Agenda packet — Sutter Creek City Council, December 18, 2023 (part 3 of 3)

2.19 Commenter questions the definition of “housing tenure” on PDF page 51.

Page 12 ends

2.20 Commenter indicates that the table on PDF page 51 doesn’t address how long people are in their household on this page; it is defined about 20 pages later in the document.

This comment is noted.

2.21 Commenter has questions on PDF page 52 about “overpaying households” and wants to know what items are being overpaid (rent and mortgage or utilities)? Commenter speculates that there are homeowners whose home has been paid off and are very low income and questions whether or not it includes property taxes, interest on mortgage, required insurances for the house? This comment is noted. Overpayment refers to when a household pays more than 30% of its income toward total housing costs and does not address or identify individual components of housing costs. There are no standards for overpayment for the individual items, such as rent, mortgage, insurance, or utilities, as identified by commentor.

2.22 Commenter shares about PDF page 60, Table II-11 that statistics are very good but would be better to also include approximate number of people working in the low-income occupations. Commenter acknowledges it may be hard to get the data, especially if some work more than one part time.

This comment is noted. Data is not reported by EDD for the County or individual jurisdictions for each of the occupations identified in Table II-11.

2.23 Commenter shares about PDF page 77, “No place like home” seems like very good priorities.

This comment is noted.

2.24 Commenter shares about PDF page 82 – Vacancy rates – “It appears Air B&B vacation rentals are a detriment to affordable housing, if they replace what was once a housing unit (rent or owner).” This comment is noted. Short-term rentals are addressed in the Annex prepared for each jurisdiction.

2.25 Commenter shares about PDF page 111 – “In recent local news, there was an article that discussed water supply issues, that there is not enough water for new planned developments in parts of the county. It is a serious issue.” This comment is noted. As previously identified, Housing Plan Program 19 addresses supporting improvements to AWA infrastructure to accommodate the housing needs in the County. Information regarding AWA’s water treatment and storage capacity is updated in Chapter III, Housing Constraints and Resources, of the Background Report.

2.26 Commenter shares about PDF pages 215-250 – “The
achievements show well documented information for follow-up and action from 2014-2019.” This comment is noted.

Mark Bennett 3.01 Introduction This comment is noted.

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Commenter shares that “Economic activity is divided into primary/production, secondary/fabrication &distribution and tertiary/administration & government. The more people engaged in tertiary occupations the closer a society moves toward economic and social collapse. It is not a coincidence that the expressions Mandarin and bureaucrat are used as synonyms. Studies, plans, consultants and documents do not produce housing. However, this exercise is required in California and my intent is to do the best job I can for Amador County. The draft Housing Element is thorough and detailed and, in a sense, a magnificent piece of work.”

3.02 Introduction, cont’d
Commenter shares that, “The goal of land use planning is to provide sufficient future sites in relative abundance since the future is unknown and the prevention of inflationary scarcity desirable. When the economics and demographics of an area change the demand for different land uses change. This study documents the need for affordable and often multiple unit housing. It is, of course, beyond the scope of this study to ask why we are short of housing.”
This comment is noted.

3.03 Introduction, cont’d
Commenter shares that, “On the frontier people hustled through the spring and summer to build a basic log cabin. As their situation improved so did their housing. This became known as the add-on tradition, a uniquely American quality. It has continued to the present as witnessed in the post war bungalows of San Mateo Country being expanded into the homes of the hi tech well to do. When immigrants packed New York City the tenements were built. They were extremely minimal, but safe and sanitary. As prosperity increased, especially in the garment industry, the standards were increased into the New Law tenements. People were always adequately housed because we built what we could afford.” This comment is noted.

3.04 Introduction, cont’d This comment is noted.

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Commenter shares that, “Mini Houses, apparently successful in some locations, if not on large enough lots cannot be expanded and a future ghetto type neighborhood could emerge. If the homes could expand with the prosperity of their inhabitants a thriving neighborhood could emerge instead. The American add on tradition is worthy of preservation.”

3.05 Introduction, cont’d
Commenter shares that, “Over the past few decades, along with downzoning in our major cities, we have moved with noble motivations but idealistic assumptions that everyone should be housed at a certain middle-class standard. Then add in overbearing environmental regulations and other causes like the Dark Skies skirmishes here and the real and potential costs increase.” This comment is noted.

