Sonoma City Council
January 31, 2023

Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-4

COMMENTER SUMMARY OF COMMENTS RESPONSE TO COMMENTS
result in more variety in housing sizes and
prices.

5. Anna
Colichidas,
Sonoma Valley
GSMOL
• Support of mobile home communities
• Support rent stabilization, just cause eviction,
and establishing a rental registry
• Consider cost-of-living-adjustment in-leu of
rental housing cost increases
• Requests objective to integrate closure and
conversion protections from AB 2782 into the
City’s existing ordinance
• The support for mobilehome communities and
discussion of the costs and concerns related to
homeowners is noted.
• Program 10 has been revised to include
additional methods to protect tenants,
including addressing excessive rent increases
and unjust evictions. Program 13 addresses
establishing a rental registry.
• Program 11 has been updated to reflect AB
2782.

6. Keith Diggs • Expresses that the Draft Housing Element fails to remove constraints to the development of
housing, indicating that the City must
streamline its review process and design
standards now not in 2026
• Concern over actual production of homes will
meet the City’s need without bold reforms
• Concern over City’s denial that its land-use
restrictions pose a serious constraint to
housing, including parking and design review
• The commenter’s concerns are noted. The
City did expedite preparation of its objective
design standards for multifamily projects and
adopted the standards on June 15, 2022.

Programs 14 and 15 ensure the City expands
its objective standards to also address mixed
use and multi-unit projects and to provide a
streamlined ministerial approval process for
eligible projects by December 2023.
• The commenter’s concerns regarding parking
and the City’s design review process are noted.

However, the City exceeded its 5th Cycle RHNA
and has multiple projects underway with a low
income component. The City processes
projects expeditiously and the City’s
requirements do not impede development at
the upper end of allowed densities.

7. Vic Conforti • Include under-utilized commercial properties for mixed-use and affordable housing
• Commercial Zoned land is a good location for
high density housing
• Economics of residential land versus
commercial land, noting land in a commercial
• There are additional development
opportunities with the City’s underutilized
properties. The inventory of residential sites
focuses on higher density and mixed use sites
that the City can demonstrate meet HCD’s
requirements for lower income housing and on
sites that are anticipated to be developed
during the 6th Cycle. Program 3 has been
amended to identify at least 4 sites for
adaptive reuse, which could include sites in the
area identified by the commenter, by 2026.
• The City continues to promote use of
commercial land to accommodate residential
uses as described by the commenter, with
Program 3 promoting adaptive reuse of
commercial and other underutilized sites.
• The comment regarding economics of
residential versus commercial zoned land is
noted. Many of the small sites included in the
Agenda Item #2.1:

Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-5

COMMENTER SUMMARY OF COMMENTS RESPONSE TO COMMENTS
zone does not have the same demand as
residential zoned land.

Housing Element in existing residential areas
are anticipated to accommodate moderate
and/or above moderate income housing.

8. Kaitlyn
Garfield,
Housing land
Trust of
Sonoma
County
• Renters are disproportionately more cost
burdened; owners able to build equity
• Support City’s goal of ensuring those who work
in Sonoma are able to live here
• Support for City’s inclusionary policy
• Support for preserving the affordability of
existing housing stock
• All inclusionary ownership units should be
required to be affordable in perpetuity
• Inclusionary units comparable to size, finish,
construction quality to market rate units
• Units converted to affordable units should be
affordable in perpetuity
• The comments regarding disproportionate
burdens to renters versus homeowners, the
commentor’s support of the City’s goal of
ensuring those who work in Sonoma are able
to live in the city, and the commentor’s
support for the City’s inclusionary housing
policy and commitment to preserving
affordability of existing housing stock and
conversion of market rate units to long-term
affordability are noted.
• Program 1 is revised to ensure that
inclusionary units are affordable in perpetuity;
the commentor’s recommended language
regarding location and quality of units is
already reflection in Section 19.44.070 of the
Municipal Code.
• Program 15 is revised to ensure that
affordable units are provided in perpetuity.

9. Collin Thomas,
Systems
Change
Advocate with
Disability
Services and
Legal Center
(DSLC)
• Prioritize removing barriers so it is easier,
quicker, and chapter to build affordable
housing
• Preserving affordable homes from becoming
market rate should be a top priority
• Support increased awareness of Section 8
vouchers and City should encourage landlords
to accept these vouchers
• Transitional and temporary housing is another
significant need
• Review homeless services, including wraparound services, so people can get and stay housed
• Barrier to housing is lack of accessible housing
for those with mobility, vision, and sight
disabilities. Visitability increases accessible
housing supply and be aware that certain
housing types that require a lift or elevator
may be difficult to make accessible
• Design neighborhoods that are accessible for
all mobility levels with examples provided of
• Programs 14 and 15 addresses removal of
constraints to various types of housing and are
both prioritized for completion in the first year
of the planning period (by December 2023).
• Preservation of assisted housing is addressed
under Program 12 and will be implemented on
an on-going basis, with outreach to property
owners at least 18 months prior to units
potentially converting, throughout the 6th
Cycle.
• Program 9 includes annual outreach to
property owners to encourage owners to
register with the Sonoma County Housing
Authority to increase the housing stock that
accepts vouchers
• Program 15 removes barriers to transitional,
supportive, and temporary housing
• Program 24 has been updated to strengthen
the approach to ensure adequate services for
unhoused persons
• Program 23 provides an administrative
(ministerial) process for reasonable
accommodation requests. Program 22 is
revised to address visitability requirements in
the Municipal Code
• An accessible transportation network is
recognized as necessary to accommodate
Agenda Item #2.1:

Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-6

COMMENTER SUMMARY OF COMMENTS RESPONSE TO COMMENTS
sidewalk and transportation features that
improve accessibility
persons with a disability. Program 22 is revised
to ensure that the City’s Circulation Element is
updated to ensure that the City’s circulation
system provides accessibility for all persons,
including persons with a disability

10. David Brigode • Inventory of sites is exhaustive as to what may potentially become available
• Some listed sites are suitable for a single unit
and likely won’t be affordable
• The commenter identifies 4 affordable housing
opportunity sites and describes characteristics
of the sites.
• 19357 Sonoma Highway is up for sale and has
a peculiar shape, has floodplain issues, would
require curb and sidewalk setbacks, requires
hillside construction, a portion is not suitable
for housing production, and 2 affordable units
would be lost.
• 477 W Napa is landlocked, it has been argued
that a seasonal stream underlies the site, and
access may be an issue.
• 45 Napa Road (18 units) is too small.
• 69 Napa Road (51 units) has been complicated
by a large number of heirs. If this site is sold to
a market rate developer, the City’s affordable
housing pool vanishes.
• The comment regarding the extensiveness of
the inventory of sites is noted.
• The inventory of sites addresses the need for
a range of income levels and is not limited to
sites for affordable housing. The inventory of
sites identifies the affordability assumptions
for each site in Appendix A.
• Comments regarding each of the 4 sites are
addressed below.
• 19357 Sonoma Highway (57 units) is included
as it is available for development. This site is

6.08 acres with a maximum allowed density
of 20 units per acre, which would
accommodate 120 units. The Housing
Element assumes that 50% of the site would
develop with residential units, which is
backed up by the City’s development code
which allows the 50% residential requirement
to be reduced or waived only in certain
instances. This assumption that 50% of the
site would develop with residential uses
would accommodates a non-residential
component as well as site constraints.

Program 28 of the Housing Plan addresses
replacement of affordable units.
• 477 W. Napa is not landlocked – this site has
access 5th Street W. For example, a reciprocal
access agreement with the adjacent Village
Green Senior Apartments (owned by Burbank
Housing) could provide more convenient
pedestrian access to Safeway for the seniors
and disabled persons at Village Green while
providing the 477 W. Napa site with a second
access route.
• State law requires that sites identified for the
very low and low income RHNA be at least 0.5
acres and not larger than 10 acres, unless
smaller or larger sizes are demonstrated to be
feasible. This site is 0.87 acres and exceeds
the State’s 0.5-acre minimum size threshold.
• The Housing Element cannot guarantee which
sites will be sold to whom as the City does not
control the affordable housing sites. The
identification of sites is based on the density
of sites, whether the site is vacant or if
existing uses would make development less
Agenda Item #2.1:

Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-7

COMMENTER SUMMARY OF COMMENTS RESPONSE TO COMMENTS
• Address prior RHNA allocation shortfalls
• Address restrictions imposed on annexation of
suitable land outside Urban Growth Boundary
for affordable housing
• The four sites listed as suitable for affordable
housing are not likely to be so under present
market conditions. The assertion that there
will be sufficient land is misleading to the
public and masks the effects of the existing
UGB boundary.
• Stating that there is no segregation in Sonoma
is untrue.
• The Urban Growth Boundary does the
opposite of Policy H-4.2- “Incentivize the
production of affordable housing through
growth management prioritization”
• Regarding Program 1, why must we sacrifice
inclusionary affordable housing to incentivize
the takeover of any remaining vacant land for
unneeded market rate development?
• Regarding Program 2, the commentor
indicates that there is no discussion of the
status and capacity of the City’s Housing fund,
or an analysis of where the money went from
the proceeds of the former Redevelopment
agency set-aside for AH.
feasible during the 6th Cycle, and whether the
site’s density is appropriate for affordable
housing.
• The City accommodated 100% of its RHNA at
all income levels in the 5th Cycle and does not
have a carryover of unaccommodated units to
address. The commentor’s suggestion that
the City offset any overproduction of abovemoderate units is noted. This is not a requirement of housing elements.
• The Housing Element does not rely on or
include any annexations. Information
regarding one site that has requested
annexation is provided for informational
purposes but is not needed for the City’s
inventory of sites.
• As described in Chapter 4 of the Background
Report, the sites meet the criteria for
affordable housing sites. There is always the
potential that sites will be purchased by a
market rate developer and not developed
with affordable housing. To reduce this
potential, Program 19 is revised to consider
an Affordable Housing Overlay to incentivize
the development of the sites with affordable
housing. It is also noted that there are 4
additional sites included in the inventory of
sites that will provide very low and/or low
income units.
• Chapter 5 has been updated to include
additional information regarding race,
ethnicity, and segregation and the findings
have been updated accordingly to
acknowledge segregation and racially
exclusive practices affecting the community.
• The Urban Growth Boundary provides a tool
for the City to manage the pace and location
of development. The City’s growth
management program, which is the focus of
Policy H-4.2 has been placed on hold as
discussed under Program 17.
• The inclusionary housing requirement is not
implementable if it unduly constrains the
development of market rate housing or if it
requires a higher rate of inclusionary housing
than is justified.
• The City’s Housing Trust Fund was added to
Program 2 and to Table 41 of the Background
Report. The City does not have remaining
set-aside funds from the redevelopment
agency; all encumbered assets of the City’s
Agenda Item #2.1:

Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-8

COMMENTER SUMMARY OF COMMENTS RESPONSE TO COMMENTS
• Program 13 does not mention monitoring, and
taking steps to remedy, the loss of any site
described as an AH opportunity zone.
• The commenter indicates that the ability of
the City Council to exempt projects from the
Growth Management Ordinance on a case by
case basis Introduces arbitrary, non-objective
judgement by the City Council on affordable
housing development in violation of State law.
• The commenter indicates that the statement
that “ the city intends to complete the
necessary actions to meet the State AFFH
requirements.” is irrelevant word salad,
proposes absolutely nothing, and does not
acknowledge the data in Table 1 or offer any
remedies to the obvious state of racial and
ethnic imbalance currently extant in Sonoma
and furthered by the City’s housing policies,
including the UGB.
• The commentor asks once vacant land is used
up, what is left to re-zone for affordable
housing?
• Adopt moratorium on market rate housing
• Adopt 50% inclusionary housing requirement
for 80% of less AMI populations.
• Institute affordable housing overlay
former redevelopment agency were
transferred to the Community Development
Commission by operation of law.
• Program 27 addresses monitoring and
replacement of housing inventory sites to
ensure no net loss in accordance with State
law.
• The GMO is currently on hold, as previously
described. However, the ability of the City
Council to exempt projects from the GMO is
not a constraint on affordable or other
housing as it allows the City Council the
opportunity to further incentivize affordable
housing projects. However, Program 17
ensures that, should the GMO be reactivated,
that it be monitored in conjunction with
Program 13 and modified to ensure adequate
incentives are provided for affordable housing
and fulfillment of regional housing needs.
• This comment is noted. The AFFH analysis
has been updated, along with references to
Program 22 and other relevant programs to
address AFFH issues.
• Jurisdictions that do not have adequate
vacant land must identify underutilized
(nonvacant) sites for reuse or intensification
or identify lands for annexation.
• A moratorium on market rate housing is not
necessary and would have a negative effect
on the Statewide housing shortage. The City
requires market rate housing to provide
affordable units through the inclusionary
requirement and has identified adequate sites
to accommodate the RHNA, including very
low, low, and moderate income units.
• A 50% inclusionary requirement would
constrain market rate housing and would not
be supportable by a nexus or other study to
justify such a high percentage.
• Program 19 is revised to consider an
Affordable Housing Overlay to incentivize the
development of the sites with affordable
housing.

Agenda Item #2.1:

Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-9

COMMENTER SUMMARY OF COMMENTS RESPONSE TO COMMENTS
• Require residency requirement for new
residential construction
• Require annual tax on unoccupied primary
residences
• Urban Growth Boundary is an impediment to
affordable housing creation
• Utilize eminent domain to acquire suitable
sites
• Requiring a residency requirement for all new
residential construction would severely limit
residential development as the City’s RHNA is
intended to accommodate the City’s fairshare of regional housing growth and not solely benefit City residents. This would also
perpetuate existing fair housing patterns
referenced by the commentor.
• Program 6 is added to address second homes,
including approaches to reduce second
homes and develop funding mechanisms to
address the effect second units have on
diminishing the housing supply available for
year-round occupancy.
• The commentor’s concern regarding the
Urban Growth Boundary is noted. The City
has adequate capacity to accommodate its
RHNA without annexation.
• Eminent domain is a lengthy, costly process
that would likely delay the provision of
housing. The City has a track record of
working successfully with developers and
non-profits for the development of affordable
housing and will continue to follow its
successful approach.

11. Fred Allebach • Reference source not found throughout Housing Element
• No substantiation of the statements by
reference source
• This comment was provided during the public
review period. The missing references were to
5 of the tables in the document. The
references were fixed and an updated version
of the Draft Housing Element, with an
explanation of the corrections on the cover,
was provided to the public on August 29, 2022.

12. David Eichar • Consider rezoning vacant lots to higher density would allow for apartment buildings and/or
condominiums to be built on the major
thoroughfare
• This comment is noted. Program 4 promotes
development of alternatives to single family
units, including duplexes, triplexes, fourplexes,
and cottage/courtyard housing. Program 19
was revised to review opportunities to apply
an Affordable Housing Overlay to provide for
increased densities and a greater variety of
housing types on lots with potential for
multifamily housing. Program 16 is revised to
address two recent bills, Assembly Bill 2011
and Senate Bill 6 that provide for streamlined
review and approval of eligible projects.

13. David Brigode • Questioned whether certain sites listed as suitable for affordable housing are under legal
control by a noon-profit developer and the
criteria for listing these as affordable housing
sites
• The referenced sites are not controlled by a
non-profit developer dedicated to 100%
affordable housing. The sites meet the size
and density criteria for affordable housing as
described in under Section 3, Realistic Capacity
and Affordability, in Chapter 4 of the
Background Report.

Response to Fred Allenbach comments to be added.

Agenda Item #2.1:

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NOTICE OF EXEMPTION
To: Office of Planning and Research From: City of Sonoma P.O. Box 3044, Room 212 No. 1 The Plaza
Sacramento, CA 95812-3044 Sonoma, CA 95476
Sonoma County Clerk-Recorder
585 Fiscal Drive Room 103
Santa Rosa, CA 95403
Project Title: 6th Cycle Housing Element Update
Project Location: City of Sonoma - Citywide
Project Description: The Project is an update to the Housing Element of the City of Sonoma 2020 General Plan that was adopted by the City of Sonoma in 2006. State Housing Law (Government Code Section 65580 [et. seq.]) mandates that local governments must adequately plan to meet the existing and projected housing needs of all economic segments of the community. Upon its adoption, the 6th Cycle Housing Element will become part of the Sonoma 2020 General Plan. The Housing Element historically has been updated every five to eight years to address changing community needs. The proposed 6th Cycle Housing Element Update covers the State of California’s designated eight-year planning period from January 31, 2023 through January 31, 2031.

In compliance with State Housing Element Law requirements, the City of Sonoma has prepared the Project to:
• Provide goals, policies, quantified objectives and scheduled programs to preserve, improve and develop housing,
• Identify and analyze existing and projected housing needs for all economic segments of the community, • Identify adequate sites that are zoned and available within the 8-year housing cycle to meet the City’s fair share of regional housing needs at all income levels, • Affirmatively further fair housing,
• Be certified (approved) by the State Department of Housing and Community Development (HCD) as complying with State law, and
• Be internally consistent with other parts of the General Plan The Housing Element of the General Plan provides policies and programs to: encourage residential development in the City to be affordable to a range of household incomes, consistent with the City’s share of regional housing needs; encourage residential development to accommodate special needs groups; support the maintenance and improvement of existing housing stock; mitigate governmental constraints to the development of housing as required by state law; identify available financial and organizational resources for housing; identify adequate sites to accommodate the City’s housing needs; encourage energy-efficiency in residential developments, and affirmatively further fair housing.

The 6th Cycle Housing Element includes the City’s “Housing Plan”, which includes the goals, policies, and programs the City will implement to address constraints and needs. The City’s overarching objective is to ensure that decent, safe housing is available to all current and future residents at a cost that is within the reach of the diverse socio-economic segments which comprise Sonoma. To this end, the Housing Plan focuses on:
• Housing diversity,
• Housing affordability,
Agenda Item #2.1:

298712.v1
• Housing and neighborhood preservation,
• Reducing governmental constraints,
• Equal housing opportunities and
• Environmental sustainability.

For a complete project description, please see Attachment A (Environmental Checklist – Sonoma 6th Cycle Housing Element).

Lead Agency: City of Sonoma
Lead Agency Contact: Wendy Atkins, Associate Planner
Applicant: N/A (City is carrying out project)
Exemption Status: Ministerial [Section 21080(b)(1); 15268]; Declared Emergency [Section 21080(b)(3); 15269(a)];
Emergency Project [Section 21080(b)(4); 15269(b)(c)];
General Rule [Section 15061(b)(3)];
Categorical Exemption. [state type and section number]
Statutory Exemption [state code number]
Other

REASONS WHY THIS PROJECT IS EXEMPT OR DOES NOT REQUIRE FURTHER ENVIRONMENTAL DOCUMENTATION:

The 2023-2031 Housing Element would not result in any direct or indirect physical changes to the environment.

The Housing Element update is strictly a policy document and does not provide entitlements to any specific land use projects. The document contains goals, policies, and programs aimed at accommodating the City’s Regional Housing Need Allocation of 311 housing units by 2031. The proposed project does not entitle, propose, or otherwise require the construction of new development or rehabilitation of existing development, but rather includes goals and policies to facilitate the development and rehabilitation of housing consistent with existing and proposed uses identified in the General Plan and allowed under the Zoning Ordinance, including housing projects mandated to be accommodated under State law.

The Housing Element supports population growth that is mandated to be accommodated by the State; the City does not have the discretion to decrease the 311 units allocated to the City through the Regional Housing Need Allocation Plan adopted by the Association of Bay Area Governments. Further, the City does not have the discretion to disapprove housing projects and densities that are mandated to be accommodated by State law, including State density bonus standards and by-right development that meets specific criteria where office, retail, or parking uses are a principally permitted use. The Housing Element focuses on accommodating development that is mandated by the State, has been planned for the Bay Area region by the Metropolitan Transportation Commission, ABAG, and is consistent with the Plan Bay Area 2050 Blueprint which addresses regional growth, transportation, and sustainability. The Housing Element does not identify any new areas for urbanization or growth, beyond those areas where development is accommodated under the General Plan, Zoning Ordinance, and State law.

As previously described, there are no development projects entitled by the Housing Element and the Housing Element does not include site-specific project design and development details.

Agenda Item #2.1:

298712.v1
Implementation of future programs and consideration of future development projects will be on a project-byproject basis, subject to individualized and project-specific analysis under CEQA. All future housing development projects will be considered a project under the California Environmental Quality Act and will be subject to sitespecific review to address project-specific impacts. The Housing Element goals, policies, and programs would not change the rate of development nor result in any new development projects as the Housing Element relies on sites identified for development by the General Plan and Zoning Ordinance and does not project densities beyond those planned by City documents and mandated to be accommodated by State law. The Housing Element also includes goals, policies, and programs to reduce constraints to housing. These goals, policies, and programs address land use designations that currently allow urban levels of development and would not result in any changes to the intensities or densities of allowed uses.

The proposed Housing Element was reviewed and analyzed through the preparation of the current Appendix "G" Environmental Checklist Form, contained in the CEQA Guidelines, to determine if any adverse effect to any environmental issue areas would occur. As shown in Attachment A, it was determined that the proposed Housing Element Update would not result in any adverse effect to any environmental issue area, including aesthetics, agricultural/forestry resources, air quality, biological resources, cultural resources, energy, geology/soils, greenhouse gases emissions, hazards and hazardous materials, hydrology/water quality, land use/planning, mineral resources, noise, population/housing, public services, recreation, transportation, tribal cultural resources, utilities/service systems, wildfire, cumulative impacts, or substantial adverse effects to human beings.

Therefore, the Housing Element Update is exempt from the provisions of the California Environmental Quality Act (CEQA) as set forth in Section 15061(b)(3) of the State CEQA Guidelines.

City of Sonoma
By __________________________________
Wendy Atkins, Associate Planner
City of Sonoma
Planning Department
(707) 933-2204
Date: January 6, 2023
Attachment A
Environmental Checklist – Sonoma 6th Cycle Housing Element Agenda Item #2.1:

298712.v1
Attachment A
Environmental Checklist
Sonoma 6th Cycle Housing Element
Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 1

INTRODUCTION
The following pages provide an analysis of the proposed City of Sonoma 6th Cycle Housing Element (Project) with respect to the Project’s potential to result in a significant environmental effect. The findings presented below demonstrate that no additional environmental analysis is required under the California Environmental Quality Act (CEQA) prior to approval of the proposed Project.

PROJECT DESCRIPTION

PROJECT LOCATION AND SETTING
The update to the Housing Element is a city-wide project. The City is located within the Sonoma Valley and is bounded by unincorporated Sonoma County on all sides. The approximately 2.74- square mile City is accessed primarily via Highway 12. The Housing Element focuses on actions and sites within the City limits and does not identify any sites for annexation.

BACKGROUND
The Project is an update to the Housing Element of the City of Sonoma 2020 General Plan that was adopted by the City of Sonoma in 2006. State Housing Law (Government Code Section 65580 [et. seq.]) mandates that local governments must adequately plan to meet the existing and projected housing needs of all economic segments of the community. Upon its adoption, the 6th Cycle Housing Element will become part of the Sonoma 2020 General Plan. The Housing Element historically has been updated every five to eight years to address changing community needs.

This current Housing Element covers the State of California’s designated eight-year planning period from January 31, 2023 through January 31, 2031. The Housing Element is the only element of the General Plan that must be submitted to State of California, Department of Housing and Community Development (HCD) in order to determine compliance with State laws. The draft Housing Element was submitted to HCD on October 26, 2022. HCD has 90 days to review the draft Housing Element and provide comments back to the City, which will be addressed in the draft Housing Element.

State requirements for Housing Elements are more detailed and exacting than for any other General Plan element. California Government Code Sections 65580 through 65589 require that Housing Elements contain:
• An assessment of housing needs and an inventory of resources and constraints relevant to meeting those needs;
• A statement of the community’s goals, quantified objectives, and policies relevant to the maintenance, improvement, and development of housing; and • A program that sets forth an 8-year schedule of actions that the local government is undertaking or intends to undertake, with specified timetables, to implement the policies to achieve the goals and objectives of its Housing Element.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 2
As required by state law, this 6th Cycle Housing Element identifies residential sites adequate to accommodate a variety of housing types for all income levels, analyzes governmental constraints to housing maintenance, improvement, and development; addresses conservation and improvement of the condition of the existing affordable housing stock; and outlines policies to promote housing opportunities for all persons. The projected housing needs for the City of Sonoma during the planning cycle were determined through the Regional Housing Need Allocation (RHNA) process. State of California Housing Element law (Section 65583 of the California Government Code) requires that the Housing Element of each jurisdiction include an estimate of its “fair share” of the regional housing needs. For the City of Sonoma, the RHNA was established by the Association of Bay Area Governments (ABAG) pursuant to Section 65584 of the California Government Code. On December 16, 2021, ABAG adopted the Final Regional Housing Needs Allocation (RHNA) Plan: San Francisco Bay Area, 2023-2031 (RHNA Plan), which established the RHNA for each jurisdiction in its nine-county area.

The RHNA Plan allocated 311 units as the fair share for the City of Sonoma to accommodate for the 6th Cycle Housing Element Planning Cycle, consisting of 83 units for Very Low Income Households, 48 units for Low Income Households, 50 units for Moderate Income Households, and 130 units for Above Moderate Income Households. State law and the RHNA Plan do not mandate that these units be constructed; they do, however, require that the City demonstrate adequate zoning and available vacant and underutilized lands to meet this projected need. The RHNA Plan for the San Francisco Bay Area incorporates the following statutory objectives:

Objective 1: Increase housing supply and mix of housing types, tenure and affordability in all cities and counties in an equitable manner.

Objective 2: Promote infill development and socioeconomic equity, protect environmental and agricultural resources, encourage efficient development patterns and achieve greenhouse gas emissions reduction targets.

Objective 3: Promote improved intraregional jobs-housing relationship, including balance between low-wage jobs and affordable housing.

Objective 4: Balance disproportionate household income distributions (more high-income RHNA to lower-income areas and vice-versa).

Objective 5: Affirmatively further fair housing.

CHARACTERISTICS OF THE PROPOSED PROJECT
The project analyzed herein involves the 6th Cycle Housing Element Update. The proposed update would not modify the 2020 General Plan Land Use Map, land use designations, or intensities/densities identified within the 2020 General Plan Land Use and Design Element. No changes to the maximum development potential approved for the 2020 General Plan would occur with the proposed Project.

