willing to build more dense residential projects, but are unable to because they would need to match 50/50 commercial to residential, which makes the projects not feasible. Allowing these property owners to build dense residential projects would create more foot traffic for the businesses along Scotts Valley Dr thus attracting more businesses and more revenue for the city. Instead, the Draft Housing Report identified only three parcels in the entire city for rezoning. We believe the city needs to look closer at other commercial parcels along Scotts Valley Dr and beyond to meet its plan. The draft housing element failed entirely to aggregate the 50/50 requirement on a larger basis - and did not assume anything for the assemblage of parcels. This is an abject failure on the part of the consultants to recognize and move on to an obvious solution.

Furthermore, we believe the draft report missed multiple appropriate and obvious opportunities elsewhere. This includes ADUs. Last year, California passed SB9 which allows for any single-family residence to build at least one ADU and in many cases more than one. Scotts Valley is truly unique in that the city contains numerous older and larger residential parcels that can take advantage of SB9 - and do so appropriately within existing residential neighborhoods.

This would not only capitalize on existing infrastructure but will also significantly disperse any impacts from this incremental approach. Yet the public draft report used historic ADU origination numbers from the last 8 years of only 3 ADUs being built per year, without taking into account the tremendous growth in ADU construction which is just now occuring from this landmark legislation. There are also many other opportunities to account for more housing such as mobile home parks, which would be an obvious choice for more dense and affordable housing.

In conclusion, rezoning the property at 125 Bethany is not appropriate for a myriad of reasons, and I formally request this property be immediately removed from the draft plan.

Sincerely,
Eli May
Co-Owner of 125 Bethany Dr. Scotts Valley CA

1 From: Charlie Eadie <[email protected]>
Sent: Thursday, June 1, 2023 10:45 AM
To: Sarah Wikle <[email protected]>
Cc: Taylor Bateman <[email protected]>; Wiseman, Bill <[email protected]> Subject: Housing Element
Hi Sarah:

Good talking to you today. Following up our conversation, here are three recommendations:

1. Add to your mixed use inventory of potential sites two parcels at 4627 Scotts Valley Drive, APNs 022-082-34.35. This site consists of just under an acre and would be a prime candidate for high density and/or mixed use high density housing.

2. Be explicit about the ratio of commercial to residential in mixed use projects in the Housing Element. The past policy in the General Plan (not the zoning ordinance) interpreted to require a 50/50 ratio (the "50 percent rule" so called), however well-intended, had the effect of killing numerous proposals for housing/commercial mixed use projects. Other jurisdictions are facilitating mixed use by either eliminating floor area ratio standards altogether, or setting the mix in a way that makes projects at least theoretically possible. For example, the County of SC now has proposed an 80/20 housing/commercial mix in their Housing Element.

3. Address processing issues. In particular, SV processing times have been extraordinarily long, and the Housing Element consultants should look into the history of that for various projects. One suggestion would be to reduce the high level of detailed engineering and other work now required by the City just to get to hearing on land use/design approval. This adds significant time and costs to getting a "complete" application, and can leave decision-makers frustrated because the project is essentially a "finished product" when they finally see it which inhibits their willingness/ability to make changes. Better to have the use and design considered and worked out before requiring the nth degree of detail in the plans.

Charles Eadie,
Principal
P.O. Box 1647, Santa Cruz, CA 95061-1647
831.431.3396 (cell) 831.426.7609 (fax)

2 [email protected] | eadieconsultants.com

June 19, 2023
To: Sarah Wikle, Senior Planner
CC: Scotts Valley City Council, Scotts Valley Planning Commission City of Scotts Valley
1 Civic Center Drive
Scotts Valley, CA 95066
RE: Draft Housing Element (May 2023)
Santa Cruz YIMBY advocates for abundant housing at all levels of affordability to meet the needs of a growing population in Santa Cruz County. We support sustainable growth, including along transportation corridors and activity centers and a commitment to lower Vehicle Miles Traveled by housing people near services and jobs.

We submit the following comments on the City of Scotts Valley’s 6th cycle Housing Element draft of May 19, 2023
1 .

Probability of Meeting Low Income Targets
“The City of Scotts Valley has facilitated the building of market rate housing in recent years, but has made little effort to develop housing for low income workers.” 2 According to the site inventory
3 Scotts Valley is expecting that all sites identified for rezoning will set aside roughly 50% of their units for very-low, low, or moderate income families, while providing little evidence that this level of affordability will be realistically produced. Meanwhile, the city’s four pipeline projects consist of only 18% affordable units. We would like the city to explain why it expects to achieve this 50% target, and how it will enable the development of additional housing if this target is not being met. For comparison, the City of Santa Cruz
4 is projecting a 20%
4 The only jurisdiction in Santa Cruz County to meet its 5th cycle goals 3 Housing Element, F-23
2 Santa Cruz Civil Grand Jury - Housing Our Workers, page 18, Finding 9 1 Scotts Valley Housing Element - Public Review Draft 5.19.2023 Santa Cruz YIMBY Response to Scotts Valley Housing Element (May 2023) Page 1 of 6

affordability rate for most parcels in its site inventory.