3.06 Introduction, cont’d
Commenter shares that, “Our local lumber mills have closed. Our county has undergone demographic changes and our transit system has morphed into a dial a ride service for the elderly and disabled. Aside from our vital agriculture, higher paying jobs have vanished as the tourist/senior citizen service economy survives. But the why of our housing situation is beyond this element.” This comment is noted.

3.07 Housing Plan, page 1
Commenter shares that Policy H-1.4 “Encourages a geographic dispersal of units affordable to all income levels throughout Amador County,” and while it seems noble to prevent “ghetto” type neighborhoods and behavioral sinks like the big city housing projects, this policy ignores access to lower paying service jobs. Commenter suggests dropping this policy.

Policy H-1.4 is revised to also promote housing that is proximate to jobs and services and promoting a variety of housing types in areas of higher opportunity within each jurisdiction.

3.08 Housing Plan, page 1
Commenter shares that Policy H-1.6 “Supports opportunities for the integration of housing in commercial districts and the adaptive reuse of non-residential structures,” and that the recently approved La Vista Motel conversion exhibits this. Commenter also shares that this is common sense and conserves resources, and there is a difference between not locating homes This comment is noted.

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next to a chemical plant and seemingly obsessive restrictions in many residential zones; apartments above businesses are commonplace.

3.09 Housing Plan, page 1
Commenter shares that per Policy H-1.7, the building of accessory units is commendable. “It should be noted that this style is somewhat traditional since the extended family has been the norm throughout history. The nuclear family isn’t much more than 100 years old. However, our admirable national labor mobility (one of the basis for the European Union) has contributed to the growth of the nuclear family. However, the inclusion of multiple units in single family areas is controversial and should be dropped. If the value of someone’s home decreases because of this is it an inverse condemnation under the 5th Amendment? But there may be some suitable sites in our cities so this idea should not be forbidden.” This comment is noted.

3.10 Housing Plan, page 2
Commenter shares that per Policy H-3.4 “the provision of family support services such as child care and after-school care,” and indicates that “we have a noble cause, but I sense this would lead to family type neighborhood segregation. We are rightly concerned with “potentially underrepresented populations” (Policy H-3.8 below) Diversity is good, but we seem to have ignored age segregation. Too many areas are young family starter homes or senior citizen housing. To my perception this has led to an uncomfortable myopia in the last few generations and may be partly responsible for our current political chaos. Remember that the younger one is the greater the effect upon them. Other issues such as child care, etc. are probably better handled through the free enterprise system. Although desirable, we are over complexifying things to the point of it possibly becoming selfdefeating.” This comment is noted. Fair housing issues, including access to housing by seniors and by family households with children present, including female-headed households, are discussed in Chapter V of the Background Report.

3.11 Housing Plan, page 2
Commenter shares that per Policy H-3.6, “Support affordable housing options for workers who providing essential infrastructure and services, including first responders and This comment is noted. Policy H-3.6 supports affordable housing options for workers - this does not limit the approval of multifamily housing that is not focused on the workforce, such as housing serving seniors, persons with a disability, or other populations that may have members both in and out of the workforce.

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teachers, to allow them to live in the community in which they work,” is too specific and can become too restrictive and complex for a proposed multiple dwelling project. All it really says is that the housing market isn’t working. Our efforts should go there rather than band aid solutions.

3.12 Housing Plan, page 3
Commenter shares that Goal H-4, Policy H-4.3 notes “transitoriented development,” and the apartments near the transit center qualify, except that the sidewalk slopes may be too steep for some. The Wicklow Lot affordable apartments will also qualify, with some early bus stop discussions underway. While bus stop/apartment combinations in places like Ione, Pine Grove, etc. are possible the infrequent service may negate their success.

Amador’s rural/ low density makes most transit difficult. The problem to solve is “the last mile”. For some people bicycles could work. This was discussed in the Bike/Ped Plan including added comments. In big cities the last mile was served by taxis or jitneys in pre-inflationary times.

This comment is noted. Policy H-4.3 is revised to also address housing within walking or bicycling distance of transit.