In compliance with State Housing Element Law requirements, the City of Sonoma has prepared the Project to:

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 3
• Provide goals, policies, quantified objectives and scheduled programs to preserve, improve and develop housing
• Identify and analyze existing and projected housing needs for all economic segments of the community
• Identify adequate sites that are zoned and available within the 8-year housing cycle to meet the City’s fair share of regional housing needs at all income levels • Affirmatively further fair housing
• Be certified (approved) by the State Department of Housing and Community Development (HCD) as complying with State law
• Be internally consistent with other parts of the General Plan

HOUSING ELEMENT ORGANIZATION
The proposed Housing Element Update covers the 2023-2021 planning period and is comprised of the following components:

Part 1: Housing Plan
Part 1 of the 6th Cycle Housing Element is the City’s “Housing Plan”, which includes the goals, policies, and programs the City will implement to address constraints and needs. The City’s overarching objective is to ensure that decent, safe housing is available to all current and future residents at a cost that is within the reach of the diverse socio-economic segments which comprise Sonoma. To this end, the Housing Plan focuses on:
• Housing diversity,
• Housing affordability,
• Housing and neighborhood preservation,
• Reducing governmental constraints,
• Equal housing opportunities and
• Environmental sustainability.

The Housing Plan includes only minor modifications to the City’s current Housing Element Goals and Policies. The Housing Plan includes a number of new programs to address State housing law including future required updates to the City’s Zoning Ordinance, new programs to support affirmatively furthering fair housing, and tracking and reporting requirements for Housing Sites.

Part 2: Background Report
Part 2 of the Project is the “Background Report” which identifies the nature and extent of Sonoma’s housing needs, including those of special populations, potential housing resources (land and funds), potential constraints to housing production, and energy conservation opportunities. In addition to identifying housing needs, the Background Report also presents information regarding the setting in which these needs occur. The Background Report comprehensively updates the background context and conditions identified in the City’s current Housing Element.

Appendices
Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 4
Appendix A presents the Inventory of Residential Sites. The Housing Element must include an inventory of land suitable and available for residential development to meet the City’s regional housing need by income level. The California Department of Housing and Community Development (HCD) requires that the Housing Sites Inventory be prepared using a Stateapproved format, included as Appendix A. No increases in maximum permitted density or intensity are proposed to accommodate the City’s Regional Housing Needs Allocation (RHNA); future residential development is expected to occur in those areas already identified for residential uses including land within mixed-use areas identified in the 2020 General Plan. All sites identified in the City’s Housing Sites Inventory are currently identified for new development consistent with the potential development capacities identified in Appendix A.

Appendix B presents the Balancing Act submissions from the public. Appendix C presents the responses to the Housing Needs and Priorities Survey. Appendix D presents the responses to the Stakeholders Survey. Appendix E provides a summary of the comments on the Public Review Draft 6th Cycle Housing Element and responses to the comments.

HOUSING ELEMENT APPROACH
The update to the Housing Element re-examined the Goals, Policies, and Programs of the 2015- 2023 Housing Element that gave direction to the City’s housing program, as well as progress that had been made toward their attainment. The 6th Cycle Housing Element update proposes a set of Goals, Policies and Programs focused on accommodating housing development, preserving the existing affordable housing stock, maintaining and improving housing, removing both governmental and non-governmental constraints to housing development, maintenance, rehabilitation, and preservation, affirmatively promoting fair opportunities in housing, and encouraging energy conservation.

HOUSING ELEMENT ORGANIZATION
The Housing Element goals, policies, and programs address:
• Housing diversity,
• Housing affordability,
• Housing and neighborhood preservation,
• Reducing governmental constraints,
• Equal housing opportunities and
• Environmental sustainability.

CAPACITY TO MEET REGIONAL HOUSING NEEDS
The Housing Element plans for housing to be accommodated on sites identified for residential, mixed use, and other development types in its adopted General Plan. As drafted, the HCD Review Draft 6th Cycle Housing Element does not include any changes to the General Plan land use map to accommodate the City’s housing needs. The Project will accommodate densities and intensities allowed under the General Plan and Zoning Ordinance, including increased densities where mandated to be allowed under State law. There are no site-specific development projects or entitlements that are proposed as part of the Housing Element. Upon adoption, the 6th Cycle Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 5
Housing Element will replace the City’s adopted 2015-2023 Housing Element, which was adopted in 2015.

The adoption of the Housing Element update will not result in the approval of specific housing projects. Nor will the adoption of the Housing Element update result in changes to the physical environment. The Housing Element is a policy document. All future housing projects will require that a project-specific environmental review occur to address the requirements of the CEQA prior to specific project approval. After adoption and certification of the Housing Element update, the City will review specific housing development proposals based on their compliance with the City of Sonoma 2020 General Plan, City of Sonoma Zoning Code, and any other applicable ordinances or regulations. Additional environmental review of potential impacts of any specific project will be performed pursuant to the requirements of CEQA as projects are submitted. Being in compliance with the Goals, Policies and Programs of the Housing Element alone, will not ensure project approval.

ENVIRONMENTAL CHECKLIST
This section incorporates the most current Appendix "G" Environmental Checklist Form, contained in the CEQA Guidelines. Impact questions and responses are included in both tabular and narrative formats for each of the 18 environmental topic areas.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 6
I. AESTHETICS -- WOULD THE PROJECT:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No Impact
a) Have a substantial adverse effect on a scenic
vista? X
b) Substantially damage scenic resources,
including, but not limited to, trees, rock
outcroppings, and historic buildings within a state
scenic highway?
X
c) In non-urbanized areas, substantially degrade
the existing visual character or quality of public
views of the site and its surroundings? If the
project is in an urbanized area, would the project
conflict with applicable zoning and other
regulations governing scenic quality?
X
d) Create a new source of substantial light or glare
which would adversely affect day or nighttime
views in the area?
X

RESPONSES TO CHECKLIST QUESTIONS
Responses a), b), c), d): No Impact. The 6th Cycle Housing Element identifies a projected need for 311 housing units to be accommodated through 2031. The Project identifies an inventory of sites with capacity under the existing General Plan, zoning, and requirements of State law that can accommodate the projected need. However, the element does not specifically identify the location, type, or design of future development projects and would not result in any direct or indirect physical changes to the environment. The proposed Housing Element update does not contain Goals, Policies or Programs that encourage the intensification of development in areas that would affect scenic vistas or other scenic areas. Additionally, the proposed Housing Element update does not change programs or policies that provide regulatory guidance for aesthetics.

Future development would be required to comply with applicable City requirements, including the 2020 General Plan, Zoning Ordinance and development standards. The Housing Element encourages a variety of housing types, including dense, mixed-use housing development, within areas of the City that are already designated and zoned to accommodate housing with adequate existing or planned infrastructure to support development, in compliance with the City’s 2020 General Plan, the Zoning Ordinance, and mandates of State law to accommodate eligible housing projects. Therefore, the 6th Cycle Housing Element would have no impact on aesthetic resources.

Agenda Item #2.1:

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II. AGRICULTURE AND FOREST RESOURCES: WOULD THE PROJECT:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of the
California Resources Agency, to non-agricultural
use?
X
b) Conflict with existing zoning for agricultural use,
or a Williamson Act contract? X
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code
section 1222(g)) or timberland (as defined in Public
Resources Code section 4526)?
X
d) Result in the loss of forest land or conversion of
forest land to non-forest use? X
e) Involve other changes in the existing environment
which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or
conversion of forest land to non-forest use?
X

RESPONSES TO CHECKLIST QUESTIONS
Responses a), b), c), d), e): No Impact. The adoption of the 6th Cycle Housing Element will not in itself result in an impact to Important Farmlands (Prime, Unique, Statewide or Local Important Farmlands), Timberland Production Zones nor will it conflict with existing zoning for agricultural use or a Williamson Act contract. The analysis of lands inventoried identified that the City has sufficient vacant and underutilized land within residential, commercial, and mixed use zoning districts to accommodate the City’s projected housing needs. The Housing Element encourages a variety of housing types, including dense, mixed-use housing development, within areas of the City that are already designated and zoned to accommodate housing with adequate existing or planned infrastructure to support development, in compliance with the City’s 2020 General Plan, the Zoning Ordinance, and mandates of State law to accommodate eligible housing projects. None of these lands are located on designated forest or timberland parcels. It is possible that some residential development could occur on agricultural parcels, however this development would be limited to areas designated for urbanization and development under the General Plan and Zoning Ordinance and would be required to be consistent with existing zoning and general plan designations and would also be required to be designed in a manner that minimizes potential impacts to agricultural parcels. Therefore, the 6th Cycle Housing Element would have no impact on agricultural/forestry resources.

Agenda Item #2.1:

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III. AIR QUALITY -- WOULD THE PROJECT:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Conflict with or obstruct implementation of the
applicable air quality plan? X
b) Result in a cumulatively considerable net increase
of any criteria pollutant for which the project region
is non-attainment under an applicable federal or
state ambient air quality standard?
X
c) Expose sensitive receptors to substantial
pollutant concentrations? X
d) Result in other emissions (such as those leading
to odors adversely affecting a substantial number of
people?
X

EXISTING SETTING
The City of Sonoma is located within the San Francisco Bay Area Air Basin, which comprises Alameda, Contra Costa, Marin, Napa, San Francisco, San Mateo, and Santa Clara counties, the southern portion of Sonoma, and the southwestern portion of Solano County. The Bay Area Air Quality Management District (BAAQMD) has jurisdiction over air quality issues throughout City of Sonoma. The BAAQMD is one of 35 local Air Districts in California and is responsible for monitoring and enforcing local, state, and federal air quality standards in City of Sonoma. Air Districts in California must develop regulations based on the measures identified in the Clean Air Act and its Clean Air Plan, as well as state regulations to ensure reduced emissions in compliance with these federal and state regulations.

RESPONSES TO CHECKLIST QUESTIONS
Response a), b), c), d): No Impact. The 6th Cycle Housing Element would not result in any direct or indirect physical changes to the environment. The Housing Element update is a policy document and does not provide entitlements to any specific land use projects. The proposed Housing Element update does not revise, replace or attempt to supersede any existing air quality standards adopted by the City, the BAAQMD, or the State of California. The Housing Element encourages a variety of housing types, including dense, mixed-use housing development, within areas of the City that are already designated and zoned to accommodate housing with adequate existing or planned infrastructure to support development, in compliance with the City’s 2020 General Plan, the Zoning Ordinance, and mandates of State law to accommodate eligible housing projects. Individual future development proposals will be subject to project-specific environmental review to ensure that the project will be in compliance with local and regional standards and procedures for minimizing impacts to air quality. Therefore, the 6th Cycle Housing Element would have no impact on air quality.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 9
IV. BIOLOGICAL RESOURCES -- WOULD THE PROJECT:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Have a substantial adverse effect, either directly
or through habitat modifications, on any species
identified as a candidate, sensitive, or special status species in local or regional plans, policies, or
regulations, or by the California Department of Fish
and Game or U.S. Fish and Wildlife Service?
X
b) Have a substantial adverse effect on any riparian
habitat or other sensitive natural community
identified in local or regional plans, policies,
regulations or by the California Department of Fish
and Game or US Fish and Wildlife Service?
X
c) Have a substantial adverse effect on state or
federally protected wetlands (including, but not
limited to, marsh, vernal pool, coastal, etc.) through
direct removal, filling, hydrological interruption, or
other means?
X
d) Interfere substantially with the movement of any
native resident or migratory fish or wildlife species
or with established native resident or migratory
wildlife corridors, or impede the use of native
wildlife nursery sites?
X
e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
X
f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community
Conservation Plan, or other approved local, regional,
or state habitat conservation plan?
X

RESPONSES TO CHECKLIST QUESTIONS
Response a), b), c), d): No Impact. The City of Sonoma encompasses approximately 2.74 square miles in central California. The City is located in the Bay Area/Delta Bioregion, which is home to varies habitats and vegetation and is a biologically diverse area. Coastal prairie scrub, mixed hardwoods and valley oaks are found among the rolling hills and mountains that descend to the ocean. Eucalyptus, manzanita, northern coastal scrub, California buttercups, goldfields, and Tiberon mariposa lily also are popular in the bioregion.

Within the Bay Area/Delta Bioregion, the City is located in the Sonoma Creek Watershed. The Sonoma Resource Conservation District indicates that the Sonoma Creek Watershed contains a great diversity of vegetation types and a diverse range of habitats. Approximately 26% of the watershed was vegetated by closed forest or woodland, 14% by grassland, 7% by chaparral, 10% by seasonal wetland, and 1% by riparian forest. Mountain lions and white-tailed deer frequent Sonoma Valley, with other species that inhabit the Sonoma Valley including beaver, black bear, Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 10
gray fox, bobcat, coyote, chinook salmon, steelhead/rainbow trout, Pacific giant salamander, bald eagle, golden eagle, northern spotted owl, and pileated woodpecker. Sonoma Valley has an estimated 20% of California’s biodiversity in an area that is 10% of Sonoma County. The Sonoma Watershed provides habitat for many species that are listed as threatened, endangered, and species of special concern (https://https://sonomarcd.org/district-watersheds/sonoma-creek/, December 2022).

The adoption of the 6th Cycle Housing Element, itself, would not result in any direct or indirect physical changes to the environment; therefore, it would not result in potential impact to biological resources. The Project is a policy document focused on addressing the City’s existing and future housing needs. All future development projects will be subject to project-specific environmental review to address impacts to biological resources, consistent with the requirements of CEQA and the 2020 General Plan. The Housing Element encourages a variety of housing types, including dense, mixed-use housing development, within areas of the City that are already designated and zoned to accommodate housing with adequate existing or planned infrastructure to support development, in compliance with the City’s 2020 General Plan, the Zoning Ordinance, and mandates of State law to accommodate eligible housing projects. The Housing Element does not identify any new areas for urbanization or growth, beyond those areas where development is accommodated under the General Plan, Zoning Ordinance, and State law.

The proposed Housing Element update does not revise, replace or attempt to supersede any existing sensitive biological resource protection standards adopted by the City. Therefore, there is no impact to biological resources.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 11
V. CULTURAL RESOURCES -- WOULD THE PROJECT:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Cause a substantial adverse change in the
significance of a historical resource pursuant to in §
15064.5?
X
b) Cause a substantial adverse change in the
significance of an archaeological resource pursuant
to § 15064.5?
X
c) Disturb any human remains, including those
interred outside of formal cemeteries? X

RESPONSES TO CHECKLIST QUESTIONS
Response a), b), c): No Impact. Cultural and historic resources are documented to occur within the City. The City of Sonoma is located in Coast Miwok territory, which at the time of European contact extended from modern day Marin County into southern Sonoma County. Villages were located to facilitate access to food resources at various times of year. The Coast Miwok moved among residences on the coast, around salt or freshwater marshes and on interior streams so that they would be close to the most abundant food supply available at a particular season.

Archeology has provided an extensive collection of the stone tools that were used, but it is clear from ethnology that basketry and cordage were used for the majority of utilitarian objects.

Through much of aboriginal California, shell beads served as a form of currency. As a coastal people, the Coast Miwok had access to the raw material and bead manufacture was an important industry because it provided currency to trade for goods from neighboring groups. The Coast Miwok used imported obsidian in making arrowheads and other edged tools and chert to form more utilitarian edged implements.

The Project area is located on lands once claimed by the Mission San Francisco Solano de Sonoma (Sonoma Mission), which was the last of the 21 California missions to be built, and the most northerly. In 1835, the Plaza de Sonoma was founded by Vallejo at Sonoma Mission with the new pueblo laid out around the plaza. Vallejo’s home, barracks and a number of adobes were built around the plaza in the 1840s. The lands of the Pueblo of Sonoma totaled 5,872 acres, with ownership confirmed in 1851.

The 6th Cycle Housing Element would not result in any direct or indirect physical changes to the environment. Additionally, the Housing Element update does not change programs or policies that provide regulatory guidance for cultural resources. The Project is a policy document focused on addressing the City’s existing and future housing needs. All future development projects will be subject to project-specific environmental review to address impacts to cultural resources. As previously described, the Housing Element encourages a variety of housing types, including dense, mixed-use housing development, within areas of the City that are already designated and zoned to accommodate housing with adequate existing or planned infrastructure to support development, in compliance with the City’s 2020 General Plan, the Zoning Ordinance, and Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 12
mandates of State law to accommodate eligible housing projects. The Housing Element does not identify any new areas for urbanization or growth, beyond those areas where development is accommodated under the General Plan, Zoning Ordinance, and State law. Overall, the 6th Cycle Housing Element would have no impact on cultural resources.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 13
VI. ENERGY-- WOULD THE PROJECT:

Would the project:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Result in potentially significant environmental
impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project
construction or operation?
X
b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency? X

RESPONSES TO CHECKLIST QUESTIONS
Responses a), b): Appendix F of the State CEQA Guidelines requires consideration of the potentially significant energy implications of a project. CEQA requires mitigation measures to reduce “wasteful, inefficient and unnecessary” energy usage (Public Resources Code Section 21100, subdivision [b][3]). According to Appendix F of the CEQA Guidelines, the means to achieve the goal of conserving energy include decreasing overall energy consumption, decreasing reliance on natural gas and oil, and increasing reliance on renewable energy sources. In particular, the proposed project would be considered “wasteful, inefficient, and unnecessary” if it were to violate state and federal energy standards and/or result in significant adverse impacts related to project energy requirements, energy inefficiencies, energy intensiveness of materials, cause significant impacts on local and regional energy supplies or generate requirements for additional capacity, fail to comply with existing energy standards, otherwise result in significant adverse impacts on energy resources, or conflict or create an inconsistency with applicable plan, policy, or regulation.

The proposed 6th Cycle Housing Element, itself, would not result in an impact to energy resources. The Housing Element update is a policy document and does not provide entitlements to any specific land use projects. The document contains Goals, Policies and Programs aimed at accommodating 311 housing units by 2031; however, the Element itself does not provide any entitlements for the construction of these units. As required by the RHNA Plan, the City is required to demonstrate adequate sites to meet the needs of all income levels and special needs groups. The proposed Housing Element update encourages development in infill areas and areas planned for urbanization where the density can be supported by existing and planned infrastructure. Individual future housing development proposals will be subject to projectspecific review to ensure that the project will be in compliance with local and regional standards and procedures for minimizing short-term and long-term effects related to wasteful, inefficient or unnecessary consumption of energy resources.

As proposed, all future housing development projects would be required to be in compliance with all applicable Federal, State, and local regulations regulating energy usage. Energy-saving regulations, including the latest State Title 24 building energy efficiency standards, would be applicable to future residential development projects. Other Statewide measures, including those intended to improve the energy efficiency of the statewide passenger and heavy-duty truck vehicle fleet (e.g. the Pavley Bill and the Low Carbon Fuel Standard), would improve vehicle fuel Agenda Item #2.1:

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economies, thereby conserving gasoline and diesel fuel. These energy savings would continue to accrue over time.

The Housing Element includes Goal 6, which promotes environmental sustainability through support of existing and new development that minimizes reliance on natural resources, and associated policies and programs that promote energy and water conservation.

Further, the Housing Element encourages a variety of housing types, including dense, mixed-use housing development, within areas of the City that are already designated and zoned to accommodate housing with adequate existing or planned infrastructure to support development, in compliance with the City’s 2020 General Plan, the Zoning Ordinance, and mandates of State law to accommodate eligible housing projects. The Housing Element does not identify any new areas for urbanization or growth, beyond those areas where development is accommodated under the General Plan, Zoning Ordinance, and State law. For these reasons, the Project would not cause an inefficient, wasteful, or unnecessary use of energy resources nor cause a significant impact on any of the threshold as described by Appendix F of the CEQA Guidelines.

The 6th Cycle Housing Element would have no impact on energy resources or to state or local plan for renewable energy or energy efficiency.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 15
VII. GEOLOGY AND SOILS -- WOULD THE PROJECT:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Less Than
Significant
Impact
No
Impact
a) Directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as
delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the
State Geologist for the area or based on other
substantial evidence of a known fault? Refer to
Division of Mines and Geology Special
Publication 42.

X
ii) Strong seismic ground shaking? X
iii) Seismic-related ground failure, including
liquefaction? X
iv) Landslides? X
b) Result in substantial soil erosion or the loss of
topsoil? X
c) Be located on a geologic unit or soil that is
unstable, or that would become unstable as a result
of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction
or collapse?
X
d) Be located on expansive soil, as defined in Table
18-1-B of the Uniform Building Code (1994),
creating substantial direct or indirect risks to life or property?
X
e) Have soils incapable of adequately supporting the
use of septic tanks or alternative waste water
disposal systems where sewers are not available for
the disposal of waste water?
X
f) Directly or indirectly destroy a unique
paleontological resource or site or unique geologic
feature?
X

RESPONSES TO CHECKLIST QUESTIONS
Responses a), b), c), d), e), f): No Impact. Sonoma County's complex geology can be explained, in part, by the historical geological processes in the Coast Range. These geologic processes include volcanic, erosion, sedimentation, and tectonic processes. The San Andreas Fault system, which is a broad zone of active, dormant, and inactive faults dominated by the San Andreas Fault, is more than 600 miles long, extending from Pt. Arena to the Gulf of California, and is located along the western boundary of the County, approximately 25 miles west of Sonoma. The San Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 16
Andreas Fault system is responsible for the structural alignment and orientation of the mountains and valleys in the Coast Range.

The topography in Sonoma County is varied, including several mountain ranges, distinctive valleys, and coastal terraces. The geology is quite complex and is continually evolving because of its location at an active plate margin. The rugged Mayacamas and Sonoma Mountains geographically form the eastern boundary and physically separate Sonoma County from Lake and Napa Counties. The Sonoma Valley runs north-south between the Sonoma Mountains on the west and the taller Mayacamas Mountains to the east.

The region has been modified by volcanic activity, evidenced by Mount St. Helena that dominates the northeastern part of the County. Erosion, sedimentation, and active faulting occurring in recent times have further modified Sonoma County’s landscape to its current form.

Earthquake and geologic hazards in the region include fault rupture, ground shaking, liquefaction, seismically induced landslides, and subsidence. Each can result in extensive property damage, personal injury, and/or death. The most widespread effect of an earthquake is ground shaking, or movement of the Earth’s surface in response to seismic activity. Ground shaking is often the greatest cause of physical damage. Buildings and utility facilities may suffer severe damage or collapse if not properly designed to withstand shaking. California has a long history of strong earthquakes that have affected communities in the San Francisco Bay Area. In order to minimize potential damage to the buildings and site improvements associated with geologic and seismic hazards, all construction in California is required to be designed in accordance with the latest seismic design standards of the California Building Code.

Adopting the 6th Cycle Housing Element will not affect geologic or soil conditions within City of Sonoma. The proposed Housing Element would not result in any direct or indirect changes to the environment. The Housing Element encourages a variety of housing types, including dense, mixed-use housing development, within areas of the City that are already designated and zoned to accommodate housing with adequate existing or planned infrastructure to support development, in compliance with the City’s 2020 General Plan, the Zoning Ordinance, and mandates of State law to accommodate eligible housing projects. Additionally, the proposed Housing Element does not change programs or policies that provide regulatory guidance for regulating development based on geology and soils. Potential geologic impacts associated with the construction of new housing units will vary on a project-by-project basis. Each development project will be subject to site-specific review at the time that the project is proposed. At that time, a comprehensive review of potential geologic impacts will be performed to address geologic impacts. The proposed Housing Element update does not contain any Goals, Programs or Policies that will result in changes to the City’s processes for addressing geologic and soil resources impacts during residential construction. Therefore, the 6th Cycle Housing Element would have no impact on geology and soils.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 17
VIII. GREENHOUSE GAS EMISSIONS – WOULD THE PROJECT:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Generate greenhouse gas emissions, either
directly or indirectly, that may have a significant
impact on the environment?
X
b) Conflict with an applicable plan, policy or
regulation adopted for the purpose of reducing the
emissions of greenhouse gasses?
X

RESPONSES TO CHECKLIST QUESTIONS
Responses a), b): No Impact. Greenhouse gases (GHGs) are those gases that trap heat in the atmosphere. GHGs are emitted by natural and industrial processes, and the accumulation of GHGs in the atmosphere regulates the earth’s temperature. GHGs that are regulated by the State and/or EPA are carbon dioxide (CO2), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF6) and nitrous oxide (NO2). CO2 emissions are largely from fossil fuel combustion. Sources of GHG emissions include area sources, mobile sources or vehicles, utilities (electricity and natural gas), water usage, wastewater generation, and the generation of solid waste. Agriculture is also a major source of both methane and NO2, with additional methane coming primarily from landfills. Most HFC emissions come from refrigerants, solvents, propellant agents and industrial processes, and persist in the atmosphere for longer periods of time and have greater effects at lower concentrations compared to CO2. The adverse impacts of global warming include impacts to air quality, water supply, ecosystem balance, sea level rise (flooding), fire hazards, and an increase in health-related problems. The common unit of measurement for GHG is expressed in terms of annual metric tons of CO2 equivalents (MTCO2e/yr).

Adoption of the 6th Cycle Housing Element will not result in impacts to greenhouse gas emissions in Sonoma. The Housing Element update is a policy document and does not provide entitlements to any specific land use projects. The proposed Housing Element update does not revise, replace or attempt to supersede any existing greenhouse gas emission standards adopted by the City, the BAAQMD, or the State of California. The Housing Element encourages a variety of housing types, including dense, mixed-use housing development, within areas of the City that are already designated and zoned to accommodate housing with adequate existing or planned infrastructure to support development, in compliance with the City’s 2020 General Plan, the Zoning Ordinance, and mandates of State law to accommodate eligible housing projects. The Housing Element does not identify new locations for urbanization and accommodates growth consistent with the regional RHNA Plan and mandates of State law to accommodate the City’s assigned housing needs. Individual future development proposals will be subject to project-specific review to ensure that the project will be in compliance with local and regional standards (i.e., AB 32 and SB 32) and procedures for minimizing short-term and long-term impacts related to increases in greenhouse gas emissions. Therefore, the 6th Cycle Housing Element would have no impact on greenhouse gas emissions.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 18
IX. HAZARDS AND HAZARDOUS MATERIALS -- WOULD THE PROJECT:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
X
b) Create a significant hazard to the public or the
environment through reasonably foreseeable upset
and accident conditions involving the release of
hazardous materials into the environment?
X
c) Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste
within one-quarter mile of an existing or proposed
school?
X
d) Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a result,
would it create a significant hazard to the public or
the environment?
X
e) For a project located within an airport land use
plan or, where such a plan has not been adopted,
within two miles of a public airport or public use
airport, would the project result in a safety hazard or excessive noise for people residing or working in the
project area?
X
f) Impair implementation of or physically interfere
with an adopted emergency response plan or
emergency evacuation plan?
X
g) Expose people or structures to a significant risk of loss, injury or death involving wildland fires,
including where wildlands are adjacent to urbanized
areas or where residences are intermixed with
wildlands?
X

RESPONSES TO CHECKLIST QUESTIONS
Responses a), b), c), d), e), f), g): No Impact. A hazardous material is a substance or combination of substances which, because of its quantity, concentration, or physical, chemical, or infectious characteristics, may either (1) cause or significantly contribute to an increase in mortality or an increase in serious, irreversible, or incapacitating irreversible illness; or (2) pose a substantial present or potential hazard to human health and safety, or the environment when improperly treated, stored, transported, or disposed of. (22 CCR 5 662.60.10.) Hazardous waste is the subset of hazardous materials that has been abandoned, discarded, or recycled and is not properly contained, including contaminated soil or groundwater with concentrations of chemicals, infectious agents, or toxic elements sufficiently high to increase human mortality or to Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 19
destroy the ecological environment. If a hazardous material is spilled and cannot be effectively picked up and used as a product, it is considered to be hazardous waste.