If the city misses its target of 50% affordability, it faces the daunting task of identifying other sites to make up the difference under No Net Loss law. With nearly half of its very-low and low income units planned for through the Town Center Specific Plan, this single project not producing as many units as expected would subject the city to this law. Additionally, there is only a 9% buffer for moderate income units, HCD recommends a buffer of between 15 and 30 percent 5 .

In order for Scotts Valley to meet the needs of its most vulnerable residents, it is essential that plans for affordable housing not only sound good, but are workable and realistic.

Pipeline Projects
A significant source of new units for the city during the 6th cycle will be from pipeline projects. For jurisdictions relying heavily on pipeline projects, HCD recommends
6 that “…the element should include programs with actions that commit to facilitating development and monitoring approvals of the projects, including the number of units and affordability (e.g., coordination with applicants to approve remaining entitlements, supporting funding applications, expediting approvals and monitoring of project progress, including rezoning or identification of additional sites, if necessary).”
In order to meet this recommendation by HCD, the city should create policies to monitor the progress of pipeline projects. This could include automatic entitlement extensions until midway through the 6th cycle and proactively reaching out to all pipeline project developers to confirm that there is still development interest.

In recent public meetings, local leaders said that they were contacting developers of existing pipeline projects to gauge their interest in resubmitting plans at a higher density or with additional units. The La Madrona and Valley Gardens projects together represent a vast majority of the city’s pipeline units. We urge the city to work with the project developers to increase the amount of multifamily and missing middle
7 housing, especially in those areas of the project site closest to Mt Hermon Road. The number of units in these two projects alone represents nearly 30%8 of the city’s RHNA, and could easily fulfill more if they were revised to have majority multifamily units. These sites offer an opportunity for Scotts Valley to demonstrate 8 On a total unit basis, not 30% of all affordability categories 7 Missing Middle Housing
6 City of Brisbane’s 6th Cycle (2023-2031) Draft Housing Element, page 3 5 Housing Element Sites Inventory Guidebook, page 22
Santa Cruz YIMBY Response to Scotts Valley Housing Element (May 2023) Page 2 of 6

leadership in building mixed density neighborhoods that bring people of different income levels together.

Goal H-1 - Housing Production
With the city’s RHNA increasing nearly tenfold from the 5th cycle, we see significant need for policies and programs which enable, not restrict, development. We applaud the city for identifying significant commercial and parking requirements as constraints to development but strongly disagree with the assertion that “...the City’s standards for lot size, setbacks, height, and site coverage are not considered [constraints]...”
9 As mentioned, the city has accurately identified its limit of 50% residential in mixed-use developments to be a constraint and is rezoning select parcels along main corridors to increase this cap to 70%.
10 We would like to see the city go further
and either remove this limitation entirely or allow for mixed-use development with an option for ground floor commercial only rather than as a percentage of total square footage. Additionally, granting this flexibility to all mixed-use projects in the city would incentivize development and allow developers to better respond to Scotts Valley’s housing shortage.

We would like to see the city commit to allowing more residential square footage in mixed-use developments if the proposed rezoning does not result in developer interest.

With regards to parking requirements, the city should go much further in reducing or even eliminating requirements and the existing programs should have stronger language. Currently, program H-1.5 does not commit to lowering parking requirements and has a timeline of 2027. We would like to see this timeline moved up and a commitment to lowering requirements to no more than half a space per unit, uncovered.

Creation of missing middle housing isn’t mentioned within the policy plan - the city should adopt zoning regulations that would incentivize this form of housing.

Examples include reducing minimum lot size, setbacks, and lot coverage restrictions.

In Redwood City’s compliant 6th cycle housing element
11 amendments such as these
are anticipated to result in an increase of at least 80 homes. Currently, duplexes are not conditionally or principally permitted in any of Scotts Valley’s zoning districts. 12 The City of Scotts Valley should seek to allow a wide variety of housing types 12 Housing Element, C-16
11 Redwood City 2023-2031 Housing Element
10 Housing Element, F-19
9 Housing Element, C-24
Santa Cruz YIMBY Response to Scotts Valley Housing Element (May 2023) Page 3 of 6

including duplexes, triplexes, fourplexes and other multifamily project types throughout the City. Much of this could be achieved without an EIR thanks to Senate Bill 10
13 .