3.13 Housing Plan – Page 4
Commenter shares that on Page 4, Goal H-1, Housing Diversity Program 2 documents the annual reporting requirement to the state. Commenter wonders why not a longer period of time given the lead time for developments? It seems like bureaucrats and consultants are creating employment opportunities for themselves. Do they fear a dangerous trend in some jurisdiction that requires an early warning? This comment is noted. The reporting is conducted annually, but will address all project applications, projects approved, and projects receiving building permits and/or certificates of occupancy during the planning period. Some of these projects will span multiple reporting periods, so the annual reporting will not limit the ability of each jurisdiction to report on longer-term accomplishments and provides the State and public with information regarding the jurisdiction’s accomplishments in accommodating and promoting a variety of housing types and addressing housing needs.

3.14 Housing Plan – Page 5 – Program 3 – Adequate Sites (All Jurisdictions) Commenter shares that this section notes “at least 16 units per acre” and other very prescriptive requirements. Obviously, those in charge feel that this is necessary. But does it inhibit possible projects? This referenced language only applies to the City of Plymouth, which must rezone sites to accommodate its lower income housing needs. The rezoning of these sites is subject to specific and stringent requirements of State law (Government Code Section 65583.2(h).

3.15 Housing Plan – Page 6 – Program 3 – Adequate Sites (All Jurisdictions)
This comment is noted. Jurisdictions in California prepare a consolidated annual financial report that typically identifies the financial situation of a jurisdiction, including services provided by the Appendix C
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Commenter shares that this section continues on page 6 with the requirement that Amador City have “1 very low, 1 low, 1 moderate, and two above moderate-income units.” Commenter continues to share that “While the state requires this of the element, it seems to be quite a burden on a tiny city. But perhaps this situation arose due to the nature of local government in California. In another state Amador City would be a village and not have the responsibilities a city. This also explains the proliferation of special districts, often single purpose, that probably wouldn’t be necessary if villages and townships existed in California. On page 28 establishing “assessment districts” are suggested. Has anyone ever done a cost/benefit analysis of California local government?” jurisdiction, cost to the jurisdiction of providing the services, and revenues of the jurisdiction.

3.16 Housing Plan – Page 9 – Program 9 – Affordable and Special Needs Housing Assistance and Incentives (All Jurisdictions) Continues on page 9 with “PD designations to provide a minimum of 10 percent of total units on site as housing affordable to extremely low, very low-, low-, and moderate-income households, or pay an in-lieu fee to support affordable development at an alternative location.” Assuming that a developer maintains the same profit margin does this meant that they raise the rent on the other units? Will one tenant be subsidizing their neighbor’s rent? If so this is unfair and totally different that policies such as the graduated income tax to redistribute to the less fortunate.

This comment is noted. Projects providing affordable units are eligible for incentives, such as a density bonus, reduction in development standards, and other accommodations that can offset a portion of the cost of providing affordable units. Financial resources available to assist with the provision of affordable housing are discussed in Chapter IV.

3.17 Housing Plan – Page 9 – Program 8 – Neighborhood Beautification and Housing Rehabilitation (All Jurisdictions) Commenter shares that, “Hardening of homes in the upcountry area needs to be added. Most items are common sense such as “promote energy efficiency” but remain ill defined. This can vary from cost effective attic insulation to orienting a building to the sun rather than a view shed the future home owner’s desire. Also allusions to stricter code enforcement in buildings needing repair can mean a building code “police force” as it does in some jurisdictions. I recall the torment given an elderly man of modest This comment is noted. The California Government Code requires that General Plans address a variety of risks, including wildfire in the Safety Element. That element is prepared and updated separately from this Housing Element. Energy-efficiency is discussed in greater detail in Chapter VII of the Background Report.

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means about his run-down trailer home. Do we want to live in a “live and let live” county or something else?”

3.18 Housing Plan – Program 9 – Affordable and Special Needs Housing Assistance and Incentives (All Jurisdictions) Commenter shares that, “This deals with the need for precise and perhaps more data to qualify for government, etc grants. This is an accurate appraisal of the “black box’ we live in and are forced to make decisions within. But can the gross dysfunction of our current housing situation galvanize us to attack the underlying reasons?” This comment is noted.