The interface of the natural and manmade environments creates potential safety hazards associated with avalanches, landslides, earthquakes, floods, and wildfires. Other potential safety hazards, such as airport operations and transportation of hazardous materials, arise from the potential for accidents during the transport of goods and people. Each of these hazards has particular characteristics that affect the future development of the City. Some of these safety hazards can be minimized with emergency planning, while other hazards are reduced by development standards and land use planning.

The 6th Cycle Housing Element would not result in any direct or indirect physical changes to the environment. As previously described, the Housing Element encourages a variety of housing types, including dense, mixed-use housing development, within areas of the City that are already designated and zoned to accommodate housing with adequate existing or planned infrastructure to support development, in compliance with the City’s 2020 General Plan, the Zoning Ordinance, and mandates of State law to accommodate eligible housing projects. Additionally, the proposed Housing Element does not change programs or policies that provide regulatory guidance for regulating development based on hazards or hazardous materials. Therefore, the adoption of the 6th Cycle Housing Element, itself, is not anticipated to result in an impact to the creation of potential hazards or hazardous materials for the Sonoma residents or users of future projects. As proposed, the Housing Element update does not contain any Goals, Policies or Programs which are anticipated to impact hazardous materials or conditions. Future development of projects will be subject to both local and regional hazard and hazardous materials regulation and will also be required to meet all adopted local and State Fire Safety Standards and applicable airport land use compatibility plans. All potential hazards will be reviewed at the time when an application for a site-specific development project is submitted. Therefore, the 6th Cycle Housing Element would have no impact on hazards or hazardous materials.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 20
X. HYDROLOGY AND WATER QUALITY -- WOULD THE PROJECT:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Violate any water quality standards or waste
discharge requirements or otherwise substantially
degrade surface or ground water quality?
X
b) Substantially deplete decrease groundwater
supplies or interfere substantially with groundwater
recharge such that the project may impede
sustainable groundwater management of the basin?
X
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of
the course of a stream or river or through the
addition of impervious surfaces, in a manner which
would:
(i) result in substantial erosion or siltation on- or offsite; X (ii) substantially increase the rate or amount of
surface runoff in a manner which would result in
flooding on- or offsite;
X
(iii) create or contribute runoff water which would
exceed the capacity of existing or planned
stormwater drainage systems or provide substantial
additional sources of polluted runoff; or
X
(iv) impede or redirect flood flows? X
d) In flood hazard, tsunami, or seiche zones, risk
release of pollutants due to project inundation? X
e) Conflict with or obstruct implementation of a
water quality control plan or sustainable
groundwater management plan?
X

RESPONSES TO CHECKLIST QUESTIONS
Responses a), b), c), d), e): No Impact. The City of Sonoma is located within the Sonoma Creek Watershed (Watershed), which encompasses approximately 170 square miles and drains to San Pablo Bay. Elevations in the Watershed range from sea level at San Pablo Bay to approximately 2,500 feet mean sea level at Bald Mountain. The City of Sonoma is located on the valley floor near the center of the elongated watershed. The central part of the Watershed on the valley bottom is mostly urbanized, while the areas of the valley farther south are mostly in agricultural production. Approximately 54% of the watershed is in agricultural use, 30% is rural and about 11% is recreational. The vegetative cover of the hill slopes of the Watershed, where not converted to vineyards, is mostly oak woodland, forest, and some areas of brush.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 21
Flooding in the Watershed is the result of intense, short-duration rainfall occurring within a larger duration storm event. The San Francisco Bay RWQCB has classified the Watershed as an impaired water body due to sedimentation, nutrients, and pathogens. The development of vineyards on steep hillsides, especially in the 1980s and early 1990s before the county developed vineyard erosion control regulations, has been attributed to be one of the major causes of erosion and sedimentation.

The Federal Emergency Management Agency (FEMA) mapping provides important guidance for the City to plan for flooding events and regulating development within identified flood hazard areas. FEMA’s National Flood Insurance Program defines floodplain and floodway boundaries that are shown on Flood Insurance Rate Maps. The majority of the City and surrounding area is designated by FEMA as Zone X, which is an area determined to be outside the 500-year floodplain.

However, portions of the City are located within the 100-year floodplain including flooding along creeks and drainages, such as Sonoma Creek along the City’s western boundary, that traverse the City. Flooding, even at its worst, presents only localized threats to property and little or no threat to life in Sonoma. Although some local urbanized areas lie within the 100-year floodplain mapped by the FEMA, flood water heights rarely exceed one-to-two feet and flood control improvements have eliminated many former problems.

Adoption of the 6th Cycle Housing Element, itself, will not result in a significant impact to hydrology and water quality. The Housing Element update is a policy document that encourages housing opportunities for a variety of income classes and any future development proposal that is intended to assist in meeting the City’s projected housing need will be reviewed to address hydrological impacts. The proposed Housing Element would not result in any direct or indirect physical changes to the environment. The Housing Element encourages a variety of housing types, including dense, mixed-use housing development, within areas of the City that are already designated and zoned to accommodate housing with adequate existing or planned infrastructure to support development, in compliance with the City’s 2020 General Plan, the Zoning Ordinance, and mandates of State law to accommodate eligible housing projects. The Housing Element does not identify any new areas for urbanization or growth, beyond those areas where development is accommodated under the General Plan, Zoning Ordinance, and State law. Additionally, the Housing Element update does not change any of the programs or policies that provide regulatory guidance for regulating development based on hydrology or water quality. All future development proposals will be subject to site-specific studies as deemed appropriate by the City and will be required to adhere to all water and waste discharge standards. Any potential hydrologic impacts of specific projects will be addressed at the time of project submittal.

Therefore, the 6th Cycle Housing Element would have no impact on hydrology/water quality.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 22
XI. LAND USE AND PLANNING - Would the project:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Physically divide an established community? X
b) Cause a significant environmental impact due to a
conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating an
environmental effect?
X

RESPONSES TO CHECKLIST QUESTIONS
Responses a) b): No Impact. The proposed project is to adopt the 6th Cycle Housing Element, which provides Goals, Policies and Programs focused on addressing housing needs within unincorporated City of Sonoma. The Housing Element update is a policy document and does not provide entitlements to any specific land use projects. The Housing Element update examines and analyzes the City of Sonoma’s current housing needs, existing constraints to housing development, and projected future housing needs. The document defines updated goals and policies concerning the existing housing needs and constraints and establishes new and updated housing programs to respond to the existing housing needs and constraints within the limitations posed by available resources. The housing program details an eight-year schedule of actions the community is undertaking or plans to undertake to achieve its housing goals and objectives. As a part of the General Plan, the Housing Element complies with and is internally consistent with the City’s adopted 2020 General Plan.

The Housing Element update is a policy document that encourages housing opportunities for a variety of income classes. The Housing Element does not identify any new areas for urbanization or growth, beyond those areas where development is accommodated under the General Plan, Zoning Ordinance, and State law. The Housing Element update does include housing programs require Zoning Code amendments; however, these programs implement mandates of State law and would be required regardless of Housing Element adoption and thus do not result in conflicts with the General Plan, Zoning Ordinance, and policies and programs that address environmental effects. Adoption of the Housing Element update would implement these housing programs and would not change policies that provide regulatory guidance for addressing the environmental effects of housing development. These housing programs would be implemented in the future.

Additionally, future housing projects will be reviewed pursuant to CEQA. Therefore, the 6th Cycle Housing Element would have no impact related to established land use policy.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 23
XII. MINERAL RESOURCES -- WOULD THE PROJECT:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Result in the loss of availability of a known
mineral resource that would be of value to the region
and the residents of the state?
X
b) Result in the loss of availability of a locallyimportant mineral resource recovery site delineated on a local general plan, specific plan or other land
use plan?
X

RESPONSES TO CHECKLIST QUESTIONS
Responses a), b): No Impact. Adoption of the 6th Cycle Housing Element, itself, will not result in a significant impact to mineral resources. The proposed Housing Element would not result in any direct or indirect physical changes to the environment. The Housing Element update is a policy document that encourages housing opportunities for a variety of income classes and does not identify any new areas for urbanization or growth, beyond those areas where development is accommodated under the General Plan, Zoning Ordinance, and State law. Further, the 6th Cycle Housing Element does not change any of the programs or policies that provide regulatory guidance for regulating development based on mineral resources. Therefore, there is no impact to mineral resources.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 24
XIII. NOISE -- WOULD THE PROJECT RESULT IN:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Generation of a substantial temporary or
permanent increase in ambient noise levels in the
vicinity of the project in excess of standards
established in the local general plan or noise
ordinance, or applicable standards of other
agencies?
X
b) Generation of excessive groundborne vibration or
groundborne noise levels? X
c) For a project located within the vicinity of a
private airstrip or an airport land use plan or, where
such a plan has not been adopted, within two miles
of a public airport or public use airport, would the
project expose people residing or working in the
project area to excessive noise levels?
X

RESPONSES TO CHECKLIST QUESTIONS
Response a) b) c): No Impact. The adoption of the 6th Cycle Housing Element will not result in the generation of substantial noise throughout the City. The 6th Cycle Housing Element would not result in any direct or indirect physical changes to the environment. As previously described, the 6th Cycle Housing Element contains Goals, Policies and Programs aimed at accommodating 311 housing units by 2031; however, the Element itself does not provide any entitlements for the construction of these units. the Housing Element encourages a variety of housing types, including dense, mixed-use housing development, within areas of the City that are already designated and zoned to accommodate housing with adequate existing or planned infrastructure to support development, in compliance with the City’s 2020 General Plan, the Zoning Ordinance, and mandates of State law to accommodate eligible housing projects. The Housing Element does not identify any new areas for urbanization or growth, beyond those areas where development is accommodated under the General Plan, Zoning Ordinance, and State law. The Housing Element update does not change any programs or policies that provide regulatory guidance for regulating development based on noise, such as the Noise Element of the City of Sonoma 2020 General Plan.

Future housing development projects will be reviewed for impacts to noise consistent with the requirements of CEQA. Additionally, these future projects are required to adhere to the City’s noise standards established by the 2020 General Plan and Municipal Code. Therefore, the 6th Cycle Housing Element would result in no impact on temporary or permanent increased in ambient noise levels or ground borne vibrations or noise levels nor expose people residing or working within the vicinity of a private airstrip or public or private airports.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 25
XIV. POPULATION AND HOUSING -- Would the project:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Induce substantial unplanned population growth
in an area, either directly (for example, by proposing
new homes and businesses) or indirectly (for
example, through extension of roads or other
infrastructure)?
X
b) Displace substantial numbers of existing people
or housing, necessitating the construction of
replacement housing elsewhere?
X

RESPONSES TO CHECKLIST QUESTIONS
Response a) b): No Impact. Adoption of the 6th Cycle Housing Element would not result in a substantial amount of population growth, nor will it displace a substantial amount of housing units or people that will result in the construction of replacement housing elsewhere. The 6th Cycle Housing Element addresses how the City will accommodate its share of growth planned for the Bay Area region by ABAG and the State. Additionally, the Housing Element update also contains Goals, Policies and Programs focused on maintaining and improving the existing housing stock and retaining existing affordable housing. The 6th Cycle Housing Element is a policy document that would not result in any direct or indirect physical changes to the environment.

Most of the proposed housing programs in the Housing Element could increase population growth as the Housing Element includes many programs to encourage housing development.

However, this growth would be consistent with the General Plan and regional growth plans, including the RHNA Plan. As previously described, the Housing Element does not identify any new areas for urbanization or growth, beyond those areas where development is accommodated under the General Plan, Zoning Ordinance, and State law.

The adoption of the Housing Element would not result in entitlements for any specific housing project. All future specific projects will be reviewed at the project-level pursuant to CEQA.

Additionally, all future housing projects will be reviewed for compliance with the General Plan, Zoning Code and specific ordinances, including design review where applicable. The 6th Cycle Housing Element would not result in population growth or displacement of housing or people as the project housing needs are in direct relation to planned population growth in the City, does not require for removal of existing housing, and provides measures to address displacement.

Therefore, the 6th Cycle Housing Element would have no impact.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 26
XV. PUBLIC SERVICES -- WOULD THE PROJECT:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
Would the project result in substantial adverse
physical impacts associated with the provision of
new or physically altered governmental facilities,
need for new or physically altered governmental
facilities, the construction of which could cause
significant environmental impacts, in order to
maintain acceptable service ratios, response times
or other performance objectives for any of the public
services:
a) Fire protection? X
b) Police protection? X
c) Schools? X
d) Parks? X

RESPONSES TO CHECKLIST QUESTIONS
Response a) b) c) d): No Impact. The 6th Cycle Housing Element would not result in any direct or indirect physical changes to the environment. The Housing Element update is a policy document and does not provide entitlements to any specific land use projects. The Project contains goals, policies, and programs aimed at accommodating 311 housing units by 2031 as well as promoting housing rehabilitation, preservation, and fair housing. The Housing Element supports population growth that is mandated to be accommodated by the State. While such growth would increase the demand for public services, the Housing Element encourages development within areas of the City that are already designated and zoned to accommodate housing with adequate existing or planned infrastructure to support development, in compliance with the City’s 2020 General Plan, the Zoning Ordinance, and mandates of State law to accommodate eligible housing projects. The Housing Element does not identify any new areas for urbanization or growth, beyond those areas where development is accommodated under the General Plan, Zoning Ordinance, and State law. Future implementation of development or programs that require an amendment to the General Plan or Zoning Ordinance will be reviewed at the project level pursuant to CEQA. Therefore, the 6th Cycle Housing Element would have no impact to public services.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 27
XVI. RECREATION -- WOULD THE PROJECT:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Would the project increase the use of existing
neighborhood and regional parks or other
recreational facilities such that substantial physical
deterioration of the facility would occur or be
accelerated?
X
b) Does the project include recreational facilities or
require the construction or expansion of
recreational facilities which might have an adverse
physical effect on the environment?
X

RESPONSES TO CHECKLIST QUESTIONS
Responses a), b): No Impact. The 6th Cycle Housing Element would not result in any direct or indirect physical changes to the environment. The Housing Element update is a policy document and does not provide entitlements to any specific land use projects. The document contains goals, policies, and programs aimed at accommodating 311 housing units by 2031. The Housing Element supports population growth that is mandated to be accommodated by the State. While such growth would increase the demand for public services, the Housing Element encourages development within areas of the City that are already designated and zoned to accommodate housing with adequate existing or planned infrastructure to support development, in compliance with the City’s 2020 General Plan, the Zoning Ordinance, and mandates of State law to accommodate eligible housing projects. The Housing Element does not identify any new areas for urbanization or growth, beyond those areas where development is accommodated under the General Plan, Zoning Ordinance, and State law. Future projects will be subject to project-specific environmental review pursuant to CEQA and must comply with all applicable County policies and regulations in regard to recreational services. Therefore, the 6th Cycle Housing Element would have no impact related to recreational resources.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 28
XVII. TRANSPORTATION -- WOULD THE PROJECT:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Conflict with an applicable program plan,
ordinance or policy establishing measures of
effectiveness for the performance of addressing the
circulation system, including transit, roadway,
bicycle and pedestrian facilities?
X
b) Would the project conflict or be inconsistent with
CEQA Guidelines section 15064.3, subdivision (b)? X
c) Substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm
equipment)?
X
d) Result in inadequate emergency access? X

RESPONSES TO CHECKLIST QUESTIONS
Response a), b) c) d): No Impact. The 6th Cycle Housing Element would not result in any direct or indirect physical changes to the environment, including the development of streets. Adoption of the 6th Cycle Housing Element would not result in potential impacts to transportation. The Housing Element update is a policy document and does not provide entitlements to any specific land use projects; therefore, the Housing Element update is not considered a development or transportation project and is not required to include a Vehicle Miles Traveled analysis pursuant to CEQA Section 15064.3. As previously described, the Housing Element supports population growth that is mandated to be accommodated by the State. While such growth would increase vehicle travel and use of roadways, pedestrian, and bicycle facilities, the Housing Element encourages development that has been planned by the Metropolitan Transportation Commission, ABAG, and is consistent with the Plan Bay Area 2050 Blueprint which addresses regional growth, transportation, and sustainability. The Housing Element does not identify any new areas for urbanization or growth, beyond those areas where development is accommodated under the General Plan, Zoning Ordinance, and State law. Implementation of future programs and consideration of future development projects will be at the project-level pursuant to CEQA.

Additionally, these future projects must comply with all applicable City policies and regulations in regard to transportation and circulation. Therefore, the 6th Cycle Housing Element would result in no impact to transportation.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 29
XVIII. TRIBAL CULTURAL RESOURCES -- WOULD THE PROJECT:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i) Listed or eligible for listing in the California
Register of Historical Resources, or in a local
register of historical resources as defined in
Public Resources Code Section 5020.1(k)?
X
ii) A resource determined by the lead agency, in
its discretion and supported by substantial
evidence, to be significant pursuant to criteria
set forth in subdivision (c) of Public Resources
Code Section 5024.1? In applying the criteria set
forth in subdivision (c) of Public Resources
Code Section 5024.1, the lead agency shall
consider the significance of the resources to a
California Native American tribe.

X

RESPONSES TO CHECKLIST QUESTIONS
Responses a.i), a.ii): No impact. As previously described, the Housing Element supports population growth that is mandated to be accommodated by the State. The Housing Element encourages development within areas of the City that are already designated and zoned to accommodate housing in compliance with the City’s 2020 General Plan, the Zoning Ordinance, and mandates of State law to accommodate eligible housing projects. The Housing Element does not identify any new areas for urbanization or growth, beyond those areas where development is accommodated under the General Plan, Zoning Ordinance, and State law and as such would not result in any substantial adverse changes to the significance of tribal cultural resources. Future projects will be reviewed at the project-specific level pursuant to the requirements of CEQA and would require future consultation of traditionally and culturally affiliated California Native American tribes. Therefore, the 6th Cycle Housing Element would have no impact on tribal cultural resources.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 30
XIX. UTILITIES AND SERVICE SYSTEMS -- WOULD THE PROJECT:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Require or result in the relocation or construction
of new or expanded water, or wastewater treatment
or storm water drainage, electric power, natural gas,
or telecommunications facilities, the construction or
relocation of which could cause significant
environmental effects?
X
b) Have sufficient water supplies available to serve
the project and reasonably foreseeable future
development during normal, dry and multiple dry
years?
X
c) Result in a determination by the wastewater
treatment provider which serves or may serve the
project that it has adequate capacity to serve the
projects projected demand in addition to the
providers existing commitments?
X
d) Generate solid waste in excess of State or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment
of solid waste reduction goals?
X
e) Comply with federal, state, and local management
and reduction statutes and regulations related to
solid waste?
X

RESPONSES TO CHECKLIST QUESTIONS
Responses a), b) c) d) e): No Impact. Most of the City’s water is supplied via connection to the Sonoma County Water system (approximately 95%). Total water allocated annually to the City under its agreement with Sonoma Water is fixed through 2035. Any additional water made available to the City will result from increased pumping of municipal wells (existing and future).

The treatment of wastewater generated within the City of Sonoma and the urbanized unincorporated area of Sonoma Valley is provided by the Sonoma Valley County Sanitation District (SVCSD), which has one treatment plant, located on 8th Street East. The SVCSD is operated and maintained by Sonoma County Water Agency.

The adoption of the proposed 6th Cycle Housing Element, itself, will not result in an impact to utilities and service systems. The Housing Element update is a policy document and does not provide entitlements to any specific land use projects. The 6th Cycle Housing Element contains Goals, Policies and Programs aimed at accommodating 311 housing units by 2031; however, the Element itself does not provide any entitlements for the construction of these units. As previously described, the Housing Element supports population growth that is mandated to be accommodated by the State. While such growth would increase the demand for utilities and service systems, the Housing Element encourages development within areas of the City that are already designated and zoned to accommodate housing with adequate existing or planned Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 31
infrastructure to support development, in compliance with the City’s 2020 General Plan, the Zoning Ordinance, and mandates of State law to accommodate eligible housing projects. The Housing Element does not identify any new areas for urbanization or growth, beyond those areas where development is accommodated under the General Plan, Zoning Ordinance, and State law.

All future housing development projects will be considered a project under CEQA and will be subject to project-level review to identify any impacts unique to the project. Therefore, the 6th Cycle Housing Element would have no impact on utilities and service systems.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 32
XX. WILDFIRE
Would the project:

Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a) Substantially impair an adopted emergency
response plan or emergency evacuation plan? X
d) Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose
project occupants to, pollutant concentrations from
a wildfire or the uncontrolled spread of a wildfire?
X
c) Require the installation or maintenance of
associated infrastructure (such as roads, fuel breaks,
emergency water sources, power lines or other
utilities) that may exacerbate fire risk or that may
result in temporary or ongoing impacts to the
environment?
X
d) Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
X

RESPONSES TO CHECKLIST QUESTIONS
Response a) b) c) d): No Impact. A portion of the Sonoma Mountain Cemetery in the City as well as areas to the north and west of the City are classified as a Very High Fire Hazard Severity Zone (CAL FIRE Hazard Severity Zones in State Responsibility Area, 2022). Development within a Very High Fire Hazard Zone could expose people and structures to a potential risk of loss, injury, or death involving wildland fires.

The City of Sonoma 2020 General Plan contains policies regarding fire protection. Additionally, the 2021 Sonoma County Multi-Jurisdictional Hazard Mitigation Plan evaluates hazards for a wide array of potential issues within the County, identifying l mitigation strategies that the City should implement to reduce losses from future hazard events, including wildland fires.

The adoption of the proposed 6th Cycle Housing Element, itself, will not result in an impact to the ability of the City, State or Federal Agencies or Local Fire Districts or Law Enforcement Agencies from carrying out an adopted emergency response or emergency evacuation plan and will not expose people or structures to significant risks related to wildfire. The Housing Element update is a policy document and does not provide entitlements to any specific land use projects. The 6th Cycle Housing Element contains Goals, Policies and Programs aimed at accommodating 311 housing units by 2031; however, the Element itself does not provide any entitlements for the construction of these units. As previously described, the Housing Element supports development and population growth that is mandated to be accommodated by the State. Further, the Housing Element accommodates growth through existing development potential within areas of the City Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 33
that are already designated and zoned to accommodate housing with adequate existing or planned infrastructure to support development, in compliance with the City’s 2020 General Plan, the Zoning Ordinance, and mandates of State law to accommodate eligible housing projects. The Housing Element does not identify any new areas for urbanization or growth, beyond those areas where development is accommodated under the General Plan, Zoning Ordinance, and State law.

Future development of projects will be subject to both local and regional hazard and hazardous mitigation plans and will also be required to meet all City of Sonoma regulatory requirements including all adopted local and State Fire Safety Standards as well all Federal Emergency Management Agency and California Office of Emergency Standards. All potential wildland fire hazards will be reviewed at the time when a site-specific development project is made, including for compliance with appropriate California Building Codes and for development within Wildland Urban Interface areas. Therefore, the 6th Cycle Housing Element would have no impact on wildland fire or adopted emergency response.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 34
XXI. MANDATORY FINDINGS OF SIGNIFICANCE --
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporation
Less Than
Significant
Impact
No
Impact
a) Does the project have the potential to
substantially degrade the quality of the
environment, substantially reduce the habitat of a
fish or wildlife species, cause a fish or wildlife
population to drop below self-sustaining levels,
threaten to eliminate a plant or animal community,
substantially reduce the number or restrict the
range of a rare or endangered plant or animal or
eliminate important examples of the major periods
of California history or prehistory?
X
b) Does the project have impacts that are
individually limited, but cumulatively considerable?
("Cumulatively considerable" means that the
incremental effects of a project are considerable
when viewed in connection with the effects of past
projects, the effects of other current projects, and the effects of probable future projects)?
X
c) Does the project have environmental effects
which will cause substantial adverse effects on
human beings, either directly or indirectly?
X

RESPONSES TO CHECKLIST QUESTIONS
Response a) c): No Impact. The proposed 6th Cycle Housing Element update is a policy document, intended to guide the City in meeting its projected housing need over the next eight years. The adoption of the proposed Housing Element update will not grant any entitlements for the development of housing. The Housing Element supports growth that is mandated to be accommodated by the State. As previously described, the Housing Element encourages development within areas of the City that are already designated and zoned to accommodate housing in compliance with the City’s 2020 General Plan, the Zoning Ordinance, and mandates of State law to accommodate eligible housing projects. The Housing Element does not identify any new areas for urbanization or growth, beyond those areas where development is accommodated under the General Plan, Zoning Ordinance, and State law. Additionally, all future housing development projects, whose outcome assists in meeting the City’s housing development objectives, will be reviewed pursuant to CEQA at the site/project specific level at the time of project submittal. Therefore, the 6th Cycle Housing Element would have no impact related to these issues.

Response b): No Impact. A project’s cumulative impacts are considered significant when the incremental effects of the project are “cumulatively considerable,” meaning that the project’s incremental effects are considerable when viewed in connection with the effects of past, current, and probable future projects. The proposed 6th Cycle Housing Element is a policy document, intended to guide the City in meeting its projected housing need over the next eight years. The 6th Cycle Housing Element contains Goals, Policies and Programs aimed at accommodating 311 Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 35
housing units by 2031; however, the Element itself does not provide any entitlements for the construction of these units. As previously described, the Housing Element encourages development within areas of the City that are already designated and zoned to accommodate housing in compliance with the City’s 2020 General Plan, the Zoning Ordinance, and mandates of State law to accommodate eligible housing projects. The Housing Element does not identify any new areas for urbanization or growth, beyond those areas where development is accommodated under the General Plan, Zoning Ordinance, and State law. Additionally, all future housing development projects, whose outcome assists in meeting the City’s housing development objectives, will be reviewed pursuant to CEQA at the site/project specific level at the time of project submittal. Therefore, the adoption of the 6th Cycle Housing Element, would have no impact on environmental effects that are individually limited by cumulatively considerable.

