From: Charles Fraleigh
To: HousingHumanServices AP; PlanningCommission AP
Cc: Ryan Dyson; Jenny Carloni
Subject: 2023-2031 Draft Housing Element comments
Date: Wednesday, May 18, 2022 8:34:37 AM
Attachments: image001.png
ATTN: Email is from an external source; Stop, Look, and Think before opening attachments or links.
May 18, 2002
Planning Commissioners and Housing and Human Services Commissioners, The Livable Sunnyvale Housing Element Committee has been reviewing the 2023-2031 Draft Housing Element which your commissions will be having a hearing on next week. We have several questions and concerns about this draft.
The Housing Element lists 58% of the sites in high density areas at Moffett Park, Lawrence Station, Downtown, and along El Camino in the lower income category. However, recent high density developments in these areas have contained only 17% lower income units. We are puzzled why the Housing Element expects a much higher percentage of lower income units in the new sites. Our concern is that Sunnyvale will not meet its RHNA targets because it is unlikely the new sites will achieve the higher 58% rate.
In section 4.1, the Housing Element states, “it is important to ensure that sites for housing, particularly lower income units, are available throughout a jurisdiction and where residents have fair and equitable access to amenities and opportunities.” The sites inventory in Chapter 5, however, allocates the lower income units such that:
81% of the lower income units are in low and moderate resource areas while only 19% are in high and highest resource areas.
89% of the lower income units are in census tracts whose average income is below the Santa Clara County AMI.
Attachment 6
None of the lower income units are in census tracts whose average income is over $200k/yr.
67% of the lower income units are in census tracts with environmental opportunity scores of 1 (out of a possible 100), while census tracts with environmental scores over 70 contain few or no lower income units.
The plan for Moffett Park would create a census tract where 60% of the households are lower income. This would be the highest concentration of lower income households in Sunnyvale.
There seems to be a disconnect between the goals presented in Chapter 4 and how the sites inventory allocates the lower income sites.
The Village Centers appear to be a good opportunity to address some of these issues, but they are currently zoned at a density of 18 du/ac. Has there been any consideration to increase the density to over 30 du/ac so they could accommodate more housing and provide opportunity for lower income units? What steps need to be taken to increase the density of the village centers?
Finally, we were pleased to see program H29 to implement Safe Parking. The timeframe for this program, however, is 2025. This is an urgent issue facing our most vulnerable residents and we would like to see this program implemented before the Housing Element is completed or at latest by early 2023.
Thank you for your consideration.
Livable Sunnyvale Housing Element Committee
Attachment 6
From:
To: Ryan Dyson
Subject: housing element comment
Date: Sunday, June 5, 2022 11:24:02 AM
ATTN: Email is from an external source; Stop, Look, and Think before opening attachments or links.
I am a parent of 31-year-old man with autism. We bought a house in Sunnyvale in 1991 and this has been the community my son has grown up in. He is lucky to be living in a Below Market Rate apartment in Sunnyvale with the help of a Section 8 Housing voucher. He is a San Andreas Regional Center client which provides him with the services he needs including supported living services.
San Andreas Regional Center serves approximately 30,000 clients in Santa Clara County. Many other parents tell me that they need to figure out the housing needs of their adult children with developmental disabilities to ensure their child is taken care of “after they exit the scene.” Securing affordable housing is their biggest challenge.
Please continue to work with agencies like Housing Choices to support set-asides for people with developmental disabilities. Many of these people, like my son, have extremely low incomes, solely on SSI or SSI/SSDI.
Clare Meyerson
1385 Deroche Court
Sunnyvale
Attachment 6
June 6th 2022
Re: Comments on Sunnyvale Housing Element
Dear Sunnyvale City Council, Planning Commission and Staff, The undersigned organizations would like to thank you so much for providing the opportunity to provide public comment on the draft Housing Element. Overall, we support its draft policies. We know that tackling the combined crises of housing affordability, inequality, and climate change in all its complexity requires structural and cultural change and we think that if implemented, many of the policies in this Housing Element will help our region address both our climate and housing crises.
We urge you to eliminate or significantly reduce parking minimums on new housing developments near transit, and special housing developments, and to permit the use of stacked parking spaces. Please commit to these reforms in your Housing Element. Ascent Environmental’s presentation to the Planning Commission on May 23rd listed parking requirements as a governmental constraint on housing, and Gov. Code § 65583(c)(3) requires the removal of such constraints where “appropriate and legally possible.” Now is the time to commit.
It is clear that you understand the barriers parking minimums provide because in policy H-4.4, Parking Standards for Special Needs Housing, you highlight the need to maintain reduced parking standards for special needs housing and housing in close proximity to public transit.
Eliminating parking minimums is a highly effective strategy to address both our housing and climate crises. Sunnyvale seeks to be a leader in climate action but if you are still subsidizing driving (which accounts for 40% of our GhG emissions) you will not meet your climate goals. Increasing density in the village centers was identified as a priority in the May 11th public meeting. Eliminating parking requirements would be a clear way to do so.
Attachment 6
The recent Bay Area Parking Census released by SPUR and the Mineta Transportation Institute found that there are 2.4 parking spaces per car1. Additionally, TransForm’s study of 80 Bay Area buildings identified that 28% of residential parking spaces were unused. This excess parking represented 1,164,600 square feet of space that could have gone to better use and cost over $198 million dollars to build. Continuing to require a minimum of two parking spaces per unit in most places will continue these wasteful mandates that drive up housing costs.
Sunnyvale’s parking minimums make worst case assumptions about how people commute - every person has a car and every person drives alone to work. More Sunnyvale residents would likely forgo driving if mandated parking were eliminated in favor of denser development near places like Lawrence station and Moffett Park. Sunnyvale has already implemented a robust TDM system, which has likely reduced overall car trips. However, studies show that abundant, “free” parking actually generates more driving trips, more traffic, and more pollution, and will make people less likely to use the TDMs2. This means the excessive parking minimums counteract the positive impacts of Sunnyvale’s TDM. Maintaining parking minimums, based on these worst case assumptions, significantly reduce the number of sites that can feasibly become senior housing in the next decade.
Reducing parking minimums and unbundling parking has never been easier with the development of new technologies to facilitate shared parking. These include Parkade, which makes it simple to administer unbundled parking while also allowing for the sharing of parking between residents and their guests. In addition, companies like Parknav have tools to help better utilize on-street parking and can guide drivers to areas with availability.
We would also like to urge you to eliminate the requirement that mobile home parks are required to provide two spaces per unit. This seems to be an equity issue. There is no reason, when the minimum parking requirement for a single family home is one parking space, that mobile homes require two.
2 https://www.nctr.usf.edu/wp-content/uploads/2014/07/JPT17.2_Hamre.pdf 1https://www.spur.org/publications/spur-report/2022-02-28/bay-area-parking-census#:~:text=There%20are %20approximately%202.4%20spaces,person%20in%20the%20Bay%20Area.
Attachment 6
We would also like to urge you to keep open space requirements. We have seen first hand the importance of open space for mental and physical health as well as carbon sequestration and biodiversity benefits.
As you consider changes to this draft element, we hope you will take our considerations in mind to prioritize people and open space and include parking policy as an item in the Housing Element.
Regards,
Zoe Siegel
Director of Climate
Resilience
Greenbelt Alliance
Alex Shoor
Executive Director
Catalyze SV
Kendra Ma
Housing Policy Analyst
Transform
Joanna Gubman
Executive Director
Urban Environmentalists
Keith Diggs
Housing Elements
Advocacy Manager
YIMBY Law
Attachment 6
June 8, 2022
Dear Mayor Klein and Council Members,
Livable Sunnyvale reviewed the Housing Element (HE) draft and many of our members attended and contributed to the meetings staff conducted with Council and City Commissions.
We wish to acknowledge the effort that has been extended on this Housing Element. With that in mind, we have the following input.
This HE Draft classifies about 60% of housing at high density sites like Moffett Park to be in the lower-income category. That is not realistic. Even if several large 100% affordable housing projects are developed there, based on our city’s history, 20% lower-income is a much more realistic number.
