Attachment C - Response Matrix_to HCD Comment Letter — Visalia City Council, December 18, 2023

Visalia 2023-2031 Housing Element Update HCD Comment Matrix Response to October 23, 2023, Comment Leter
Please note: Page numbers reference the track change version, which is required by HCD.

November 2023 1
# HCD Comment Project Team Response
A The element must provide a cumula�ve evalua�on of the eﬀec�veness of past goals, policies, and related ac�ons in mee�ng the housing needs of special needs popula�ons (e.g., elderly, persons with disabili�es, large households, female- headed households, farmworkers, and persons experiencing homelessness).

We have revised the document to include a
cumula�ve evalua�on of the eﬀec�veness of
programs in mee�ng special housing needs on
page 389.

B1.1 Fair Housing Enforcement and Capacity: While the housing element includes a summary of fair housing enforcement and outreach capacity at the county level, it must also quan�fy and evaluate complaints at the City level. In addi�on, the element should discuss how the City complies with exis�ng fair housing laws and regula�ons, any past fair housing lawsuits, consent decrees or other related legal maters.

Added how the City complies with applicable
fair housing laws and added statement that
there are no past/pending lawsuits or legal
issues regarding fair housing.

B1.2 Paterns and Trends: While the element reports general informa�on and data, it must analyze this data for trends over �me, paterns across census tracts, and coincidence with other components of the assessment of fair housing that go beyond general statements. Addi�onally, the element must broaden its regional analysis. For example, the element could compare the City with neighboring coun�es such as Kings, Kern, and Fresno County.

Added comparisons to Fresno and Kern
Coun�es in the Regional Trends sec�on
throughout the AFFH analysis.

B1.3 Racially Concentrated Areas of Poverty/Aﬄuence): The element iden�ﬁed one census tract that qualiﬁed as a R/ECAP and a total of three census tracts that qualiﬁed as RCAA’s; however, the element should evaluate the factors that contribute to this outcome. This analysis should u�lize local data knowledge and other relevant factors to achieve a comprehensive analysis. For example, the element could examine past land use prac�ces, investments, and quality of life rela�ve to the rest of the City and region and then formulate appropriate programs to
promote more inclusive communi�es and equitable quality of life. Based on a complete analysis, the City can consider addi�onal ac�ons (not limited to the Regional Housing Need Alloca�on (RHNA)) to promote housing mobility and improve new housing opportuni�es throughout the City.

Added addi�onal discussion of R/ECAP and
RCAAs.

B1.4 Dispropor�onate Housing Needs Including Displacement: The element must evaluate paterns and needs related to housing condi�ons and people experiencing homelessness. For housing condi�ons, the element should evaluate whether any
neighborhoods or areas have a higher need of rehabilita�on and replacement than other areas. For persons experiencing
homelessness, the element should examine dispropor�onate impacts on protected characteris�cs (e.g., race, disability) and paterns of need, including access to transporta�on and
services. The analysis should u�lize local data and knowledge from service providers and code enforcement oﬃcials. Pending a complete analysis, the element should highlight any gaps in addressing the need and integrate policies and programs to eﬀec�vely overcome dispari�es in addressing the City’s housing stock and unsheltered popula�on.

Added details on race/ethnicity of homeless
popula�on and added comment reques�ng
addi�onal informa�on on geographic trends
and needs of the homeless popula�on (pages
328-331). Expanded discussion on substandard
housing.

Based on the City’s site loca�on rela�ve to all components of the fair housing analysis, the City must iden�fy addi�onal sites to AFFH. The element men�ons that most sites, including those for lower-income households, are in areas of high and highest resource; however, there are s�ll large concentra�ons of lower- income units near lower-resource, (low-income) census tracts that have high concentra�ons of Hispanic/La�no residents, including in the City’s Downtown. While the City’s mul�family zones are limited, the element should iden�fy addi�onal innova�ve strategies to eﬀec�vely promote housing mobility and integra�on throughout the City. For example, missing middle unit types can be used as a tool to promote addi�onal units throughout the City.

We have added Program 2.7 to address and
encourage missing middle housing.