Agenda Item #2.1:

ENVIRONMENTAL CHECKLIST – SONOMA 6TH CYCLE HOUSING ELEMENT JANUARY 2022 City of Sonoma PAGE 36

REFERENCES
• Association of Bay Area Governments/Metropolitan Transportation Commission, Final Blueprint Compendium Play Bay Area 2050, December 2020. • Association of Bay Area Governments. Final Regional Housing Needs Allocation (RHNA) Plan: San Francisco Bay Are, 2023-2031. Adopted December 2021, Updated November 2022.
• Bay Area Air Quality Management District. California Environmental Quality Act Air Quality Guidelines, May 2017.
• City of Sonoma. City of Sonoma 2020 General Plan. October 2006. • City of Sonoma. HCD Review Draft 6th Cycle Housing Element. October 2022. • City of Sonoma. Common Materials Files: Cultural Resources Analysis – Elise Barrow, M.A., Historical Resources Study of APNs 018-051007, 018-051-012, and 018-091-018, May 2017. Final Regional Housing Needs Determination for City of Sonoma (HCD, 2018).

December 2018
• City of Sonoma. City of Sonoma Municipal Code. Current through Ordinance 09-2022, June 21, 2022.
• Sonoma County/De Novo Planning Group. The Springs Specific Plan Existing Conditions Report. September 2016.
• Sonoma Resource Conservation District. https://sonomarcd.org/districtwatersheds/sonoma-creek/. Accessed December 2022, January 2023. • Tetra Tech. Sonoma County Multijurisdictional Hazard Mitigation Plan Update 2021, October 2021.
• Tetra Tech. Sonoma County Multijurisdictional Hazard Mitigation Plan Update 2021 City of Sonoma Annex, 2021.

Agenda Item #2.1:

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Agenda Item #2.1:

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City of Sonoma
RESOLUTION # - 2023

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SONOMA ADOPTING THE 2023-2031 HOUSING ELEMENT, AND ADOPTING FINDINGS THAT APPROVING THIS

RESOLUTION IS EXEMPT UNDER THE CALIFORNIA ENVIRONMENTAL QUALITY ACT (“CEQA”) PURSUANT TO CEQA GUIDELINES 14 CAL.CODE REGS. SEC. 15061(B)(3) BECAUSE THERE IS NO POSSIBILITY THAT SUCH APPROVAL WILL

HAVE A SIGNIFICANT IMPACT ON THE ENVIRONMENT
WHEREAS, the California legislature has found that California has a housing supply and affordability crisis of historic proportions and lack of supply and rising costs are compounding inequality and limiting advancement opportunities for many Californians (Gov.

Code § 65589.5.) and;
WHEREAS, California government Code Section 65300 et seq. requires every city and county in California to adopt a General Plan for its long-range development, and further, to periodically update that plan to reflect current conditions and issues; and; WHEREAS, in 2006, the City Council adopted the City of Sonoma 2020 General Plan (“General Plan”) covering a year period from 2006 and beyond; and WHEREAS, the General Plan includes goals and policies related to land use, transportation/traffic, infrastructure, and design and establishes uses and development standards within the City; and
WHEREAS, the General Plan includes text and diagrams specifying the distribution, location, and extent of the uses of land and other essential facilities within the City; and WHEREAS, California Government Code Section 65302(c) mandates that each City shall include a Housing Element in its General Plan, and that the Housing Element be updated regularly on a schedule set forth in the law to reflect current conditions and legal requirements; and
WHEREAS, the City Council adopted the Fifth Cycle 2015-2023 Housing Element Update of the city of Sonoma General Plan on March 16, 2015; and WHEREAS, the Housing Element must comply with the statutory provisions of California Government Code Section 65580 et seq. and is required to identify and analyze existing and projected housing needs, and include statements of the City of Sonoma’s goals, policies, quantified objectives, and programs for the preservation, improvement, and development of the City’s share of the regional housing needs; and WHEREAS, State law requires that the City take meaningful steps to promote and affirmatively further fair housing opportunities (Gov. Code § 65583(c)(5)); and WHEREAS, State law requires that the City make zoning available for all types of housing, including multifamily housing (Gov. Code § 65583(c)): and WHEREAS, State Housing Element Law (Article 10.6 of Government Code) requires that Agenda Item #2.1:

2 299537.v1
the City Council adopt a Housing Element for the Sixth Cycle period of 2023-2031 to accommodate the City of Sonoma’s regional housing need allocation (RHNA) of 311 housing units, comprised of 41 extremely-low income units, 42 very-low income units, 48 low income units, 50 moderate-income units, and 130 above-moderate income units; and WHEREAS, the existing 2015-2023 Housing Element was adopted on March 16, 2015, and the information in the 2023-2031 Housing Element has been revised and expanded to provide a current assessment of housing needs and an inventory of resources and constraints relevant to meeting those needs; and
WHEREAS, the City prepared the 2023-2031 Housing Element (sometimes referred to as the “Housing Element Update”) in conformance with State and local planning law and practices, considering local conditions and context, including economic, environmental, and fiscal factors. The 2023-2031 Housing Element is attached hereto as Exhibit A and incorporated by this reference; and
WHEREAS, the Housing Element Update must be adopted to comply with State law, affirmatively further fair housing opportunities, and facilitate and encourage a variety of housing types for all income levels, including multifamily housing (Gov. Code §§ 65583.2 and 65583(c)); and
WHEREAS, the preparation, adoption, and implementation of the Housing Element Update require a diligent effort to include all economic segments of the community; and WHEREAS, the Housing Element Update includes an inventory of sites that can accommodate new housing sufficient to meet the City’s RHNA obligation at each income level; and
WHEREAS, with the exception of 5 very low-income units, the City does not need underutilized sites to meet its RHNA obligations; but as to those 5 units, the Housing Element Update identified underutilized sites on which those units could be built. In addition, the Housing Element Update identifies excess underutilized sites which are included to encourage development throughout the 6th Cycle by including additional opportunities for development on those underutilized sites; and
WHEREAS, in August 2022, the City commenced an extensive community outreach process and solicited public input on the 2023-2031 Housing Element; and WHEREAS, the City’s multi-lingual outreach efforts included a housing needs and priority survey and use of an online Sites Inventory tool called Balancing Act; and WHEREAS, public input influenced the development of the housing opportunity sites, housing plan, and the policies and programs of the Housing Element Update; and WHEREAS, the 2023-2031 Housing Element was made available for public comment from August 8, 2022 through September 16, 2022; and
WHEREAS, on October 26, 2022, the City submitted the draft 2023-2031 Housing Element to the State Department of Housing and Community Development (HCD) for its review.

HCD has 90 days, or until January 24, 2023, to provide the City with comments and questions about the Housing Element Update. In the event that HCD timely submits comments which may Agenda Item #2.1:

3 299537.v1
be addressed through insubstantial modifications to the Housing Element Update approved by the Planning Commission, then those modifications have been made by City staff and are shown in or attached to the Housing Element Update in redline/strikeout format or the City Manager, after consultation with the City’s Interim Planning and Community Services Director and City Attorney, shall be authorized and directed to make such insubstantial modifications to the Housing Element Update (which said insubstantial modifications shall be deemed to be incorporated into the Housing Element Update) and submit same to HCD for HCD’s certification; and
WHEREAS, in accordance with Government Code Section 65583, the City Council finds that the 2023-2031 Housing Element complies with the duty to affirmatively further fair housing opportunities, and complies with State Housing Element Law; and WHEREAS, in approving the Housing Element Update, the City Council finds that such action is exempt under CEQA Guidelines 14 CCR Section 15061 (b) (3), as it can be seen with certainty that because the Housing Element Update does not entitle any development or physical activity, but only adopts goals, policies and programs (and for the other reasons articulated below), there is no possibility that the 2023-2031 Housing Element may have a significant effect on the environment; and
WHEREAS, on January 10, 2023, the Planning Commission adopted a resolution recommending that the City Council adopt the City of Sonoma the 2023-2031 Housing Plan and Background Report, Resolution, and CEQA Notice of Exemption; and WHEREAS, the adoption of the 2023-2031 Housing Element is referred to herein as the “Project”; and
WHEREAS, on January 31, 2023, the City Council reviewed the staff report and Project at a duly noticed public hearing, at which time all interested parties had the opportunity to be heard; and
WHEREAS, the Record of Proceedings (“Record”) upon which the City Council bases its decisions herein includes, but is not limited to: (1) the 2020 General Plan, the 2015-2023 Housing Element and the EIR and other environmental clearance documents adopted in connection therewith, (2) the staff reports, City files and records and other documents, prepared for and/or submitted to the City relating to the Housing Element Update covering the 2023-2031 planning period, (3) the evidence, facts, findings and other determinations set forth in this resolution, (4) the Sonoma Municipal Code, (5) all studies, data and correspondence submitted by or to the City in connection with the Housing Element Update, (6) all documentary and oral evidence received at public workshops, meetings, and hearings, and (7) all other matters of common knowledge to City decision makers including, but not limited to, City, state, and federal laws, policies, rules, regulations, reports, records and projections related to development within the City of Sonoma and its surrounding areas. The location and custodian of the records is the Sonoma Community Development Department, No. 1, The Plaza, Sonoma, CA 95476.

NOW, THEREFORE THE CITY COUNCIL FOR THE CITY OF SONOMA
RESOLVES THAT: the above recitals are true and correct and made a part of this Resolution.

BE IT FURTHER RESOLVED THAT: the City Council of the City of Sonoma adopts the 2023-2031 Housing Element as shown in attached Exhibit A and incorporated herein by reference.

Agenda Item #2.1:

4 299537.v1
BE IT FURTHER RESOLVED THAT: The decision of the City Council is based on the following findings, considering the staff report and the whole of the record:

1. The City Council hereby finds that approval of the 2023-2031 Housing Element is exempt from CEQA because the 2023-2031 Housing Element would not result in any direct or indirect physical changes to the environment. The Housing Element Update is strictly a policy document and does not provide entitlements to any specific land use projects. The document contains goals, policies, and programs aimed at accommodating the City’s Regional Housing Need Allocation of 311 housing units by 2031. The Housing Element Update does not entitle, propose, or otherwise require the construction of new development or rehabilitation of existing development, but rather includes goals and policies to facilitate the development and rehabilitation of housing consistent with existing and proposed uses identified in the General Plan and allowed under the Zoning Ordinance, including housing projects mandated to be accommodated under State law.

The Housing Element Update supports population growth that is mandated to be accommodated by the State; the City does not have the discretion to decrease the 311 housing units allocated to the City through the Regional Housing Need Allocation Plan adopted by the Association of Bay Area Governments. Further, the City does not have the discretion to disapprove housing projects and densities that are mandated to be accommodated by State law, including State density bonus standards and by-right development that meets specific criteria where office, retail, or parking uses are a principally permitted use. The Housing Element Update focuses on accommodating development that is mandated by the State, has been planned for the Bay Area region by the Metropolitan Transportation Commission, ABAG, and is consistent with the Plan Bay Area 2050 Blueprint which addresses regional growth, transportation, and sustainability. The Housing Element Update does not identify any new areas for urbanization or growth, beyond those areas where development is already accommodated under the General Plan, Zoning Ordinance, and State law.

As previously described, there are no development projects entitled by the Housing Element Update and the Housing Element Update does not include site- specific project design and development details.

Implementation of future programs and consideration of future development projects will occur on a project-by-project basis, and subjected to their own, individualized CEQA analysis. All future housing development projects will be considered a project under the California Environmental Quality Act and will be subject to site-specific review to address project-specific impacts. The Housing Element Update’s goals, policies, and programs would not change the rate of development nor result in any new development projects as the Housing Element Update relies on sites identified for development by the General Plan and Zoning Ordinance and does not project densities beyond those planned by City documents and mandated to be accommodated by State law. The Housing Element Update also includes goals, policies, and programs to reduce constraints to housing. These goals, policies, and programs address land use designations that currently allow urban levels of development and would not result in any changes to the intensities or densities of allowed uses.

Agenda Item #2.1:

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As such, it can be seen with certainty that there is no possibility that adoption of the Housing Element Update will have any significant impact on the physical environment, and is thus exempt from CEQA under 14 Cal.Code Regs. section 15061(b)(3).

2. The 2023-2031 Housing Element establishes appropriate goals, policies, and programs to address land use, housing, and is consistent with the 2020 General Plan.

3. Adoption and implementation of the 2023-2031 Housing Element will not be detrimental to the public interest, health, safety, or welfare of the City.

4. The 2023-2031 Housing Element is internally consistent, and is consistent with the City’s General Plan.

5. The 2023-2031 Housing Element conform with the relevant and applicable provisions of the California Government Code in that it adequately addresses all of the statutorily required components and content.

6. In the event that HCD timely submits comments to the City which may be addressed through insubstantial modifications to the Housing Element Update approved by the Planning Commission, then those modifications either have been made by City staff and are shown in or attached to the Housing Element Update (Exhibit A attached hereto) in redline/strikeout format or the City Manager, after consultation with the City’s Interim Planning and Community Services Director and City Attorney, shall be authorized and directed to make such insubstantial modifications to the Housing Element Update (which said insubstantial modifications shall be deemed to be incorporated into the Housing Element Update approved hereby) and submit same to HCD for HCD’s consideration and certification.

PASSED, APPROVED AND ADOPTED on this 31st day of January 2023, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:
_______________________________
Sandra Lowe, Mayor
ATTEST:

Rebekah Barr, MMC, City Clerk
Agenda Item #2.1:

Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-1
COMMENTER #

SUMMARY OF

COMMENTS RESPONSE TO

COMMENTS
Sonoma Valley Collaborative

1.1 Description of SBC SVC policy platform SVC’s policy platform is noted.

1.2 Revise objectives to be specific, measurable and occur faster Objectives have been revised for more specificity. Housing Plan timelines reflect the City’s resources and time anticipated to implement various programs.

1.3 Clarify precedence of city specific commitments in Admiratively Further Fair Housing
The AFFH program matrix as well as complementary programs throughout the Housing Plan have been revised for consistency.

1.4 Policies lack program implementation measures Policies do not have individual program implementation measures.

Policies establish a standard the City will follow and each policy does not require a program. Programs are designed to achieve overall goals and to address specific constraints and issues where identified in the Background Report. However, where policies would benefit from an implementing action, programs have been added or revised accordingly.

1.5 Sonoma acknowledge racial history and commit policies to achieve fair housing future
The Affirmatively Furthering Fair Housing (AFFH) analysis has been revised to include additional data and information regarding segregation and the City’s racial history, including identification of areas with limited diversity and acknowledgement of past racially exclusive practices in Sonoma. Programs have been revised accordingly to promote diversity, both economic and racial, by increasing access to areas with less diversity.

1.6 Add a commitment to pursue a Pro-housing Designation from HCD
Program 7 (formerly 6) has been revised to pursue a Pro-housing Designation.

1.7 Program 1 - add language to inclusionary requirement Program 1 is revised to ensure that inclusionary units are affordable in perpetuity; the commentor’s recommended language regarding location and quality of units is already reflection in Section 19.44.070 of the Municipal Code.

1.8 Programs 2 and 6 - Add new objectives to affordable housing funding sources
Programs 2 and 6 have been revised to identify specific objectives

1.9 Program 3 - Add new objectives to produce feasible
redevelopment places
Program 3 has been revised to identify potential sites for adaptive reuse by 2026.

1.10 Program 4 - Objective should include numbers of alternative units
Program 4 is revised to include a quantified objective
Agenda Item #2.1:

Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-2

1.11 Program 5 - Address comments from Napa-Sonoma ADU Center Program 5 Napa-Sonoma ADU Center did not submit a comment on Sonoma’s Draft Housing Element

1.12 Add a program to reduce the number of second or empty homes Program 6 is added to address second homes, including approaches to reduce second homes and develop funding mechanisms to address the effect second units have on diminishing the housing supply available for year-round occupancy.

1.13 Program 7
– support objective and fast timeline The City did expedite preparation of its objective design standards for multifamily projects and adopted the standards on June 15, 2022. Programs 14 and 15 ensure the City expands its objective standards to also address mixed use and multi-unit projects and to provide a streamlined ministerial approval process for eligible projects by December 2023.

1.14 Add a program to provide tenant protections Former Programs 10 and 11 are combined into a revised Program 11 to address tenant and resident protections

1.15 Program 12 - Add data addressing the level of risk of conversion for non-multi-family units
Program 12 is revised to address inclusionary and other affordable units at-risk of conversion to market rate

1.16 Program 13 - Include a rental registry Program 13 is revised to develop a rental, ADU, and SB 9 registry.

1.17 Program 14 - Revise timeline for design guidelines and design review
Program 14 is revised to reflect the City’s adoption of objective design standards for multi-family development on June 15, 2022

1.18 Program 15
– Clarify paragraph A, reduce or eliminate parking
requirements, address inclusionary standards
Program 15
– Paragraph A is applicable. The recommendation
regarding removal or unbundling of parking requirements is noted.

Parking has not been a constraint for development projects in the City, demonstrated by the City exceeding its 5th Cycle RHNA. An amendment is not necessary to address ensuring that inclusionary units are provided in perpetuity as that will be addressed through implementation of Program 1.

1.19 Program 18
– reducing, unbundling, or eliminating parking for
new or redeveloped residential projects.

Program 18 - No changes are made related to parking, as previously described.

1.20 Program 19 - Clarify density bonus requirements Program 19 – clarified to state that density bonuses will be granted to eligible projects consistent with State law

1.21 Program 21
– make smaller multi-unit buildings (duplexes up to
5-plexes) allowable in all residential zones, distribute subsidized units for low and very low-income households fairly across all neighborhoods and residential zones Program 21
– State ADU law allows 3 units on any property with a
single-family residence and allows 2-4 units on lots zoned for single family uses that meet the requirements of SB 9. In combination, these laws provide for 2 to 3 units, which can function as a duplex or triplex or stand-alone units, throughout zones that allow single family residential uses providing for increased density and increased opportunities, similar to the commentor’s recommendation. The City will also implement methods to increase density in residential Agenda Item #2.1:

Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-3
neighborhoods as described in Program 4, which has been integrated into Program 22, Table 1.

1.22 Program 22 - Require visitability standards in residential construction
Program 22 is revised to address visitability requirements for new residential construction and multifamily remodels

1.23 Program 25 - Add objective to integrate closure and conversion protections from AB 2782 into the City’s existing ordinance Program 25 focuses on mobile homes as a source of housing for seniors. Program 11 (formerly 10 and 11) addresses mobile home protections and other renter protections at a broader level and is updated to reflect the statutory requirements of AB 2782.

1.24 Program 26
– SVC members and other community organizations
should be named here; materials and events should be designed from the start in both English and Spanish Program 26 is revised to identify organizations that provide significant housing resources to Sonoma by name

1.25 Program 28 - Strengthen draft provisions for displacement protection of lower-cost housing, including below moderateincome units Program 28 implements the requirements of State law related to replacement units. The suggestion to extent protections to below moderate-income households is noted.

1.26 Program 29
– Water supply limitations are compatible with new
infill affordable housing, across Sonoma County, water
consumption per person has dropped while the population has grown Program 29
– comments regarding benefits of infill affordable housing in terms of water supply are noted.

1.27 Program 31
– Mistakenly labeled as Program 29 Program 31
– renumbered.

Omar Paz Jr. 2.01 Support for Sonoma Valley Collaborative comment, noting the time has come to provide serious investment in affordability, retention of local community, and leadership for a housing blueprint that promotes equity for workers and families that are the backbone of the community The commenter identifies their support for the Sonoma Valley Collaborative Comment – please see Response to Comment #1.

Linda Bruce 3.01 Support for Sonoma Valley Collaborative comment The commenter identifies their support for the Sonoma Valley Collaborative Comment – please see Response to Comment #1.

Bryce Jones 4.01 Support for higher density, mixed-use, missing middle and affordable housing
The commenter’s support for higher density, mixed use, missing middle, and affordable housing is noted.

4.02 Plans falls short of the needs of the community and direction the State is encouraging cities and counties to develop Plan for needs of young and old; families and singles; workers and students More inclusive, more effort on creating types, sizes, and price ranges While the commenter indicates the Housing Element falls short of the needs of the community, the commenter does not recommend any specific programs. A number of revisions have been made to the Housing Element to provide more detail regarding fair housing, including historical practices in the community that resulted in segregation, and includes modifications to programs in the Housing Plan to improve tenant protections, provide for earlier implementation of programs related to promoting affordable housing, and to increase Agenda Item #2.1:

Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-4
the emphasis on the range of housing types, which would also result in more variety in housing sizes and prices Anna Colichidas, Sonoma Valley GSMOL

5.01 Support of mobile home communities The support for mobile home communities and discussion of the costs and concerns related to homeowners is noted.

5.02 Support rent stabilization, just cause eviction, and establishing a rental registry
Program 10 has been revised to include additional methods to protect tenants, including addressing excessive rent increases and unjust evictions.

5.03 Consider cost-of-living-adjustment in-leu of rental housing cost increases
Program 13 addresses establishing a rental registry.

5.04 Requests objective to integrate closure and conversion protections from AB 2782 into the City’s existing ordinance Program 11 has been updated to reflect AB 2782.

Keith Diggs 6.01 Expresses that the Draft Housing Element fails to remove constraints to the development of housing, indicating that the City must streamline its review process and design standards now not in 2026
The commenter’s concerns are noted. The City did expedite preparation of its objective design standards for multifamily projects and adopted the standards on June 15, 2022. Programs 14 and 15 ensure the City expands its objective standards to also address mixed use and multi-unit projects and to provide a streamlined ministerial approval process for eligible projects by December 2023.

6.02 Concern over actual production of homes will meet the City’s need without bold reforms
The City accommodated 100% of its RHNA at all income levels in the 5th Cycle.

6.03 Concern over City’s denial that its land-use restrictions pose a serious constraint to housing, including parking and design review The commenter’s concerns regarding parking and the City’s design review process are noted. However, the City exceeded its 5th Cycle RHNA and has multiple projects underway with a low income component. The City processes projects expeditiously and the City’s requirements do not impede development at the upper end of allowed densities.

Vic Conforti 7.01 Include under-utilized commercial properties for mixed-use and affordable housing
There are additional development opportunities with the City’s underutilized properties. The inventory of residential sites focuses on higher density and mixed use sites that the City can demonstrate meet HCD’s requirements for lower income housing and on sites that are anticipated to be developed during the 6th Cycle. Program 3 has been amended to identify at least 4 sites for adaptive reuse, which could include sites in the area identified by the commenter, by 2026.

7.02 Commercial Zoned land is a good location for high density housing
The City continues to promote use of commercial land to accommodate residential uses as described by the commenter, with Program 3 promoting adaptive reuse of commercial and other underutilized sites.

Agenda Item #2.1:

Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-5

7.03 Economics of residential land versus commercial land, noting land in a commercial zone does not have the same demand as residential zoned land.

The comment regarding economics of residential versus commercial zoned land is noted. Many of the small sites included in the Housing Element in existing residential areas are anticipated to accommodate moderate and/or above moderate moderate-income housing.

Kaitlyn Garfield, Housing land Trust of Sonoma County

8.01 Renters are disproportionately more cost burdened; owners able to build equity Support City’s goal of ensuring those who work in Sonoma are able to live here Support for City’s inclusionary policy The comments regarding disproportionate burdens to renters versus homeowners, the commentor’s support of the City’s goal of ensuring those who work in Sonoma are able to live in the city, and the commentor’s support for the City’s inclusionary housing policy and commitment to preserving affordability of existing housing stock and conversion of market rate units to long-term affordability are noted.

8.02 Support for preserving the affordability of existing housing stock All inclusionary ownership units should be required to be affordable in perpetuity Inclusionary units comparable to size, finish, construction quality to market rate units Program 1 is revised to ensure that inclusionary units are affordable in perpetuity; the commentor’s recommended language regarding location and quality of units is already reflection in Section 19.44.070 of the Municipal Code.

8.03 Units converted to affordable units should be affordable in perpetuity
Program 15 is revised to ensure that affordable units are provided in perpetuity.

Collin Thomas, Systems Change Advocate with Disability Services and Legal Center (DSLC)

9.01 Prioritize removing barriers so it is easier, quicker, and chapter to build affordable housing
Programs 14 and 15 addresses removal of constraints to various types of housing and are both prioritized for completion in the first year of the planning period (by December 2023).

9.02 Preserving affordable homes from becoming market rate should be a top priority
Preservation of assisted housing is addressed under Program 12 and will be implemented on an on-going basis, with outreach to property owners at least 18 months prior to units potentially converting, throughout the 6th Cycle.

9.03 Support increased awareness of Section 8 vouchers and City should encourage landlords to accept these vouchers
Program 9 includes annual outreach to property owners to encourage owners to register with the Sonoma County Housing Authority to increase the housing stock that accepts vouchers

9.04 Transitional and temporary housing is another significant need Program 15 removes barriers to transitional, supportive, and temporary housing
Agenda Item #2.1:

Appendix E
City of Sonoma 6th Cycle Housing Element Update
Public Review Draft Comments and Responses
E-6

9.05 Review homeless services, including wrap-around services, so people can get and stay housed
Program 24 has been updated to strengthen the approach to ensure adequate services for unhoused persons

9.06 Barrier to housing is lack of accessible housing for those with mobility, vision, and sight disabilities. Visitability increases accessible housing supply and be aware that certain housing types that require a lift or elevator may be difficult to make accessible Program 23 provides an administrative (ministerial) process for reasonable accommodation requests. Program 22 is revised to address visitability requirements in the Municipal Code

9.07 Design neighborhoods that are accessible for all mobility levels with examples provided of sidewalk and transportation features that improve accessibility An accessible transportation network is recognized as necessary to accommodate persons with a disability. Program 22 is revised to ensure that the City’s Circulation Element is updated to ensure that the City’s circulation system provides accessibility for all persons, including persons with a disability David Brigode 10.01 Inventory of sites is exhaustive as to what may potentially become available
The comment regarding the extensiveness of the inventory of sites is noted.

10.02 Some listed sites are suitable for a single unit and likely won’t be affordable
The inventory of sites addresses the need for a range of income levels and is not limited to sites for affordable housing. The inventory of sites identifies the affordability assumptions for each site in Appendix A.

10.03 The commenter identifies 4 affordable housing opportunity sites and describes characteristics of the sites.

Comments regarding each of the 4 sites are addressed below.

10.04 19357 Sonoma Highway is up for sale and has a peculiar shape, has floodplain issues, would require curb and sidewalk setbacks, requires hillside construction, a portion is not suitable for housing production, and 2 affordable units would be lost. 19357 Sonoma Highway (57 units) is included as it is available for development. This site is 6.08 acres with a maximum allowed density of 20 units per acre, which would accommodate 120 units. The Housing Element assumes that 50% of the site would develop with residential units, which is backed up by the City’s development code which allows the 50% residential requirement to be reduced or waived only in certain instances. This assumption that 50% of the site would develop with residential uses would accommodates a non-residential component as well as site constraints. Program 28 of the Housing Plan addresses replacement of affordable units.

10.05 477 W Napa is landlocked, it has been argued that a seasonal stream underlies the site, and access may be an issue.
477 W. Napa is not landlocked
– this site has access 5th Street W. For
example, a reciprocal access agreement with the adjacent Village Green Senior Apartments (owned by Burbank Housing) could provide more convenient pedestrian access to Safeway for the seniors and disabled persons at Village Green while providing the 477 W. Napa site with a second access route.