Currently HCD allows this unrealistic assignment because of Moffett’s high density designation; however, as Moffett is developed and reality hits, Sunnyvale will be required to back-fill those missing lower-income sites. If Sunnyvale becomes non-compliant, the City may have to pay fines & fees, lose valuable state and regional grants, and possibly face court-issued takeover of our land-use authority (see attachment).
A second issue is that 89% of the lower-income sites are located in census tracts where the average income is already below Santa Clara County’s AMI. The HE Draft does not address how putting the vast majority of lower-income sites in locations that are already lower income will improve the fair housing issues identified in Chapter 4. There is not even a Goal listed in section
2.1 to address the fair housing issues identified in Chapter 4.
The HE Draft indicates that as Moffett is built out, more resources will also be built. However, there is no analysis to demonstrate how much the opportunity index of the Moffett Park area will improve. Furthermore, the only commitment in the HE Draft is program H34 which would build a library, park, and zone for a school. It seems unlikely that a low resource area can be transformed into a high resource area simply by building a library, park, and elementary school.
The way to alleviate both of the above problems is to increase our pool of available lower- income housing sites, especially in the southern parts of the city. Specifically, change program Attachment 6
H2 to provide a total of 1,500 lower-income units rather than just 100. Some possible ways to do this are:
• Zone Village Centers to be greater than 30 du/ac
• Add new Village Centers. Possible sites include:
o Hollenbeck and Homestead (Loehmann’s Plaza)
o Fremont and Wright
o Wolfe and Homestead (Sunnyvale side)
• Increase density or allow more mixed use on ECR
• Increase Sunnyvale’s inclusionary rate to 20%
• Rezone most small strip malls to be mixed use sites
We believe these actions need to happen sooner than later because the longer the City waits, the fewer options we will have; for example, if we don't increase the density for Village Centers as soon as possible, many Village Center sites will have been built at lower density and with less lower income housing.
Another option to increase density and better meet our RHNA goals is to address the parking standards. To be clear we are not asking to get rid of parking, we would like to see parking spaces not wasted. The ABAG-MTC Parking policy, https://abag.ca.gov/sites/default/files/ documents/2021-10/Parking_Policy_Playbook_compiled_vF20211020.pdf , is a great resource that specifically outlines parking ideas such as unbundling, parking minimums and parking maximums. Unbundling parking would give the developers flexibility to build denser. We can also review Mountain View’s plans such as their North Bay Precise plan, https://www.mountainview.gov/civicax/filebank/blobdload.aspx?BlobID=31204 , that is constraining parking. The past Housing Element and this current Housing Element essentially mention the same ideas for parking. We would like to see the city go further and implement these parking standards or at the very least commit to studying unbundling, parking minimums and parking maximums.
Livable Sunnyvale supports the City’s commitment to meeting RHNA goals and providing housing to all income levels. We all desire a city that can sustain diversity and a livable environment. Our input for a moderate lower-income density in Moffett Park and increased density in high opportunity areas in the southern parts of the city will give us a better chance of meeting our RHNA goals. It will also lead to a Sunnyvale where households at all income levels can live throughout the city in an integrated and sustaining environment.
Sincerely,
Livable Sunnyvale Housing Element Committee
Attachment 6
Attachment 6
Attachment 6
June 8, 2022
Planning Department and City Council
City of Sunnyvale
456 W. Olive Ave.
Sunnyvale, CA 94086
Re: Draft Housing Element Needs Ambitious Parking Updates Dear Sunnyvale Planning Department and Sunnyvale City Council, Thank you for submitting your draft Housing Element early and allowing for robust comment.
TransForm is a regional non-profit focused on creating connected and healthy communities that can meet climate goals, reduce traffic, and include housing affordable to everyone.
We applaud Sunnyvale’s inclusion of Goal H-2 and Policy H-1.3 that streamline affordable development to help reach RHNA goals. However, building 6,709 units of housing will be no easy task and we believe Sunnyvale must implement smart parking policies like reducing or eliminating parking minimums, implementing unbundling, and requiring robust Transportation Demand Management (TDM) programs.
Policies H-4.4, 17, and 19 all mention reviewing parking standards to eliminate constraints on development, but lack specifics on how Sunnyvale will conduct this review or how it will be funded. We encourage Sunnyvale to commit to a specific timeline and to fund a dedicated study of parking reform, especially how the above mentioned smart parking policies could positively impact housing, transportation and other goals.
The need to eliminate or greatly reduce parking minimums is more important than ever. Each new parking space costs $30,000-$80,000. With inflation driving up construction costs since these1 estimates, two spaces may now cost up to $200,000. Beyond construction costs, parking takes up essential space that could provide more homes, services, or community amenities.
The recent Bay Area Parking Census released by SPUR and the Mineta Transportation Institute found that there are 2.4 parking spaces per car . Additionally, TransForm’s study of 80 Bay Area buildings2 identified that 28% of spaces were unused. This excess parking represented 1,164,600 square feet of 2https://www.spur.org/publications/spur-report/2022-02-28/bay-area-parking-census#:~:text=There%20are%20appr oximately%202.4%20spaces,person%20in%20the%20Bay%20Area. 1 https://www.shoupdogg.com/wp-content/uploads/sites/10/2016/05/Cutting-the-Cost-of-Parking-Requirements.pdf 560 14TH STREET , SUITE 400, OAKLAND, CA 94612 | T: 510.740.3150 | WWW.TRANSFORMCA.ORG 1 Attachment 6
space—an estimated $198 million dollars in costs that could have been used to produce more housing in these 80 developments.
To show the tremendous benefits these policies can have, we have used our GreenTRIP Connect tool to create scenarios for a potential future development site at 174/184 N Sunnyvale Ave. GreenTRIP Connect is recommended by the California Office of Planning and Research as a tool to use while developing General Plans and is especially useful during development of Housing Elements. The tool is free to use whether planning at the site or city-wide level.
By eliminating the high costs of parking, homes can be offered at more affordable prices, reducing the number of community members that face extreme housing cost burdens, getting priced out of their community, and/or becoming unsheltered.
Please let me know if you have any questions. TransForm hopes this information explains why Sunnyvale should make parking reform and affordable housing development a priority in the Housing Element update.
Sincerely,
Kendra Ma
Housing Policy Analyst
[email protected]
560 14TH STREET , SUITE 400, OAKLAND, CA 94612 | T: 510.740.3150 | WWW.TRANSFORMCA.ORG 2 Attachment 6
From:
To:
Cc:
Subject:
Date:
Attachments:
ML Stefan
Ryan Dyson
Mei-Ling Stefan
comments on Housing Element
Wednesday, June 8, 2022 5:08:45 PM
image.png
image.png
ATTN: Email is from an external source; Stop, Look, and Think before opening attachments or links.
Public transit in Sunnyvale is so poor that reduced parking needs, especially for the elderly and people with disabilities, does not make sense.
Moreover, policies that eliminate on-site parking near "high-quality" transit means using streets as parking garages, and will change neighborhoods and compromise pedestrian and bike riders' safety. Policy H-4.4 is not consistent with H-6.2 When I was growing up in Hong Kong, my parents did not own any car, so the parking space was rented to a neighbor who owns more than one car. This kind of flexibility is better than no parking provisions.
Thank you
Mei-Ling Stefan
Attachment 6
From:
Cc:
Subject:
Date:
Kenneth Rosales
Mathew Reed
Making Housing Elements Work through State Enforcement
Wednesday, June 8, 2022 10:45:42 PM
ATTN: Email is from an external source; Stop, Look, and Think before opening attachments or links.
Good Evening Honorable Mayor, Councilmembers, and City Staff, Your jurisdiction is either preparing for the release or is reviewing the first draft of your 6th Cycle Draft Housing Element before it is submitted to the California Department of Housing and Community Development (HCD) for initial review.
As you may have heard, the vast
majority of cities in the first rounds of submissions have received substantial comments from HCD outlining deficiencies and are being required to complete additional work to adjust and improve their housing elements so that they move into compliance.
We believe this current
moment presents an opportunity to assess working drafts with an eye on how the HCD review team has described some common issues they have observed. As of April 2022, jurisdictions in three major regions had submitted their “final” Housing Elements by their given deadlines but have continued to work with HCD on developing compliant Housing Element Updates:
The San Diego Association of Governments’ Housing Element deadline was on April 15, 2021, of which only 7 of 19 jurisdictions were in compliance; The Southern California Association of Governments’ deadline was on October 15, 2021, of which only 7 of 197 jurisdictions were in compliance; and The Sacramento Council of Governments’ Housing Element deadline was on May 15, 2021, of which only 17 of 28 jurisdictions were in compliance.
On March 25, 2022, SV@Home hosted a discussion during our monthly Housing Action Coalition event with David Zisser and Melinda Coy, HCD’s leadership for the Housing Element review team, titled
“Making Housing Elements Work through State Enforcement” (click here).
David and Melinda discussed how they will enforce Housing Element law and provided local advocates guidance on what they can do to help jurisdictions meet Housing Element requirements. Therefore, we would like to share the event recording and presentation slides as resources for your jurisdiction to use as you draft, publish, edit, and submit your Draft Housing Elements to HCD (available here
). We have included time stamps on key topics within
the webpage to make it easier to navigate the recording.
HCD reinforced the fact that they no longer consider the Housing Element Update to be a paper exercise, but instead a contract between jurisdictions and the state on housing commitments for eight-and-a-half years. To this end, HCD’s new Housing Accountability Unit will be monitoring implementation and will hold jurisdictions to the commitments laid out in the Housing Element’s plan.The following are key take-aways from HDC’s presentation, which we felt were particularly useful to consider as drafts are being finalized and reviewed:
Attachment 6
Most Common and Overarching Concerns - HCD has found that Housing Elements overwhelmingly describe but do not analyze the data that is provided.
Whenever data is included into Housing Elements, they want jurisdictions to ask themselves: What does the data mean? How are these assumptions supported? Further, HCD discussed they would like jurisdictions to “show their work” for the conclusions that are drawn, to avoid assumptions, and to use their analyses as tools that guide solutions, rather than simply explaining existing conditions. In this way, the various sections (e.g. needs assessment, sites inventory, constraints, etc.) should be reflective of and inform each other.
Affirmatively Furthering Fair Housing (AFFH) - HCD is looking for an analysis of patterns and trends - a story about the jurisdiction over time and how it has changed - rather than a demographic “data dump”.
They provided an example of what jurisdictions can ask themselves when providing their analyses: has our community become more diverse? Less diverse? Where are the areas of poverty and how have they evolved? How does this help to highlight the housing needs of each jurisdiction?
HCD would also like to see strategies for how local jurisdictions can “move the needle” (i.e. make progress) and assess whether the metrics and milestones of their actions will be successful in eight-and-a-half years.
They recommended jurisdictions review the City of Sacramento’s Housing Element on
how AFFH can be adequately addressed and the City of Folsom’s Housing Element for a good example of AFFH in a high resourced community.
AFFH: High-resourced and Lower-resourced neighborhoods - Under AFFH guidelines, it is important to add affordable housing opportunities throughout the jurisdiction. They clarified, however, that AFFH is also about providing community development options or programs to increase resources in low-resourced areas, preventing displacement, and increasing housing opportunities in terms of both sites and mobility.
Site Inventory - HCD recommended jurisdictions provide supporting data to the selection of their sites, including the underlying assumptions to pick a site, such as development trends and substantive site-specific analysis.
When choosing sites, HCD suggested that a discussion of the selection process be included, answering: Why were the factors that shaped the process chosen, and how did those assumptions relate to answering the question: “is this a development Attachment 6
opportunity within the planning period?”
For non-vacant sites, they mentioned jurisdictions should specifically provide
substantial evidence that an existing use is likely to be discontinued. Such evidence could include: 1) site specific information on whether the use will be discontinued in an eight-and-a-half year period and explain the factors leading to that conclusion, 2) what market and development trends are there to support discontinued use, and 3) what programs and actions could be taken by the jurisdiction to address the constraints that might impede the redevelopment of non-vacant sites.
Further, HCD expects site inventories to be responsive to the AFFH analysis, rather than be considered independent.
Governmental and Market Constraints to the Development of Housing - HCD discussed that constraints are to be analyzed and assessed for their potential impact, rather than simply noted and/or justified.
They also advised jurisdictions to consider the perspective of a potential developer and ask: how does the range of development standards, processing fees, various impact fees, etc. affect the development of housing? How long does it take to get planning and construction approvals, and what are the additional costs? What are the points of discretionary uncertainty in the process? Are there systems in place to process streamlined applications? How might substantial or minor changes in these elements of the development process have the cumulative impact of facilitating more development in your jurisdiction?
HCD delved into the need of a thorough assessment and a clear timeline for developing concrete policy or program changes in response to these analyzed constraints rather than referencing on-going or future assessments that need to be conducted. They want to see studies made within the Housing Element Update itself to construct a policy or program rather than prescribing a “study” as the policy or program itself.
Importantly, HCD recommended that the constraints analysis be reflected in the assessment of site-specific conditions that are identified in the site inventory.
Programs and Policies - HCD explained how jurisdictions should present clear prioritization and provide specific actions and timelines for each policy and program, along with clearly explaining what a jurisdiction will do to make implementation more realistic and feasible.
They suggested jurisdictions avoid the use of general language like “explore”, “consider'', “evaluate”, or “study”. Instead, HCD would like to see a detailed discussion about what exactly is going to be explored, what will be done, to what end, and what Attachment 6
the outcome(s) would be. HCD gave the example of replacing language such as "will explore providing incentives" with "we will develop an incentives program that will reduce fees/provide cost savings".
Moreover, HCD deliberated on how a jurisdiction’s policies and programs should build on the assessment of existing measures and go beyond previous cycles. Policies and programs should support the narrative in the housing needs and development constraints analysis and be responsive to additional requirements of the AFFH analysis.
Funding - HCD detailed how they will not accept the rationale that the lack of subsidies for affordable housing development is an insurmountable impediment to fulfilling housing commitments. Instead, they advised jurisdictions to find ways to spur development through land use reforms and additional financing mechanisms. These might include adopting a strong local density bonus program, an inclusionary housing ordinance with a robust in-lieu fee structure, or other impact fees as a mechanism to support affordable housing development. HCD also recommended looking into ways of lowering costs by deferring or waiving fees and taxes.
Non-Compliant Housing Elements - HCD cautioned that jurisdictions with non- compliant Housing Elements will be ineligible for, or face delays in receiving, state funding. Jurisdictions would also be unable to use inconsistent zoning/general plan standards to deny affordable housing projects, and could be subject to additional legal ramifications and fines.
Implementation of RHNA through the 6th Cycle - HCD re-emphasized that jurisdictions are required to monitor and adjust their site inventories to sustain capacity for their housing allocation throughout the planning period.
Enforcement - HCD will review actions and inactions submitted in the Annual Progress Report by local jurisdictions and they will take action on jurisdictions that are inconsistent with their Housing Elements. HCD will also respond to public complaints if a jurisdiction's actions are in violation with state law.
We appreciate that additional guidance has been made available from multiple sources, including ABAG/MTC and the Santa Clara County Planning Collaborative - they have been instrumental in guiding us all through this complicated process. We know that the Housing Element Update has been a significant undertaking and that the HCD review process has been less central to the public and council’s engagement to date. We hope that this letter provides constructive insight into what HCD will likely highlight and that it further enables local engagement throughout the next phases of the Housing Element process. We also hope that meaningful public participation will continue to be a priority as feedback is received from the Attachment 6
state and incorporated into future drafts.
We appreciate your continued coordination on this Housing Element journey and we look forward to deepening our engagement as we move closer to January 2023.
Best,
Kenneth Rosales (He/Him)
Planning Senior Associate| SV@Home
408.518.0676
[email protected]
#ReimaginingHome Learn more about Affordable Housing Month 2022 Attachment 6