In addi�on to evalua�ng and revising
development standards and adop�ng
incen�ves, we have added an ac�on within the
program commi�ng the City to iden�fying
vacant parcels in low-density single-family
areas, par�cularly in high resource areas, with
poten�al for mul�-family missing middle
housing development, and contac�ng property
owners to discuss site constraints and
opportuni�es for addi�onal density or reduced
development standards to incen�vize
development of missing middle housing. The
goal for this ac�on is to engage 25 property
owners each year.

B1.6 Contribu�ng Factors: The element iden�ﬁes many contribu�ng factors to fair housing issues but must priori�ze these factors to beter formulate policies and programs and carry out meaningful ac�ons to AFFH.

Assigned low/medium/high priority to
contribu�ng factors.

B2.1 Farmworkers: While the element includes data on seasonal and permanent farmworkers, it should also analyze housing needs and characteris�cs to beter formulate policies and programs. An analysis should address housing challenges and condi�ons, present strategies, and resources to meet the need, and provide an assessment of gaps in resources for farmworkers within the City. The element should enhance exis�ng policies and programs based on a revised analysis. Furthermore, while trends seem to point to a decline in farmworkers in Visalia, the element should con�nue to consider the presence of farmworkers from the broader areas (county-wide) and those employed seasonally, including within the City’s boundaries.

We have added informa�on on housing needs
and characteris�cs from the UC Merced
Farmworker Health Study (see pages 77-78).

We have added an ac�on to Program 5.9
commi�ng the City to adop�ng incen�ves for
farmworker housing by 2026.

We have added a Program 5.10 to further
address farmworker housing needs and
condi�ons.

B3.1 Progress toward the RHNA: As you know, the City’s RHNA may be reduced by the number of new units built or approved since June 30, 2023; however, the element must demonstrate the aﬀordability of units in the planning period based on actual sales price, rent level, or other mechanisms ensuring aﬀordability (e.g., deed restric�ons). While the element provides aﬀordability assump�ons based on deed restric�ons for projects listed on P . 131, the element doesn’t demonstrate aﬀordability for the remaining projects in(Table 55) of the element. In addi�on, the element must discuss the availability or likelihood that units will be built in the planning period and should account for remaining steps in the en�tlement process, any barriers to development, phasing, an�cipated build-out horizons, market condi�ons, and other relevant factors to demonstrate their availability in the planning period.

Adjusted the aﬀordability of the pending and
approved projects in Table 55.

Visalia 2023-2031 Housing Element Update HCD Comment Matrix Response to October 23, 2023, Comment Leter
Please note: Page numbers reference the track change version, which is required by HCD.

November 2023 3
# HCD Comment Project Team Response
B3.2 Realis�c Capacity: While the element provides conserva�ve assump�ons for buildout, realis�c capacity assump�ons must s�ll account for all land use controls and site improvements. In addi�on, the element should demonstrate how trends, factors, and evidence in Table 57 led to capacity assump�ons in Table 59.

For example, projects used to make capacity determina�ons seem limited to the City’s R-1-5 and R-M-2 zones and generally do not account for the City’s higher-density zones and
commercial zones. Moreover, the City seems to use capacity assump�ons in Table 62 that are higher than Table 59. The element should validate capacity assump�ons in both tables.

Lastly, the element assumes 55 percent capacity for
nonresiden�al zones. While this capacity assump�on is
conserva�ve, the element provides no support for these
assump�ons. For example, the element could examine all
development ac�vity within the nonresiden�al zones, assess how o�en residen�al development occurs, and then adjust the calcula�on of residen�al capacity along with relevant policies, and programs. Moreover, the element should commit to a mid- cycle assessment of residen�al development in zones that allow 100 percent nonresiden�al usage and make adjustments, as appropriate, to capacity assump�ons. Based on observable trends, the City may need to iden�fy addi�onal sites to meet the RHNA.

Added more comparison to pipeline and
development trend projects to jus�fy the
realis�c allowable density. Including examples
of allowable densi�es in diﬀerent zones.

Addi�onal sec�on was added to discuss the
likelihood of residen�al uses developing in
nonresiden�al zones. This includes a new table
with all residen�al uses developed in
nonresiden�al zones over the past 5 years.