10.06 45 Napa Road (18 units) is too small. State law requires that sites identified for the very low and low income RHNA be at least 0.5 acres and not larger than 10 acres, unless smaller Agenda Item #2.1:

Appendix E
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69 Napa Road (51 units) has been complicated by a large number of heirs. If this site is sold to a market rate developer, the City’s affordable housing pool vanishes. or larger sizes are demonstrated to be feasible. This site is 0.87 acres and exceeds the State’s 0.5-acre minimum size threshold. The Housing Element cannot guarantee which sites will be sold to whom as the City does not control the affordable housing sites. The identification of sites is based on the density of sites, whether the site is vacant or if existing uses would make development less feasible during the 6th Cycle, and whether the site’s density is appropriate for affordable housing.

10.07 Address prior RHNA allocation shortfalls The City accommodated 100% of its RHNA at all income levels in the 5th Cycle and does not have a carryover of unaccommodated units to address. The commentor’s suggestion that the City offset any overproduction of above-moderate units is noted. This is not a requirement of housing elements.

10.08 Address restrictions imposed on annexation of suitable land outside Urban Growth Boundary for affordable housing
The Housing Element does not rely on or include any annexations. Information regarding one site that has requested annexation is provided for informational purposes but is not needed for the City’s inventory of sites.

10.09 The four sites listed as suitable for affordable housing are not likely to be so under present market conditions. The assertion that there will be sufficient land is misleading to the public and masks the effects of the existing UGB boundary.

As described in Chapter 4 of the Background Report, the sites meet the criteria for affordable housing sites. There is always the potential that sites will be purchased by a market rate developer and not developed with affordable housing. To reduce this potential, Program 19 is revised to consider an Affordable Housing Overlay to incentivize the development of the sites with affordable housing. It is also noted that there are 4 additional sites included in the inventory of sites that will provide very low and/or low income units.

10.10 Stating that there is no segregation in Sonoma is untrue. Chapter 5 has been updated to include additional information regarding race, ethnicity, and segregation and the findings have been updated accordingly to acknowledge segregation and racially exclusive practices affecting the community.

10.11 The Urban Growth Boundary does the opposite of Policy H-4.2- “Incentivize the production of affordable housing through growth management prioritization” The Urban Growth Boundary provides a tool for the City to manage the pace and location of development. The City’s growth management program, which is the focus of Policy H-4.2 has been placed on hold as discussed under Program 17.

10.12 Regarding Program 1, why must we sacrifice inclusionary affordable housing to incentivize the takeover of any remaining vacant land for unneeded market rate development? The inclusionary housing requirement is not implementable if it unduly constrains the development of market rate housing or if it requires a higher rate of inclusionary housing than is justified.

10.13 Regarding Program 2, the commentor indicates that there is no discussion of the status and capacity of the City’s Housing fund, The City’s Housing Trust Fund was added to Program 2 and to Table 41 of the Background Report. The City does not have remaining set-aside Agenda Item #2.1:

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or an analysis of where the money went from the proceeds of the former Redevelopment agency set-aside for AH. funds from the redevelopment agency; all encumbered assets of the City’s former redevelopment agency were transferred to the Community Development Commission by operation of law.

10.14 Program 13 does not mention monitoring, and taking steps to remedy, the loss of any site described as an AH opportunity zone.

Program 27 addresses monitoring and replacement of housing inventory sites to ensure no net loss in accordance with State law.

10.15 The commenter indicates that the ability of the City Council to exempt projects from the Growth Management Ordinance on a case-by-case basis Introduces arbitrary, non-objective judgement by the City Council on affordable housing development in violation of State law.

The GMO is currently on hold, as previously described. However, the ability of the City Council to exempt projects from the GMO is not a constraint on affordable or other housing as it allows the City Council the opportunity to further incentivize affordable housing projects. However, Program 17 ensures that, should the GMO be reactivated, that it be monitored in conjunction with Program 13 and modified to ensure adequate incentives are provided for affordable housing and fulfillment of regional housing needs.

10.16 The commenter indicates that the statement that “the city intends to complete the necessary actions to meet the State AFFH requirements.” is irrelevant word salad, proposes absolutely nothing, and does not acknowledge the data in Table 1 or offer any remedies to the obvious state of racial and ethnic imbalance currently extant in Sonoma and furthered by the City’s housing policies, including the UGB.

This comment is noted. The AFFH analysis has been updated, along with references to Program 22 and other relevant programs to address AFFH issues.

10.17 The commentor asks once vacant land is used up, what is left to re-zone for affordable housing?
Jurisdictions that do not have adequate vacant land must identify underutilized (nonvacant) sites for reuse or intensification or identify lands for annexation.

10.18 Adopt moratorium on market rate housing A moratorium on market rate housing is not necessary and would have a negative effect on the Statewide housing shortage. The City requires market rate housing to provide affordable units through the inclusionary requirement and has identified adequate sites to accommodate the RHNA, including very low, low, and moderate income units.

10.19 Adopt 50% inclusionary housing requirement for 80% of less AMI populations.

A 50% inclusionary requirement would constrain market rate housing and would not be supportable by a nexus or other study to justify such a high percentage.

10.20 Institute affordable housing overlay Program 19 is revised to consider an Affordable Housing Overlay to incentivize the development of the sites with affordable housing.

10.21 Require residency requirement for new residential construction Requiring a residency requirement for all new residential construction would severely limit residential development as the City’s RHNA is intended to accommodate the City’s fair-share of regional housing Agenda Item #2.1:

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growth and not solely benefit City residents. This would also perpetuate existing fair housing patterns referenced by the commentor.

10.22 Require annual tax on unoccupied primary residences Program 6 is added to address second homes, including approaches to reduce second homes and develop funding mechanisms to address the effect second units have on diminishing the housing supply available for year-round occupancy.

10.23 Urban Growth Boundary is an impediment to affordable housing creation
The commentor’s concern regarding the Urban Growth Boundary is noted. The City has adequate capacity to accommodate its RHNA without annexation.

10.24 Utilize eminent domain to acquire suitable sites Eminent domain is a lengthy, costly process that would likely delay the provision of housing. The City has a track record of working successfully with developers and non-profits for the development of affordable housing and will continue to follow its successful approach.

Fred Allebach 11.01 Reference source not found throughout Housing Element No substantiation of the statements by reference source This comment was provided during the public review period. The missing references were to 5 of the tables in the document. The references were fixed and an updated version of the Draft Housing Element, with an explanation of the corrections on the cover, was provided to the public on August 29, 2022.

David Eichar 12.01 Consider rezoning vacant lots to higher density would allow for apartment buildings and/or condominiums to be built on the major thoroughfare This comment is noted. Program 4 promotes development of alternatives to single family units, including duplexes, triplexes, fourplexes, and cottage/courtyard housing. Program 19 was revised to review opportunities to apply an Affordable Housing Overlay to provide for increased densities and a greater variety of housing types on lots with potential for multifamily housing. Program 16 is revised to address two recent bills, Assembly Bill 2011 and Senate Bill 6 that provide for streamlined review and approval of eligible projects.

David Brigode 13.01 Questioned whether certain sites listed as suitable for affordable housing are under legal control by a noon-profit developer and the criteria for listing these as affordable housing sites The referenced sites are not controlled by a non-profit developer dedicated to 100% affordable housing. The sites meet the size and density criteria for affordable housing as described in under Section 3, Realistic Capacity and Affordability, in Chapter 4 of the Background Report.

Fred Allebach (8/18/22 – Armstrong Estates)

14.01 Armstrong Estates
• Armstrong Estates includes 19 vacant lots which are
allocated in the 6th Cycle to 37 above-moderate income housing and 0 at moderate-income or below-income. Two The inventory of sites allocates affordability of very low and low income units based on sites that meet criteria for size and density discussed in Chapter 4. The Armstrong Estates lots do not meet these criteria. Very low and low income units may be developed on lots identified for above moderate units – however, none of these lots are currently proposed for very lor or low income units and the City cannot Agenda Item #2.1:

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Comments within this letter are sorted by topic.
lots (590 E. Armstrong and 505 Armstrong) are larger than 0.50 acres. Remaining lots are under 0.50 acres. • CC&Rs or Conditions of approval stipulate that lots must be minimum of 20,000 s.f. or 0.459 acres, which leads to underutilized space and questions how optional rules can lock in wasted and inequitable space like this? • Vacant lots fronting Napa Street East are close in size to the

1.9-acre AltaMadrone/Altamira lot on Broadway, where 48.60% of the average median income and lower-income units were allocated. • Suggest that the two big lots on East Napa are divided into parcels smaller than 0.50 acres each except for one (505 Armstrong). If these open spaces were joined, there would be more 0.50 acre lots. take credit in its inventory for programs in the Housing Element that will increase lower income opportunities in single family areas. To encourage additional lower income and more diverse housing options in the City’s neighborhoods that are zoned single family, the Housing Element includes Program 4 – Alternative Housing Models, which supports co-housing, shared housing, and assisted living for seniors, among others. Program 5 – Accessory Dwelling Units and Junior Accessory Dwelling Units (ADUs) also allow 3 units on any property with a single-family residence and allows 2-4 units on lots zoned for single family uses that meet the requirements of SB 9. Minimum lot size is based on the City’s zoning. The City does not prepare or adopt the CC&Rs for a project. The comment regarding vacant lots fronting Napa Street East is noted.

14.02 R-L Zoning
• No density bonus, very-low or low-income housing can be applied for and thus the zone is effectively closed off to integration by (arbitrary) city policy to maintain the character of neighborhoods. • The city then identifies land elsewhere, all along Hwy 12, in the worst, densest spots near a state highway. This plan effectively recaps redlining segregation, and Urban Renewal’s relocation of the poor to the worst spots, this in modern terms through tacit, neutral-term city zoning, Development Code, and the HE. • Sonoma residential areas includes more than 50% of R-L low density, and single-family zoning, and thus more than 50% of possible residential development excludes very-low and low-income housing units, which results in segregation with protected classes. • Concentrating above-moderate income housing away from very-low and low-income housing units in different zones suggests segregation. • Low density NIMBYism is a known issue, one not admitted by Sonoma. https://www.nytimes.com/2022/08/18/opinion/californiahousing-unions.html Program 19 – Affordable Housing/Access to Opportunities Density Bonus and Incentives: Applicants of residential projects of five or more units in any residential or mixed-zone may apply for a density bonus and additional incentives if the project meets specific requirement. Density bonuses do not exclude very low-, or low-income housing units. Density bonuses can be requested in the R-L zone. A density bonus may be requested for any project that meets State density bonus eligibility criteria. Sites identified for lower income housing meet size criteria identified by the State. As previously discussed, the Housing Element includes Program 4 – Alternative Housing Models, which supports co-housing, shared housing, and assisted living for seniors, among others. Program 5 – Accessory Dwelling Units and Junior Accessory Dwelling Units (ADUs) also allow 3 units on any property with a single-family residence and allows 2-4 units on lots zoned for single family uses that meet the requirements of SB 9. Program 1 - Inclusionary Housing: The City’s inclusionary housing ordinance ensures that a component of affordable housing is provided with new development, ensuring that future single family subdivisions and other residential projects provide affordable units. This has been successful in the City, with affordable units provided in completed Agenda Item #2.1:

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• This all acts to concentrate wealth in the R-L, single family zoned areas, especially the east side, and concentrate poverty on Hwy 12 where the worst air, light and noise pollution is. subdivisions residential projects and proposed in pending projects.

Rental projects require a minimum of 25% of units to be affordable to extremely-, very-, and low-income categories, and ownership projects require at minimum 25% of the total units to be affordable to households in the low-, moderate-, and middle-income categories. An in-lieu fee may also be paid instead of providing affordable units in a residential project of four or fewer units. This program is the City’s primary tool to provide affordable housing throughout the community and ensures access to areas of opportunity, amenities, and housing available to a range of income levels. The City will also re-evaluate its current ordinance to ensure that the provisions remain appropriate and do not impede the development of housing and are effective in providing an affordable component to new development.Program 3 – Adaptive Reuse converts existing buildings, including market-rate housing to provide opportunities for new residential uses and new affordable and special needs housing. The City identifies at least 4 sites for adaptive reuse, which could include sites in the area identified by the commenter, by 2026. As part of considering alternative housing types under Program 4, the City may identify opportunities for lot consolidation in predominantly single family areas to increase potential for very low-, and low-income housing sites. The City does not select sites that are “the worst” for affordable housing development. Further, the California Environmental Quality Act (CEQA) requires the City to consider and mitigate potentially significant environmental impacts to development projects, including but not limited to vehicle miles traveled (VMT), flood, light and glare, air quality and noise. Any discretionary project, either affordable or market rate, will be subject to CEQA. Very low- and low-income housing units do not necessarily correspond to “poverty”, as persons living above the poverty threshold are also eligible for lower income housing.

Fred Allebach (8/18/22 –

15.01 Armstrong Estates, additional comments:
• If “realistic development potential” depends on land price and price is lower at city edges, it follows that urban growth Comments regarding Armstrong Estates and inclusionary housing are addressed above.

Agenda Item #2.1:

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General Comments)
Comments within this letter are sorted by topic.
limit annexations and/or extra-urban growth limit annexations would garner cheaper land and be better for “realistic development potential.” • The vacant lots meet a current city threshold for very-low and low-income affordable housing units. If other properties in the city can be identified to take excess capacity for verylow and low-income RHNA units, and the east side needs integration, why are Armstrong lots not identified for verylow and low-income potential? Could it be that the Armstrong CC&Rs prohibit development that would result in integration of lower average-median income homes? That would be modern redlining which should be illegal. If land price is prohibitive on the east side, that is evidence that shows a pattern of segregation.

Annexations: While “realistic development potential” could involve properties outside the City’s current boundaries, the Housing Element does not rely on or include any annexations. Urban Growth Boundary: The Urban Growth Boundary provides a tool for the City to manage the pace and location of development. The City’s growth management program, which is the focus of Policy H-4.2 has been placed on hold as discussed under Program 17. Further, the ability of the City Council to exempt projects from the growth management ordinance is not a constraint on affordable or other housing as it allows the City Council the opportunity to further incentivize affordable housing projects. Program 17 ensures that, should the GMO be reactivated, that it be monitored in conjunction with Program 13 and modified to ensure adequate incentives are provided for affordable housing and fulfillment of regional housing needs.

15.02 Safeway-adjacent lot:
• The Safeway-adjacent lot counts Affirmatively Furthering Fair Housing (AFFH) very-low and low RHNA from an unproven commercial conversion (the city has no track record of experience to convert commercial property to affordable housing), which jeopardizes the potential development of such affordable housing.

Comments regarding Affordable Development Housing Opportunities are discussed above. The City will work with the Safeway-adjacent lot project proponent upon submittal of any discretionary development application to address consistency with the General Plan, Zoning Code, Housing Element, and CEQA.

15.03 Orchard lot:
• The orchard lot by SPARC puts the lowest-income residents in the 100-year flood danger near Sonoma Creek, and also near a highway, which increases light, noise, and air pollution.

The realistic capacity calculation for this site includes setbacks from the riparian corridor and development on the site would be located outside of the 100-year floodplain. Units in proximity to Highway 12 would be reviewed for compliance with the City's noise standards, which address interior noise. Trip levels along Hwy 12 in that area do not trigger a health risk assessment and development in that location would not be subject to significant impacts associated with toxic air contaminants. Further, any discretionary project, either affordable or market rate, will be subject to CEQA. Additional comments regarding environmental impacts are discussed above.

15.04 DeNova Montaldo Apartments and First Street East Townhomes:
• 12% (14) of very-low and low-income inclusionary units are from the pending 19320 Hwy 12 DeNova Montaldo Apartments and First Street East Townhomes with 10 low-, The City implemented its housing programs to accommodate affordable housing and fully met its 5th Cycle RHNA. Sites included in the inventory to accommodate the City's RHNA meet the State requirements to demonstrate that the City can accommodate its very low and low income sites. Program 13 – Housing Element Agenda Item #2.1:

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10 moderate-, and 80 above-moderate income housing units. • The DeNova Montaldo Apartments and First Street East
Townhomes are both examples of City housing opportunity sites that RHNA designated for low-income but then were sold at market rate. This sets a precedent for two thirds of the 88% of the current housing element's AFFH on two housing opportunity sites to go market rate as well, which would leave an inadequate very-low and low-income site inventory buffer.

Monitoring/Annual Reporting in the Housing Plan requires the City to review its inventory throughout the cycle and adjust if sites become unavailable or if the City's remaining inventory cannot be accommodated.

15.05 St. Francis Preserve (across from Bragg Street):
• The city owns the St. Francis Preserve lot near the Alta Madrone SAHA project (formerly Altimira Apartments).
• Why isn't the city not using this publicly-owned land in the site inventory?
• There is no news on what the issues are, or what contacts have been made to address those issues.
• The city owns this lot and should deal with the issues and put them on the table in this housing element, and then give the land to an affordable housing developer. • Missing information: The site is not listed in the Housing Element; it has no lot number or ID on City zoning map. Failure to identify this big, city-owned lot in the site inventory, and to discuss and analyze options in the Housing Element, is an oversight.

This site was not included as a potential housing site because it is a wetland preserve and open space area and is not available for development.

15.06 Sites 1-70:
• 363 total sites are vacant and underutilized; 101 very-low income, 66 low-income, 47 moderate-, 149 abovemoderate. • 205 lettered lots A-S are all pending/approved vacant and underutilized; 11 very-low, 16 low, 22 moderate, 155 abovemoderate.

This comment is noted.

15.07 Map label # 1 on Excel chart: 19357 Hwy 12 (53 very-low income, low-income and mixed-use housing units; 32 very low-income units, 21 low-income units) • 19357 W. Hwy 12 is an empty lot with an orchard on it behind the SPARC pot store and near Sonoma Creek. Rather than integrate wealthy segregated east side, city is This comment is noted. There is no current development application on file for the property at 19357 Highway 12. This site is identified as a site that can accommodate a portion of the City’s RHNA during the 6th Cycle. As outlined in the Housing Plan, the City will actively support Agenda Item #2.1:

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sacrificing precious green open space that everyone is always trying to protect. • Where is the project? • How will this reasonably go very low- to low-income? • How will “the free market” do this without aid? • What efforts to have an AH developer buy it? • What is the land value? • What appraisals and by who? • Are there metrics to show how the City arrived at “realistic development potential?"
development of the identified lower income sites in the inventory in order to meet the RHNA, as well as engaging in efforts to increase affordable opportunities and diversity throughout the community. Program 2 will encourage the City to work with affordable funding developers. Assessed values for each site are determined by the County Assessor are shown in Appendix A. The City will work with the project proponent upon submittal of any discretionary development application to address consistency with the General Plan, Zoning Code, Housing Element, and CEQA.

15.08 Map label # 2 on Excel chart: 19380 Hwy 12. 1 above moderateincome housing or mixed-use housing unit • This is the Starling bar lot on Spain and Hwy 12.
• If this is mixed use and above-moderate housing, why is the orchard lot very close by appropriate for mixed use but not very-low and low-income housing? • Can the City just assume mixed use will be whatever
average-median income unit it wants for RHNA?
• This shows that top-down zoning assumptions are possible. • Zoning has to change through some process and one of those ways is planner tweaking in Housing Elements.
• Ultimately, zoning is a shell game that can be played to garner the results desired, to separate discreet land uses or to mix and unite them, to separate people or mix and unite them. • If, in a limited two square mile space, the City has more than half of residential areas at R-L (low-density zoning, single family zoning, exclusionary zoning), and a top City goal is to protect the character (white and wealthy) of that R-L, that leaves fewer and fewer options for space to take very-low and low-income units, i.e. poor people, and thus, R-L protective zoning becomes a tool of segregation. • Segregation is not somehow accidental or non-existent; it’s real and it’s contingent on zoning choices.
• R-L protectors like to explain this all (admitting no segregation exists) as simply market forces at work, beyond These comments are noted.

Affordability assumptions are based on project-specific details for sites with proposed projects and site criteria described in Chapter 4 of the Background Report. See response to previous comments regarding programs to increase affordable housing in single family zones and high resource areas. Property zoning (such as R-L) is designated by the zoning map and zoning amendments are approved by the City Council. Single-family zoning does not necessarily exclude very low- and low-income housing categories and therefore does not directly lead to housing segregation. The City will work with the project proponent upon submittal of any discretionary development application to address consistency with the General Plan, Zoning Code, Housing Element, and CEQA.

Agenda Item #2.1:

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City control, denying a pattern of and responsibility for segregation, blaming 1% Wall Street for cashing out the 10% R-L residents, who see themselves as victims of capitalism on par with VL and L residents as victims of the system. The game of Monopoly laid it out quite well. Park Place is the 1%, Ventnor Ave. is the 10%. Baltic Ave is the BIPOC working class. And as Richard Rothstein proved in his book The Color of Law, the US gov’t itself enabled the 1% and the 10% to externalize the BIPOCs. Big fish eat little fish. R-L fish dominate dense VL and L fish.

15.09 Map label #3 on Excel chart: 19366 and 19370 Hwy 12, mixed use, mixed income
• This is an empty lot on Lyon on the way to SAHA Sonoma Oaks affordable housing development.

The comment is noted.

15.10 Map label # 11 on Excel chart: (590 West Napa, 5th cycle, 5 moderate-income housing and 5 above moderate-income housing) No comment
Noted.

15.11 Map label # 28 on Excel chart: 477 West Napa (, VL. L; Safeway lot, vacant part of lot, commercial. 45 units, 27 VL/ 18L • This property has a top, center-city valuation yet is used for very-low and low-income housing?
• Who will pay Safeway top dollar for the land for the verylow and low-income housing? • If the land goes for sale, what is stopping DeNova from doing more of the same lion at the water hole behavior? • The city needs to show more serious, concerted plans and tactics to see that the very-low and low-income housing goals actually happens here. • The problem is wishful thinking with no track record of converting commercial property to affordable housing.
• Safeway is a vampire squid giant corporation that can’t be realistically expected to conform to any benevolent local intentions, and has shown no interest in affordable housing. • The City denied Safeway a gas station in Sonoma, now the City wants a favor?
These comments are noted. This site meets the size and density criteria for affordable housing. The Housing Plan presents the City’s approach to encouraging affordable housing, including advertisement and outreach related to lower income sites. Program 2 will ensure that the City coordinates with local affordable housing developers to explore every opportunity for the development of affordable housing. The City will work with the project proponent upon submittal of any discretionary development application to encourage affordable units and to address consistency with the General Plan, Zoning Code, Housing Element, and State requirements. VMTs are calculated through function of traffic impact studies, which are required for large development projects. The comments regarding future use of the site and speculation regarding future possibilities is noted.

Agenda Item #2.1:

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• Safeway costs 4x as much as Grocery Outlet for the exact same items, how does this being closer to amenities qualify as possibly boosting access to higher opportunities? • Any lower income person with a car will never shop in Sonoma, too many savings elsewhere, this is why the idea of walk and bike to goods and services amenities is false, you need to be able to afford to buy anything, and in Sonoma, prices are laughably high. • VMT is going to be wrong in Sonoma Valley if a box is checked as simply being close to a grocery store, and that will somehow lower VMTs. Not if that grocery costs 4x as much as at a Napa Grocery Outlet. Everything in Sonoma Valley costs more; the way to lower costs is to free up infrastructure and development constraints so enough population can justify more discount stores. • Here we bump up against the essential trouble of Sonoma Valley, a Sleepy Hollow Stasis protectionism has disallowed big enough transportation arteries so the area can’t grow bigger, and this locks in a fundamental segregation and inequity. How to integrate a place where consciously restricted space results in skyrocketing land values? This is Aspen-ization. Do Sonoma essential, workers need to live in barracks 20 miles away? • What we really need here is to make a City of Sonoma
Valley out of the whole urbanized area and USA from Glen Ellen, SDC, to the Springs, Temelec, Sonoma, 8th East industrial area, east side and Sonoma Mountain TCAC High areas, and down to Vineburg on an axis with the sewage treatment plant. Then there would be space enough to plan to include/enfranchise everyone. • As long as Sonoma clings to a defensive Balkanization of its own predominant narrow R-L interests, this will be the poison pill that stops rational, equitable planning for the rest of the contiguous Sonoma Valley area noted above. See the most recent LAFCO MSR where it is recommended, in polite terms, that the City expand its urban growth boundary and annex the Springs.

Agenda Item #2.1:

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15.12 Map labels #35 and #36 on Excel chart: These are lop-sided above-moderate sites in low density zoning
• This indicates lack of effort to integrate wealthy east side and city moderate- to high-income TCAC opportunity areas.

As indicated above, projected income levels are based on site and project characteristics for the purposes of accommodating the RHNA and do not limit future development of a site to specific income levels. The Housing Plan includes programs to evaluate progress on the RHNA and to ensure that adequate sites are available to accommodate the RHNA throughout the planning period. Distribution of sites based on fair housing issues is discussed in Chapter 5 of the Background Report. As previously discussed, the Housing Plan includes programs to increase housing opportunities in single-family and high resource areas.

15.13 Map label #37 on Excel chart: 532 2nd St East 12 units Above Mod, underutilized; empty space on a lot
• Why not look for empty space on the east side and up-zone to higher density and aim at very low- and low-income housing inclusion? If land prices are all uniformly high because of a restricted space, pressure-cooker lid effect, then a self-fulfilling prophesy is created. The will to rezone and integrate is negatively impacted by the very zoning and land uses (and resulting high prices) that have been chosen in the first place.

See response to previous comment.

15.14 Map label #67 on Excel chart: 0 Fryer Creek Drive, city-owned, .24 acres - 2 moderate-income and above moderate-income housing units • 0 Fryer Creek Dr. is not an address on Google maps.

This comment is noted. Sites with a “0” address have not yet been assigned a street number.

15.15 Map label # 69 on Excel chart: 250 Napa Road, just east of Friedman’s, 21 vacant residential units, 10 moderate-income housing units, 11 above moderate-income housing units • Across the street from Friedman’s to the south calls for very-low income and low-income housing, same area, why the difference in zoning and RHNA average median income? If smaller private parcels will sell for higher prices, and City areas for AFFH and AH are increasingly marginal, something has to give in City land use and zoning so as to meet state AFFH objectives.

This comment is noted. As indicated above, projected income levels are based on site and project characteristics for the purposes of accommodating the RHNA and do not limit future development of a site to specific income levels. The Housing Plan includes programs to evaluate progress on the RHNA and to ensure that adequate sites are available to accommodate the RHNA throughout the planning period. Distribution of sites based on fair housing issues is discussed in Chapter 5 of the Background Report. As previously discussed, the Housing Plan includes programs to increase housing opportunities in single-family and high resource areas.