3.19 Housing Plan – Page 12 – Program 10 – Preservation of Existing Affordable Housing (All Jurisdictions) Commenter shares that, “The goal of deed restrictions on affordable housing units and especially those built with government subsidy has an obvious logic. But how long do these restrictions last? Is it a short-term solution that could encumber future changes and inhibit a quicker free market response?” Deed restrictions vary depending on the funding source and requirements of the local government. Typically, projects receiving California Low Income Housing Tax Credits (a standard funding source for affordable housing) are required to be affordable for a minimum of 55 years.

3.20 Housing Plan – Page 12 – Program 11 – Preserve Multifamily and Mobile Home Opportunities (All Jurisdictions) Commenter shares that, “While the goals of providing affordable housing and adequate notice to tenants are admirable, what is their cost? Can we be too myopic? The standard doctrine has always been the highest and best use. That is why our zoning preserves mineral resource areas and why local governments use eminent domain to build projects deemed more essential.” The comment is noted. Public notice is provided to ensure residents are aware of the potential need to relocate and understand their housing rights; this type of notice can reduce the impacts of displacement on residents by ensuring residents have adequate time to plan for new housing in the event that the affordable unit they live in is converted to market rate. Funding source for Program 11 is the General Fund.

3.21 Housing Plan – Page 14 – Program 13 – Affirmative Further Fair Housing (All Jurisdictions) Commenter quotes “…help foster more inclusive communities…” and asks, “Is it really to the benefit of someone of modest means with modest job skills to, in reality, strand them in say Pioneer or Buckhorn rather than the economically vital county core? Currently we have several Upcountry youth totally dependent upon meager bus service to maintain their minimum wage jobs in Martel. Although not analogous to the above Stockton has had a mixed track record of success with this concept.” This comment is noted. The commenter is referred to the Affirmatively Furthering Fair Housing discussion provided in Chapter V.

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This discussion continues with a Table of Action Items.

3.22 Commenter shares that Housing Plan – Page 18 “Talks about outreach as a requirement of each jurisdiction. Outreach and related functions repeat throughout this Element. When does this become too much? What is the borderline between helping and encouraging dependency? Are we sick of the excuse: They didn’t tell me that?” This comment is noted. Public outreach is required by State law and the program aims to ensure adequate opportunities are made for public involvement in the decision-making process.

3.23 Commenter shares that Housing Plan – Page 25 - Goal H-4, Advancing Opportunities “Requires a reduction in on-site parking spaces for multiple dwellings. While this appears obvious common sense, it totally depends upon the adequacy of adjacent on street parking. Look at our existing cities. In our rural areas it can be a serious problem. There was recently an issue with some rental housing near Pine Grove with inadequate off-street parking and apparently dangerous visitor parking on a curvy narrow shoulder less road.” This comment is noted. Program 17 provides for context-sensitive parking reductions (e.g., reduced parking for smaller unit sizes, senior housing, etc.).

3.24 Commenter shares that Background Report – Page 37 - “… landlords willing to work with roommate situations…” presumes this was a reported problem; however the extent of it is likely unknown, and continues to share that as a prior manager of rental housing, commenter knows this can bring difficulties, but leaving it up to anyone but the property manager may have, as in other provisions here, unintended consequences.

This comment is noted. The language referenced by the commentor was information reported through the Service Providers, Community Organizations, and Housing Developers/Providers Survey.

3.25 Commenter shares that Background Report – Page 70 - Affordable Housing Development Constraints, states: “Tax credits are not worth as much to investors if their incomes have dropped.” While that, in and of itself, is not a great impediment to needed housing, it clearly illustrates a phenomenon that runs through this Element. Complexity breeds complexity. Therefore this Element has to note the problems prior processes have bred.

This comment is noted.

3.26 Commenter shares that Background Report – Page 72:

This page begins the inventory of available water deficits which we know just delayed a 46-unit project in Sutter Creek. It is not Housing Plan Program 19 addresses supporting improvements to AWA infrastructure to accommodate the housing needs in the County. Information regarding AWA’s water treatment and storage capacity Appendix C
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the task of this Element to ask: Why? The answers are simple: prior directors of AWA plus the prevention of the Devil’s Nose Dam. limitations is added to Chapter III, Housing Constraints and Resources, of the Background Report.