Unaddressed Constraints
Along with the commercial and parking constraints discussed in the prior section, there are other constraints that we believe the city should address to ensure that housing can be built.

We expect projects to make use of State Density Bonus law for feasibility of development of affordable housing. Currently, Scotts Valley zoning code includes constraints and limitations that could limit affordable multifamily or mixed-use housing from achieving assumed base densities. These include but are not limited to building height, FAR, and parking requirements.

The city should better explore to what extent its density restrictions are a constraint to development. With the city’s highest density residential zoning district capped at 20 du/acre, this is likely a significant barrier. We recommend the city expand its rezoning efforts to all ‘Very High Residential’ parcels at a minimum and allow up to 40 du/acre on such parcels.

There are a number of small sites on the inventory which fall outside of the parcel size requirements set forth by AB 1397. These sites may still be included for a variety of reasons, in Scotts Valley’s case “…a program to facilitate lot consolidation.” 14 There
is no such program in the policy plan.

Town Center
One of the largest projects projected for Scotts Valley’s 6th cycle will be further development of the Town Center Specific Plan, encompassing 58 acres in the heart of the city. This area is well situated to accommodate a significant amount of housing and associated amenities. While we are pleased that the city anticipates 657 units to be built on these sites we would like to see more in the housing element to indicate that the city is determined to see this housing come to fruition.

This plan has been in the works since at least 2008
15 and has not seen a significant
amount of the proposed housing be built in that time. According to the city, “...project applications have been submitted for the Plan, but development was not successful. Interest in developing the Town Center area has increased over recent 15 Scotts Valley Town Center Specific Plan EIR
14 Housing Element, F-21
13 SB 10 - California YIMBY
Santa Cruz YIMBY Response to Scotts Valley Housing Element (May 2023) Page 4 of 6

years.”
16 Despite these failed developments and increased interest, there is no mention or analysis of the reasons for these failures or why development has not moved forward for this area in the housing element.

Additionally, we would like the city to provide more detail on the affordability projections for the Kings Village parcel
17 as part of the Town Center plan. While the
other four parcels are publicly owned (by METRO or the city) this shopping center is privately owned. The city estimates that this parcel will produce a 50% affordable project, but provides no indication that there is interest from the owner, a developer, or any other type of agreement that would be required for housing production to happen.

Mid-cycle Review
To ensure the city makes appropriate progress towards its 6th cycle goals we would like to see a commitment to a mid-cycle review and adjustment (if needed). Tying this review to programs to increase housing production such as rezoning, ADU incentives, or removing development constraints would allow the city to quickly make up lost ground and minimize impacts of falling behind in the 6th cycle. This would also be a time to review pipeline projects which have not progressed.

Additional mid-cycle programs could include:
● Ministerial approval process for all site inventory projects ● SB10 upzoning of small sites to 10 units per parcel
● Tracking commercial occupancy, and if vacancy is too high, relaxing commercial requirements in favor of more residential, including live/work units
Transit Oriented Development
Despite being home to the Cavallaro Transit Center (CTC), Scotts Valley lacks any current or planned high quality transit stops. In the 2040 MTP/SCS 18 the CTC was
identified as such a site, however, it was subsequently removed in the 2045

MTP/SCS
19 . We encourage the city to commit to working with AMBAG in the 2050 MTP/SCS (scheduled for June 2026) to designate the CTC as a planned high quality major transit stop. This designation would incentivise more sustainable, affordable, and equitable development in an area identified for a significant amount of new housing in the 6th RHNA cycle.
19 AMBAG 2045 Metropolitan Transportation Plan
18 AMBAG 2040 Metropolitan Transportation Plan
17 Parcel #022-601-18
16 Housing Element, F-12
Santa Cruz YIMBY Response to Scotts Valley Housing Element (May 2023) Page 5 of 6

Scotts Valley is currently not a pedestrian and bike friendly community. The transit center is a key connector for jobs and opportunities for low income people that do not own cars. Further investment in housing around transit stops has been shown to increase ridership on public transit. Denser housing and investments in walking and biking infrastructure between the Valley Gardens, Town Center, and the CTC could together make great strides in helping Scotts Valley achieve its housing, climate, and safety goals while also making it easier for people of all ages, abilities, and incomes to access the city.