Agenda Item #2.1:

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Via Program 13, the Housing Element will be regularly monitored and annual reporting will occur to assess affordable housing programs and progress towards RHNA.

15.16 Map label # 70 on Excel chart: 250 Napa Road, just east of Friedman’s, 21 vacant residential units, 10 moderate-income housing units, 11 above moderate-income housing units AND 45 Napa Road (same lot as 69 Napa Road, different part of lot including vacant residential, housing opportunity site; 11 very low-income housing units and 7 low-income housing • Both sites will need to be streamlined for development. - This is where there are rumors of a Darius Anderson hotel/ affordable housing tradeoff for satisfying the housing requirement for the extreme CEQA-stalled Plaza hotel. • These lots are not listed as pending, but something seems to be pending in this area; maybe a sphere annexation of the Zepponi lot? • 250 Napa Road - This is the back end of the Four Corners auto service station lot.
• 250 Napa Road - Where is the Darius Anderson housing
trade-off site everyone keeps talking about and why is this site not mentioned in the Housing Element? • 45 Napa Road - Zepponi sphere site is immediately adjacent to the south, that would require annexation.
• 45 Napa Road - Growth management ordinance at 122 units from accumulated growth manage ordinance allocation; maybe this is the Darius site? Comments regarding location and uses of sites is located. As indicated above, projected income levels are based on site and project characteristics for the purposes of accommodating the RHNA and do not limit future development of a site to specific income levels. The Housing Plan includes programs to evaluate progress on the RHNA and to ensure that adequate sites are available to accommodate the RHNA throughout the planning period. Distribution of sites based on fair housing issues is discussed in Chapter 5 of the Background Report. As previously discussed, the Housing Plan includes programs to increase housing opportunities in single-family and high resource areas.

15.17 RHNA Allocation
• If total RHNA allocation is 311, there is a discrepancy with the city is listing of 568 units on the Excel site inventory chart. It is not clear what the reserve is for. • Of 311 total RHNA units, half (155 units) has to be lowincome and very-low income. • East side land valuations are much higher than the west side. The city needs to show a track record that development of certain sites will be possible. On the east side there is a much higher likelihood of above-moderate The City is listing sites that are anticipated to be available to accommodate the RHNA during the 6th Cycle. As shown throughout the Housing Plan, the City has identified many programs to support and further affordable housing, including programs that provide for integration of affordability into high resource areas. As discussed in Chapter 4, there is excess capacity. Program 2 - Partnerships with Affordable Housing Developers: Vacant parcels are not necessarily controlled by non-profit developers who dedicate 100% of their units to affordable housing. Program 2 encourages creative approaches to finance, build, and rehabilitate affordable and special needs housing.

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housing being developed than anything below-moderate, that is the track record. • If segregation is not to simply be a default outcome of city land use policy, the city needs to show active plans to integrate the east side despite higher land values. • East side plans missing from Housing Element; east side integration is totally eluded in the Housing Element, and zoning is not identified as a constraint. • RHNA 2000-2020 identifies 236 moderate- and belowincome housing units and 293 above-moderate income housing units, which indicates that affordable housing production is what's needed most in Sonoma and the Housing Element should bend over backwards with assertive, bold programs and policies to realize that goal. • 88% of all affirmatively furthering fair housing, very-low, and low RHNA units are located on three sites along Highway 12 with no guarantee that affordable housing developers will purchase these sites. Sites are individually owned and will be developed as the market dictates. • City staff indicates that opportunity sites are not owned by a non-profit developer dedicated to 100% affordability.
• Sites are individually owned and will be developed as the market dictates.
• The criteria used to determine opportunity sites was based on lot size, realistic development potential, and location. Each site has its own realistic capacity column and the potential number of affordable units and affordability level. Only a percentage of the sites on the opportunity sites list have the potential to be developed with affordable housing.” • This puts the AFFH buffer at risk with no backup because the city has few two-acre minimum sites for realistic affordable housing development capacity left. • What about collaboration plans with the County to address super high County RHNA in Rezoning sites at Merlo by Broadway Market? The City has partnered with several different non-profit developers in the provision of affordable ownership and rental housing. Additionally, the City will work with the project proponent upon submittal of any discretionary development application to address consistency with the General Plan, Zoning Code, Housing Element, and CEQA. The City will work with the project proponent upon submittal of any discretionary development application to address consistency with the General Plan, Zoning Code, Housing Element, and CEQA. Affordability of sites is based on the characteristics of proposed and approved projects, deed restriction, past performance of similar projects or units, and site criteria assumptions for affordability, as discussed in the Inventory of Residential Sites in the Background Report.

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• Why list Doyle as all Above Mod and Mod when it could be top-down zoned as an Opportunity Site for very-low and low-income housing just like 69 Napa Road? • If annexed sites would count toward RHNA, why no plans for the 182 accumulated GMO units at Merlo and Zepponi?

15.18 R-L Zoning, additional comments:
• The City modus operandi now is to use zoning to protect R-L “character”, to play as many “historic” cards as possible so as to limit density in single family home areas; no one ever mentions the increased property values that come with such protection.

Chapter 4 of the Background Report provides metrics for realistic capacity. See response to previous comments regarding increasing affordable housing opportunities in high resource and single family zones. Program 14 – Design Guidelines and Design Review: Development Standards: The City uses design review to ensure development embodies excellence in architectural design and complements the scale, character, and rich history of the community. Such standards are applied City-wide, not just R-L zoned properties.

15.19 Segregation:
• The city needs to provide metrics for “realistic capacity.” “Potential” is also constrained by voluntary city zoning and code choices that force affordable housing projects out of RL and R-M zones, thereby creating and maintaining pattern of segregation. • In a way, control of City zoning and the City Municipal, Code can be seen as a racket by the predominantly single-family home owners (and their enablers) who dominate and who have dominated City government, that protects their vested stake in increasing property values and in a status quo that denies any culpability for segregation. This Housing Element seems like an extension of the priorities of that racket, or regime of power and control. • The city cannot satisfy AFFH and integrate the
predominantly white, wealthy east side with just ADUs that will likely all rent above average median income.

Chapter 4 of the Background Report provides metrics for realistic capacity. See response to previous comments regarding increasing affordable housing opportunities in high resource and single family zones. See discussion of fair housing issues in Chapter 5 of the Background Report. Program 21 – Affirmatively Further Fair Housing (AFFH): The AFFH includes data and information regarding segregation and the City’s racial history, including identification of areas with limited diversity and acknowledgement of past racially exclusive practices in Sonoma. Programs have been revised accordingly to promote diversity, both economic and racial, by increasing access to areas with less diversity. Program 15 – Development Code Amendments – Housing Constraints: This program minimizes governmental constraints under the City’s control to facilitate the provision of housing and encourages innovation in design, ownership, and living arrangements.

15.20 Market rate housing:
• DeNova Homes has been buying available land in the City for market rate projects, with as high a price point as possible (as evidenced by the Mockingbird Lane R-O site project where prices ended up being up to $500,000 more than DeNova said, because the market went up). DeNova is like lions waiting at the watering hole, they are killing the These comments are noted. Any developer, including DeNova Homes, has the right to purchase available land to develop homes for sale at market rate. The City’s inclusionary housing requirement and Program 1 require such developers to set aside a percentage of both rental and ownership units for affordable housing.

Agenda Item #2.1:

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City on a glut of market rate housing. If the City’s plan is basically to be a deer in the headlights for the market, and surrender to market forces, then the Housing Element will basically just continue the pattern of overproduction of above-moderate income housing. • No annexation plans appear except for possibly the 20455 5th East, the Doyle lot (DeNova Homes). The site inventory says this will be 59 units total, 47 above-moderate income housing and 12 moderate-income housing. • The Housing Element says, “if annexed, development would count towards RHNA.” Is the same true for other possible sphere annexations on the Merlo, Zepponi, and Serafini lots? This counts towards RHNA at what average median income? More market rate glut? • DeNova advertised this in an initial presentation as
“attainable housing” but refused to give a price point. This refusal to be specific is kind of like the current City HE, say whatever you need to say to get what you want. • The city should actively and aggressively counteract the market by considering the suggestions of David Brigode and David Eichar, whose housing element public comments needs to be considered, as opposed to excuses and denial.

Comments regarding development partnerships with affordable housing developers, annexation, and feedback from David Brigode and David Eichar are discussed above.

15.21 ADUs:
• ADUs are all classed as moderate-income for the site
inventory, and 64 ADU units are expected through the whole 6th cycle. • People rent ADUs, not buy them. • ADUs are in the same size as SB-9 units, 700-800 sf. • If rental ADUs and rental SB-9 units are essentially the same size, why can one be forced to be deed-restricted as lowincome housing (top end 80% AMI) and the other counted as moderate-income housing (top end 120% AMI)? Landlords routinely maximize the allowable rent, so top end is a reasonable expectation. • ADU policy will need clear, enforceable parameters to measure if any are actually rented at moderate, very-low, or low-income. A potential ADU tenant needs to know if the ADUs are classed as moderate income based on the City’s 5th Cycle reporting of ADU units. This is not a limitation that restricts ADUs to only being affordable to moderate income households. Program 5 provides for affordability of ADUs to be tracked and it is anticipated that a number of ADUs will be affordable to very low and low income units based on Bay Area data collected for ADUs. Deed-restriction requirements for ADUs are based on State law.

Agenda Item #2.1:

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unit is ear-marked as affordable at some level, and what rights they have. • Can only locate five ADUs on the site inventory Excel chart.

15.22 Additional constraints to affordable housing:
• This AFFH site location potentially concentrates poverty, not integrating any into east side tax credit allocation committee (TCAC) moderate- and high-opportunity areas. This also puts actual construction up to a wing and prayer. • Where are the lower-average median price developers who will build?
• Where are the plans and affordable housing developer
relationships to be ensuring that these sites do not go market rate? • What evidence is there that Safeway will do anything? The city has no track record of a conversion of a commercial property like Safeway to affordable housing; this should be questioned by HCD. • The zoning at 20455 5th East is classed as “sphere.” What will that City zone be? Can the County help out and rezone/up-zone ahead of time? What productive, cooperative relations with the County have set the table to meet the needs of both City and County RHNA? An R-O site? R-H High density? This Doyle lot has City high density on one side and City medium on the other and no neighbors want high density no matter what the AMI range; this possible project will be NIMBY WW3. • [How to answer this?] For the vacant and underutilized and 6th cycle AFFH, we see the city under pressure to show better lower AMI #s, but without specific plans to recruit non-profit developers, which there have been none in public nor in any public meetings, it appears the city is just saying stuff here to pass the HE. See David Brigode’s site inventory public comments.

See response to previous comments. As previously discussed, the AFFH includes data and information regarding segregation and the City’s racial history, including identification of areas with limited diversity and acknowledgement of past racially exclusive practices in Sonoma. Programs have been revised accordingly to promote diversity, both economic and racial, by increasing access to areas with less diversity. Affordable housing developers may build in any residential or mixeduse zone and include affordable housing provisions via Program 1. The City will work with the project proponent of the Safeway lot upon submittal of any discretionary development application to address consistency with the General Plan, Zoning Code, Housing Element, and CEQA. Program 2 will ensure that the City coordinates with local affordable housing developers to explore every opportunity for the development of affordable housing. Comments regarding AFFH, development partnerships with affordable housing developers, annexation, and feedback from David Brigode are discussed above.

15.23 Missing information:
• Unable to find or access site inventory in two online Housing Element documents given by the city; the digital copy is very cumbersome.

These comments are noted. The site inventory is located in Appendix A and is discussed in Chapter 4 of the Background Report. Land values and existing development information is based on County Assessor data.

Agenda Item #2.1:

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• Unable to find a text explanation of the Excel chart because the massive Adobe .pdf document is too complicated, not user friendly; page numbers do not work or are not numbered in logical fashion. • This Housing Element is particularly inscrutable. This site inventory chart needs a short explanation of what it is and how it’s laid out. • Unable to see that any specifically reserve sites are laid out; will the city outline the 311 RHNA allocation and have a dedicated reserve buffer, or mix them all together? • If mixed, will they all be counted as 6th cycle units? • The Excel site inventory chart does not total to 311 anywhere, have to manually add up all the numbers.
• The land value and improvement value categories fail to explain the metrics, is it by square foot, by the acre, what? What is the rationale here? Improvement to land value ratio is unexplained, there is no basis given to believe this or not. • If there are lower land values on the edge and just outside the City, and the City is very small, two square miles, this gives a rationale to expand the UGB to gain access to appropriately sized and priced lots for AH. • If the City wants to find every reason why not to have new land for AH, but then not have realistic AFFH/ AH land capacity in the City, then HCD will start to see a glimmer of Sonoma’s Green Checkmate, NIMBY land management pattern. • Possible SB-9 units are not identified as part of inventory. If only 5.4% of all units are expected to go SB-9, that would be at 16 of all of Sonoma’s 311 6th Cycle RHNA. • This is important because the city SB-9 ordinance says all SB-9 units for renters have to be deed-restricted to Low AMI (Mod for ownership), so the public has to be able to see which units the city expects to go SB-9 and then to count them to the proper RHNA AMI category. Why are possible SB-9 units not identified in the site inventory? • If any rental SB-9 units count as moderate or abovemoderate income housing, this won’t be consistent with city SB-9 ordinance, or if any are classed as very low-income Program 17 speaks to the growth management ordinance, which manages increases in service and infrastructure demand from development consistent with available water supplies and sewer treatment capacities. This ordinance limits the City to a development average of 65 units per year. If implemented, this number is sufficient to accommodate Sonoma’s regional housing needs, defined as 311 units for the 6th cycle.The approach to SB 9 sites is discussed in Chapter 4 of the Background Report.

Agenda Item #2.1:

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housing, that would be inconsistent as well. The City has boxed itself in with ADU, SB-9 and affordable by design inconsistences. The City SB-9 ordinance assumes affordable by design is impossible in Sonoma in single family zoned/ RL areas, therefore if the city counts any market rate Mod rental units in SFZ areas to 6th cycle RHNA, this goes against its SB-9 ordinance rationale to deed restrict all SB-9 units. To be consistent, all rental moderate-income and below housing units in the city’s 6th cycle RHNA need to be deedrestricted, or the SB-9 deed-restriction needs to be lifted.

15.24 A few Ta-Nahisi Coates quotes:
• “… ‘gentrification’ is but a more pleasing name for white supremacy, is the interest on enslavement, the interest on Jim Crow, the interest on redlining, compounding across the years, and these new urbanites living off of that interest are, all of them, exulting in a crime. To speak the word gentrification is to immediately lie… white people are, in some profound way, trapped; it took generations to make them white, and it will take more to unmake them.” • “To ignore the fact that one of the oldest republics in the world was erected on a foundation of white supremacy, to pretend the problems of dual society are the same as the problems of unregulated capitalism, is to cover the sin of national plunder with the sin of national lying.” • “White America” is a syndicate arrayed to protect its exclusive power to dominate and control (Black) bodies. Sometimes this power is direct (lynching), and sometimes it is insidious (redlining).” Noted. See AFFH analysis in the Background Report.

Fred Allebach (8/22/22 – Site Inventory)
Comments within this letter are sorted by page number.

16.01 Page 95
• Table 61 shows that 6th cycle pending and approved above moderate-income housing units (113) is outstripping moderate- and below (39) by far. This is the same pattern as 2000- 2020 RHNA performance, where the city had an above moderate-income housing unit overproduction of 293, and a 236 underproduction of moderate-income housing and below. Throughout the Housing Element the city emphasizes having met 5th cycle RHNA targets but ignores aggregate performance from 2000-2020.

Aggregate 2000-2009 reporting is outside the scope of this Housing Element. Comments regarding housing segregation and underutilized properties are addressed above.

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• There are 91 above moderate-income housing units in
vacant areas not allowed for very low- and low-income housing and 22 above moderate-income housing for underutilized areas not allowed for very low- and lowincome housing. Therefore, 111 sites in the city, for above moderate-income housing are closed off from very low- and low-income housing, mostly low and medium density areas; is this a pattern of segregation?

16.02 Page 96
• There 64 ADUs for the 6th cycle, all at the moderate
average median income (AMI) level. There is no requirement for this, it’s a guess and a hope. Moderateincome housing is 80-120% AMI. Rents almost always go to maximum level possible. With no deed restriction, ADUs can be expected to rent for whatever the market will bear and in Sonoma, that is a LOT, most likely higher than 120% AMI. ADUs will thus only reasonably be affordable to the above moderate-income AMI class. It is extremely likely that no low -or very low-income renters will be able to afford 6th cycle ADU rents and moderate-income housing may be priced out too, even as the city counts all ADUs as moderate-income for RHNA. • The city assumes some ADUs will be affordable to lowincome and very low-income AMI. HCD should require that the city show proof that ADUs are renting at the moderateincome level, and require the city to undertake enforceable actions and trackable programs to ensure that ADUs rent at that level. • Note, the City SB-9 process and ordinance, where
“affordable by design” housing is assumed to be impossible in Sonoma at any square foot level and therefore the City size and deed-restricted SB-9 units to 800 sf and Low AMI for rentals and Mod AMI for ownership. • This deed restriction is an impediment, deterrent, and constraint to housing construction because owners will be less able to recoup construction costs from low- and moderate-income housing rents. As Planning Commissioner Steve Barbose said, “If you require on a single-family lot in town that people build an affordable housing unit, with These comments have been shared above, and are noted again here.

Comments relating to ADUs and affordable housing development opportunities are addressed above. In summary, ADUs are governed by State law; where they are permitted and developed are driven by residential property owners.

Agenda Item #2.1:

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building costs what they are, effectively what you’re going to do is keep that house from being built… Because the person who’s thinking about building is not going to be able to afford it.” • Critical info for the reader on why VL and L sites are all on Hwy 12: 20 units per acre is state “default density” for VL and L This is cited in the HE • City sites for VL and L are zoned C (commercial), MX (mixed use) and R-O (housing opportunity site) from .5 - 10 acres. Why a default density of 20? bc VL and L can’t be produced at a one-off level, larger scale and numbers are needed to make affordable unit production pencil. AH developers need two acres and at least 50 units to make a lower AMI affordability project pencil. • However, in Sonoma R-O sites are routinely bought by
market rate developers (DeNova) and made into market rate projects. • Sites anticipated to accommodate VL and L: There are WAY too many typos and errors here, very hard to navigate, took me 40 minutes to decipher, very poor proof reading, so many typos and errors wastes the public’s time. • The pending 1st St East townhomes (Listed as site J in HE, is actually site H; listed as 50 units, 0 VL, 10 L, 10 Mod and 80 Above Mod • Site 38 typo, 38 is Above Mod, maybe site 28 477 W. Napa St/ Safeway?
• Site 80, there is none on site inventory, only goes up to #70 is this 19357 Hwy 12? The behind SPARC orchard site?
• Site C is a typo, this is site B, only one VL and L each anyway • Site A is correct, 10 VL, 4 L, 41 Above Mod • The huge bulk, 88%, of the VL (101) and L (66) units for 6th cycle RHNA are in three locations along Hwy 12: Napa Rd/ Hwy 12 and Broadway, the Safeway vacant lot on Hwy 12/ Napa St. and an old orchard site behind SPARC on Hwy 12. Addresses for the above: 19357 Hwy 12, 45 & 69 W. Napa Rd., 477 W. Napa St. • Aside from the above, the 12% other VL and L in the HE are 10 VL and 13 L. Of these, 10 VL and 4 L are at DeNova’s Agenda Item #2.1:

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Montaldo Apts. on Hwy 12, and then 9 L at First St. East townhomes • Hwy 12: 167 VL and L units, 88%, Montaldo and First St East Townhomes: 23 VL and L units, 12%

16.03 Page 97
• R-M zoning (moderate) can go 10 per acre density in R-M, moderate density can also go on R-H (high density), C and MX zoning • This is telling: “The City has used these default density thresholds as a guide in allocating its sites inventory by income category, as presented in Table 61 and detailed by site in Appendix A.” • What this says is that the City makes zoning rules to protect R-L and R-M from VL and L integration and then turns around and says “we are only obeying and being consistent with the rules.” This is the Plato’s Cave shadow of exclusionary zoning. • East side lots of smaller size had to be subdivided at some point. Lots of size in Armstrong could be reaggregated to make sizes sufficient for AH projects. Land cost would be similar to the Safeway vacant lot the City is calling for all VL and L. My thought process here is how to get east land for AFFH? One way would to get the size and the AFFH/ TCAC location would be to annex east side sphere parcels 885 and 905. • “… development trends in the City indicate strong support for redeveloping sites with more intense residential uses.” Why not redevelop and rezone the east side? Why all on Hwy 12? These comments related to inclusionary housing, Armstrong Estates, and housing segregation have been shared above, and are noted again here.

16.04 Page 98
• Development trends in Sonoma have been demonstrably,
predominantly market rate, and Above Mod. ABAG RHNA performance website: 2000 -2020, Sonoma underproduced Mod and below by 236 units and overproduced Above Mod by 293; this is the actual lay of the land, yet City keeps saying “we met 5th cycle RHNA, everything is great.” This is like having had cancer but then never mentioning it to the doctor bc you didn’t have it in the last eight years.

These comments related to housing segregation have been shared above, and are noted again here. See response to previous comments.

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• Market conditions: no mention of 2000- 2020 RHNA
performance, a performance that led to and maintains current R-L and R-M segregation.

16.05 Page 99
• Projects with entitlements; Pending projects: all Above Mod. BAU in Sonoma is Above Mod. Above Mod is what drives all prices up and what is predominantly on the east side. Important to note that there are no 100% AH/ 60% AMI and below projects pending. SAHA (AltaMadrone Apts) on Broadway was the last 100% AH project for many years before and after. The City has all manner of excuses why not. This while the Springs (contiguous unincorporated area right next to Sonoma) has 170 60% AMI and below units pending in two big projects. Sonoma has no big projects pending and there is no guarantee that the three Hwy 12 locations ID’d for VL and L units will not go market rate. This shows Sonoma is just not creating the conditions, “setting the table”, to have AH here and it is really only the HE process that is forcing the City to even talk about it. • City 6th cycle RHNA for VL is 83 and for L is 48, 131 total for VL and L. On the three Hwy 12 sites noted above that are planned to take 88% of 6th cycle VL and L, there is a 36-unit excess VL and L capacity. Since these sites are in no way guaranteed to not go market rate, and no plans or projects are lined up, one would have to conclude that the City has put almost all, except for 12%, its VL and L eggs in one unsure basket, and therefore there is not a reasonable, planned-for excess capacity for VL and L in the site inventory. If any of these three Hwy 12 sites do not pan out, that leaves only the 23 at Montaldo and First St East townhomes as back-up, to make up the 6th cycle 131 for VL and L. My impression is that current site inventory is not a very sure or assertive way to go about meeting the VL and L RHNA requirements. Maybe rezoning R-L exclusionary zoning at the two .5+ acre lots at Armstrong estates should be added as options? • I suggest VL and L site option #1 should be to annex the east side sphere parcels; that would be way more like meeting the intentions of AFFH.

Noted. The SAHA project was completed during the 5th Cycle. The City has had multiple projects with affordable components in recent years (5th Cycle) as discussed in Chapter 6 of the Background Report. Commenters concerns regarding potential market rate development of sites identifies as having capacity to accommodate lower income housing are noted and have been addressed previously.

Agenda Item #2.1:

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16.06 Page 100 - ADUs
• 64 ADUs over the whole 6th cycle. “…it is anticipated that a portion of ADUs will be affordable to VL and L income households.” What is “a portion?” How many? How? Under what magical spell? • All ADUs in the HE however, will be classed as Mod. This is troubling bc in the City’s SB-9 ordinance it is assumed that nothing below market rate can be affordable by design in Sonoma, that’s why the City deed-restricted all SB-9 rental (800 sf max) to Low and ownership to Mod. • If ADUs at 700-1200 sf can be assumed to go Mod, why not SB-9 units too? Seems like the city is speaking with a forked tongue here; on one hand 700 sf ADUs are affordable by design to “a portion” of VL and L residents but an 800 sf SB9 unit cannot be affordable by design and needs to be deed restricted to L for renters? • Upshot: SB-9 units should be consistent with ADU
assumptions on attainability and have the City SB-9 deed restriction changed to 80-120% AMI for renters, otherwise there are two diff objective standards at play for the same square foot units. If nothing in Sonoma can be affordable by design, then all site inventory at Mod and below should be required to be deed-restricted. • Table 62
o For .5 and more acres, vacant sites: there are
23 vacant R-L sites and one R-M site in the City; these are all closed to VL and L by default density assumptions that R-L and R-M will not be rezoned in the 6th cycle HE, bc as the City lays out, there are adequate sites elsewhere. To this, I counter that there is an existing pattern of east side segregation that needs to be addressed, and that all HE VL and L site eggs are in one basket leaving an uncertain buffer. o For 1 to 2.5 acres vacant, for R-L and R-M there
are five more sites. These should be, with R-L first, ID’d for multi-family units of four or more each.

These comments related to ADUs have been shared above, and are noted again here.

Agenda Item #2.1:

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16.07 Page 101
• For underutilized there is one R-L site at five acres. Upshot, there are plenty of .5 – 10 acre sites in R-L and R-M zoned areas, it is only an arbitrary zoning classification that keeps poor, BIPOC people, VL, L, out; this can be seen as modern redlining, exclusionary zoning without the overt racial terminology. The five acre R-L siter should be ID’d for VL and L in the site inventory. • See my SB-9 objective language analysis essay where the true intentions behind City Dev. Code objective language are revealed by Planning Commissioners and later voted for by the City Council. • That nearly All VL and L are going on or right near Hwy 12, recaps redlining and Urban Renewal’s poor relocation record of putting poor people in the worst locations; this is framed by the City as an improvement to “revitalize” these Lower Resource TCAC areas. This “revitalization” seems like a pure fantasy, pulling the wool over the public’s eyes with a nebulous term that practically has low chances of succeeding without more assertive, honest and meaningful guardrails than Program 21 set by the city to make sure the ideas come to fruition and that actual patterns of segregation are addressed. • The HE site inventory as a whole could just as easily be seen as furthering intentional segregation by protecting the “character” of low density, single family-zoned areas, under the guise that higher density is more appropriate elsewhere, for a variety of optional, not necessary assumptions about land use and use-compatibility. • The Figure 2 aerial map of inventory, is very hard to read.

This should be worked on to make it easier to see, lighten the background, make ID colors and markings clear and distinct, double the size and make a foldout.

These comments related to housing segregation and underutilization of sites have been shared above, and are noted again here.

16.08 Page 105
• AFFH: “taking meaningful actions, in addition to combatting discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics.” These comments related to fair housing and segregation have been shared above, and are noted again here.