3.27 Commenter shares that Background Report – Page 87:

This page documents the protection of Biological Resources. In a similar vein as the tax credits mentioned above and many others, more complexity and constraints inhibit housing construction. And while these protections are desirable, trade off decisions are made in the “real” world. In Egypt the Aswan High Dam flooded ancient temple sites for hydropower and irrigation. A subway was dug under Rome.

This comment is noted. Projects must comply with State and Federal laws related to biological resources, including endangered species and sensitive habitats.

3.28 End Notes
The entire Element is available at https://www.amadorgov.org/departments/planning/2022-housing-element Generally my citations note a goal or policy only once, but most of them run repeatedly throughout the Element.

This comment is noted.

3.29 End Notes, cont’d
This Element requires, as it should, non-discrimination and diversity. While not within its purview a related situation needs repeated awareness: age segregation. We build young family starter home communities, senior citizen communities, etc. Young people are often unexposed to the life experiences of others. I suspect that this contributes to the malaise of our youth which could be defined as lack of grounding (except that provided by social media?) Throughout this Element the nearness to childcare facilities is repeated. While this is again a worthwhile idea it could have the untended consequences of aiding age segregation.

This comment is noted. Fair housing issues, including access to housing by seniors and by family households with children present, including female-headed households, are discussed in Chapter V of the Background Report.

3.30 End Notes, cont’d
Much of my evaluation of this Element has centered on the long run negative economic effects of the growth of rules and bureaucrats, illustrated even more extremely in education. However, I am not a naïve or an ideological critic. In times past municipal budgets were low because police officers, building inspectors, etc. received part of their income as cash bribes. In This comment is noted and the commentor’s time and effort spent performing a detailed review of the element and providing thoughtful comments is appreciated..

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Buffalo, NY homes within a quarter mile of the Niagara River were not connected to the sewer system, but “efficiently” dumped into the river. (What did the tourists see visiting Niagara Falls a few miles downstream?)

3.31 End Notes, cont’d
The detail is vast and one could wonder if this super detailed this cataloging of all housing sites, income data, etc represents the way our government is going in many other areas.

This comment is noted. The Housing Element is intended to meet the requirements of State law, which require a detailed assessment of housing needs, constraints, inventory of sites, fair housing issues, and previous performance, as well as a plan that demonstrates each jurisdiction’s commitments to addressing housing needs for the 6thCycle.

3.32 End Notes, cont’d
Note: Pages 30 to 35 of Appendix B, Housing Needs and Priorities Survey Results were missing (or perhaps where was a numbering error) These pages were intentionally omitted for confidentiality as they included personal information of survey respondents.

Katie Moose, CA Health Collaborative

4.01 Commenter suggested Housing Element Changes for Amador County. Specifically, an addition is requested in Section A. Goals and Policies, Goal H-3 – Fair Housing: Policy H-3.9: To reduce secondhand and thirdhand smoke death and disability, adopt a comprehensive smoke-free ordinance for multifamily housing properties that covers all exclusive-use areas, both exterior areas (such as private balconies and decks) and interior unit spaces, as well as common areas not already covered by state law.

Policy H-3.9, with modifications, is added to the Housing Plan to promote smoke-free living environments.

4.02 Commenter suggested Housing Element Changes for Amador County. Specifically, an addition is requested in Section B. Housing Programs, Goal H-3 – Fair Housing:

Program 16: Smoke-free Multifamily Housing (All Jurisdictions) The health and safety of the home is key to physical and mental health. For individuals who live in multifamily housing, involuntary exposure to secondhand smoke at home is all too common. Tobacco smoke can easily travel through light fixtures, crawl spaces, and doorways. Residents of multifamily housing have no rights or recourse even when regularly exposed to secondhand smoke—and moving is not always an option. Children, the elderly, and people living with chronic conditions Program 15B, with modifications, is added to the Housing Plan to promote smoke-free living environments.