We have added a mid-cycle assessment of
residen�al development in zones that allow
100 percent nonresiden�al usage to Program

9.3, as well as a commitment to recalculate
capacity assump�ons and rezone land, as
appropriate, should any shor�all occur. B3.3 Suitability of Nonvacant Sites: The element must include an analysis demonstra�ng the poten�al for redevelopment of nonvacant sites. The analysis shall consider factors including the extent to which exis�ng uses may cons�tute an impediment to addi�onal residen�al development, the City’s past experience with conver�ng exis�ng uses to higher density residen�al development, the current market demand for the exis�ng use, an analysis of any exis�ng leases or other contracts that would perpetuate the exis�ng use or prevent redevelopment of the site for addi�onal residen�al development, development trends, market condi�ons, and regulatory or other incen�ves or
standards to encourage addi�onal residen�al development on these sites. For example, the element lists various factors (e.g., age of structure, improvement to land value ra�o, and FAR) to indicate the poten�al for redevelopment in the planning period; however, the element should evaluate development trends or provide recent experience in redevelopment of structures based on those factors.

Addi�onal sec�on included that details the site
selec�on criteria for nonvacant sites. This
includes addi�onal analysis on all nonvacant
sites selected for the sites inventory and which
criteria they meet.

We have added Program 2.6 commi�ng the
City to adopt incen�ves to encourage
redevelopment of nonvacant sites.

Visalia 2023-2031 Housing Element Update HCD Comment Matrix Response to October 23, 2023, Comment Leter
Please note: Page numbers reference the track change version, which is required by HCD. 4 November 2023
# HCD Comment Project Team Response
B3.4 City-Owned Sites: The element should analyze the suitability and availability of City-Owned sites to meet the RHNA in the planning period. The analysis should discuss the status, an�cipated steps for development including disposi�on, any known barriers to development and other relevant factors to development in the planning period. Based on a complete analysis, the element should add or modify programs to comply with the Surplus Land Act, commit to numerical objec�ves, including aﬀordability, aligned with assump�ons in the
inventory, and a schedule of ac�ons to facilitate development. A schedule of ac�ons may include coordina�on with appropriate en��es, including poten�al developers, disposi�on of the land, zoning, funding, facilita�ng other en�tlements and issuing permits. Lastly, the program should iden�fy and make
alterna�ve sites with zoning of equivalent capacity and density by a speciﬁed date if sites are not made available by a date early in the planning period.

City of Visalia to provide the status of these
sites.

We had added Program 1.6 addressing City-
owned Sites and compliance with the Surplus
Land Act
B3.5 Large Sites: While the element states large sites will only use ten acres of buildable acreage to accommodate lower-income
RHNA, it must s�ll provide analysis regarding the development of housing for lower-income households on large sites where the acreage of the parcel exceeds ten acres. Absent suﬃcient evidence that sites of equivalent size with aﬀordability were successfully developed during the planning prior planning period or other evidence that demonstrates the suitability of these sites, the large sites are deemed inadequate to accommodate housing for lower-income households. For example, the element should describe the characteris�cs of an�cipated development on iden�ﬁed large sites, including opportuni�es and �ming for speciﬁc-plan development, further subdivision, parceling, site planning or other methods to facilitate appropriately sized sites that encourage the development of housing aﬀordable to lower- income households. Based on the outcomes of this analysis, the element should add or modify programs.

Addi�onal sec�on and analysis added for all
sites over 10 acres and their intended uses.

We have revised Program 3.17 to include
incen�ves to encourage the development of
Large Sites.

B3.6 Infrastructure Availability: The element should clarify if there is suﬃcient infrastructure capacity to accommodate the RHNA. In addi�on, if the City is dependent on the expansion of a water treatment facility to accommodate the RHNA, the element must include a program commi�ng to ac�ons and a �meline to make suﬃcient infrastructure available to accommodate the RHNA.

Added clarifying statement about
infrastructure and RHNA capacity.

Visalia 2023-2031 Housing Element Update HCD Comment Matrix Response to October 23, 2023, Comment Leter
Please note: Page numbers reference the track change version, which is required by HCD.