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(Race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability) • Meaningful actions, discrimination, access to opportunity, patterns of segregation, barriers that restrict access to opportunity… What would not undertaking any HE rezoning and keeping VL and L out of R-L and R-M zoning be then if not discrimination, denying access to opportunity, patterns of segregation, and barriers that restrict access to opportunity? • I have to conclude that the city is avoiding naming and being responsible for segregation and not taking meaningful actions bc a segregation problem is refused to be admitted to. Sonoma and the consultant have adopted a willfully ignorant, partial view that seeks to spin the facts of Sonoma to be different than clear patterns of segregation, that can be seen and demonstrated with the data in this HE, esp. from the AFFH data viewer. • AFFH analysis avoids key zoning and segregation Census Block Group data, denies visible, demonstrable trends and patterns of segregation, allows segregated near-RCAAs to stand, doesn‘t address already-externalized regional minorities and protected classes, does not utilize the three east side Block Groups to give higher VL and L AMI protected classes access to opportunity; keeps disparities going by restricting VL and L income access to R-L and R-M zoning areas and the HE fails to have a reference section that shows what research the City did to arrive at its conclusion that there is no pattern of segregation, or to show what materials were not cited. • Outreach - Is the full HE translated to Spanish?

16.09 Page 106
• Workshops and Public Hearings - Some Planning
Commission members are hostile and unresponsive to housing advocate’s points, esp. in the recent SB-9 process. City Council is unresponsive. It is routine for the public to get no response to communications or public comments. What good is public involvement if it’s not accounted for in any policy or action? Comment noted. The City is required to accommodate the RHNA as allocated by ABAG.

Agenda Item #2.1:

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• Balancing Act online engagement tool - This was a good idea but I found the software difficult to use and to do a thoughtful site distribution. The options did not let me slice and dice like I wanted. There was a paltry response (14 responses) from the public, making results inconclusive. Outreach was maybe not that strong, and/or is representative of a disengaged citizenry. Putting announcements on the City website is not enough outreach. • The citizenry that did show up for the City’s 2019 Housing Our Community (HOC) series made a public recommendation of 725 new units for the 6th cycle, half deed-restricted, yet the City acted to reduce its initial RHNA from 480 to 311. The HOC materials are very difficult to find on the City website, took me 10-15 mins and there is no summary of findings.

16.10 Page 107
• Housing Survey 381 responses, 343 from city Responses were mostly how great it is in Sonoma, which for people for whom money is no object would say. And, all of Coastal Cal is a very nice place to live climatically and geographically, regardless of jurisdiction. • The survey showed signs of trouble too: 43% concerned about unaffordable rent, 29% struggle to pay rent or mortgage, 30% are intimidated to ask for repairs by property manager or landlord. • Stakeholder Input - Sonoma Valley Housing Group, SVHG, a left of center group of which I am a member, a group well known and among the few who show up to comment on housing issues, was not asked to participate in stakeholder input. This was disrespectful for a group that shows up way more than others, but the ultra-Right Farm Bureau was asked to comment, and they never show up to anything here.

Noted. The City will add SVHG to the stakeholder list for future projects.

16.11 Page 108
• Assessment of Fair Housing Issues - Key data and
background info is from a 2012 county study. 10 years old. This study is said to be: “the most recent comprehensive regional analysis of fair housing issues.” This is These comments related to fair housing and segregation have been shared above, and are noted again here.

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preposterous! 2012?!Q%@# With so many newer studies it is inexplicable why a 2012 study would be relied on. • What about UC Berkeley Otherling and Belonging regional segregation studies? What about numerous local studies I shared with the City and the consultant? Since there is no references section or citations for many items, it’s impossible to see what the consultant did or do not consider for data. No reference section or textual citations makes it easy to see why the HE comes off as rosy colored sunglasses spin; the City wants to pass the HE and not make waves by drawing attention to local segregation and inequity, the more problems ID’d, the more work and responsibility would be entailed. • This HE draft almost seems like a calculated test to see how little can stick with HCD. I hope that when the City gets its first rejection letter from HCD, that the next draft will have a redline version so the public will not have to wade through all of this again to see that all details, comments, suggestions, and questions have been addressed. • Indeed, an off the record staff comment, about why the City would not take any of the county’s huge RHNA to further “smart“ city-centered growth, or to offset the proposed 1000 units at SDC, staff said in effect, the higher the City RHNA obligation, the more chance to fail… why would the City take on more risk? • The City is more concerned to check easy boxes and pass the HE then to honestly address patterns if segregation and Valley housing issues in a bold way, would rather play it safe and pass than to address patterns of segregation and fail. • “The unexamined life is not worth living.” Socrates • I sent the following links to the City and to HE consultant Beth Thompson and never had a response and was told by City staff I should not contact the consultant without city staff present. My sense is that the HE is spun away from grappling with real Valley/ regional disparity issues and is narrowly focused on Sonoma as a fantasy island of privilege, where housing equity problems are framed as only applying within city boundaries. Since the poor and BIPOC have largely been externalized from Sonoma, there’s no Agenda Item #2.1:

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problems! A larger view would dig deeper into why the City TCAC Education score was so low. Why? Bc the Valley socioeconomically disadvantaged who have been displaced from Sonoma are counted in City school/ TCAC education scores. This is just the tip of an inter-related Valley housing iceberg not even hinted at in the City HE. o District R maps 2020 Census-based, from
Sonoma county Redistricting process; you can get really granular with these in any county areas o DWR DAC mapping tool o Hidden in Plain Sight study 2017, Sonoma Valley Fund
o County EDB studies, EDB Hispanic
Demographic Trends 10/22/20
o Hanna Fortulezas/ Latinos in Sonoma Valley
study, 2020
o Los Cien’s Latino Scorecard and United Way
Real Cost presentations, 10/22/20
o Sonoma Valley Collaborative’s Homes for a
Sustainable Sonoma Valley, 2020
o The State of Working Sonoma, Fall 2018, Jesus
Guzman (I can produce the report for you)
o Generation Housing State of Sonoma County
Housing 2022
o Measure of American Portraits, Sonoma
County/ Springs, 2010, 2020 HDI scores
o Urban Displacement Project shows Sonoma
and Springs areas as “becoming exclusive” and “early ongoing gentrification”

16.12 Page 109
• Fair Housing Enforcement and Outreach Capacity - Pretty weak, landlords and property manager agents have all the cards, tenants have a seriously over-burdened Legal Aid and few rights, and very low ability to undertake any legal proceedings with City Code enforcement already stretched too thin to enforce Sonoma’s many rules and regulations, it’s doubtful that fair housing enforcement will be apt in any meaningful way.

These comments related to fair housing have been shared above, and are noted again here. Also: Program 20 – Fair Housing Services: Fair Housing Advocates of Northern California is the designated provider of fair housing and tenant-landlord information throughout the County. This agency Agenda Item #2.1:

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provides fair housing investigation and coordinates referral services to assist individuals who may have been victims of discrimination.

16.13 Page 110
• Compliance with Fair Housing Laws - Density bonus law: If VL and L are not allowed in R-L and R-R zoned areas, to keep the density low and protect the “character”, then a density bonus does nothing to integrate these areas. • Housing Accountability Act: the City has done an end-run on the HAA having a VL, L and Mod- restrictive zoning code, and by loading up City Development Code objective language to reflect low density protectionist values. Dense infill with VL, L, and Mod units, in R-L and R-R areas are already, a priori disapproved. • An excessive historic preservation pattern in Sonoma
further restricts development.
• Least Cost Zoning Law: here the City shows circular
justifications for maintaining segregation of near-RCAA areas; all income categories need to be covered in the HE, compliance is achieved through implementing the GP and HE, “consistent with” a zoning code that perpetuates segregation and denies VL, L, and Mod access to higher opportunity east side Block Group areas. • Excessive Subdivision Standards: “Refrain from imposing criteria for design or improvements for the purpose of rendering infeasible the development of housing for any and all economic segments of the community.” This is exactly what the City did with its SB-9 and UGB ordinances, inserted poison pill language “for the purpose of rendering infeasible the development of housing.” • This may also apply to Armstrong Estates, no study has been done on Sonoma CC&Rs to show how subdivision standards plus zoning may chill neighborhood inclusion of VL, L and Mod housing. • The state has already called out Sonoma on its SB-9 poison pills, the City UGB has the same exact poison pill pattern: rendering infeasible any extra-UGB annexation with excessive deed-restriction, lot size limits, and a clause that there can be no extra-sphere annexation if there is vacant These comments related to housing segregation, fair housing, and fair housing services have been shared above, and are noted again here.

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or underutilized land in the city without defining what the economic feasibility of such vacant and underutilized land is. • The pattern here is that the City uses the letter of the law, that it creates in secret-to-99% Development Code language, to minimize integration potentials, rather than take a more assertive, proactive course for AFFH; this is Miles’ Law, the people in power at the City are protecting their low density, single family home-zoned character, this is the primary value when it comes to housing. The dominant view since Mayor Harvey left, is of low-density protectionism.

16.14 Page 111
• Housing Element Law - Ditto above comments on a GP and HE system primarily designed to protect and preserve low density, single family zoning which has the effect of modern redlining of three east side Block Group areas. • The HE here cites the 2012 study (when many more recent studies are available) and seeks to proscribe the discussion of AFFH to avoid addressing segregation, specifically impediment #2: ethnic segregation and lack of AH.
• If the City has externalized BIOPOC protected classes through conscious, triple bottom line unsustainable economic and tourism policy, then outreach to these classes is not necessary, even as such BIPOC people live right next to the City in unincorporated, racially concentrated areas of poverty, specifically Census Tract 1503.05. • If the City has already externalized BIPOC and concentrated wealthy whites in $800,000 to $2 million east side homes, can the City then claim there is no segregation in town? This is disingenuous. If the whole HE is avoiding Sonoma accountability for actual patterns of segregation, and regional segregation in Sonoma Valley is not even mentioned, a picture is given of a place that is just OK, as if it can live in a self-satisfied bubble and not account for its relation to the rest of Sonoma Valley or account for past behavior and lack of action and policy that caused such displacement.

These comments related to fair housing have been shared above, and are noted again here.

Agenda Item #2.1:

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• The presumption seems to be that such displacement and segregation is accidental and therefor no one’s responsibility. • The whole HE can be seen as an effort to underplay the true scope of Sonoma AFFH issues; serious partial spin is in play with the Sonoma HE. References to UC Berkeley Othering and Belonging 2019 and 2021 regional segregation studies are conspicuously lacking, one reason possibly being that the city power is more ideologically aligned with the NIMBY think tank Embarcadero Institute, as said in-effect, by the HE consultant in the 8/18 Planning Commission HE presentation. Yes, state housing laws are onerous, is the assumption. • Lack of City info on AFFH and of prioritizing AH as the crisis that it is shows that the City is eliding that it is the 18th most segregated city Bay Area; do you get to be the 18th most segregated city in the Bay Area by accident? No one knew? This is merely a matter of people’s choices? Better read The Color of Law by Richard Rothstein and think again. • Upshot: the City needs to take AFFH outreach and
enforcement way more seriously, but this can only realistically happen if the City first admits there are segregation problems that need more urgency to address

16.15 Pages 115-116 - Analysis of available Fed, State, and local data and knowledge
• Integration and segregation patterns and trends -
Segregation is RCAA and RE/CAPs, concentrated areas of affluence or poverty. The City says there are none. What if it is close and there are substantial similarities? Just bc the threshold is not crossed patterns can be ignored? • Lack of references indicates that spin is at play and data contradicting the rosy colored picture view has been left out. You are not going to find what you are not looking for; Sonoma has not had a strong AH policy presence and this weak direction from electeds that tends by default to favor single family home, low density residents, signals to staff and consultant that a weak tea, just check the boxes approach to AFFH is OK.

These comments related to fair housing and housing segregation have been shared above, and are noted again here.

Agenda Item #2.1:

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• Diversity Index: According to 2021 UC Berkeley
https://belonging.berkeley.edu/roots-structural-racism, Sonoma is in a larger area of low to moderate segregation. The same source fingers Sonoma as the 18th most segregated city in the Bay Area, right in there with Marin County. • One thing that happens with selective data slicing and dicing ion the HE is that Census Tract areas get averaged across jurisdictional boundaries, and pockets of more concentrated segregation get minimized. This is the case for the three east side Block Groups that have a clear RCAA-type segregation pattern, and also for Tract 1503.05 in the unincorporated Springs with a clear poverty pattern. • In Table 1 Demographic Trends, Sonoma as a whole is listed but not the highly RCAA-type segregated east side Block Groups. In some sense, there has to be the will to want to look for something and prove it. Who is the consultant working for? Every stakeholder group? Just some? Just the City as directed by a few people? • Table 1 mentions that the west side is more diverse, but no analysis of the east side like I have done. Why not? One thing that has happened in Sonoma is that a racially, and wealth-segregated community has come to believe this is normal, by accident, attributable to “the market”, and not connected to past antecedents, and therefore no inequity problems or responsibilities are admitted; this is a highly bubbled, covert segregationist view characteristic of the modern, post redlining approach to maintaining segregation. • Ta-Nahisi Coates: “To ignore the fact that one of the oldest republics in the world was erected on a foundation of white supremacy, to pretend the problems of dual society are the same as the problems of unregulated capitalism, is to cover the sin of national plunder with the sin of national lying. The lie ignores the fact that closing the “achievement gap” will do nothing to close the “injury gap” in which black college graduates still suffer higher unemployment rates than white college graduates, and black job applicants without criminal Agenda Item #2.1:

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records enjoy roughly the same chance of getting hired as white applicants with criminal records.”

16.16 Pages 116-117 - Mapped patterns of integration and segregation
• This does not mention race and ethnicity but does mention wealth/ income group. In 3rd paragraph, says “looking beyond Sonoma’s boundaries…” but only refers to disabilities/ seniors, married couples, female-headed households. Why not “look beyond Sonoma’s boundaries” for the bigger picture of a local Plantation economy? Look how Sonoma’s equity issues have been externalized to the unincorporated Springs, specifically Tract 1503.05.

These comments related to fair housing and housing segregation have been shared above, and are noted again here.

16.17 Page 117
• “Patterns of moderately segregated wealth, as indicated by median income, do exist in Sonoma.” refers to east and west sides here, but, east side is $55-87,000 and east side is $87-125,000, not the same, there is more white- segregated wealth on the east side. • The latter assertion belies the clear wealth and race RCAAtype segregation pattern in three east side Block Groups. • Lower AMI communities in Sonoma County “are somewhat more likely to be located in the more racially and ethnically diverse portions of the county”; this is BS, not “somewhat”, Tract 1503.05, the Latino Springs, directory adjacent to Sonoma, shows significant disparities with Sonoma along a clear range of documented indicators; what I see here is an intentional underplaying of local disparity in the HE. Roseland and Moorland along Hwy 101 are even worse concentrations of poverty. Hardly “somewhat.” • “As described throughout this HE, the City is committed to supporting the development of housing affordable to lower income households in locations throughout the city…”; this statement stands contrary to how the east side has no VL and L units in the HE. “throughout the City” seems to really mean on Hwy 12 only. • Findings
o “There are some patterns of isolation and
segregation apparent when considering certain
These comments related to fair housing and housing segregation have been shared above, and are noted again here.

Agenda Item #2.1:

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characteristics (apparently not wealth, race, and ethnicity in Sonoma Valley and in the City) …the City will continue to…reduce patterns of isolation and segregation and increase access to housing-related and other resources in these areas in order to effect change from current conditions.” o Words here say segregation will be addressed.

The site inventory tells another story, with overwhelming majority of VL and L all being put in existing areas of VL and L, and all on unproven sites on Hwy 12. Above Mod in Sonoma is left segregated as default areas of R-L affluence. o I have to conclude that the City is intentionally
not taking the City and Valley segregation bull by the horns, has a HE of minimizing issues, just checking the boxes and doing the least or nothing, as in the case of east side -near RCAA/ white segregation. It seems from the Whittier CA HCD HE rejection letter, that most of points I am making here are validated by HCD’s critique of Whittier’s weak HE showing. Hopefully the City will not just ratchet up to the next weak level and see what flies. • Figure 8 race ethnic neighborhood concentration
o This map shows Sonoma as “LatinX-white”,
omitting 80-85% east side white/wealthy and omitting Tract 1503.05 as majority Latino, lack of a studied, granular view presents a false view of what is really on the ground here. The fact Tract 1503.05 is 50+% Latino does not show on this map. o Tract 1503.05 shows up time and again as an
area of great disparity with Sonoma, yet the HE gives no indication of this, this has to be an intentional omission bc the data clearly shows the disparity with Sonoma, esp with the three east side Block Groups. 1503.05 is the source Agenda Item #2.1:

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of low City TCAC Education scores, the data and stats and indicators from 1503.05, combined with the disparity with Sonoma east side Block Groups, tell the real story of Valley patterns of segregation, why does the City HE just confine this analysis to City TCAC Ed scores? o As HCD can see, I sent plenty of Valley-level
segregation resources up front to the consultant.
• Figure 9 diversity index by Block Group 2018
o East side clearly has lower diversity. 1503.05
shows up as highest diversity, and the Valley as more diverse than 2010 o Maybe the Trump undocumented exodus, plus
fire effects on rent prices and displacement had not registered by 2018, bc many undocumented Latinos have left the Valley bc of 2017 fires and Trump ICE oppression… o A better attempt at more current Valley and
City demographic info is warranted, but with no text citations and a reference section, can’t tell at a glance what info is from what date. • Fig 15 proportion of senior by Census tract
o Seniors are clearly concentrated in assisted
living facilities on south and west sides. Need data on rental costs here, do seniors need to be wealthy to be housed in Sonoma? How much do local senior housing and assisted living facilities charge? • Fig 16 median household income by Block Group
o East side is clearly the wealthy area, my Block
Group analysis shows this, and this correlates with racial segregation.

16.18 Page 127
• Racially or ethnically concentrated areas of poverty
(R/ECAP) - Must have a non-white pop. of 50% or more, i.e. Tract 1503.05 in the Springs does. My EnviroScreen 4.0 These comments related to fair housing and housing segregation have been shared above, and are noted again here.

Agenda Item #2.1:

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analysis of this Tract shows that the population metrics have not been calculated by the CA EPA and/or by the State. • Look at DWRs DAC tool for a breakdown of Valley Block Groups and annual incomes. There are “no R/ECAPs in Sonoma County…” Are HUD metrics being used here to elide local poverty? That Measure of America’s Portrait data show on very low HDI scores for Roseland, Mooreland and the Springs? This has been a game played by the powers that be, to not address Springs poverty issues, to say there is less of a problem there than there really is; The Springs 1503.05 is a mini-Roseland; these are not fundamentally R/ECAP patterns? • “Comparing Figure 9 (Diversity Index) to Fig 16 (median household income), the HE says it appears that areas of high diversity do not generally correlate with lower incomes and that areas of low diversity reflect a range of income levels. • This totally misses 1503.05 as an area with high diversity and lower income, similar to Roseland and Moorland. And, the HE says that far east side, 1502.04 Block Group 1 as high diversity and lower income, this seems total wrong from my analysis of the latter Block Group. I live in this area. The 1502.04 Block Group 1 analysis suffers from averaging the city portion with non-city portion of the Block. I have to conclude that a deep analysis of east side wealth was not done; what took so long to get the HE out if not to research these topics more thoroughly? • Racially/ concentrated areas of affluence (RCAA) - The HE admits that white race can correlate with affluence. An RCAA is: 80% or more white, median household income $125,000 or greater. No RCAAs in Sonoma, but it is close, % white is there, home value is there, near east side TCAC high area median income is $101,000-$105,000. The TCAC Education score brings in non-City, non-east side residents and this then lowers the east side score, making east side Block Groups appear to be something they are not. • For a matter of $20,000 a year income and an inaccurate TCAC Ed score, the near east side would be an RCAA area, therefore there is no white affluence concentration issue? Agenda Item #2.1:

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• Table 2 does not examine east side Block Group stats.

16.19 Page 128
• Disparities in access to opportunities - Which areas offer low-income better chances? Clearly from TCAC scores and Census Block Group data, the east side. The HE uses CalEnviroScreen 3.0 4.0 is out now. The HE can use 4.0, not 3.0 As noted, inn my analysis, Springs population data is missing in EnviroScreen 4.0, and TCAC website that conclusions can be affected by lack of data. • No census block groups have the Highest TCAC score, but one east Block has High and one has Medium.
• “…the proposed sites to accommodate the 6th cycle RHNA are located throughout the City in varying levels of opportunity to the extent feasible, given the City’s exiting built-out development pattern.” “Throughout” apparently doesn’t mean VL or L sites in the City TCAC High and Medium areas. • What does “to the extent feasible given the City’s exiting built-out development pattern” mean? Does it mean the R-L and R-R are immune from integration? No rezoning to combat east side segregation? “Built out” would mean all areas get to high density or R-O density, that’s why they have rezoning, things change. Exclusionary zoning is not right nor adaptive, it’s an old segregated suburban residence pattern than needs to change. “Built out” here seems to mean nothing can change in segregated R-L areas. • The R-L development pattern itself is against AFFH, it lets stand white, wealthy plunder while other areas are integrated.

These comments related to fair housing and housing segregation have been shared above, and are noted again here.

16.20 Page 129
• Table 67 TCAC Opportunity resource levels by Tract - By promoting Low TCAC areas, the City intends to improve these areas with more goods and services, access to transit, jobs. The HE says “the City must look to Low/ Moderate resource areas to accommodate new development”; why must? While ignoring segregation and not rezoning the east side? These comments related to fair housing, ADUs and housing segregation have been shared above, and are noted again here.

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• HE says “the city has distributed these units throughout the resource levels to promote more equal and equitable patterns of opportunity? The is BS, not true, east side is decidedly not taking any VL and L, this is not throughout resource level areas, it’s 88% on Hwy 12 in Low Resource areas. • The HE claims that ADUs in all areas represents a
commitment to equity, to “all income levels in diff geographic areas of the city”; more BS, all ADUs are Mod (120% AMI) for RHNA and SB-9 ordinance sets precedent that affordable by design is not possible in the city; to say that ADUs will cover all income levels is not even consistent with what is said earlier in the HE about ADUs. And, ADUs, without some controls, will all go market rate anyway. • Economic Opportunity - The HE Says econ scores are
“inconstant in the city.” Areas east of 12 have a lower job proximity index; what about the type of low paying tourism hospitality jobs? People with million+ dollar houses are going to work in tourism, hotels, and hospitality? Where is any analysis of the actual, specific jobs available here and that the people who have them can’t afford to live in Sonoma? This section needs to be beefed up to show types of jobs, the pay etc.

16.21 Pages 129-130
• Educational Opportunity - SVUSD is 63.1% Hispanic, 56.2% of students come from socioeconomically disadvantaged backgrounds. The HE has no analysis of how this data here represents Valley-level segregation, only how it effects the City’s TCAC Ed score, this is a paltry and blindered view. • The HE might look at:
o SVUSD Student Population Forecast By
Residence
o School Year 2021-2022 Report o Forecast 2022-23 to 2028-29 o Davis Demographics 2/16/22 • Sonoma’s scores are lower than other county Tracts and then in Napa County, this points to serious trouble here in Sonoma Valley with Census Tract 1503.05, which is a miniThese comments are noted.

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Roseland next to affluent Sonoma. These education data points are the tip of the iceberg of a HE, un-analyzed Valley segregation and major disparity with the east side and 1503.05

16.22 Page 130
• Env Opportunity - CA EnviroScreen socio-econ scores are lacking for Tract 1503.05.
o The east side has better environmental scores
but whole city is good for green scores.
• Transportation - No mention of bus headway times.

Sonoma is more isolated in the county, it is well known that public transit headway times are bad. • The fact is the Valley has fought urbanization since the 1960s and made sure there are no big roads in and out, so as to protect rural character; this is the Sleepy Hollow Stasis and the Green Checkmate, a corollary effect of which is wealthy, white segregation and a high housing cost burden for anyone (poor whites included) who is not a wealthy white • Findings
o The fact that Education scores are impacted by
out-of-city factors which reduce City TCAC scores shows the inter-relatedness of Sonoma to the surrounding unincorporated areas. Econ scores are admitted to vary (only “somewhat”, which is disputable), east side Block Group analysis shows affluent racial segregation. Then HE says that sites to accommodate lower AMI units are “distributed between (TCAC) Low and Mod resource areas” but this is false bc none are in the near east side Mod area, 88% of VL and L eggs are in the Hwy 12 Low basket o City says new MX development will provide
jobs and commercial opportunities to provide goods and services, without any breakdown of the type of jobs or the cost of goods; what if there is a good chance the jobs are low paying and the goods overpriced? City HE needs some analysis of what kind of jobs people might have These comments related to fair housing and housing segregation have been shared above, and are noted again here. Programs 29, 30, and 31 address environmental sustainability and ensures that Sonoma grows in a responsible manner. The comments regarding transportation, economic and education scores, and sensitive communities are noted.

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given the local economy, with citations, from county EDB for example. o The spin here is that Low areas will be brought
up rather than High and Medium areas rezoned and integrated, this allows affluent areas to remain segregated and lock in an unsustainable status quo. o City then trumpets boilerplate about improving
ratio of jobs to housing with a 311 RHNA that is not even half what the public asked for in the 2019 City Housing Our Community series. The city is not leading the Valley in smart growth infill to protect SDC, even as city council members protest density at SDC. • Fig 17 TCAC Econ score
o Shows Block Group 2 of 1504.02, the near west
side, is City’s poor area, while lumping known low/ fixed-income Mobile Home Park areas into a “more positive” econ area. Far east side Block Group is lumped with 8th East, dilutes, makes a lower rating of a fundamentally MedHigh area, The high concentration of Above Mod housing inventory by income on the far east side shows that this is not a low opportunity area. • Fig 18 TCAC Ed score
o Shows how City is inter-related with and
affected by Latino Springs. SVUSD and Santa Rosa school districts have lowest scores, SR annexed Roseland and will annex Moorland; Sonoma keeps Springs as unincorporated and denies/ ignores issues; this Ed score shows how Springs is economically disadvantaged and segregated as well o Why did SR step up to address unincorporated
inequity issues but Sonoma is not? Do wealthy white cities get to play segregated fantasy island and then make all the rules the preserve that? Sonoma sets rules to maintain Agenda Item #2.1:

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segregation and then claims to be too small to do anything about it, a Catch-22. • Fig 19 TCAC Env score
o Text on p. 130 says the whole city is good, is
OK, and east side has better Env scores.
o This map shows the bulk of the City as “less
positive” with the whole 1502.02 Tract with slightly better scores. It’s likely that heavy traffic on Hwy 12 and 8th East causes air pollution as well and lots of leaf blowing negatively affects air quality. o The huge bulk of VL and L City RHNA is set for
the areas with the worst Env score, along Hwy 12. General impression, HE analysis is shallow and designed to try and pass HCD, rather than to dig into real issues and unmask and address them, the consultant is working for the City, not for equity and justice; the City wants to pass the HE more than it wants to address real inequity and segregation issues. • Fig 20 TCAC Opportunity Areas
o The near and north east side High and
Moderate areas correlate exactly with the City’s high concentration of Above Mod housing inventory by income. Census data also shows how the far east side has the same high concentration of Above Mod housing inventory by income, even as this map has the far east side as TCAC Low. o The legend shows a category for high
segregation, but apparently UC Berkeley segregation studies have not been included, that have Sonoma as the 18th most segregated city in the Bay Area. • Fig 21 Job proximity
o The City is two square miles, everything is close
to everything.