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are more likely to live in multifamily housing and are the populations most in need of protection from secondhand smoke. Secondhand smoke exposure in multifamily housing exacerbates many pre-existing health risks among multifamily residents, further threatening their health. Through implementation of an ordinance, each jurisdiction in Amador County will work with owners and managers to include smoke-free language in their leases and to ensure that smokefree property signs are posted around the properties. None of the jurisdictions should utilize police, or impose fines or eviction to enforce the policy, but instead should utilize a tiered enforcement structure that includes written warnings and referrals to quit services through the County. Responsible Department/Agency: Amador County Public Health Department & Building Department of each jurisdiction Funding Sources: California Tobacco Control Program funding (Prop 99 and 56) Program Objectives and Timeframe:
• Conduct resident opinion surveys on secondhand smoke
exposure and opinions on a comprehensive smoke-free multifamily housing policy. • With assistance from the Public Health Law Center,
contact County Counsel to draft language for a comprehensive smoke-free ordinance. Ordinance will encourage compliance through education, signage requirements, and property manager actions rather than police, fines, or evictions. • Conducted targeted education to landlords and tenants on the benefits of smoke-free multifamily policy.
• Conduct targeted outreach to landlords with resources including language to include in leases, assistance available to purchase signage, and local resources for residents who want to quit tobacco.

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Emily Nguyen 5.01 Encourage the County to ban smoking (e-cigarettes, cigarettes, cigars, etc.) in apartments and multi-unit housing buildings to protect non-smokers from second-hand smoke and help them maintain good health – unfair to expose non-smokers to negative health effects due to smokers The added policy and programs referenced above encourage practices that help to reduce exposure to second-hand smoke and to promote public health and wellness.

Thomas P. Infusino, Esq., Foothill Conservancy

6.01 A) Program 19: Water and Wastewater Infrastructure Capacity Thank you for acknowledging the limitations on new construction associated with the potable water treatment and wastewater treatment constraints of the local service providers. (Draft Housing Element, p. 27.) These service providers may not be able to expand those treatment capacities during this housing element cycle because designing, financing, and constructing such systems can take a great deal of time. In the meantime, we can stretch existing resources by increasing water conservation and reducing effluent among all willing customers. There are state programs to finance these efforts. These include the Drinking Water State Revolving Fund, the Integrated Regional Water Management Implementation Grant Program, and the Safe and Affordable Drinking Water Fund. The latter program has spent $98.2 million dollars on 48 projects statewide. (See https://www.caclimateinvestments.ca.gov/saferdrinking-water) The water and wastewater treatment capacity gains reaped should be reserved for affordable housing proposals. (See Chapter 727, Statutes of 2004, SB 1087; Gov. Code. Sec. 65589.7(a).) Program 19 addresses water and wastewater capacity in Amador County (including cities) is revised to also include promoting water conservation and reduced effluent.

6.02 B) Require a component of affordable housing in new subdivisions. Again, we encourage the cooperating jurisdictions to require a reasonable and lawful percentage of affordable housing in larger new subdivisions. (See California Building Industry Association (CBIA) v. City of San Jose (2015) 61 Cal.4th 435; Gov. Code Sec. 65850(g) - 65850.01.) Sometimes these take the form of smaller homes or second units compatible with the surrounding subdivision. While we do not expect such policies to secure very low-income housing opportunities, they could provide additional workforce housing for moderate income households. It is good This comment is noted. Program 6 promotes affordability projects in special planning areas and planned developments, particularly in Amador County and the Cities of Ione and Sutter Creek.

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for our communities if the people who get paid to work in Amador County are also able to live here, support local businesses, and pay local taxes.

6.03 C) Housing Rehabilitation & Energy Conservation Initiatives Given the limitations on new construction due to potable water and sewer treatment capacities, it is very good that the draft housing element seeks to retain our existing affordable housing stock through housing rehabilitation and similar efforts. (See Housing Rehabilitation Program, p. 9; Public Investment in Neighborhoods, p. 17.) It is also good to improve energy conservation in our affordable housing stock. (See Program 25, Energy Conservation Initiatives, p. 31.) Most of the homes in Amador County were built for the 20th Century, not for the 21st. Existing affordable homes are threatened by water supply shortages, higher energy costs, electricity interruptions, wildfire, and increasing fire insurance rates. To retain our affordable housing stock, there is a huge need to improve energy conservation, energy self-sufficiency, water conservation, defensible space, and home hardening. The latter two efforts not only improve the likelihood that the structure will survive a wildfire, but also may result in fire insurance premium reductions. There are state and federal programs to finance these efforts. Upgrading exteriors to comply with WUI requirements for lowincome home owners can be funded with grants or loans though the USDA’s Section 504 Home Repair program. (https://www.rd.usda.gov/programs-services/singlefamilyhousingprograms/single-family-housing-repair-loans-grants/ca .) Grants are also available for such housing rehabilitation from the state’s Department of Housing and Community Development (https://www.hcd.ca.gov/grants-andfunding/ programs-active .) Fuel reduction projects can be funded through CAL FIRE’s Wildfire Prevention Grants Program. As of May 31, 2022, this program has spent $219 million implementing 306 projects statewide. (https://www.caclimateinvestments.ca.gov/firepreventiongrants) While some of these funds are made available directly to This comment is noted. Program 8 is revised to also include wildland urban interface/wildfire fire hardening among the activities promoted and supported by the program and to list potential funding sources, including those referenced by the commenter.

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individuals, more funds can be secured through applications by local governments. These property rehabilitation efforts would provide work for local plumbers, electricians, and other contractors, thereby improving the local economy. Every year tens of millions of dollars of capital are drained from our local economy in the form of state and federal taxes. It is time to get more of that money back to improve our local communities and our local economy.

6.04 D) Transitional Housing
Please consider taking specific actions in the Housing Element to address the need for transitional housing to give a hand to people who want to be lifted back into the main stream. In our work cleaning up local homeless camps, our volunteers see the need for transitional housing first hand. Wounded people need a place to heal. Addicted people need a place to become clean and sober. Troubled spirits need a place to rediscover joy. Divided families need a place to reunite. We hope that your efforts to establish such housing programs will be successful.

Transitional and supportive housing is addressed in Program 17 of the Housing Element. Program 5B has been added to provide additional coordination and support related to services for the homeless population.

6.05 E) Administration
We are so pleased that the County and the local cities are continuing to cooperate in preparing the housing element. We hope that in this cycle these jurisdictions will take the next step to form an administrative body with the capacity to implement the housing programs to achieve or exceed their numerical targets.

This could mean increasing the institutional capacity of an existing joint powers authority (JPA), or forming a new joint powers authority with the sole purpose of implementing the housing element. Such a JPA would need to have full-time paid staff sufficient to implement the housing element. The Foothill Conservancy has over 30 years of experience working with volunteers, consultants, and paid staff. It has been our experience that volunteer efforts, consultant assistance, and parttime staff work is most effective when coordinated by a fulltime paid staff dedicated to a single purpose. We believe that This comment is noted. A countywide housing working group is addressed in Program 1 of the Housing Plan.

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such a staff is necessary to effectively implement the many programs in the draft housing element.

Amador Water Agency

7.01 Housing Plan - AWA is also pleased to support Policy H-1.8 to integrate energy- and water-conserving designs into residential development. Ln addition to other important reasons for such a policy, considering AWA's water treatment capacity constraints discussed below, and the likelihood that solutions will take some time to implement, water conservation and efficiency are the most effective near-term actions to help protect water service reliability for all of the Agency's customers. Perhaps there should be an express link between Policy H-1.8 and Program 18: Code Review.

This comment is noted. Program 18 has been updated to reference Policy H-1.8.

7.02 Housing Plan – AWA is pleased to see that the discussion within Program 19 includes AWA's shared concerns with its treated water capacity. These capacity challenges are well documented in the Agency's 2O21 Water Master Plan Study and 2022 Tanner and lone Water Treatment Plants Capacity Study, which should be cited in the Background Report in the section addressing potable water (page 72). AWA looks forward to working together with the jurisdictions in efforts to fund and implement treatment capacity expansion in order to accommodate the regional housing needs allocation (RHNA). lt is noteworthy that the issues being faced involve both the physical capacity to serve additional housing and the affordability of that service.

This comment is noted. The discussion is updated to include information related to the 2021 Water Master Plan Study and the 2022 Tanner and Ione Water Treatment Plants Capacity Study.

7.03 Background Report
The third paragraph of the discussion of River Pines PUD (page 74) refers to water purchased from AWA. ln fact, River Pines PUD is served from its own wells. Under a services agreement, AWA provides certain water and wastewater operator services to River Pines on a time and materials basis, but does not deliver AWA water to River Pines.