November 2023 5
# HCD Comment Project Team Response
B3.7 Annexa�on Required to Accommodate RHNA: If the City must rely on annexa�on to accommodate its regional housing need, the element must include a program commi�ng to comple�ng the annexa�on. In addi�on, the element must also include an evalua�on of the suitability of the annexed sites, including the following informa�on:
•consistency with LAFCO policies;
•ac�ons to pre-zone prior to annexa�on;
•descrip�ons of the zone, density, development standards and design requirements;
•the an�cipated housing capacity allowed by each site;
•�meline to complete annexa�on which is early enough in the planning period to facilitate development of annexed sites (e.g., within the ﬁrst two years of the planning period);
•analysis of the suitability and availability of sites including iden�ﬁca�on of any known barriers to development in the planning period such as conserva�on easements or condi�ons under Williamson Act contracts; and
•if necessary, demonstrate compliance with the requirements of the adequate sites program requirements of Government Code sec�on 65583.2, subdivisions(h)and (i).

Instead of relying upon annexa�on, the City may u�lize other sites within exis�ng City boundaries. For example, nonvacant sites or exis�ng nonresiden�al zoned sites within the current City boundaries could be re-zoned to appropriate residen�al zoning designa�ons and densi�es to accommodate the regional housing need. Or exis�ng residen�al zoned sites within the current City boundaries could be re-zoned to residen�al zoning designa�ons with higher densi�es to accommodate the regional housing need. If choosing these alterna�ves, the element must describe the suitability of these sites and include programs commi�ng to comple�ng the rezoning early in the planning period (e.g., within three years of the beginning of the planning period). For addi�onal informa�on, see the Building Blocks at htps://www.hcd.ca.gov/planning-and-community-
development/housing-elements/building-blocks/inventory-of- land-suitable.

We have added the required informa�on to the
discussion of Annexa�on Sites. Please see
pages 185 and 186.

We have added Program 1.7 to address
annexa�ons. The program details the
remaining steps in the annexa�on process and
commits the City to zone appropriate acreage
within lower income annexa�on sites in
compliance with Government Code sec�on
65583.2(h) and (i).

B3.8 Previously Iden�ﬁed Nonvacant and Vacant Sites: If nonvacant sites iden�ﬁed in a prior adopted housing element or vacant sites iden�ﬁed in two or more consecu�ve planning periods, the sites are inadequate to accommodate housing for lower-income households unless:
•The site’s current zoning is appropriate for the development of housing aﬀordable to lower-income households by either
including analysis or mee�ng the appropriate density and

•The site is subject to a housing element program that requires rezoning within three years of the beginning of the planning period to allow residen�al use by right for housing
developments in which at least 20 percent of the units are aﬀordable to lower-income households. (Gov. Code, § 65583.2, subd. (c).)

We have added the appropriate language to
Program 1.1.

Visalia 2023-2031 Housing Element Update HCD Comment Matrix Response to October 23, 2023, Comment Leter
Please note: Page numbers reference the track change version, which is required by HCD. 6 November 2023
# HCD Comment Project Team Response
B3.9 Environmental Constraints: While the element generally describes poten�al environmental constraints, it must s�ll describe any other known environmental or other condi�ons that could impact housing development on iden�ﬁed sites in the planning period (e.g., shape, access, contamina�on, easements, condi�ons, compa�bility).

Sec�on added on environmental constraints on
the Sites Inventory sites.

B3.10 Electronic Sites Inventory: For your informa�on, pursuant to Government Code sec�on 65583.3, the City must submit an electronic sites inventory with its adopted housing element. The City must u�lize standards, forms, and deﬁni�ons adopted by HCD. Please see HCD’s housing element webpage at
htps://www.hcd.ca.gov/community-development/housing-
element/index.shtml#element for a copy of the form and
instruc�ons. The City can reach out to HCD at
[email protected] for technical assistance.

Noted. We will provide the form with our next
submission.

B3.11 •Emergency Shelters: The element should clarify whether emergency shelters are permited without discre�onary ac�on, discuss status (vacant vs nonvacant)and reuse or redevelopment opportuni�es, proximity to services, and list and evaluate development standards and capacity as poten�al constraints. In addi�on, the element must comply with the requirements of Chapter 654,Statues of 2022 (AB 2339). For more informa�on, please see HCD’s guidance at
htps://www.hcd.ca.gov/sites/default/ﬁles/docs/planning-and- community/ab2339-no�ce.pdf.

We have revised the analysis of emergency
shelters beginning on page 89. The analysis
includes ﬁndings/standards required of
emergency shelters and iden�ﬁes constraints
within them. We have also added an analysis of
compliance with AB 2339.

We have added ac�ons to Program 5.2
commi�ng the City to upda�ng the zoning
code for compliance with AB 2339.

B3.12 •Low Barrier Navigation Centers (LBNC): LBNC’s shall be a use by-right in zones where mul�family and mixed uses are
permited, including non-residen�al zones permi�ng
mul�family uses pursuant to Government Code sec�on 65660.

While the element provides informa�on on how LBNC’s are allowed, the City condi�onal use permit (CUP) requirement in non-residen�al zones is not incompliance with state law; therefore, the City must add a program as appropriate.

We have revised our analysis to iden�fy this
constraint (see page 93).

We have also added an ac�on to Program 5.8
commi�ng the City to allows LBNCs by right
(without condi�onal use or other discre�onary
permit) in nonresiden�al zones permi�ng
residen�al uses.

B4.1 Land Use Controls: The element must iden�fy and analyze the impact of all relevant land use controls as poten�al constraints on a variety of housing types in all zones that allow residen�al uses, including commercial zones open to residen�al uses. The analysis should address any impacts on cost, supply, housing choice, feasibility, �ming, approval certainty, and ability to achieve maximum densi�es and include programs to address iden�ﬁed constraints. Speciﬁcally, the element should analyze minimum lot size, and height requirements in mul�family, commercial, and mixed-use zones. For example, in the R-M-3 zone, minimum lot requirements require a two-acre minimum.

Requiring such a large lot size could pose a constraint on mul�family development. Lastly, the element should evaluate current parking standards (p. 101) as a constraint and include a program to mi�gate the constraint.

We have added cumula�ve analyses of
development standards by zone type,
beginning on pages 104-105. We have
iden�ﬁed the lot size requirement for the R-M
zones as a constraint within the analysis, and
have added an ac�on to Program 5.8
commi�ng the City to revise the zoning code
in response to this constraint.

Related to parking: We have iden�ﬁed parking
requirements as a constraint to the
development of studios, 1-bedroom units, and
aﬀordable mf housing (see pages 106-107).

Program 5.8 commits the City to upda�ng
parking requirements for these housing types
to no more than one space per unit.

Visalia 2023-2031 Housing Element Update HCD Comment Matrix Response to October 23, 2023, Comment Leter
Please note: Page numbers reference the track change version, which is required by HCD.

November 2023 7
# HCD Comment Project Team Response
B4.2 Local Processing and Permit Procedures: While the element outlines decision-making criteria and oﬀers a general overview of processing �meframes, it should describe and analyze processing �mes and the procedures for a typical single-family and mul�family development that is consistent with zoning. The analysis should address the approval body, the number of public hearings, if any, approval ﬁndings, and any other relevant informa�on. In addi�on, the analysis should address impacts on housing cost, supply, �ming, and approval certainty.

The required data is provided in tables 48 and

49. We have added an analysis of this data to
page 117 under the heading “Typical
Processing Times”
B4.3 In addi�on, the element indicates mul�family development in zones permi�ng mul�family development require a CUP for projects greater than 80 units. The element must analyze the CUP process as a poten�al constraint on housing supply and aﬀordability. The analysis should iden�fy ﬁndings of approval for the CUP and their poten�al impact on development approval certainty, �ming, and cost. The element must demonstrate this process is not a constraint or it must include a program to address and remove or mi�gate the CUP requirement. For
addi�onal informa�on, see the Building Blocks at
htps://www.hcd.ca.gov/planning-and-community-
development/housing-elements/building-blocks/processing- and-permi�ng-procedures.

We have included a program ac�on commi�ng
the City to raising the CUP threshold to 200.

Please see Program 1.3. We brought this to the
aten�on of HCD during a Zoom mee�ng on
November 9, 2023, and HCD staﬀ informally
indicated that this ac�on suﬃciently addresses
this comment.

B4.4 In addi�on, the element should clarify how approval certainty is facilitated for residen�al projects in the OC and CMU zones.

Currently, the element men�ons projects in these zones are evaluated on a per-project basis in the absence of development standards (p. 85).

We have revised the analysis of zoning for
mul�family housing types beginning on page

86. B4.5 Finally, the element should discuss compliance with the Permit Streamlining Act and intersec�ons with CEQA and �ming
requirements, including streamlining determina�ons and add or modify programs as appropriate.

We have added a discussion of compliance
with the Permit Streamlining Ac�on and CEQA
�ming requirements to page 118.

We have also added Program 5.11 commi�ng
the City to adopt a process that ensures
compliance with the Permit Streamlining
Ac�on and CEQA �ming requirements.

B4.6 Fees and Exac�on: The element should describe and analyze fees as a propor�on of the development costs for both single- family and mul�family housing. Based on the outcomes of the analysis, the element should include programs to address iden�ﬁed constraints.

We have added the required analysis under the
heading Development Fees and other Exac�ons
on page 121.

B4.7 Housing for Persons with Disabili�es (Reasonable
Accommoda�on): The element describes the City currently has a procedure for reques�ng and gran�ng reasonable
accommoda�on for persons with disabili�es; however, the element should also describe approval ﬁndings and the process for providing reasonable accommoda�ons.

We have updated the analysis of reasonable
accommoda�on on pages 124 and 125. In
response to poten�al constraints, we have
revised Program 5.8 to include commitment to
amending the Municipal Code to provide a
ministerial process for approving reasonable
accommoda�on requests, including objec�ve
ﬁndings for approval.

B4.8 Zoning and Fees Transparency: The element must clarify its compliance with new transparency requirements for pos�ng all zoning, development standards, and fees for each parcel on the jurisdic�on’s website pursuant to Government Code sec�on 65940.1(a)(1)((A) and (B)).

We have added text clarifying compliance
under the heading “Zoning and Fees
Transparency” on page 124.

Visalia 2023-2031 Housing Element Update HCD Comment Matrix Response to October 23, 2023, Comment Leter
Please note: Page numbers reference the track change version, which is required by HCD. 8 November 2023
# HCD Comment Project Team Response
B5.1 Permit Times and Request for Lesser Densi�es: The element must include analysis of requests to develop housing at densi�es below those iden�ﬁed in the site inventory; and the length of �me between receiving approval for a housing development and submital of an applica�on for building permits. The element must address any hinderance on the development of housing and include programs as appropriate.

We have included required analyses under the
heading “Requests to Develop Below Iden�ﬁed
Densi�es and Approval Times” on page 132.

C1.1 To have a beneﬁcial impact in the planning period and achieve the goals and objec�ves of the housing element, programs must have discrete �ming (e.g., at least annually or by 2025) and speciﬁc commitment to housing outcomes and refrain from language such as “explore” while also having discrete �ming (e.g., at least annually or by January 2024). The following programs should be revised:
•Program 1.3: Condi�onal Use Permit Process
•Program 1.4: Housing Educa�on
•Program 2.5: Incen�ves for Inﬁll Aﬀordable Housing
•Program 3.2: Mul�ple Family Developments
•Program 3.11: City Incen�ves for Aﬀordable Housing
•Program 3.15: Promo�ng Accessory Dwelling Units
•Program 3.17: Planning for Large Sites
•Program 5.9: Special Needs Housing Outreach and Incen�ves •Program 7.2: Socio-economic Segrega�on and Concentra�ons of Low Resources Areas
•Program 7.3 Improve Place-Based Strategies
We have revised each of these programs to
include addi�onal details and objec�ves, as
appropriate.

C2.1 As noted in Finding B3, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shor�all of sites or zoning available to encourage a variety of housing types.

We have added rezone requirements related to
previously iden�ﬁed lower income vacant and
nonvacant sites to Program 1.1.

C2.2 As a reminder, the element must be revised to include a program to comply with the requirements of the Surplus Land Act. Program goals and objec�ves must commit to numerical objec�ves, including aﬀordability, aligned with assump�ons in the inventory, and a schedule of ac�ons to facilitate
development. In addi�on, programs to facilitate large lot development must be included. For example, the element can include programs to facilitate and incen�vize lot splits.

We have added Program 1.6 to address
compliance with the Surplus Land Act.

We have revised Program 3.17 (Large Sites), to
provide addi�onal ac�ons facilita�ng large lot
development.

C3.1 In Visalia, 18 percent of renter households are considered overcrowded. While proposed policy and program ac�ons
support larger unit types, program metrics, and objec�ves should be enhanced commensurate with the need. For example, Program5.6 can go beyond facilita�ng the construc�on of 16 units per year.

We have increased the objec�ves related to
large households under Program 5.6 (in
combina�on with Program 5.9).

C4.1 As noted in Findings B4 and B5, the element requires a complete analysis of poten�al governmental and nongovernmental
constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mi�gate any iden�ﬁed constraints.

Noted.

C4.2 In addi�on, Program 1.3 (Condi�onal Use Permit Process) should be revised to eliminate replace or modify the CUP requirement for projects above 80 units. While the element commits to reviewing this process on an annual basis, CUP processes aﬀect the cost and �ming of aﬀordable projects and therefore should be treated as a constraint to housing.

No change necessary. We’ve raised the
threshold to 200 and HCD has informally
approved this ac�on.

Visalia 2023-2031 Housing Element Update HCD Comment Matrix Response to October 23, 2023, Comment Leter
Please note: Page numbers reference the track change version, which is required by HCD.

November 2023 9
# HCD Comment Project Team Response
C5.1 As noted in Finding B1, the element must include a complete analysis of AFFH. The element must be revised to add goals and ac�ons based on the outcomes of a complete analysis, including lis�ng and priori�za�on of contribu�ng factors to fair housing issues. Goals and ac�ons must signiﬁcantly seek to overcome contribu�ng factors to fair housing issues and must include quan�ﬁable metrics and milestones for evalua�ng progress on programs, ac�ons, and fair housing results. Goals and ac�ons must speciﬁcally respond to the analysis and to the iden�ﬁed and priori�zed contribu�ng factors to fair housing issues and must be signiﬁcant and meaningful enough to overcome
iden�ﬁed paterns and trends. Ac�ons must have speciﬁc
commitment, milestones, geographic targe�ng and metrics or numeric objec�ves and, as appropriate, must address housing mobility enhancement, new housing choices and aﬀordability in higher opportunity areas, place-based strategies for community preserva�on and revitaliza�on and displacement protec�on.

Noted.

We have added Program 2.7 to promote and
encourage missing middle housing and housing
mobility.

New Housing Choices and Aﬀordability in
higher opportunity areas: see Programs 3.2,

3.6, 3.10, 3.11, and 3.17.

Place-Based Strategies for Revitaliza�on:
emphasized in Programs 7.2 and 7.3.

Displacement: we have added an ac�on to
Program 7.1 commi�ng the City to adop�ng
an an�-displacement strategy.

C6.1 Program 5.8 (Municipal Code Updates): Accessory Dwelling Units (ADU) must be permited in all zones that allow residen�al uses. In addi�on, and in the interim, un�l the City adopts an ADU ordinance compliant with state law, the element should commit to defer to state ADU and Junior Accessory Dwelling Unit (JADU) laws.

We have added the required language to
Program 5.8.

D1.1 As a reminder, public par�cipa�on in the development, adop�on, and implementa�on of the housing element is
essen�al to eﬀec�ve housing planning. Throughout the housing element process, the City must con�nue to engage the
community, including organiza�ons that represent lower-income and special-needs households, by making informa�on regularly available and considering and incorpora�ng comments where appropriate. Moreover, the City’s considera�on of public comment shall not be restricted by the ﬁndings in this review.

Lastly, the element must be revised to include how feedback was considered and incorporated into the dra� element following the City’s second community workshop.

Noted.

We will con�nue to seek and incorporate input
from residents, stakeholders, and organiza�ons
that represent lower-income and special needs
households.

We have updated the public input summary in
the Introduc�on to include a descrip�on of
how feedback from Workshop #2 was
incorporated into the Housing Element. Please
see page 24.

Visalia City CouncilDecember 18, 2023

Visalia City Council
December 18, 2023