Tenant Protections
As a city with a growing percentage of renters, it is important to have strong tenant protections. The housing element notes that “[a]bout 51.8 percent of renters are cost burdened, and 33.1 percent are severely cost burdened.” 20 There are a number of
programs we would like to see implemented or expanded in the city including:
● Elimination of or cap on rental application fees
● Creation of a rental registry. This was recently passed by both Salinas 21 and
Monterey
22 ● Local preference for people employed in the county ● COPA
23 and TOPA24 programs
● Conduct a disparate impact analysis of non-high(est) resource areas 25 and
apply a live-work preference if if it matches county demographics 25 2023 CTCAC HCD Opportunity Map
24 EBCLC's Tenant Opportunity to Purchase Act (TOPA) - East Bay Community Law Center 23 Community Opportunity to Purchase Act (COPA) | San Francisco 22 Monterey City Council moves ahead with rental registry 21 Salinas passes rental registry
20 Housing Element, B-14
Santa Cruz YIMBY Response to Scotts Valley Housing Element (May 2023) Page 6 of 6

June 2, 2023
Sarah Wikle
City of Scotts Valley, Planning Dept.

Via email: [email protected]
Subject: Comments on the 2023-2031 Housing Element
Hello Sarah. Attached are my compiled comments on the Housing Element. Most are indexed to specific policies and programs, although some include reference to information from the Appendices. There are a few comments at the end related to information in Appendices B and C.

It is rather confusing that there is identical numbering for the Policies and the Programs, as (for example) Policy H-1.1 speaks to housing variety in general while Program H-1.1 is specific to the 6th cycle RHNA.

Since this document will be used for the next 10 years, there could be some benefit to having some nomenclature distinction between these two classes (“PoH-1.1” v “PrH-1.1”, for example).

I’ll look forward to seeing the final draft. Feel free to reach out to me if there are any questions.

Michael Shulman
Scotts Valley resident
[email protected]
Cc: [email protected]

Program H-1.1 (RHNA): Table F-2 shows very encouraging numbers that bely publicly expressed concerns over the RHNA assigned to SV. Table F-6 takes an appropriately expanded view of the housing opportunities at the Town Center, recognizing the potential to redevelop certain existing parcels beyond their current singularly commercial purpose. The re-zoning opportunities along SV Drive, in addition to offering housing sites, can also generate long-needed economic revitalization along this corridor. But it is not clear why the rezoning is being proposed for only 33 identified parcels. An overlay zone that allows all property owners an ability to participate avoids the potential trap of the City attempting to pick winners-and-losers based on the ephemeral and potentially transient reasons offered on Page F-19.

Identifying just these 33 parcels also creates unjustified inequitable development opportunities between adjacent parcels that may put the City on tenuous legal footing. We can’t know who will want to redevelop or who will constructively engage in lot consolidation; properties can change hands and zoning-based advantages can simply raise the perceived value of a parcel rather than necessarily lead to its prompt development.

There should also be more consideration given to allow 100% residential along at least some portions of this corridor rather than insist on minimum 30% commercial development. There simply may not be a viable market for commercial anytime soon and the encumbrance on all properties is counterproductive.

The City’s economic viability no longer relies on the sales and business tax generation that was the basis for the non-residential legacy zoning of SV Drive. A high density residential overlay combined with PD (planned development) regulations along SV Drive, from Mt. Hermon all the way to Victor Square, could simplify and stimulate redevelopment, make great strides towards fulfilling our RHNA, and provide more resident wallets that will drive economic growth in our existing retail and employment centers.

Program H-1.4 (ADU) – ADUs are perceived as an easy fix to affordable housing challenges because their small size makes them inherently more affordable, and by spreading them out within existing neighborhoods it can diffuse the opposition often associated with larger residential developments. But we should not overlook the adverse impacts they can have on fully developed neighborhoods by introducing more cars and traffics without any commensurate expansion of infrastructure, the loss of vegetation and open space (which matters, even when on individual parcels), and the crowding of structures and potential loss of privacy (depending on how the ADU is sited). ADUs should be accommodated where they work well in a particular neighborhood but we should be cautious about incentivizing them (as per H-2.2, Design Review). We can achieve our RHNA through commercial rezoning and undeveloped residential properties without reliance on one-off ADUs that warrant selective support and individual consideration; they are essentially a neighborhood-level ‘remodel’ and the incentives should focus on retaining the positive qualities of that neighborhood rather than be driven by quantity of units. The total number of projected ADUs shown in Table F-2 (40) speak to their near irrelevance to meeting SV’s RHNA. Some actions proposed are contrary to good planning and pose enforcement challenges -- permit ready ADU plans may conflict with the character of a property or neighborhood, and affordability deed restrictions on individual property owners are intrusive, difficult to effectively regulate, and can generate conflict when the property changes hands.

Program H-1.5 (removal of constraints) – This program needs more substance; it only says we’ll talk about it and conduct research. Yet despite this ambiguity, it seems to have concluded that parking