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• Fig 22 Sensitive communities (this is “sensitive” for disproportionate housing needs but the map only says “sensitive) o Something is counter-intuitive here as the near
and far east side are listed as the same level of sensitive as the Latino Springs and as the City’s near west side Block Group 2 of Tract 1502.02 o What is happening here is that in Tract 1502.02
as a whole, which the map shows as all sensitive, the west side of 1502.02 is being conflated with the east side; in reality, it is the west side that is sensitive, as shown clearly by the TCAC Econ score map. In no way is the east side equivalent in AFFH sensitivity to the LatinX Springs. That the level of analysis here is so shallow and goes against all the other data about the east side, shows that the whole HE maybe has or could have the same level of diffuse, shallow analysis, it took them years to make the HE, and in two weeks I see problems? o It could be that this “sensitive” for
disproportionate housing needs means the
east side is too cloistered, but if so, that would support my whole analysis of east side segregation.

16.23 Page 137
• Discussion of disproportionate housing needs
o Overcrowded households are not significant in
the city, but are significant in the Springs Tract 1503.05. Why account for disadvantaged unincorporated in the TCAC Ed. score but not make any analysis of the other local unincorporated indicators? The Latino Springs has a high concentration of over-crowding and of multi-family units, all this and more can all be seen by using layers of the county’s DistrictR mapping tool. • Figs 23-24
These comments related to partnerships with affordable housing developers, fair housing and housing segregation have been shared above, and are noted again here. .

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o Renter cost burdened households: the whole
City south of Napa Street is 60-80% cost burdened bc of the proximity to the wealthy east side, this is an inflation infection stemming from an inordinate east side wealth concentration. Landlords are charging as high rent as they can get and people who want to stay in their community have to pay or be displaced or find a studio-efficiency unit for the same price they were paying for two bedrooms. o Owner cost burden has the same conflation of
west and east sides as the sensitive communities, showing the east side as equivalent to the west when in fact, the west side is more cost burdened and likely the same as the rest of the City at a 40-60% cost burden range. A more detailed reading of Census Block Group and the AFFH data viewer map layers is called for in the HE, by someone who is not scared to see issues that may cause meaningful action problems for the City. o The text says: “Overpayment increases the risk
of displacing residents who are no longer able to afford their housing costs.” Where is any data on displacement rate? How many people have been displaced in Sonoma since 2008 Great Recession, the fires, Covid-19, and current increased inflation? How many second home owners and wealthy Silicon Valley amenity migrants have come in? o For displacement, more and better data
needed: The Urban Displacement Project shows parts of Sonoma as “becoming exclusive.” Look at net migration by county maps. Lack of data and analysis here, for trends City officials speak about, underplays the seriousness of this displacement and cost burden issue.

Agenda Item #2.1:

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o Then, the HE gives a paltry mitigation of
“incentives to encourage affordable development … and a targeted program to connect lower income residents … with affordable opportunities.” With a city that constantly says there is not enough staff, and with a track record of doing basically nothing for new AH development since SAHA’s AltaMadrone Apts. on Broadway (that took 10-15 years to come to fruition in early 2021) I can only conclude that what the City is proposing is largely words and in not “meaningful actions” to address the scope of the housing crisis here. o If segregation problems are denied, then no
meaningful actions are needed to solve them, this seems to me to be a core fault of the HE, not seeing and eliding the actual for AFFH. o The HE says commercial in lieu fees will cover
new AH unit costs, but the city council recently diluted an aggressive Planning Commission effort to make such fees actually cover the costs. o Also note that City Sustainable Tourism web
page has NOTHING about living wages or labor equity and makes equity policy all a matter of voluntary business choices, in fact, the page has nothing about labor at all; tenant and labor issues come up short in Sonoma. • Future Growth Needs
o “The City’s future growth need is based on the
(311) RHNA..” For the 6th cycle HE; in a city that has become progressively more east side class and race segregated, what about based on reality? As lower income residents are displaced, and the City sorts to higher wealth, “growth”, for VL and L cohorts, is more at displacement mitigation, clawing back the displaced working class that has been lost through unsustainable tourism policy that only Agenda Item #2.1:

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serves the visitors and hoteliers and hospitality sector, and does not account for the social aspects of the sustainability triple bottom line. o “… proposed affordable units are dispersed
throughout the community, to the extent feasible based on the city’s existing built-out land uses, and do not present a geographic barrier to obtaining affordable housing.” This phrase is LOADED with assumptions; AH units are only dispersed throughout insofar as they don’t impinge on exclusionary zoned R-L and RR areas. Feasible means that R-L and R-R cannot be rezoned bc they are supposedly built out at low density. This basically says that for half the City residential area, low density is enshrined as an immutable characteristic, which is false bc all zoning is subject to change based on societal needs and change. R-L and RR are barriers to AH bc they close off more than half the City’s residential area to AH and VL and L units. This might as well be a mountain lion habitat-type of equity avoidance program, coupled with historic barriers. City low density protectionism as embodied in City zoning Code, is clearly an administrative, elective barrier to integration and AH based on enshrining the economic and social advantages of R-L/ R-R property owners. o The City is “accommodating” its 6th cycle
RHNA by failing to address and by preserving east side class and racial segregation, and by putting the huge bulk AH and VL and L units in the worst environmental locations in an exact recap of the worst relocation failings of 1970s Urban Renewal relocation and of redlining. • Existing Needs
o
The City does have a history of working with
AH developers, but since the whole SAHA/ AltaMadrone process, there has been nada, Agenda Item #2.1:

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nothing, no public evidence of work to recruit a project and in fact, the City has developed a line of denial that it is not the City’s responsibility to facilitate anything, it is only a matter of money, and loss of Redevelopment money, and the City’s recent AH fund is not big enough. Equity as a housing concern is mocked by City low density protectors. o Since loss of Redevelopment money the City
has been like a deer in the headlights, paralyzed AH advocates are supposed to trust single family home, low density property owners who dominate City government, to have their best interests in mind, kind of like trusting foxes who are guarding the henhouse o Out of 5778 total City housing units, 439 are
AH, 7.5% of City housing is AH. Is that OK? Seems pretty small… Renters make up near half the population, many of whom are cost burdened. Seem like the City needs to aim at 50% AH to really serve the populace’s housing needs. David Brigode’s bold housing policy ideas should be tried on for size. o “The City actively works with affordable
housing developers…” When? Who? Where is there any public record of this or of council direction? This almost seems like a lie. In the last 20 years, the neighboring Springs has hosted four large AH projects, two finished and two entitled for near 400 units. In the same time frame the City has done one 48 unit AH project. The county is killing the City in local AH production in Sonoma Valley. I can only conclude that inflated City land prices and City zoning protectionism are the causes for the lack of City AH progress. If the City wanted more action, it could get it. The City could also address land availability by rezoning and relaxing its sphere and UGB hard lines, take the Agenda Item #2.1:

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pressure cooker lid off the space so prices can go down • Cost Burden
o Location is one of the biggest factors for price:
east side is a high dollar location. 56.7% of renters overpay, the majority in lower income groups. HE says the majority are on south side, but Fig 23 shows everything south of Napa St east as “the south side, which conflates the east and west sides as the “south side”; local sense has the south side starting at MacArthur, not Napa St. East, who proof-read this?

16.24 Page 138
• Cost Burden, cont’d
o 30.5% of homeowners overpay, most in
southern Sonoma, which Fig 28 has as a more accurate representation. In fact the cost burden here is so great that displaced people routinely are unable to find a place to live, and with City SB-9 ordinance, deed-restriction was required bc the City felt affordable by design was simply not possible, even for an 800 sf duplex on a small lot; this is not just in various City locations but in all zones where R-L is allowed, well more than half the residential areas. • Findings
o “Based on input from the community and the
County AI (what is county AI? HE needs an acronym list), the most disproportionate housing needs includes rehab of existing housing stock and increased variety of housing types at affordable prices, including housing for lower income households.” o But, the substandard housing section above
this said that cost burden was likely the greatest problem, not rehab problems. It is surprising that the consultant would fall back on a weasel word phrase like a general, These comments related to fair housing and Armstrong Estates have been shared above, and are noted again here.

Agenda Item #2.1:

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undefined “affordable prices.” In Sonoma we can assume that anything below market rate would have to be “for lower income households” and be deed-restricted or be very small like a JADU to be “affordable”; the HE needs to define the need by AMI range, and since only 7.5% of Sonoma housing stock is AH, i.e. deed-restricted but the cost burden is 56.7% for renters and 30.5% for owners, it follows that for “increased variety of housing types at affordable prices”, the percent of AH needs to be increased to a level of 56.7% for renters and 30.5% for owners, not merely 7.5% and not merely rehabbing an undefined number of multi-family homes, 50.1% which would be for L and Mod. o Need to know how many units this MFH
program would project? It sounds good, what are the number of units for RHNA? o City needs to be bolder and call for multiple
100s of AH units at 60% AMI and below, and that these units go not just on Hwy 12 but also on the two TCAC Moderate and High Areas on the east side, specifically the two .5+ acres lots at Armstrong Estates. If Armstrong has CC&Rs that prohibit high density or MFHs, this needs to be called out in HE subdivision constraints as modern redlining. Also, annex the far east side sphere areas as #1 AFFH AH area, a perfect place to line up a 100% AH project.

16.25 Pages 138-139
• Displacement Risk
o Vacant sites represent the majority of site for
new housing (and AH.) Two Armstrong lots at .5+ acres each on far east side, in an obvious High/ Moderate TCAC area, not “Low”, if these lots are vacant, there is no good reason I can think of to not ID these for VL and L, if not for Ledson CC&Rs? These comments related to fair housing, displacement, and Armstrong Estates have been shared above, and are noted again here.

Agenda Item #2.1:

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o The .5+ acre Sebastiani parking lot, lot #324
MX zoning is in a TCAC High area. Of lot #324 total: the big lot is 14000 sq ft and the small one is 8300 so the total is about 1/2 acre (0.51); 0.3 acres and 0.2 acres respectively, as per a local surveyor. o The ag zoning next to this lot # 324 could be
rezoned and voila, a nice big parcel for VL and L RHNA in a TCAC High area. If AFFH and integration are priorities, this kind of rezoning should be looked at, there are no crops next to lot #324, just grass and picnic tables; this is not even Sebastiani, it’s some faceless corporation with no production facilities any longer on site bc labor cost too much.

16.26 Page 139
• “To date, the City has no evidence that new development (affordable or market rate) has resulted in economic displacement.” This seems on par with the no segregation assertion. We need serious research to show unequivocally where displacement is at, in the City and the Valley, and the Bay Area. • However, the HE says, if displacement might occur, see Action Program 21; this see Action Program 21 needs to be cross-referenced with page # so the reader does not have to fumble through the whole HE to find it. It seems like the City has no evidence about displacement period, there being no reference here, its’ hard to check what the city’s evidence is? • What about the Urban Displacement Project that shows
Sonoma and Springs areas as “becoming exclusive” and “early ongoing gentrification.” • What about RHNA performance from 2000- 2020 that
shows a City 293 over-production of market rate and 236 underproduction of Mod and below; does not citing data make it go away? • The above coupled with high east side concentration of Above Mod home prices shows that the east side is the driver of high inflation. East side R-L home price inflation is These comments related to fair housing and displacement have been shared above, and are noted again here.

Agenda Item #2.1:

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driving City cost burden and displacement, while east side property values are protected and grow to benefit homeowners who dominate city government. • I might be getting carried away, but it seems like a
protection racket, what Ta-Nahisi Coates says is a white syndicate. What about Mockingbird Lane and Oliva Apts and other DeNova projects where the price points ended up being substantially higher than advertised? Affects displacement? If prices were 4 to $500,000 more than promised, “bc of market conditions”, doesn’t that displace locals who can’t afford that? • We are in a regime now where home offers have been 100s of 1000’s over asking prices, in cash, new development is not part of that? What qualifies as evidence here? With no index, the reader can’t find displacement in the HE and check all the assumptions and refs given, the HE seems intentionally obscure, hard to navigate and lacks evidence to prove points made

16.27 Page HP 18, Program 21
• I have to conclude Program 21 is NOT meaningful action and is in fact very weak tea, the words belie a do-as-little-aspossible approach that fundamentally, a priori, denies serious housing issues in the City, and then proposes to do very little about it; this is NOT an activist document that shows the City determined to address the housing crisis for lower AMI residents, but rather a slick, boilerplate effort at minimization, denial, and minimal commitment to address a housing crisis. Program 21 is not convincing as a serious effort. • Program 21 immediately refers to an impediments analysis in another section, it should re-state the core impediments here in the text, don’t give the runaround. Segregation and displacement are already not defined as impediments. • In order to show meaningful action to address AFFH,
Program 21 proposes: to put something on the City website and do two events a year in lieu of outreach, offer FHANC services, acronym not spelled out, Legal Aid is not referred to; rely on ADUs “at all income levels” even though ADUs will likely be market rate; and ADU’s RHNA AMI price points These comments related to fair housing, displacement, and housing segregation have been shared above, and are noted again here. Comments related to Program 21 are noted. Program 13 monitors the Housing Element on an annual basis to ensure that the City continues to assess its affordable housing programs.

Agenda Item #2.1:

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are inconsistent with City SB-9 assumptions that affordable by design at any size is not possible in Sonoma. • Program 21 will rely on Section 8 vouchers which are about impossible to get and to realize.
• Program 21 will re-evaluate 25% inclusionary ordinance to see it is not an impediment, even as the 25% is used to show the city being a good actor with AFFH. • Program 21 will provide housing opportunities in TCAC High and Mod areas “for all members of the community” by having ONE annual meeting with AH developers to ID opportunities; NO mention here that city zoning does not allow VL and L in the R-L TCAC High and Mod areas anyway and that to develop AH here there would need to be scale of at least 50 units per project, which R-L would not allow; why not do this upfront with rezoning the east side in the HE rather than put all the poor people on Hwy 12? • Program 21 will improve City TCAC scores by doing at least two projects (no scale mentioned, could be a duplex) that improve any one of the three (Econ, Ed. Env) TCAC scores: the Ed. score can only be improved by the City engaging with the county on Springs disparities, an action and policy the City has avoided, see my Grand Jury comments about the City having a myopic focus on itself to the exclusion of regional Valley issues; this item does not even get close to how to introduce any numbers and scale of AH units into TCAC High and Mod areas, this is simply not a serious effort. • Program 21 makes housing rehab an item when the HE later states that cost burden (low wages/ high prices for everything here, local inflation airport effect) is the most serious housing issue, not rehab. • Program 21 will reduce discrimination by landlords by having ONE annual meeting, this won’t do shit without any legal rights for tenants, of which I see about ZERO in the HE, need to contact Margaret DeMatteo of Legal Aid and get tenant protections into the HE. • Program 21 will conduct an annual displacement analysis:
the fact that no existing displacement analysis can be cited to continue upon shows that there is no current Agenda Item #2.1:

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displacement research and thus the later HE assertion that there is no evidence for econ displacement (coupled with lack of systemic document references) can be suspected as an unsupported statement. • Tract 1502.04 is cited as an area of displacement
susceptibility, yet without specifying the Block Group at stake this conflates the west side with the east side Block Groups, resulting in an inaccurate statement. • What is really happening here is that east side super home price inflation (based on protective, segregatory R-L zoning that is not even acknowledged in the HE) is making the west side Block Group 2 “sensitive” to displacement; this is “vulnerable to displacement” even without the effect of new housing causing it. • A look at the AFFH Viewer maps clearly shows a west side Block Group 2 difference and a consistent affinity of east side Block Groups 1 and 3 with higher wealth, higher home values and higher internal Block Group Education ranks, and higher white % demographics, the HE does not dig into this and in fact, elides it by continuing to conflate the east side with west side. • Conclusion on displacement and Program 21: the City is not looking to dig any deeper and is content to stay on the surface and make a weak tea HE based on superficial analysis that intentionally does not recognize patterns of segregation and displacement and then makes weak meaningful actions like Program 21 to not address AFFH problems that are not seen.

16.28 Page 139
• Critical point
o The City is justifying putting all VL and L on Low
Resource areas along Hwy 12 as “most appropriate” on the basis of access to transit, lower real estate values, curing supposed blight, and MX zoning. This then makes these rationales, in aggregate, a higher value than AFFH and integrating lower AMI residents into City segregated TCAC High and Mod areas.

These comments related to fair housing, displacement, and housing segregation have been shared above, and are noted again here.

Agenda Item #2.1:

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o In a two square mile City, everyone as good
access to transit, in all areas.
o Access of AH developers to lower real estate
values are a reason to make extra-UGB annexations, but these have been put off limits by UGB poison pill language. o One person’s “blight” is another’s “character”,
what blight are we talking about? Where? Broadway Market? 4 Corners auto shop? That is the kind of rural character place people supposedly value. o MX zoning on Hwy 12 as “most appropriate”
for VL and L RHNA is a choice that will not necessarily yield the most social goods bc for many, proximity to jobs means proximity to wealthy east side home owners who need: yard work, home health care, house cleaning, construction/ maintenance etc. Many City jobs are for worker bees at the wealthy, Above Mod homes. This is a good rationale for an east side sphere annexation, closer to work, could walk or bike to work. o No proximity to goods will serve VL and L
income residents anyway, bc if they have a car, they will never shop in Sonoma anyway bc so much better prices are to be had in Napa and the 101 Corridor o The City should layer its own Ellis Act reform,
just cause and rent stabilization onto whatever state “just cause” laws are cited in the HE.

16.29 Page 139
• “Research has shown…” what research? Citation?
This is based on the impetus to address fair housing, including exposure to environmental issues and access to high-performing environmental area. Access to environmental opportunity is discussed in Chapter 5 of the Background Report.

16.30 Pages 139-140
• Findings
These comments related to displacement and Program 21 have been shared above, and are noted again here.

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o “The City is committed to making diligent
efforts to engage underrepresented and disadvantaged communities in studying displacement.” Why doesn’t it seem that way? Program 21 is cited again, how “diligent” is that, to have weak tea annual meetings and rely on ADUs no lower-AMI residents can afford anyway? This seems like words only, no sense of real purpose and desire to address deep issues.

16.31 Page 140
• For Mobile Home park conversions, the City HE should
adopt a law that gives MHP residents the right of first purchase should the property come up for sale. • C. Sites Inventory
o Site inventory “considers whether the
identified sites serve the purpose of replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity.” o How does putting basically all the RHNA VL and
L units on Hwy 12 in three locations and none on the Central-East Planning Area demonstrate that the City is “carefully considering how the development of new affordable housing options can promote patterns of equality and inclusiveness”? o A look at AFFH Data viewer maps, DAC tool
maps, Measure of America maps, DistrictR map tools, and local studies cited in hyperlink above shows that one, the Sonoma Valley USA is highly segregated, and two that Sonoma’s east side is segregated from not only the rest of the Valley USA but also from the rest of Sonoma. o All these sources were shared with Beth
Thompson of DeNovo.

These comments related to fair housing and housing segregation have been shared above, and are noted again here.

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o It sure looks like the City is fueling and
supporting a thesis to put all “inclusiveness” in already Low TCAC opportunity areas and none in TCAC Mod and High areas. This does not seem in any way like promoting patterns of equality and inclusiveness and rather seems like a convoluted set of rationales to protect east side R-L zoning from increased density and inclusion; part of the rationale is to not have any HE rezoning and assume that R-L and R-R residential patterns are “built out”, permanent, and not subject to upzoning for integration. See my SB-9 Objective language review for a show ofunderlying City R-L protectionism values. • C.1. Segregation/ Integration
o Here is the zinger of the whole HE: “The City
finds there are no known historic patterns of segregation by race and ethnicity, persons with disabilities, familial status, age, or income.” “Nevertheless, as described throughout this HE, the City is committed to supporting the development of housing to promote a balanced and integrated community.” o A balanced and integrated community seems
to be seen by the HE as at the level of the whole City and not at the level of challenging the status existing R-L segregated neighborhoods (half the City residential area) that are also High and Medium TCAC areas, and also not at the level of comparing the City to the Latino Springs. o Why is the City claiming not, when strong
evidence says there are patterns of segregation, esp. the east side? Sonoma is the 18th most segregated city in the Bay Area. https://belonging.berkeley.edu/mostsegregated-and-integrated-cities-sf-bay-area Agenda Item #2.1:

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o The top tax credit Resource Opportunity Areas
in the City: Census Tract 1502.04 Block Group 1, and Census Tract 1502.02 Block Group 3, the Central-East Planning Area, are 80% - 85% white respectively, with home values reaching to $2 million with 80+% white ownership. Technically, the Block Groups noted above are not RCAAs but they are close enough to see a clear RCAA pattern. The low TCAC Ed. score was explained above as not representing the actual educational attainment of these latter east side Block Groups. Census data does give ed. attainment by Block Group. o Census Tract 1502.04, Block Group 3 is in the
middle of Mod and High TCAC areas but the wealthy white signal is diluted by being lumped in geographically with the 8th East industrial area. This Block Group has two .5+ acre, appropriate for VL and L AH, lots at Ledson’s Armstrong Estates. o These above Block Groups are also heavily if
not 100% single family zoned, low density areas which are known indicators of high segregation. o I would have to say the HE consultant and the
City are trying to pull the wool over the public’s eyes by one, denying obvious segregation, and two, failing to recognize and admit that zoning is not a government constraint on fair, affordable housing. R-L exclusionary zoning is the new redlining, and three, denying that displacement is an issue. o The HE site inventory has almost all VL and L
RHNA units in three vacant lot locations (Napa Rd. and Broadway, Safeway, and on an orchard behind SPARC, all on Hwy 12, none integrated into the Block Groups noted above. All eggs are in this basket, with little buffer back up should any of these sites go market rate. This Agenda Item #2.1:

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allows a clear east side, affluent, white, segregated pattern to stand, which is consistent with Sonoma’s, on the record stated values of preserving and protecting the historic character of low density, single family zoned areas as its top housing priority.

16.32 Page 140
• The HE goes on to say that the VL and L sites “…are located throughout the community and are not concentrated in areas of lower diversity…” This seems like a stretch bordering on a false statement. “Throughout the community” is actually all on Hwy 12, and avoiding “areas of lower diversity”, i.e. the east side, means no VL and L at all on the east side where more diversity is called for by AFFH by not concentrating whites and wealth. • Note that Sonoma is already substantially less diverse than the Springs, where overall Valley segregation between the City and Springs can be seen. If the City was being honest, a substantially-similar-to-RCAA-pattern on the east side should be acknowledged and mitigated, and rezoning should be done to address de facto east side zoning redlining, and annexing the far east side sphere lots should be the #1 AFFH option.

These comments are noted.

These comments related to fair housing and diversity have been shared above, and are noted again here.

16.33 Page 141
• “proposed sites, including VL and L RHNA sites are
distributed throughout the community with a number (how many? see below) of sites located in areas with high and highest median household incomes.” This is a big, nonspecific stretch, the bulk of VL and L are not on the east side, the area with the highest incomes, the huge, overwhelming bulk, 88% of VL and L are on Hwy 12 in Low TCAC areas. If the City keeps saying this in the HE, I have to repeat myself as well. • There are only 10 L and no VL on the 1st Street East
townhome project, 5 Mod and 41 Above Mod; is this what we get for “including VL and L RHNA sites are “distributed throughout the community”, on a Housing Opportunity Site? This account for VL and L units: “distributed throughout the community” besides on Hwy 12? These comments related to fair housing and diversity have been shared above, and are noted again here.

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• I’d have to say that the HE is vastly overstating any efforts at real integration of lower AMI residents with higher TCAC areas, to the point of being mostly false. • The City’s rationale for not integrating the east side is to improve opportunities and incomes in Low TCAC areas, bc these projects “may be transformative.” This would be more believable if the City was actually showing interest in socioeconomic transformation, but the fact that the city has no equity platform at all shows there is little track record of interest in equity. The City has an economic department it pays for with the Chamber, and a Climate Action Commission and an Environmental Sustainability Coordinator, but no equity pillar to be seen. • R/CAPS, RCAAs
o Recognizable Valley and City concentrations
and patterns of wealth and poverty are being spun by the HE to avoid coming to grips with Sonoma’s larger segregation from the Springs and to downplay clear patterns of wealth disparity within Sonoma between the east and west sides. o Sonoma is internally segregated by class and
racial diversity has been externalized to the Springs.
o If a HE consultant was instructed by the City to
play up patterned segregation and wealth concentrations, to make an activist HE, it could easily be done, but none of that shows o Conclusion: status quo low density, R-L
protectionism is the highest City housing ideal but that is kept covert in the HE. Problems like segregation and displacement are minimized and elided and hence Goals, Programs and Policies appear as weak tea. It’s a minimal, non-assertive, hands-off program. o The R/CAPS, RCAAs section says: “areas of low
diversity reflect a wide range of income levels “, but an analysis of east side Block Groups show this to not be true in these locations. The Agenda Item #2.1:

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City appears to be trying, when convenient, to collapse the east side into the rest of the City, to hide a wealth concentration issue, so that VL and L RHNA will not have to go there and mess up the “character of the neighborhood.” • 3. Access to Opportunity
o The HE says Sonoma doesn’t not have any High
Resource areas, wrong, it does, with a .5+ acres MX-zoned parking lot and an empty “ag” area that is not used for ag purposes. This ag lot could be another prime AFFH 100% AH project spot, along with the east side sphere lots. o The City does admit it has a TCAC moderate/
medium resource area (near east side) but this area has not been ID’d to accommodate any of the lower AMI RHNA. Therefore, the statement that the RHNA is “distributed throughout these areas” is wrong. o A rationale follows for putting all VL and L on
Hwy 12: “help to create more lower AMI housing in those areas, that new residents will create more neighborhood stability” there, and “expand opportunities for people to both live and work in Sonoma.” The exact same general rationales can easily apply to the near east side. o The paragraph goes on, in planning-speak, with
more of the same rationale: “help diversify the land use pattern”, “improve conditions by providing greater housing choice and a broader range of goods and services”, bring new residential development closer to transit and jobs”, and “otherwise support community revitalization.” o As long as Sonoma Valley as a whole has a
Plantation economy arrangement with the Springs, and east side wealth infects the rest of the city with overall unsupportable high prices, Agenda Item #2.1: