Town Council
January 31, 2023

The following documents, revised per comments from HCD as discussed by Council, are attached for Council authorization to resubmit to HCD after Council approval of a method for meeting the RHNA as set forth in Tables 3-5 and Appendix G-1 (referred to as RHNA Plan):

1. Revised Response to Comments Memorandum (see Attachment C).

2. Revised Section 1.0 Introduction section (Attachment D).

3. Revised Section 3.0 Housing Element (Attachment E).

4. Revised Appendix F- Housing Development Constraints and Zoning Analysis (Attachment F).

5. Revised Appendix G – Adequate Sites Analysis (Attachment G).

6. Revised Appendix H – Public Engagement
In addition, all of the previously approved and unchanged appendices to the Housing Element will be resubmitted to HCD as supporting documents. The appendices are available on the Town website at the following link:
https://www.woodsidetown.org/sites/default/files/fileattachments/planning/page/33617/woodsi de_housing_element_appendices_rev._7-16-22.pdf . Further revisions will be required for Section 3.0 Housing Element and Appendix G Adequate Sites Inventory after Council provides direction on January 31st regarding whether to include Town owned sites in the RHNA Plan.

The areas requiring further revisions in these two documents are highlighted.

Discussion/Analysis
The purpose of this report is to focus on the remaining key policy areas including the following:
• ADU annual production proposal.
• Rezoning density.
• Inclusion of Town-owned High Road and Raymundo/Runnymede sites for housing. • Zoning for a variety of housing types.
• Affirmatively furthering fair housing.

ADU Production
The first draft of the Housing Element submitted to HCD in July, and the recent discussion draft submitted in early January, assumed annual production of 20 ADUs that were distributed across income categories per the Association of Bay Area Governments (ABAG) Technical Memorandum “Using ADUs to Satisfy RHNA”. The historic average of ADU production in recent years is 15 ADUs annually which is considered a “safe harbor” by HCD. This means a future production assumption based on prior experience should be sufficient for HCD to accept the future production assumption in the RHNA Plan. Since the initial future production assumption (20 units annually) was higher than the past experience (15 units annually), policies were added to the January Draft Housing Element submittal to monitor actual production and, if the annual production goal is not met after two years following adoption of the Element, to “review measures to increase production”. Based upon the two January discussions with HCD, the monitoring policy is appropriate but not sufficient, and should be supplemented with a firmer commitment to on-going ADU affordability such as deed restrictions placed on ADUs when they are approved.

Item A Page 4 Town Council Special Meeting January 31, 2023

The Council discussed deed restrictions at the January 10th meeting and concern was expressed about this approach. However, there was not a consensus of the Council about an acceptable ADU production assumption. Support was expressed for the higher 20-unit rate assumption if it meant Town-owned sites did not have to be added back in to the RHNA Plan, while others preferred a lower 15-unit rate to avoid imposing deed restrictions. Council direction on this assumption is required to complete the RHNA Plan for resubmittal to HCD. The advantages and disadvantages of each option are as follows:
15 ADU Assumption Advantages
• 15 units is within safe harbor production rate based on prior experience. • This rate is less likely to require deed restrictions or other monitoring and enforcement programs.
• This rate is most likely to be approved by HCD.
15 ADU Assumption Disadvantages
• The 15-unit rate lowers the number of affordable units in the RHNA Plan, requiring at least one Town site be added back into the Plan to achieve the affordability requirements.
20 ADU Assumption Advantages
• The 20-unit rate potentially allows removal of Town-owned sites from the RHNA Plan if HCD is convinced the higher production rate can be realized to meet the balance of needed affordable units above what is projected at Cañada College and 773 Cañada Road.
20 ADU Assumption Disadvantages
• The 20-unit rate exceeds the safe harbor based on historical production. • This rate will likely require deed restrictions and/or other affordability monitoring and enforcement mechanisms to be approved by HCD.
• This rate still may not be sufficient for HCD, even with deed restrictions, due to a lack of variety of housing types.

Alternative ADU production rates are further explored in the RHNA Plan options in the section “Town Sites for Rezoning and RHNA Plan Options” below. There was also Council discussion of different ADU production rates (16 through 19 units annually) at the January 10th meeting.

This alternative is explored as part of Option 2b, below. It is worth noting that, it the ADU projection exceeds the safe harbor rate of 15 units per year by any amount, HCD will likely look for a deed restriction program and/or other measures to ensure the affordability of those units.

Rezoning Density
The Town-owned sites and the privately-owned 773 Cañada Road site were proposed by staff to be rezoned to a higher density of 20 dwelling units per acre (du/ac) to meet the RHNA requirement, and to meet the default definition of affordable housing zoning set forth in State law. In a prior discussion in mid-2022, Council directed the sites be rezoned at 10 units per acre, and this density was included in the Table 3-5 Proposed RHNA Plan sites inventory that was submitted to HCD as part of the first HCD Housing Element review in July 2022. Per the comments made by HCD in its review letter, it is recommended to reconsider a density of 20 du/ac for the following reasons:

Item A Page 5 Town Council Special Meeting January 31, 2023

• Accessory Dwelling Unit (ADU) Reliance - The Woodside RHNA is a total of 328 units for all income categories, of which 142 or 43% are very low and low income (collectively referred to as lower income). Per Table 3-5, Woodside proposes to meet 67% (96 units) of the lower income allocation through ADU production. The HCD comments on ADU production (Page 7 of HCD letter) reflect reservations about whether this level of ADU production can be accomplished, and asks for commitments, including rezoning of parcels, if ADU targets are not met. Establishing rezoning with 20 du/ac allows the ADU production rate to be lowered to the historic 15 ADUs experience that may be more acceptable to HCD.
• Default Density- State law (Government Code Section 65583.2) states zoning for suburban jurisdictions (which Woodside is defined as by law) of at least 20 du/ac is appropriate to create housing affordable to lower income households and can be used to satisfy RHNA requirements for these income categories.
• Lower Density Justification – HCD commented on the Town’s proposed lower income rezoning (Page 6) at 10 du/ac stating the Housing Element does not support the lower density assumptions per the analysis required by State law (Government Code Section 65583.2(c)(3) (B). This code section provides a jurisdiction can either zone at the minimum density required to assume lower income affordability (20 du/ac), or “Provide an analysis demonstrating how the adopted densities accommodate this need. The analysis shall include, but is not limited to, factors such as market demand, financial feasibility, or information based on development project experience within a zone or zones that provide housing for lower income households.” As HCD points out, this analysis has not been provided to justify the 10 du/ac rezoning density. To comply, an analysis would need to be undertaken that demonstrates why there is not market demand for more affordable housing at the increased density, why it is financially infeasible to create affordable housing with higher density, and provide development project experience within a zone that supports lower income housing (e.g., the multifamily zone for Cañada College). This analysis would be unlikely to support the lower density of 10 du/ac. Increasing the rezoning to 20 du/ac eliminates the need for this difficult analysis.

The options discussed in the RHNA Plan Options section assume 20 du/ac, as the higher density meets the default standard and allows potentially one Town site to be included in the RHNA instead of two if the lower 15-unit annual ADU production assumption is used.

Council direction is needed on this item to plan on rezoning at 10 or 20 units per acre for the Response to Comments Memorandum and the Housing Element revisions.

Town Sites for Rezoning and RHNA Plan Options
HCD Response to Removal of Town-Owned Sites
The Housing Element is required to list sites that can be developed for housing to meet the RHNA. Four sites were previously considered and included in the draft Housing Element submitted in July 2022, consisting of one privately-owned site at 773 Cañada, and three TownItem A Page 6 Town Council Special Meeting January 31, 2023

owned sites at Farm Hill Road, High Road, and Raymundo Drive (previously referred to as Runnymede). The Town-owned sites were considered for rezoning for higher density housing and developed by a non-profit affordable housing developer such as Habitat for Humanity, pursuant to the Surplus Land Act (SLA) disposition process. All three Town-owned sites were included in the Table 3-5 Proposed RHNA Plan in the initial July 2022 draft element submitted to HCD for review.

At the Council update meeting in December 2022, the Town-owned sites were discussed by Council and testimony was received from the public, including nearby residents. The Council decided to remove the Farm Hill Road site from the Plan due to an open space covenant affecting the site. The Council also directed staff to discuss with HCD the prospect of removing the other two Town-owned sites and relying on the planned units for Cañada College, 773 Cañada Road, and ADUs for RHNA compliance. On January 10, 2023, the Council heard a report from staff on two meetings held with HCD in early January. HCD commented that removing all Town-owned sites from the Plan would be problematic for HCD certification of the Housing Element, as it would result in a lack of diversity of housing types, and an overreliance on ADUs. The Council asked staff to outline options in light of this feedback from HCD, and to provide a discussion of pros and cons for each option.

Staff has identified three fundamental approaches that the Council can take in structuring the RHNA Plan to be incorporated in the next draft Housing Element to be submitted to HCD: 1) include no Town-owned sites and continue to pursue higher ADU production to meet RHNA; 2) structure the RHNA Plan so High Road is the only Town-owned site included; or 3) structure the RHNA Plan so that Raymundo Drive is the only Town-owned site included. These approaches are analyzed as options below. Although not included as one of the options analyzed below, the Council also has the fourth option of including both the High Road and Raymundo Drive sites in the RHNA Plan, which would result in an excess of projected housing at each affordability level.

Options for RHNA Plan
Option 1 – No Town Sites/ Higher ADU Production
Assumptions:
• No Town-owned sites.
• 20 du/ac rezone for privately owned 773 Cañada.
• 20 ADUs annual production rate with a deed restriction program and/or other affordability monitoring and enforcement mechanisms.

Item A Page 7 Town Council Special Meeting January 31, 2023

Table 1. RHNA Plan Option 1 – No Town-Owned Sites and 20 ADUs Annually Low and
Very Low
Income
Moderate
Income
Above
Moderate
Income Total
Current Zoning Sites
Vacant Single-Family Sites 106 106
Non-Vacant Single-Family sites 46 46
Pipeline Projects 4 4
Cañada College 75 75
ADUs @ 20 annually 96 48 16 160
Rezoning Sites
773 Cañada Site @ 20 du/ac 16 11 27
Total 171 64 183 418
RHNA Allocation - Base 142 52 134 328
RHNA Buffer @ 20% 28 10 27 65
Total RHNA + Buffer 170 62 161 393
Surplus/Deficit +1 +2 +22 +25
Advantages:
• Addresses concerns regarding utilizing Town-owned sites. • Spreads added density throughout the Town.

Disadvantages:
• ADU rate exceeds safe harbor prior production rates, which HCD may not accept as a feasible projection.
• Likely to require an ADU deed restriction program and/or other monitoring and enforcement mechanisms to gain approval by HCD.
• Affordability monitoring and enforcement programs may deter applications for ADUs, lowering actual production rate.
• HCD may require the Town to designate one or more of the Town-owned sites for midcycle rezoning during Cycle 6 if ADU production falls below the projection. • Does not respond to HCD comment to have a variety of housing types.

Option 2 - Include High Road Town Site
Because High Road is only 1.1 acres, it will not yield the units needed to meet the RHNA requirements at a density of 20 du/ac if the ADU projection is reduced to the safe harbor rate of 15 units per year. Therefore, to meet RHNA utilizing High Road alone (i.e., without also including Raymundo), its density would either need to be increased to 33 du/ac (Option 2a) or the ADU projection must be set at 17.5 units per year (Option 2b).

Item A Page 8 Town Council Special Meeting January 31, 2023

Option 2a – High Road to be Zoned at 33 Units per Acre; 15 ADUs per year Assumptions:
• Include High Road Site rezoned at 33 du/ac for disposition to a non-profit developer. • Rezone 773 Cañada at 20 du/ac.
• Assume 15 ADUs annually – deed restriction program unlikely.

Table 2a. RHNA Plan Option 2 - High Road Site and 15 ADUs Annually Low and
Very Low
Income
Moderate
Income
Above
Moderate
Income Total
Current Zoning Sites
Vacant Single-Family Sites 106 106
Non-Vacant Single-Family sites 46 46
Pipeline Projects 4 4
Cañada College 75 75
ADUs 72 36 12 120
Rezoning Site
773 Cañada Site 16 11 27
High Road @ 33 units/acre 23 10 33
Total 170 62 179 411
RHNA Allocation - Base 142 52 134 328
RHNA Buffer @ 20% 28 10 27 65
Total RHNA + Buffer 170 62 161 393
Surplus/Deficit None None +18 +18
Advantages:
• Includes one Town-owned site instead of two.
• Assumes ADU production rate equal to historic safe harbor production rate. • May not require deed restrictions for ADUs.
• Lower ADU rate and absence of deed restrictions make actual production more feasible. • Responds to HCD comment to include a variety of housing types.

Disadvantages:
• Requires use of a Town-owned site.
• Requires the site to be zoned for even higher density than the “default” of 20 du/ac. • Likely requires multi-family development form (e.g., condominiums or supportive housing).
• Site is physically constrained by parcel shape, topography, drainage, and soil conditions Item A Page 9 Town Council Special Meeting January 31, 2023

Option 2b – High Road to be Zoned at 20 Units per Acre; 17.5 ADUs per year Assumptions:
• Include High Road Site rezoned at 20 du/ac for disposition to a non-profit developer. • Rezone 773 Cañada at 20 du/ac.
• Assume 17.5 ADUs annually – deed restriction program and/or other monitoring and enforcement measures likely to be required.

Table 2b. RHNA Plan Option 2 - High Road Site and 17.5 ADUs Annually Low and
Very Low
Income
Moderate
Income
Above
Moderate
Income Total
Current Zoning Sites
Vacant Single-Family Sites 106 106
Non-Vacant Single-Family sites 46 46
Pipeline Projects 4 4
Cañada College 75 75
ADUs 84 42 14 140
Rezoning Site
773 Cañada Site 16 11 27
High Road @ 20 units/acre 16 4 20
Total 175 62 181 418
RHNA Allocation - Base 142 52 134 328
RHNA Buffer @ 20% 28 10 27 65
Total RHNA + Buffer 170 62 161 393
Surplus/Deficit +5 None +20 +25
Advantages:
• Includes one Town-owned site instead of two.
• The assumed rate of 17.5 ADUs per year exceeds the safe harbor rate by only 2.5 units per year, and thus is more likely to gain approval from HCD than the higher rate proposed under Option 1, above.
• Responds to HCD comment to include a variety of housing types.

Disadvantages:
• Requires use of a Town-owned site.
• HCD would likely require a deed restriction program and/or other monitoring and enforcement programs to ensure ADU affordability.

Item A Page 10 Town Council Special Meeting January 31, 2023

• HCD may require that the Raymundo Drive site be designated for mid-cycle rezoning in the event ADU production fails to meet the projection.
• Likely requires multi-family development form (e.g., condominiums or supportive housing).
• Site is physically constrained by parcel shape, topography, drainage, and soil conditions.

Under either Option 2a or 2b, the Council could adopt a program to rezone the High Road site for multi-family development (MFRD zone) with a requirement that the sale of the parcel be for an ownership condominium housing project. The developer and type of housing would be controlled through the Purchase and Sale Agreement between the Town and a non-profit developer.

Option 3 – Include the Raymundo Drive Town-Owned Site and Project 15 ADUs Per Year Assumptions:
• Include and rezone Raymundo Drive site at 20 du/ac.
• Rezone 773 Cañada at 20 du/ac.
• Assume 15 ADUs annually – deed restrictions and/or other affordability monitoring and enforcement programs unlikely.

Table 3 RHNA Plan Option 3 – Raymundo Site and 15 ADUs Annually Low and
Very Low
Income
Moderate
Income
Above
Moderate
Income Total
Current Zoning Sites
Vacant Single-Family Sites 106 106
Non-Vacant Single-Family sites 46 46
Pipeline Projects 4 4
Cañada College 75 75
ADUs 72 36 12 120
Rezoning Sites
773 Cañada Site @ 20 du/ac 16 11 27
Raymundo Drive @ 20 units/acre 23 10 33
Total 170 62 179 411
RHNA Allocation - Base 142 52 134 328
RHNA Buffer @ 20% 28 10 27 65
Total RHNA + Buffer 170 62 161 393
Surplus/Deficit None None +18 +18
Item A Page 11 Town Council Special Meeting January 31, 2023

Advantages:
• Includes one Town-owned site instead of two.
• Allows ADU production rate to equal historic safe harbor production rate. • May not require a deed restriction program or other affordability monitoring and enforcement mechanisms for ADUs.
• Lower ADU rate and absence of deed restrictions make actual ADU production more feasible.
• Responds to HCD comment to include a variety of housing types. • The size of the Raymundo site would allow it to be developed as ownership small parcel single-family residences (see Figure 1).

Disadvantages:
• Requires rezoning and disposition of a Town-owned site. • Seismic conditions are a potential constraint.
• Sewer improvements are required at an estimated cost of $2.6 million. • Parcel is close to other affordable housing sites (773 Cañada and Cañada College).

Figure 1. Example of Small Lot Single Family Homes at 20 Units per Acre • Lot sizes = 2,200 square feet.
• Ownership single-family units.
• 1,995 square-foot home with 3 bedrooms.
• 1,400 square-foot footprint.
• 800 square-feet of yards and setbacks.
• Down payment assistance to reach lower income – HEART and County programs. • Affordable to Lower-income = $93,000 (Very Low) to $149,000 (Low), 4 persons. • Affordable for teachers, public safety employees, Town employees, private service workers.

Item A Page 12 Town Council Special Meeting January 31, 2023

For this option the Council could adopt a program to rezone the Raymundo site for higher density (20 du/ac) single-family zoning with a requirement that the sale of the parcel be for an ownership small lot single-family housing project. The developer and type of housing would be controlled through the Purchase and Sale Agreement between the Town and a non-profit developer.

Council direction is needed on this item to select one of the options for the Response to Comments Memorandum and the Housing Element revisions.

Zoning for a Variety of Housing Types
As discussed in the Baker Tilly Memorandum for the December Council meeting, page eight of the HCD Comment Letter discusses information and policies required for several categories of special housing types including emergency shelters, transitional housing, by-right permanent supportive housing, low barrier navigation centers, single room occupancy (SRO) housing, and manufactured housing. The Response to Comments Memorandum cites where existing zoning allows some of these housing types (emergency shelters, supportive housing in single family zones, and manufactured housing) and recommends the addition of a new section to the Housing Element: “Policy 4.3 - Provide for Emergency Shelter and Transitional Housing.” This new policy adds the following:

Item A Page 13 Town Council Special Meeting January 31, 2023

• Add to Policy H4.3a Emergency Shelters that shelters are a permitted use in the Community Commercial zone.
• Add a subsection allowing supportive housing and low barrier navigation centers as a by-right use, in the Multi-Family Residential District (MFRD) zone. • Add a new program to amend the Municipal Code to add SRO units as a permitted use in the Community Commercial zone.
• Add a subsection on farmworker housing providing a definition of a single-family home to include farmworker housing for up to six employees, and farmworker housing as a permitted use in all zones except MFRD (to be consistent with the Employees Housing Act- Health and Safety Code Section 17021.5).

Affirmatively Furthering Fair Housing
State law (Gov. Code, § 65583, subd. (c)(10)(A).) requires that the Housing Element include an assessment of fair housing in the jurisdiction. Fair housing is the right to choose housing free from unlawful discrimination on the basis of race, color, national origin, religion, sex, familial status, and disability. The State-mandated assessment must consider the Town’s ability to provide enforcement and its outreach capacity; analyze patterns of integration and segregation over time; identify any Racially and Ethnically Concentrated Areas of Poverty (R/ECAP) or Affluence (RCAA); discuss disparities in access to educational, environmental, and economic opportunities; and evaluate disproportionate housing needs and the risk of displacement for vulnerable groups within the community. The results of the assessment must be summarized in a matrix that prioritizes any fair housing issues identified and specifies meaningful actions the Town will take to address them together with metrics to monitor improvements over time.

Additionally, the assessment must also include an evaluation of whether build out of the housing sites inventory would improve or exacerbate any existing patterns of segregation or over-concentration.

Appendix K of the Draft Housing Element submitted to HCD included an assessment of fair housing in Woodside that addressed the legal requirements in part; however, in its comment letter of October 14, HCD requested substantial new data and analysis be incorporated in the subsequent draft. Staff and the consultant team is working to address comments received from HCD and to create the matrix prioritizing fair housing issues and meaningful actions and metrics. Direction from the Council regarding the sites to be included on the inventory is needed to complete the revised draft of Appendix K, including the matrix. It is anticipated that the assessment will identify the need for some new programs to address fair housing issues in Woodside, which are principally related to access to educational, environmental, and economic opportunities.

By way of example, like many neighboring communities in San Mateo County, Woodside is designated as a Racially Concentrated Area of Affluence (RCAA) by the State, meaning that a large majority of the population is comprised of White households earning more than $125,000 annually. This indicates a pattern of systemic socio-economic segregation, and under State law, Item A Page 14 Town Council Special Meeting January 31, 2023

the Town is required to incorporate programs into its Housing Element to help redress this pattern over time. The objective of such programs would be to affirmatively further fair housing by increasing the diversity of housing types in the community and expanding options for lower income households, a demographic disproportionately comprised of people of color.

The current draft of the Housing Element includes programs that further this objective, including programs that aim to remove barriers to ADU/JADU construction; incentivize higher density housing; and facilitate construction of other special needs housing. However, to fully respond to comments on the Draft Housing Element from HCD and ensure certification of the Housing Element, additional supportive programs will be needed to address fair housing issues identified in the analysis. One example of a supportive program that could be added would be for the Town to participate in a local Home Share program, which matches home providers with home seekers in exchange for minimal rent and/or services. Under this type of program, an older adult homeowner who is in need of assistance (transportation, cooking, housekeeping, yardwork, companionship, pet care, etc.) and has an extra available room in his/her home, could be matched with a local college student.

Based on direction from the Town Council regarding housing opportunity sites, the revised draft of Appendix K will be completed, with additional supportive programs incorporated into the matrix of fair housing issues, meaningful actions, and metrics.

CEQA Analysis
The Housing Element and the rezoning of private and public sites requires environmental review pursuant to the California Environmental Quality Act (CEQA) to examine potential environmental impacts from policies that will encourage additional housing units. As discussed in the report for the December Council meeting, a focused Environmental Impact Report (EIR) will be required instead of a Mitigated Negative Declaration (MND). This is due the estimated vehicle miles traveled (VMT) generated by the new RHNA units that will exceed the acceptable VMT threshold even with mitigations. The VMT impact is “significant and unavoidable” which precludes the use of an MND and requires an EIR instead. The EIR will be brought to the Town Council for certification at the time the Housing Element is brought back for final adoption.

Final adoption will occur after HCD completes its second formal review of the Housing Element, which will start after the Council authorizes submission of the revised Housing Element on January 31st.

Additional Revisions
During the two meetings with HCD staff in January, staff discussed other HCD recommended changes to the Housing Element besides the ADUs and Town-owned sites discussed above.

These changes will be reflected in the revised Response to Comments memorandum and Housing Element sections and are summarized as follows:
• 773 Cañada Development Constraints – additional information is added regarding the status of the existing unit on the property that will be demolished. HCD requires information on existing structures on sites identified for higher-density development, Item A Page 15 Town Council Special Meeting January 31, 2023

such as whether the unit(s) was previously occupied by a lower income household and what replacement housing measures will be taken. In addition, information is added that the existing structure does not have historical significance (see Attachment G for additional description information).
• Analysis of MFRD Multi-Family Zone- Appendix F- Housing Development Constraints and Zoning Analysis, was revised to add information about the potential constraints imposed by the development standards in the Municipal Code, per HCD’s request. This zone should be amended to allow special needs housing approvals as permitted uses (instead of current Planning Commission discretionary approval), and to increase the allowable density to 20 units per acre to meet State affordability standards.

In addition to the above HCD requested revisions, staff also revised Appendix H – Public Engagement, to reflect the December and January Council meetings during which public input was received regarding the RHNA Plan (see Attachment I).

Council Discussion Items
Council direction is needed for the following items to complete the Housing Element for resubmission to HCD:

1. Whether to include a Town-Owned Site for rezoning and disposition:
a. The Raymundo Town-owned site for rezoning and disposition at 20 du/ac for small lot single-family affordable housing, or
b. The High Road Town-owned site for rezoning as MFRD for an ownership condominium housing project of 33 units instead of the Raymundo site if it is not acceptable to rezone Raymundo; or rezone the High Road site to 20 du/ac and revise the ADUs production rate to 17.5 units per year.

2. Whether to include a policy to rezone the 773 Cañada site at 20 du/ac.

3. Whether to revise the RHNA Plan (Tables 3-5 and G-1) to reduce the number of ADUs to 15 units annually; or 17.5 units if the High Road site is included in the RHNA Plan at 20 units per acre instead of 33 units.

Conclusion
Revisions to the Housing Element to be submitted with the Town’s Response to Comments will provide the greatest opportunity for receiving HCD certification. Staff requests that the Council review the options outlined in this report, receive public input, and provide direction on how to structure the RHNA Plan to be included in the next Draft Housing Element to be submitted to HCD. Once the draft for resubmittal is completed, it will be posted to the Town’s website at least seven days prior to submission to HCD, per State requirement.

Attachments
A. Attachment A – Initial Draft Housing Element - https://www.woodsidetown.org/planning/drafthousing-element-hcd-review B. Attachment B – HCD October 14, 2022, Review and Comment Letter - https://www.woodsidetown.org/planning/state-hcd-comments-draft-housing-element Item A Page 16 Town Council Special Meeting January 31, 2023

C. Attachment C – Revised Baker Tilly Response to Comments Letter D. Attachment D – Revised Section 1.0 Introduction
E. Attachment E – Revised Section 3.0 Housing Element
F. Attachment F- Revised Appendix F- Housing Development Constraints and Zoning Analysis G. Attachment G – Revised Appendix G – Adequate Sites Analysis H. Attachment H – Revised Descriptions of Rezoning Sites I. Attachment I – Revised Appendix H – Public Engagement Item A Page 17 Town Council Special Meeting January 31, 2023 BAKER TILLY • 1730 MADISON ROAD • CINCINNATI, OH 45206 • 513 861 5400 • FAX 513 861 3480 To: Kevin Bryant, Town Manager, Town of Woodside
From: Patrick O’Keeffe, Special Advisor
Subject: Responses to State Department of Housing and Community Development First Housing Element Review Comment Letter – January 31, 2023, Authorization to Submit to State
Date: January 25, 2023
The following provides information to respond to questions and comments from the State Department of Housing and Community Development (HCD) in their first Housing Element review letter dated October 14, 2022. The HCD comments are attached as Attachment A and the responses follow the order and organization of the HCD letter (which follows the order of the HCD Compliance Checklist). Each response first summarizes the HCD comment, then provides a response for HCD consideration. In some cases, the response is a summary of where the information requested already exists. Where supplemental information or policies may be appropriate there is a recommended revision to the element. For either type of response, the applicable page numbers are stated at the end in bold to assist HCD staff with completing the HCD Compliance Checklist.

The Town staff and its consultant team met twice with HCD in January 2023, to discuss the responses and key issues. A meeting with the Town Council was also held in January to discuss the additional January HCD comments. This revised version of the Response to Comments reflects additional responses and revisions to Housing Element policies for the Council to consider on January 31st. If these revised documents are authorized by Council, a second version of the Housing Element will be resubmitted to HCD for a second formal review, along with all of the appendices and this revised Response to Comments memorandum.

A. Review and Revision
HCD Comment
The comment starts with Government Code Section 65588(a) and (b) requiring review of the previous element (Cycle 5) to evaluate the implementation progress. The HCD comment adds a statement requiring a thorough program-by-program review in addressing housing goals, including quantifying results and evaluating effectiveness, and including special needs populations.

Woodside Response
Section 2.0 of the Cycle 6 draft Housing Element contains the information set forth in the statute and the addresses the HCD comments as follows:

Item A Page 18 Town Council Special Meeting January 31, 2023 ATTACHMENT 1C
Woodside Response to HCD Comments 1-31-23 Page 2
• Section 2.1 and Table 2-1 describe how the Town met and exceeded its Cycle 5 RHNA goals by 63 units (Page 2-1).
• Section 2.2 and Table 2-5 is a program-by-program review and evaluation of each housing policy in the Cycle 5 element and includes how the policy will be carried over and/or modified for Cycle 6 based on the review. Where appropriate, data is quantified to support the analysis such as Table 2-3 showing building permits issued for Accessory Dwelling Units (ADU’s) (Pages 2-4, 2-6)
• Special needs groups are discussed in Section 3.0, “Goal H4: Promote the Availability of Housing for Special Needs Groups” promoting housing opportunities for the disabled and seniors. Section 2.2 includes a narrative discussion on modification of the Town Municipal Code in Cycle 5 to facilitate special needs housing and additional measures needed for Cycle 6. Information and data on other special needs groups including large households, female-headed households and homeless are included in Section 1.2 Woodside Demographics – Characteristics and Trends (Pages 2-5, 1-3).

B. Housing Needs, Resources, and Constraints

1. Affirmatively Furthering Fair Housing (AFFH)
HCD comments start with a citation of Government Code Section 65583 (c)(10)(A) regarding measures to assess and promote fair housing in the community. Comments and responses about specific aspects of compliance with this section are discussed in the following sections a) through h).
a) Fair Housing Enforcement and Outreach
HCD Comment
In summary this comment states the element must include information about the Town’s ability/capacity to provide enforcement and outreach for fair housing, including investigation of complaints, remedies, efforts/methods to communicate with protected classes and the public, and compliance with fair housing laws and regulations.

Woodside Response
Appendix K1 of the Cycle 6 Housing Element states that from 2013 to 2021 only two fair housing inquiries were filed, and from 2017 to 2021 no fair housing complaints were filed (data was available in different time frames). Section 3.0 of the Cycle 6 draft Housing Element contains information on outreach including Town Council meetings, webinars, and Planning Commission meetings. Per national data from the National Fair Housing Alliance (provided in Appendix K1), 73% of the 2020 fair housing complaints were processed by private fair housing organizations rather than state or federal government agencies. (Pages: Appendix K.1 Page 5, and Housing Element Section 3.3 page 3-4).

In addition, the following policies to provide outreach to protected classes were implemented for the Cycle 5 Housing Element (Page 299):
• Goal H5: Provide, Develop, and Maintain Public Information Regarding Housing Availability – contains information about the Town providing extensive information on Item A Page 19 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 3
the Town website regarding housing resources available in the region. The Town has recently updated the links for Housing Resources on the website. • Policy H1.1(b) Rental Availability Information – states the Town will continue to provide information on its website as a resource for listings of affordable rentals. • Policy H5.4f Public Participation – states the Town will solicit additional input at rezoning hearings.
• Policy H4.4(a) Equal Opportunity Housing Organizations – states the Town supports a variety of equal opportunity housing organizations including HIP Housing and the Housing Endowment and Regional Trust (HEART) and provides links to housing resources on its website, as outreach to protected classes based upon race, age, gender, family status, and religion.
• Policy H4.4(b) Referrals- states the Town has and will provide links to housing resources on its website, including links to two investigative and enforcement agencies:
the U.S. Department of Housing and Urban Development, and the State Department of Fair Housing and Employment. These agencies provide resources and a means for resolution of fair housing complaints, including filing complaints related to discrimination against protected classes.

Recommended revision for the Cycle 6 element: Include the above polices from the Cycle 5 Housing Element as Cycle 6 policies under Goal H2 Affirmatively Further Fair Housing as new subsection H2.2. In addition to the above policies from the Cycle 5 element add the following new outreach polices for protected classes:
• “The Town will distribute fair housing information in languages other than English, in a handout that will be distributed with ADU applications, and for display at the Cañada College, Woodside Library, and Town Hall.”
• “Add information to the Town website on housing complaints enforcement and contact information for non-profit information and enforcement organizations, including Project Sentinel, Legal Aid Society of San Mateo County, and the Community Legal Services of East Palo Alto. Include this information in the handouts developed for ADU applications.”
b) Integration and Segregation
HCD Comment Summary
In summary this comment recognizes that the draft Housing Element includes data on integration and segregation but lacks analysis of patterns over time. Further, the comment indicates that the analysis should include patterns regarding family status, disabilities, and income both locally, and in comparison to the region, with a summary of issues. The comment calls for a description of local concentrations of white residents, and racial disparities within the region.

Specific HCD Comments and Town Responses
• HCD Comment: “Analysis of integration and segregation patterns over time.” Woodside Response: Appendix K.1 is a detailed analysis of integration and segregation locally and within the region. Housing Element Section 3.4 Affirmatively Furthering Fair Item A Page 20 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 4
Housing (AFFH), subsection b – History of Segregation in the Region, contains an analysis of patterns of segregation over time from Appendix K and the San Mateo County Historical Association, including a narrative of the segregation patterns since the World Word II migration, the discriminatory practices that contributed to the patterns of segregation, and a history of state and federal legislation prohibiting discrimination (Pages: Appendix K.1 Page 2; Housing Element Page 3-12). • HCD Comments: “…analyze segregation and integration of family status, income, and persons with disabilities… both locally and regionally and concluding with a summary of issues. Describe local concentrations of white residents and compare to region” “…regional analysis should analyze how town relates to immediate surrounding areas to examine significant differences in income patterns”. “Describe local concentrations of white residents within the Town and evaluate disparities and differences in race within the region.” ”A summary of these three issues should be added to the Housing Element.”
Woodside Response:

Family status is analyzed in Appendix B Housing Needs Data Report, however the body of the Housing Element does not repeat the information.

Recommended revision: add the following bullet to Housing Element Section 3, subsection 3.4 Affirmatively Furthering Fair Housing (AFFH), subsection (c) Woodside Fair Housing Assessment, list of bullets page 3-14, as a new bullet: “Woodside households are predominately Married Couple Households at 74.8 % with Female Headed Households representing 5.6% of the households (compared to 10.1% Countywide)., but 46.7% of the female headed households in Woodside fall below the Federal Poverty Line.”
Income: Income is analyzed in Appendix K.1 (Page 13) and summarized in the Housing Element with the following statement: “Economic diversity is also limited: 75% of households in Woodside earn more than 100% of the Area Median Income (AMI) compared to 49% in the county overall. Nearly all census block groups in the town have median incomes above $125,000 and households experiencing poverty is low throughout Woodside.” (Page 3-14).

Disabilities: Persons with disabilities is analyzed in Appendix B Housing Needs Report and summarized in Section 1 of the Housing Element with a statement that Woodside has proportionately fewer households with disabilities (5%) than the County as a whole (8%), but this proportion is likely to increase as the population ages. The most common disabilities in the town for all ages are ambulatory (2.6%), hearing (2.3%), and independent living (1.7%) (Page 3-14).

Recommended revision: Repeat the above sentence in the Section 3, subsection 3.4 Affirmatively Furthering Fair Housing (AFFH), subsection (c) Woodside Fair Housing Assessment, list of bullets page 3-14, as a new bullet.

White Residents: Appendix K.1 contains a detailed analysis of integration and segregation locally and within the region (Page 11). Portions of the appendix are included Item A Page 21 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 5
in the body of Housing Element Section 3, subsection 3.4 Affirmatively Furthering Fair Housing (AFFH), subsection (c) Woodside Fair Housing Assessment, list of bullets page 3-14 as follows: “Compared to the county overall, Woodside has limited racial and ethnic diversity: Countywide, racial/ethnic minorities account for 61% of the overall population; however, in Woodside, they account for 21%.” (Page 3-14) Summary:

Recommended revision/addition to Section 3, subsection 3.4 Affirmatively Furthering Fair Housing (AFFH), subsection (c) Woodside Fair Housing Assessment, list of bullets page 3-14, as a new paragraph following the bullets: “In summary the Town experiences low levels of racial and economic diversity, disability, and female headed households compared to the County. The aging of the population and the large percentage of female headed households below the poverty line are potential areas of concern for future policies regarding fair housing, integration, and segregation.” c) Racial/Ethnic Areas of Concentration of Poverty and Affluence HCD Comment
In summary this comment recognizes information that was included in the element regarding Racially and Ethnically Concentrated Areas of Poverty (R/ECAP) but requires additional information regarding concentrated areas of affluence (local and regional), the reasons for the affluence including past land use practices, lack of public investment in affordable housing; and add policies that promote inclusion, housing mobility and new housing choices.

Woodside Response
• Concentration - Section 1.2 Woodside Demographics – Characteristics & Trends in the Housing Element, and Appendix B Housing Needs Report, contains information about racial and income concentration in Woodside and compared to the region as set forth in Table 1-2 Population by Race, Table 1-4 Households by Household Income Level, and accompanying explanatory text (Pages: 1-4; 1-6).

Recommended revision/addition: add on Page 1-6 just above Table 1-4, the following text: “According to State Department of Housing and Community Development data and maps, the Town has a predominance of higher income households compared to the region and is a Racially Concentrated Area of Affluence with high concentrations of higher income White residents.”
• Analysis of Concentration
Racial -The Housing Element Section 3.4 Affirmatively Affirming Fair Housing, subsection b. History of Segregation in the Region – describes the historic patterns of discriminatory real estate practices that contributed to the racial concentration in Woodside. (Page 3-12). Notwithstanding this historic pattern Appendix K.1 Fair Housing Assessment, Section II Integration and Segregation, Dissimilarity, and Isolation Indices states that on a scale of 0-100 (0 equals perfect integration and 100 equals complete segregation); with values of 0-39 generally indicating low segregation, Item A Page 22 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 6
Woodside has a lower Dissimilarity Index value of 16 compared to the Bay Area average of 43. (Appendix K, Page12).

Land Use - the Town has historically retained a low-density character due to a combination of infrastructure and environmental constraints, conservation of open space/wildlife habitat, and providing regulations that allow land suitable to accommodate medium to large domestic animals (e.g., horses) within the densely populated region. . Environmental constraints are described in the Housing Element Section 3.6 Sites Inventory and Assessment to Accommodate Housing Units including “very high fire hazard zones, steep topography, limited access to sewer, and environmentally protected habitats (e.g., stream corridors that contain habitats for endangered or threatened species such as the San Francisco Garner Snake and California Red legged Frog) that are widespread throughout the Town of Woodside. Housing development in Woodside is additionally constrained by geologic conditions such as known and inferred earthquake faults, including the San Andreas Fault, and active landslide areas in the Western Hills.” This text is geographically illustrated in Map NH2 Fault Zones, Map NH 3 Flood Zones and Map LUE Western Hills and Environmentally Sensitive Areas. (Pages 3-20 to 3-22).

Investment in Affordable Housing/Inclusive Community – The Town has amended its Municipal Code to support the creation of ADU’s as a source of affordable housing that is feasible with the area’s high land cost. Discussion of ADU’s is found in Housing Element Section 3.8 a. Strategies to Meeting RHNA Cycle 6, Accessory Dwelling Units and Junior Accessory Dwelling Units. These units are discussed in various sections of the element as a means of increasing housing opportunity and mobility, and creating inclusive affordable housing geographically dispersed throughout the community. (Page 3-31). Further, in the Cycle 5 Housing Element the Town created a Multi-Family Overlay Zone for the Cañada College site to allow higher density development with greater affordability for teachers and students (Page 3-33).

Policies for New Housing Choices – Section 3.8 of the Housing Element also discusses additional actions to promote housing mobility and new housing choices with its discussion of SB 9 lot splits and rezoning of one parcel for higher density. (Pages 3-31 to 3-38).
d) Disparities in Access to Opportunity
HCD Comment
This comment recognizes information already provided on opportunity disparities but states there is a lack of qualitative and quantitative support. The comment seeks additional information regarding factors contributing to education access, high economic opportunity scores with low employment, geographic difference in economic opportunity in the western portion of the Town (including impacts to protected classes), access to transportation, reasons for low Town scores on environmental outcomes, and access to opportunity for disabled persons.

Item A Page 23 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 7
Woodside Response
• Education Access –Appendix K.1 Section III -Access to Opportunity – describes the racial characteristics and percentage of students receiving free or reduced lunch benefits of the four school districts serving Woodside and compares that data to the Countywide districts data. Factors that contribute to the disparity for which data is provided in this appendix include: 1) students that are learning English, with data presented on low math and English scores, and higher rates of absenteeism; and 2) lower rates of college admission and higher rates of high school dropouts for non-white students. Policy solutions to these disparities are the purview of the school districts (Page Appendix K.1

• Economic Opportunity Access- Appendix K.1 Section III analyzes Town employment including the top employment industries, the jobs to household ratio (including a comparison to the County ratio), and low unemployment. The analysis indicates high out-commuting and retired households as the causes for high economic opportunity scores with low employment. Data is also presented from the State Tax Credit Allocation Committee (TCAC) Economic Opportunity Score (consisting of factors such as poverty, adult educational attainment, employment, job proximity, and home value) of .75 for the Town as a whole and .25 for the western part of town. The factors that go into the score (which are listed in this section) are the explanation for the score, i.e., the Town as a whole has lower rates of poverty, higher rates of educational attainment, low unemployment rates, and high home values. The explanation for the high score in comparison to the low employment opportunities is explained by the high rate of commuting to employment which is stated in this section. The lower score for the western area is stated in the appendix as the area west of the town, not the western portion of the town. The area west of the town is unincorporated area consisting of regional parks (Huddart and Wunderlich) and very low-density housing. Similarly, the western portion of town is low-density residential. The lack of population in these areas explain the lower score as factors that comprise the score are based on population characteristics. As these areas are parkland or a Very High Fire Hazard Area, it is inappropriate to add policies that would increase the population thereby raising the low score. (Pages Appendix K.1 20 to 22).
• Transportation –This topic is discussed in Appendix K.1 Section III, Transportation, and discusses the bus and paratransit services that are provided to Woodside by the San Mateo County Transit District. Seniors are served by both services. Private ride sharing services such as Uber and Lyft are also a good resource for seniors, although current usage data for Woodside residents is not available. (Page Appendix K.1 Page 18). • Environmental Outcomes- This topic area includes geographic areas vulnerable to sources of air and ground pollution, and is discussed in Appendix K.1 Section III, Environment. The scores are TCAC scores based on the CalEnviroScreen 3.0 Indicators (updated in October 2022 to version 4.0). The appendix states Woodside “scores moderately to poorly on environmental outcomes…” which is the basis for the HCD comment reflecting that language. (Page Appendix K.1 Page 19). However, in reviewing the CalEnviroScreen 3.0 Map (see Figure 1 for excerpt of the map) this information is not Item A Page 24 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 8
correct, rather the majority of the Town is rated at the lowest category of 1 to 10%, with small portions the 11 to 20% and 51 to 60% categories, which means lower potential exposure to pollution sources. (The new 4.0 version map is the same). Since the environmental outcome is actually positive it will not be necessary to discuss the factors contributing to a poor score.

Recommended revision to the Appendix K: Delete the second paragraph and replace with the following sentence: “Woodside scores low on potential exposure to pollution sources and the majority of the Town is in the lowest category of potential exposure compared to the surrounding region.”
Figure 1. Excerpt From CalEnviroScreen Map 3.0
• Opportunity Access for Persons with Disabilities -This information is provided in Appendix K.1 Section III. Data provided includes the comparison of 5% disabled compared to 8% County-wide, and the most common disabilities consisting of ambulatory, hearing, and independent living. The data shows no unemployment and no concentrations of persons with disabilities. Since the predominant disabilities are associated with the senior population, the existing polices in the draft Element for senior housing address this area (Page Appendix K.1 Page 20).
e) Disproportionate Housing Needs and Displacement
HCD Comment
Item A Page 25 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 9
This comment recognizes the data showing good stability for protected classes that might experience housing needs due to cost burden, overcrowding, homelessness, and substandard housing, compared to the County; but states the analysis must include displacement risk due to the Town’s affluence, and potential disasters (fire, flood, and earthquake).

Woodside Response
• Affluence - Appendix K.1 Section IV – Disproportionate Housing Needs –describes the high housing cost for both housing values and rent levels. Further, the section describes the 28% of households that are burdened by high housing costs and the higher impact of this burden on Hispanic households than White households. Large households have a smaller rate of cost burden at 12% of the households. It seems self-evident that cost burdened households are at higher risk of displacement due to the Town’s higher housing costs supported by its higher levels of affluence, but a sentence to that effect could be added to this section of the appendix if appropriate (Page Appendix K.1 Page 23).
• Disaster Risk – This topic is discussed in Housing Element Section 3.6 Sites Inventory and Assessment to Accommodate Housing Units, which includes the following: “very high fire hazard zones, steep topography, limited access to sewer, and environmentally protected habitats (e.g., stream corridors that contain habitats for endangered or threatened species such as the San Francisco Garner Snake and California Red legged Frog) that are widespread through the Town of Woodside. Housing development in Woodside is additionally constrained by geologic conditions such as known and inferred earthquake faults, including the San Andreas Fault, and active landslide areas in the Western Hills.” This text is geographically illustrated in Map NH2 Fault Zones, Map NH 3 Flood Zones and Map LUE Western Hills and Environmentally Sensitive Areas. Disaster risks are discussed in further detail in the General Plan Natural Hazards and Safety Element with several illustrative maps. All of these risk factors could lead to displacement on a temporary or permanent basis (Pages 3-19 to 3-22).

Recommended revision to the Housing Element: add the following sentences to Section

3.6 Sites Inventory and Assessment to Accommodate Housing Units, to the end of the last paragraph prior to subsection a): “Further information on areas unsuitable for housing due to natural features that create the potential for natural disasters can be found in the General Plan Natural Hazards and Safety Element.” f) Sites Inventory
HCD Comment
“…include an analysis demonstrating whether sites identified to meet …RHNA are distributed throughout the community in a manner that affirmatively furthers fair housing.” HCD states the analysis should address the income categories the sites will address and how the location of the sites will improve or exacerbate integration/segregation. HCD asks that policies are included to promote an inclusive and equitable community.

Item A Page 26 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 10
Woodside Response
• Site Distribution - Appendix G, Table G-1 Proposed RHNA Plan, lists the sites that are suitable for housing development by income category and in comparison to the RHNA.

The map in Figure G-2 Housing Sites and Environmental Constraints, depicts the geographic distribution of these sites throughout the community demonstrating a dispersal of housing opportunity that enhances integration of income groups and avoids concentration of affordable housing (Page: all of Appendix G).

Recommended revisions to the Housing Element: add the following sentence to Section

3.6 Sites Inventory and Assessment to Accommodate Housing Units, subsection d) Affirmatively Furthering Fair Housing, on page 3-26 to the end of the paragraph prior to Figure 3-9: “This geographic dispersion of new units avoids concentration of affordable units in one area and promotes integration and access to opportunities and resources.”
• Policies- Housing Element Section 3.9 Housing Program and Action Plan – Guiding Principles, Goals, Policies, and Programs, sets forth as Guiding Principal #1 a policy to provide adequate housing for all protected classes and lists all the classes. Goal H1 and Policy H1.2 encourages development of ADU’s and JADU’s as affordable housing (Page 3- 42).

Recommended revision: add to Policy H1.2 - Promote ADUs and JADUs as an Opportunity for Affordable Housing – the following: “to Promote an Inclusive and Equitable Community.”
g) Contributing Factors
HCD Comment
List contributing factors to fair housing issues, such as community opposition, lack of affordable housing, etc.

Woodside Response
Recommended revision: add a new subsection “d.” to Section 3.4 Affirmatively Furthering Fair Housing titled “Contributing Factors to Fair Housing Issues” and add the following text:
“One of the major methods of creating affordable housing in Woodside is through development of ADUs. Resident survey information concerning ADUs demonstrates strong support for this approach. The Town will continue to support ADU creation supplemented by rezoning of a site for higher density housing and supporting higher density housing at the Cañada College site. Potential contributing factors that may make these solutions to the lack of affordable housing difficult to implement include the following:
• Limited local job opportunities.
• Limited access to frequent and widespread public transportation. • Lack of access to sewer infrastructure.
• Limitation on density from existing zoning.
• Difficulty in obtaining public or private financing to offset the costs of affordable units.

Item A Page 27 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 11
• Timing of the Cañada College capital improvement program. • Limited site capacity due to environmental constraints such as fault zones, fire hazards, and slopes.

These factors are addressed by the discussion of sites in Section 3.8- Strategies to Meeting RHNA Cycle 6, and policies in Section 3.9- Housing Program and Action Plan – Guiding Principles, Goals, Policies, and Programs.”
h) Goals, Actions, Metrics and Milestones
HCD Comment
HCD comments on what the element must include are summarized as follows:
• Goals and actions based on a complete analysis.
• Goals and actions must address contributing factors to fair housing issues. • Actions must have specific commitment, milestones, metrics, and geographic targeting. • Address as appropriate housing mobility, new housing choices, affordability in high opportunity areas.
• Place based strategies for community preservation.
• Displacement protection.

Woodside Response
This section is discussed in Section 3.9- Housing Program and Action Plan – Guiding Principles, Goals, Policies, and Programs (Page 3-42). The following responses use the word “policies” to mean principals, goals, programs, and actions. The narrative policies in Section 3.9 are summarized in Table 3-6-Action Plan for Program Implementation (Page 3-54). • Policies Based on Analysis – All of the policies are based on the numerous studies in appendices A to K.

Recommended Revision: add a column to Table 3-6 Titled “Analysis/Factor” and add for each policy the analysis appendix the policy is based on (e.g., Appendix B) • Contributing Factors
Recommended revision: add the contributing factor the policy addresses where appropriate in the new Table 3-6 column for Analysis/Factor (add the factors discussed above to the bottom of the table and number them to allow use of the number in the column).
• Commitment, Milestones, Targeting, Metrics – The policies start with more general goal statements and work toward more specific actions for each goal as set forth in Table 3-6 (Page 3-54). Each specific action is described in the program column and is a commitment to implement demonstrated by the other columns describing the responsible department or agency, funding source, program measures, targets, and implementation timing. • Mobility, Choices, Affordability – The policies set forth in Section 3.9 Housing Program and Action Plan are a suite of programs designed to address broader housing mobility, encourage development of more housing choices, and create more housing affordability throughout the community which as a whole is a high opportunity area (Page 3-42). • Place Based Strategies – Per HCD Building Blocks: “Place-based strategies to encourage community conservation and revitalization involves approaches that are focused on conserving and improving assets in areas of lower opportunity and concentrated poverty Item A Page 28 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 12
such as targeted investment in neighborhood revitalization, preserving or rehabilitating existing affordable housing, improving infrastructure, schools, employment, parks, transportation, and other community amenities.” As discussed throughout the needs, resources, and constraints portions of the element, Woodside does not have areas of concentrated poverty, low resources and opportunities, affordable housing resources in need of rehabilitation, or a deficiency of schools and parks in good condition. The conditions and strategies described in HCD Building Blocks do not have application to Woodside.
• Displacement Protection – Per HCD Building Blocks: “Protecting existing residents from displacement comprises strategies that protect residents in areas of lower or moderate opportunity and concentrated poverty and preserves housing choices and affordability.” As discussed in the section above these conditions and improvement strategies do not have application to Woodside.

2. Analysis of Population and Employment Trends/Quantification of Needs for All Income Levels
HCD Comment
For extremely low-income households (ELI), quantify existing/projected ELI households and their housing needs including tenure and overpayment.

Woodside Response
Recommended Revisions: add the following text to Section 1.0 Introduction, subsection, c.

Housing and Household Characteristics, as a new section at the end after the subsection on Special Needs Residents starting on Page 1-13:

Extremely Low-Income Households (ELI)
Number of Households - Housing Element Introduction Section 1.2 Woodside Demographics, Table 1-4 Household Income Levels, shows the percentage of extremely lowincome households (less than 30% of Area Median Income-AMI) at 8% compared to 13.3% for the County and 14.7% for the Bay Area (Page 1-6). The 8% ELI Woodside households is comprised of approximately 144 households (1799 total households). HCD’s Housing Element guidance notes that jurisdictions may use their RHNA for very low-income households to calculate their projected extremely low-income households at 50% of the very low-income allocation. The Cycle 6 RHNA allocation to Woodside for extremely low-income households is 45 using 50% of the very low-income households allocation. Therefore, the Town will need to plan for an additional 45 ELI households housing needs over the next eight-year planning cycle.

ELI Housing Needs – These households can be negatively impacted by the following factors:
• Cost burden – Is defined by a household paying more than 30% of its income on their housing payment. This is particularly important for ELI households as their discretionary income is limited. Per Figure 26-Cost Burden by Tenure, in Appendix B – Housing Needs Data Report (Page 39), six percent of renters are cost burdened (compared to 11.6% for ownership). This burden falls more heavily on lower income households. The Figure 27 – Cost Burden by Income Level (Page 40) - indicates 96% of ELI households are experiencing cost burden.

Item A Page 29 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 13
• Displacement - The table on Page 27– Disproportionate Housing Needs, of the Appendix K.1 - Woodside Fair Housing Assessment, shows eight percent of Woodside residents moved in the past year (compared to 12% County-wide) and the Urban Displacement Project does not identify any Woodside areas vulnerable to displacement.
• Housing condition- The table on Page 27 – Disproportionate Housing Needs, of the Appendix K.1 - Woodside Fair Housing Assessment, shows fewer than 1% of households are living in units considered substandard.
• Overcrowding - The table on Page 27 – Disproportionate Housing Needs, of the Appendix K.1 - Woodside Fair Housing Assessment, shows there are no households experiencing overcrowding.
• Affordable unit availability- Per Table G-1 Cycle 6 RHNA (Page Appendix G-10) the Town will have sufficient housing production over the eight-year planning period to house the projected number of ELI households.”

3. Household Characteristics
Overpayment
HCD Comment
Analyze the number of households overpaying by tenure.

Woodside Response
See Figure 26-Cost Burden by Tenure, in Appendix B – Housing Needs Data Report, (Page 39), and text addition in the prior Section 2 response.

Housing Conditions
HCD Comment
Include analysis of housing conditions in addition to the federal data on plumbing and age of housing.

Woodside Response
Per information from the Town Building Division there are approximately six units in need of rehabilitation. Due to the expensive nature of the community’s housing stock, housing in poor condition is not a significant issue.

Recommended revision: add a second sentence to Housing Element H6.2.d – Utilize Rehabilitation Programs- “The Town website contains information about County rehabilitation programs under the Housing Resources page.”

4. Residential Development Land Inventory
RHNA Progress
HCD Comment
Item A Page 30 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 14
Reduction of RHNA by units approved/under construction since June 2022; and clarify Table 3- 5 pipeline units are current applications or basis of assumptions that units are in the pipeline.

Woodside Response
Recommended revision: Add footnote to Table 3-5 explaining status of pipeline units.

Sites Inventory
HCD Comment
Include calculation of units in whole number increments, demonstrate potential development capacity for parcels with existing uses, identify sufficient sites for above moderate income in Tables 3-5 and G-1.

Woodside Response
Recommended revisions: Per a new sites analysis by Dyett and Bhatia the number of units in Tables 3-5 and G-1 are revised to show sufficient units to satisfy above moderate- income RHNA allocation as shown in Table 1. The new analysis is detailed in the revised HCD Excel Site Inventory spreadsheet. These tables are reformatted to simplify the data presentation.

Table 1. Revised Table 3-5 Proposed RHNA Plan [Insert final version of this table per 1-31-23 Council direction]
Low and
Very Low
Income
Moderate
Income
Above
Moderate
Income Total
Current Zoning Sites
Vacant Single-Family Sites 106 106
Non-Vacant Single-Family sites 46 46
Pipeline Projects 4 4
Cañada College 75 75
ADUs 96 48 16 160
Rezoning Sites
773 Cañada Site 16 11 27
Total 171 64 187 422
RHNA Allocation - Base 142 52 134 328
RHNA Buffer @ 20% 28 10 27 65
Total RHNA + Buffer 170 62 161 393
Surplus/Deficit +1 +2 +26 +29
Cañada College Site
HCD Comment
Item A Page 31 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 15
Clarify if there is an existing development application or analyze feasibility of new residential development including affordability assumptions, College plans and timing, restrictions of units to students/faculty, and actions that facilitate approvals.

Woodside Response
Housing Element Section 3.8 Strategies to Meeting RHNA Cycle 6, Subsection d. Higher Density Housing, describes the prior units approved for the College site, the Town’s rezoning of the site for multi-family development, and the planned allocation of an additional 75 units to be included in a new San Mateo College District (District) master plan for all college campuses (Page 3-33).

There is no pending application for these new units. The units will be restricted to student and family and employee housing. The Housing Element already has policies to facilitate development by streamlining the application approval process and supporting the development (Page 3-46).

Recommended revision: add the following text to the Higher Density Housing section of the Housing Element on Page 3-33: In July 2022, the San Mateo County Community College District adopted the 2022 Districtwide Facilities Master Plan (FMP), which was developed to guide short- and long-term planning for the District’s three campuses.

The District is now actively seeking funding for student and family housing at its campuses. As a first phase, the District is in the process of applying for a State grant to support housing at the College of San Mateo campus. If successful, the District would move to a second phase to obtain grant funding to support student and family housing at one of its other two campuses, including Cañada College. The second phase application submittal could take place as soon as July 2023. The District has indicated that 75-80 units at Cañada College is a reasonable assumption.

Realistic Capacity
HCD Comment
Provide support for residential build out assumptions including land use controls, utility availability, past residential trends, and likelihood of 100% commercial development on commercial property included as potential housing sites.

Woodside Response
The detailed HCD Excel Sites Inventory spreadsheet includes this information.

Small and Large Sites
HCD Comment
Demonstrate suitability of sites less than a half-acre or larger than 10 acres, and non-vacant sites, to accommodate lower income housing.

Woodside Response
A new map of sites depicting sites for new housing by income group has been added as Figure G-2 Housing Sites and Environmental Constraints in Appendix G.

SB 9 Sites
Item A Page 32 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 16
HCD Comment
Analyze experience, trends and market conditions that support lot split assumptions. Provide information that existing uses on sites are not an impediment to lot splits. Provide information on existing zoning controls or planned controls or amendments to encourage lot split development.

Woodside Response
Recommended revision: add the following paragraph as a new second to last paragraph in Section 3.8 Strategies for Meeting Cycle 6 RHNA, subsection b – SB9 Units: “In response to the enactment of SB 9, the Town adopted Ordinance 2022-624 (amended by Ordinance 2022-625), and Resolution 2021- 7464 establishing subdivision, zoning, and design standards for ministerial approval of SB 9 lot splits. A significant number of existing lots in Woodside cannot be divided under existing minimum lot size requirements. Therefore, SB 9 lot splits can result in ministerially approved smaller parcels, making it substantially easier and more attractive for property owners to subdivide their lots and construct smaller units that will be more affordable. In the past year since the State’s approval of SB 9, there has been some interest expressed from property owners in SB 9 lot splits in Woodside. SB 9 is a new state law, so there is minimal recent experience on how many SB 9 lot split applications might be received, so the Table 3-5 Proposed RHNA Plan does not include units produced from SB9 lot splits.

Recommended revision: Add to the policy H2.1 Provide Opportunities for Varied Housing Types two new sub sections: “c. Provide information to property owners on SB9 lot split standards, and survey their interest in pursuing lot splits, as part of the annual information postcards mailed for ADU information in Policy H1.2.a”; and “d. Review the SB 9 ordinance to allow homes with size limitations similar to ADU limits in the ADU ordinance.

Replacement Housing Requirements
HCD Comment
Sites identified as affordable housing sites for RHNA units with existing units that are affordable and are removed for new units cannot be counted for RHNA unless the Town has an adopted policy regarding replacement housing per Government Code Section 65915(c)(3). This State regulation applies to units created using the density bonus provisions of the Government Code.

Woodside Response
Although the Town has not adopted an ordinance to implement the density bonus provisions of State law, the law applies. The site that is identified for affordable units through rezoning for higher densities, and the Cañada College site do not have existing affordable units that would be removed requiring replacement housing.

Accessory Dwelling Units (ADUs)
HCD Comment
The element projects 20 ADUs per year. Clarify the assumptions for this rate of production.

Include policies that incentivize affordable ADU’s. Commit to monitoring ADU production if not meeting targets and implement additional actions to meet RHNA if ADU production is less than Item A Page 33 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 17
estimated. Several areas of the Town’s existing ADU ordinance are not compliant with State law and a program should be added to amend the ordinance.

Woodside Response
The Housing Element already includes incentives for ADU production per Policy H1.3- Continue to Remove Barriers to Constructing ADUs and JADUs (Page 3-42). The Town held a series of workshops in Fall 2022 to provide information to residents on how to apply for ADU approvals per the Town’s ADU ordinance. Seventy three percent (73%) of the residents attending expressed interest in developing an ADU or JADU.

Recommended revision, add policies: “H1.3f – Monitor ADU Production. After two years following the adoption of the Housing Element, assess the number of applications for ADUs and JADUs approved and compare to the annual estimate of 20 units per year in Table 3-5 Proposed RHNA Plan. If the actual number of applications approved is less than 20 units annually, review measures to increase ADU production.”; and policy: “H1.2d Periodically amend the ADU ordinance to be consistent with State law and recommendations from HCD.” Previously Identified Nonvacant and Vacant Sites
HCD Comment
These sites must be rezoned within one or three years at appropriate by right densities for developments with at least 20% affordable units for lower income households. If these sites were included in the prior planning period, they must be identified and planned for rezoning.

Woodside Response
The Cañada College site was previously identified in the prior Housing Element and was rezoned for multi-family housing. A new site in the Cycle 6 Housing Element is scheduled for rezoning within one year of the adoption of the new Housing Element per Policy H3.2 – Rezone Properties Allowing Increased Housing Density (Page 3-47).

Infrastructure
HCD Comment
Demonstrate existing or planned infrastructure to support the RHNA units, and for sites with inadequate infrastructure analyze the constraints and impacts on the RHNA sites.

Woodside Response
The utilities serving the sites are set forth in the HCD Excel Site Inventory spreadsheet of housing sites and are discussed in Appendix G Adequate Sites Inventory. All sites are adequately served by utilities with the exception of sewer. Most parcels rely on septic tanks or leach fields for sanitary waste disposal. Policies for coordinating with utility providers to serve development are set forth in Section H5-2 Provide Adequate Utilities (Page 3-51).

Recommended revision - add the following text to the end of the section Identifying Adequate Sites (Page 3-29): “The 773 Cañada site requires a connection to an existing sewer district. The estimated cost of installing sewer for 773 Canada is $125,000 which is a minor cost for a development estimated to cost $27 million (at $500 per square foot development cost as estimated by Appendix F-1, excluding land cost). For the ADU/JADU units assumed in Table 3-5 Proposed RHNA Plan, the sites will have existing infrastructure serving the existing Item A Page 34 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 18
residence that will serve the ADUs as well. The cost of expanding septic tanks or leach fields to accommodate ADUs will vary on a parcel-by-parcel basis and cannot be defined as a constraint at this time.

Per Government Code Section 65589.7 the Town will provide a copy of the Housing Element to all utility service providers following its approval by the Town Council. Utility providers are required to prioritize service to developments that provide affordable housing.” Environmental Constraints
HCD Comment
Describe environmental constraints that could impact identified housing sites including the Farm Hill open space covenant and the High Road site.

Woodside Response
The Town Council removed the Farm Hill site from the RHNA list of sites due to constraints posed by the open space covenant on the site. The Housing Element Section 3.8 Strategies to Meeting RHNA Cycle 6, Subsection d. Higher Density Housing (Page 3-31) describes the new development site and its respective environmental constraints. None of the constraints are significant enough to preclude the development at the assumed densities or pose significant cost factors that would make the development economically infeasible. [Add discussion of constraints for Town-owned sites if added per Council direction].

Zoning for a Variety of Housing Types
HCD Comments
• Emergency Shelters – Clarify they are allowed in the Community Commercial (CC) zone, capacity of zone, and development standards.
• Transitional and Supportive Housing – demonstrate compliance with State law allowing this use in all residential zones
• By-right Permanent Supportive Housing – demonstrate compliance with State Law allowing this use in all multi-family residential and mixed-use zones • Low Barrier Navigation Centers – demonstrate compliance with State law allowing this use by-right in multi-family and mixed-use zones
• Single Room Occupancy Units (SRO) – describe where SRO’s are allowed • Farmworker Housing- demonstrate compliance with State law concerning how farmworker housing is permitted
• Manufactured Housing- Describe if these units are allowed in a single-family zone on a permanent foundation
• ADUs – Add program to update ADU ordinance once HCD comments on the ordinance have been received by the Town.

Woodside Response
Recommended revision: Add a new subsection to Section 3-5 (Page 3-29) Housing Element Section Sites Inventory and Assessment to Accommodate Housing Units titled “g. Special Needs Housing” with the following text: “Government Code Sections 65583 (c) (4)(A), (c) (1) and 65583.2(c) require the assessment of zoning and site availability for a variety of special needs Item A Page 35 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 19
housing including emergency shelters, transitional housing, supportive housing, low barrier navigation centers, single room occupancy units, farmworker housing, and manufactured housing. Emergency shelters, transitional housing, supportive housing, and low barrier navigation centers are forms of housing for the homeless, some with accompanying services that assist with employment training, substance abuse counseling, and transition to permanent housing.

Per Section 1.2 - Homelessness - Woodside has almost no homeless residents. In 2017 and 2019, when the most recent “snapshot” surveys were conducted, no homeless persons were found to be living in Woodside (down from 2 in 2015, and 6 in 2013). However, State housing laws require cities to provide zoning that supports these housing types. The following is an analysis of the zoning and site availability for each of these housing types. • Emergency Shelters – Are a permitted use in the Community Commercial (CC) zone (Municipal Code Section 153.100 Zoning Districts, Table A-1 Permitted Uses in Residential and Commercial Zoning Districts). The areas with this zoning are developed with commercial buildings and the opportunity for establishing a shelter would be within a vacant tenant space already constructed to commercial development standards. Parking for these existing commercial uses support what would be needed for shelter employees.
• Transitional/Supportive Housing – Is permitted in all single-family residential zones per Municipal Code Section 153.100 Zoning Districts, Table A-1 Permitted Uses in Residential and Commercial Zoning Districts. There are no special restrictions for this type of housing different from the restrictions and standards of the single-family residential zoning districts. Supportive housing includes group homes. • By-Right Permanent Supportive Housing – Per Government Code Section 65583.2 byright housing means housing that is permitted without discretionary approvals and does not require CEQA analysis. Per Government Code Section 65651 by-right supportive housing must be allowed in multi-family zones if certain restrictions regarding affordability are met. The current zoning per Municipal Code Section 153.100 Zoning Districts, Table A-1, does not allow supportive housing in the Multi-Family Residential Development Overlay (MFRD) zone. The Housing Element contains a new policy in Policy 4.3 – Provide for Emergency Shelter and Transitional Housing- to amend the Municipal Code to allow supportive housing as a by-right use in the MFRD zone provided the conditions for affordability per State law are met. • Low Barrier Navigation Centers – is another form of supportive housing that provides supportive services. Navigation centers typically provide longer terms of stay than emergency shelters, making them more like supportive housing, and they are considered a form of supportive housing for the purpose of zoning compliance. These facilities are also a by-right use for multi-family zones per Government Code 65660.

This use will be added to the new Policy 4.3.
• Single Room Occupancy (SRO) units – Are similar to a hotel use and are often a converted hotel or motel. No such facilities are present in Woodside and are not listed as a permitted or conditionally permitted use. Per Section 153.107 of the Municipal Code “Uses not listed in the table under any case category, shall not be permitted under Item A Page 36 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 20
this chapter unless the Planning Commission determines that the use is similar to the uses listed in the table.” For the purpose of a Planning Commission determination, SRO facilities will be considered a commercial use allowed in the Community Commercial zone. New policy 4.3 will include a program to amend the Municipal Code to add SRO units as a permitted use in the Community Commercial zone. • Housing for Farmworkers – The Employee Housing Act, Health and Safety Code Section 17021.5, requires housing for six or fewer employees to be treated as a singlefamily residence and a permitted use. Housing of up to 12 units or 36 beds are a permitted use in zones that allow agricultural uses. Policy 4.3 will include a provision for the definition of a single-family home to include farmworker housing for up to six employees. Agricultural uses are permitted in all residential and commercial zones except multi-family residential. Policy 4.3 will describe farmworker housing as permitted use in all zones except multi-family residential. • Manufactured Housing – Is a permitted use in all single-family zones.”

5. Analysis of Governmental and Nongovernmental Constraints for Housing of All Income Levels
Land Use Controls
HCD Comment
The Housing Element must analyze:
• Land use controls as constraints on a variety of housing types. • Land use controls effect on cost, feasibility, densities, timing, and approval certainty. • Past and present efforts/programs to remove constraints. • Development standards for the multifamily MFRD zone.
• Densities and uses allowed in each zone.
• Zones that meet the default density requirements.
• By-right residential uses in the Community Commercial zone. • Constraints for the Special Conservation Planning (SCP) zone and impact on development.
• Measure J height restrictions impact on development and program to amend.

Woodside Response
Recommended revision: Add a new Section 3.5 to the Housing Element (and renumber subsequent sections) titled “Governmental and Nongovernmental Constraints on Housing” and add a first sentence: “The following is a description and analysis of the various potential constraints on the production of a variety of housing types to meet the housing needs of all income levels as required by Government Code 65583(a)(5). Where appropriate policies to overcome the constraints are included.
• Land Use Controls Constraints – Appendix F - Housing Development Constraints, Development Costs, and Zoning Analysis – provides an analysis of constraints due to land use controls. As explained in Section 3.6 Sites Inventory and Assessment to Accommodate Housing Units – substantial portions of the community are affected by Item A Page 37 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 21
natural hazards including fault traces, landslides, severe fire hazards, streams, and flooding. These hazards combined with State open space and environmental preservation goals, and historic community values for a low-density environment discussed in the Wildland Urban Interface section of Appendix F, support the lowdensity zoning limitations with single family residences. • Land Use Controls Effect on Cost/Feasibility/Timing – Appendix F and Appendix F-1 also have information on development cost and the limitations on housing development based on high land and construction costs. High construction costs are found throughout the Bay Area and are due to high labor and materials costs that cannot be significantly lowered by local housing policy. High land costs in Woodside are partly a function of a desirable environment due to the beauty of the area and its low density, combined with quality schools and proximity to high paying employment.

Increasing density of zoning throughout the community could decrease per unit land cost but is inconsistent with environmental goals and constraints. Per Policy H2.1a - Provide Opportunities for Higher Density Housing with Access to High Resource Areas – the Town will rezone a site for higher density housing and has previously established a multifamily zone allowing higher densities. The Town’s ADU and SB9 ordinances are a form of density increase throughout the community within the context of existing zoning as they add additional units in all zones regardless of zoning lot size minimums. Appendix F has information regarding the timing for development approvals and the time frames for Woodside are comparable or better than other San Mateo County jurisdictions and indicate a reasonable expectation of approval certainty.

Woodside development fees are comparable to other San Mateo jurisdictions as a percentage of development costs.
• Past and Present Programs to Remove Governmental Constraints – The ADU, SB9, and Multifamily Residential Development (MFRD) overlay district ordinances are previously adopted policies for removing density constraints. The ADU ordinance will be amended to be consistent with state law. Additional new policies for removing constraints are the modification of regulations and expediting permits for ADUs set forth in Policy H1.3; rezoning properties for higher density in Policy H3.2; incentivizing higher density housing in Policy H3.3; and providing adequate utilities per Policy H5-

2. • Density and Development Standards – Density and development standards for each zone are discussed in Appendix F.

The MFRD zone provides for a density of eighteen units per acre. Allowed uses are multifamily residential and ADUs. Development standards are summarized in Table C of Section 153.110 of the Municipal Code. Policy H3.2b will be added to Policy H3.2 Rezone Properties to Allow Increased Housing to revise the MFRD zone unit maximum density to 2,200 square feet per unit (from current 2,400 square feet per unit) to meet Government Code Section 65583.2 regarding the default density of 20 units per acre for housing affordable to lower income households. The other standards in the MFRD zone including setbacks, height, and pervious area are appropriate.

Item A Page 38 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 22
The Special Conservation Planning (SCP) zone has a minimum lot size of five to 10 acres. This zoning category is reserved for areas of high environmental sensitivity (Fire zone, earthquake zone, streams, soil instability, flooding) as discussed in Appendix F (Page F-6) and are not appropriate for higher density development.

The Community Commercial (CC) zone is intended for commercial rather than residential uses, however single-family, supportive, transitional, and emergency shelter housing residential uses are permitted. This is a non-discretionary permit process but not by-right (CEQA analysis is still required). There is a limited amount of commercial zoning in the community and these areas are not significant opportunities for residential use.

Measure J height restrictions are set forth in Appendix F. The measure was a citizen initiative that has limited application to parcels zoned commercial that front on Woodside Road. There are no plans to seek an amendment to this policy constraint because it is uncertain whether voters would approve the amendment, and because the limitations apply to so few parcels that it only minimally affects the Town’s ability to promote housing development.
• Fees and Exactions – Woodside fees for single-family and small multifamily (ADUs) are set forth in Appendix F. These fees are shown on a per unit basis, as a percentage of development cost, and compared to other jurisdictions in San Mateo County.

Building permit fees for ADUs were recently reduced to encourage ADU development.

Per the Town’s Fee Schedule development fees (entitlement planning fees and building fees) are either flat fees or based on estimated building value, so the per unit fees for large multi-family units will be the approximately the same as ADU unit estimates. Fees are available on the Town website per the transparency requirements of Government Code Section 65940.1 with a link to the fees in the Planning Department section.
• Local Processing and Permit Procedures –Development approval for single-family and multifamily residential units require Architectural and Site Review Board (ASRB) review. Applications for ASRB review are available on-line with information on submittal requirements. Development standards are clearly described in the zoning ordinance. These permits take a reasonable amount of time to obtain as set forth in Appendix F Table F4 Permit Processing Times (Page F-5), and therefore do not create uncertainty for approval. The permit costs as a percentage of the development cost are reasonable in comparison with other San Mateo County cities as set forth in Appendix F Table F-3, (Page F-4).
• Compliance With State Density Bonus Law - Government Code Section 65915 sets forth the requirements for approval of density bonuses that may be requested if a portion of a project is affordable to low-and-moderate income households. Per new program H3.3.c (within policy “Incentivize Higher Density Housing”) the Town will develop a Density Bonus ordinance in 2024 setting forth the standards and application of density bonuses per State law.
• On/Offsite Improvements – Subdivision improvement requirements are set forth in Chapter 152, Article X of the Municipal Code. Modifications to the standards may be Item A Page 39 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 23
approved by the Planning Commission if it finds the alternative standards are in the public interest. The minimum street widths in Section 152.115 Table A are reasonable with 40-foot minimum width for rural roads, 60 foot minimum for collectors, and 80 foot minimum for arterials. Sewage disposal for most of the town consists of septic tanks and drain fields which is a lower cost solution than sewer. Geotechnical, grading, and erosion control requirements are consistent with the Town’s hilly terrain. Overall, on/offsite improvement requirements do not add unreasonable costs that would constrain the supply and affordability of housing.
• Codes and Enforcement – Building and Zoning codes are set forth in Chapters 150 and Chapter 153 of the Municipal Code. The Town periodically adopts the most recent version of the State Building Codes. The adopted code includes Chapter 7A – Materials and Construction Methods for Exterior Wildfire Exposure which may add to the cost of construction but is required due to the substantial risk of wildfire. Code enforcement procedures are commonly initiated in response to a complaint made to the Town and are carried out by the Town Community Preservation Officer and Town Attorney’s Office, if necessary. The codes and enforcement activities are customary and do not pose constraints on housing cost and supply.
• Constraints on Housing for Persons with Disabilities – Persons with disabilities may be housed in supportive housing. The definition of supportive housing includes housing that was previously referred to as group homes providing long term housing with supportive services for persons with disabilities. Supportive housing is permitted in all single-family residential zones per Municipal Code Section 153.100 Zoning Districts, Table A-1 Permitted Uses in Residential and Commercial Zoning Districts.

There are no special restrictions for this type of housing different from the restrictions and standards of the single-family residential zoning districts. The definition of family in the Municipal Code is: “An individual, or group of two or more persons occupying a dwelling and living together as a single housekeeping unit in which each adult resident has access to all parts of the dwelling.” This definition allows supportive housing of groups. The Housing Element includes a program to allow supportive housing in multi-family zones per the discussion of “Zoning for a Variety of Housing Types” above.
• Other Local Ordinances – The Town does not have other ordinances that would impact the cost and supply of housing such as inclusionary requirements for affordable housing or growth controls.
• Nongovernmental Constraints – These potential constraints include land costs, construction costs, and the availability of financing. Development costs including land and construction costs are discussed in Appendix F-1. The section above: “Land Use Controls Effect on Cost/Feasibility/Timing” discusses how development costs might be reduced through land cost reductions with higher density zoning and approval of ADUs. Financing for development in Woodside is available at the same availability as the County as a whole. There are no mortgage deficient areas or underserved groups.

To the extent that special governmental financing is needed for the development of affordable units at the Cañada College site, there are policies for the Town to assist the Item A Page 40 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 24
San Mateo Community College District with obtaining this financing per Policy H3.1 – Support New Independent Housing at Cañada College.

6. Analysis of Nongovernmental Constraints for Housing of All Income Levels HCD Comment
The element generally did not address this requirement. Provide analysis of construction cost, financing availability, approval time frames, requests to develop less than anticipated in the land use inventory, and hindrances to meeting RHNA.

Woodside Response
The Housing Element will combine the analysis of governmental and nongovernmental constraints into one section with nongovernmental constraints discussed as a subsection (see above). The analysis of development cost (land and building costs) is set forth in Appendix F-1.

Approval time frames are discussed in the proposed addition to the Housing Element for governmental constraints above. Requests for approval of projects with densities lower than planned has not been experienced for RHNA sites and is not anticipated to be an issue. The potential hindrances to the Town meeting its RHNA are discussed in other sections above and are addressed as needed with new policies to be added to the Housing Element.

7. Analyze Special Housing Needs and Opportunities for Energy Conservation HCD Comment
While the element includes some information on special needs groups, it must include the following additional information:
• Number of seniors.
• Number of persons with disabilities (not just seniors). • Analyze special housing needs for all groups.
• Analyze residential energy conservation opportunities.

Woodside Response
• Seniors
Recommended revision: add to Introduction Section 1, subsection on Special Needs Residents the following sentences: [as the first sentence] “The following analysis of special needs groups is based on Appendix B Housing Needs Data Report.” [amend the second sentence to read]: “In Woodside the population is aging, and Appendix B Figure 2 shows approximately 1,175 seniors in Woodside or approximately 21% of the total population.”
• Disabilities
Recommended revision: amend the third sentence in the special needs subsection to read:
“5.3% of residents of all ages have one or more disabilities and may require accessible housing.”
• All Group Needs – The Introduction Section 1 subsection on Special Needs Residents summarizes the needs of all special needs groups, and Appendix B Housing Needs Data Report contains detailed information on all special needs groups. With the exception of Item A Page 41 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 25
the large percentage of seniors, there are few people with special needs that would suggest policies other than existing and new zoning policies that support the establishment of special needs housing (emergency shelters, transitional and supportive housing). • Energy Conservation Opportunities
Recommended revision: add a new subsection 3.7 to Section 3.0 Cycle 6 Housing Element (and renumber subsequent sections) titled “Energy Conservation Opportunities” and insert the following text under the heading: “The housing needs analysis required by Government Code 65583(a) includes a requirement to analyze the opportunities for energy conservation in residential development. The Town of Woodside has adopted the most recent Title 24 CALGreen Building Code that includes energy conservation measures. Section A4.602 is a table of measures that will be implemented for new development that includes enhanced durability, construction waste reduction/recycling, pollutant controls, insulation, and Energy Star appliances.

Planning policies that assist with conservation include policies to meet the RHNA housing needs for all income groups, encouraging ADUs, establishing the multifamily MFRD zone, and rezoning of properties for higher density.” C. Housing Programs

1. Housing Program with Implementation Timeline
HCD Comment
Programs must have specific commitments and discrete timelines. Compliance comments were made on 21 programs/policies within the element.

Woodside Response
Each of the 21 program comments from HCD are responded to in a combination of changes to the full policy language (referred to as narrative) and changes to the summary in Table 3-6 Action Plan for Program Implementation.
• Program H2.c- Provide Public Transit
HCD comment: Include frequency of transit information outreach.

Recommended response: Add to narrative section: “on an annual basis” and revise Table 3-6 implementation column to read “annually” instead of “on-going”. • Program H3.1.a Cañada College Housing Support–
HCD comment: Describe resources to be provided, affordability levels, status, and timing.

Woodside response: The status of this program is described in the policy.

Recommended additional response: add to the narrative as new last sentences: “The Town will assist the District in obtaining local non-profit, state and/or federal financing to allow a portion of the units to be affordable to very low income (50 units) and low income (25 units) persons. The specific timing of this assistance and this program will be determined with the District based on the District’s facilities master plan implementation schedule but will be within the RHNA Cycle 6 planning period.” • Program H3.1.b Cañada College Development Standards Streamlining – HCD comment: Include affordability levels of the units.

Item A Page 42 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 26
Recommended revision: add to the narrative a second sentence: “The target housing goals are at least 75 units of which 50 are very low income and 25 are low income to implement the Cycle 6 RHNA.”
• Program H3.3.a Reducing Fees for Higher Density Housing – HCD comment: Add commitment to housing outcomes, completion by 2022, and allowed densities.

Recommended revisions: Add second and third sentences to the narrative: “The outcome of the review may be the reduction of fees for projects that are in multifamily (MFRD) zones, or achieve 20 units per acre, to assist with the creation of affordable units to meet the Cycle 6 RHNA. The review will be completed by the end of 2023.” Also amend the table implementation time frame to 2023.
• Program H3.3.b Expedite Higher Density Housing –
HCD comment: describe density, program outreach, and application to more than ADUs.

Recommended revisions: add to the first sentence in the narrative: “including ADUs, JADUs, and developments of 20 units per acre” (after the words higher density housing).

Add a second sentence: “Applicants for higher density housing will be informed of this policy when inquiries are made for higher density sites and as part of the ADU page on the Town website.” Amend the table targets column to add “and developments of 20 units per acre”.
• Program H4.1.a Enable Disabilities Housing Access –
HCD comment: state status of Reasonable Accommodation Procedure, add metrics and outreach.

Recommended revisions: Add to the narrative new sentences at the end of the paragraph:
“The Town will develop and implement a Reasonable Accommodation Procedure to inform disabled persons of their rights and remedies under the federal Fair Housing Act and Americans with Disabilities Act, including Town code exceptions and referral to County and non-profit resources for resolution of discrimination complaints, and funding resources for home modifications. The procedure will be developed and added to the existing Housing Resources website page by the end of 2023 and will be added to the annual mailout of information regarding ADUs.” • Program H4.1.b Amend Zoning for Disabilities Exceptions – HCD comment: specify what amendments are needed, specific actions and timing.

Town response: this policy does not refer to existing code requiring amendments, rather to future amendments that may be needed to respond to changes in State law which are currently unknown.

Recommended revision: Delete the existing policy language and substitute the following language in this section: “The Town will amend and expand the existing Municipal Code section 153.204 -Exceptions for Minor Improvements for Disabled Access – to include ADUs.”
• Program H4.1.c Group Homes –
HCD comment: add group homes are allowed in all residential zones, objective standards for facilities larger than six residents, and implementation timing.

Item A Page 43 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 27
Town Response: Under the new section for transitional/supportive housing types under the Zoning for a Variety of Housing Types discussed above, supportive housing is defined to include group homes which are allowed in all residential zones.

Recommended revision: add a second sentence to the narrative: “Group homes are considered supportive housing and are allowed in all residential districts pursuant to Welfare and Institutions Code Section 5116. Supportive housing of six or fewer residents is a permitted use in the Town’s zoning code. The Town will develop a supportive housing zoning classification in 2024 for facilities that exceed six residents as a conditional use including objective approval standards.” • Program H4.2 Promote Special Needs Housing Opportunities – HCD comment: Programs should include persons with special needs.

Town Response: As discussed above in the zoning for a variety of housing section, the major special needs group is seniors. Policies are included for disabled and homeless as these are required housing types for zoning, but there is little data support for large family and farmworker housing policies. The following revisions reorganizes the special needs housing into one section for clarity.

Recommended revisions: Add a new “Program H4.3 Other Special Needs Housing”.

Move the senior housing policy from the existing H4.2 section to this new section and retitle existing H4.2 to H4.3. Move the existing policy and program H4.3 Emergency and Transitional housing to the new special needs section 4.3 as subsection a. • Program H4.2.b Employee Housing Opportunities –
HCD comment: Description of employees does not match state requirements; clarify compliance with Employee Housing Act; add outreach, timing, metrics, and objectives.

Town Response: The senior housing policy in this section will be moved to the special needs policy as discussed above and the title of the section will be revised to remove seniors and disabled (also Table 3-6). The remaining policies will be focused on housing for public sector employees and private sector housing for estate management such as caretakers and equestrian managers. To provide the background for the new policies that will be added to this section the recommended revision adds a new subsection “l. Employee Housing Act” to section 1.3 Recent State Housing Laws and Town Implementation with the following Text: “The Employee Housing Act is set forth in Health and Safety Code Section 17000 and is administered and enforced by the San Mateo County Department of Environmental Health Services. The Act regulates housing that is provided by an employer to employees and establishes standards for the construction and maintenance of employee housing. The regulations apply to facilities housing five or more employees. The Town does not currently have employee housing facilities but has established policies in the event a private property owner desires to construct a facility.”
Recommended revisions to the revised “Policy H4.2 Promote Affordable Housing Opportunities for Service Personnel, Caretakers, Equestrian Managers/Employees and Public Sector Employees” add a new subsection/program “a. Private Sector Employee Housing - Revise the Town website Housing Resources page to provide information on the provisions of the Employee Housing Act and contact information for the San Item A Page 44 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 28
Mateo County Department of Environmental Health Services as the regulator of the law. Provide this information to property owners as part of the annual mailout for ADUs information.” Revise Table 3-6 to be consistent.
• Program H4.3.a Cooperate with Agencies Providing Emergency Shelter – HCD Comment: add specific implementation, frequency, timing, and funding that will be provided.

Woodside response: This policy is an on-going pledge of support through appropriate zoning for agencies that may wish to establish a facility. There is no Town funding pledged to support facilities.

Recommended revision: Add a second sentence to this policy: “Support includes the permitted use zoning for these facilities in the Community Commercial zone.” • Program H5. 1c Facilitate Neighborhood Preparedness – HCD Comment: Provide frequency, outreach, and specific actions.

Town Response:

Recommended revision: Add annual time frame to this policy for CERT training and add the following as a second sentence to this program: “Include information to the annual mailout to property owners about the CERT program and preparedness resources available on the Town’s Emergency Services page.”
• Program H5.2.a Provide Sewer to Address Waste Disposal Failures – HCD Comment: Add information on frequency of information dissemination and actions to improve sewer access.

Town Response: Allocation of sewer capacity and sewer connection policies are set forth in Town of Woodside Ordinance 2022-627 and the Sanitary Sewage Master Plan. These documents are available in the Town website. The low frequency of failures does not support continuous dissemination of this information, rather it is provided as needed in response to resident inquiries.
• Program H5.2.b Prioritize Sewer for Higher Density Residential Development – HCD comment: Program should prioritize affordable housing.

Woodside response:

Recommended revision: add the words “for affordable housing” to the policy. • Program H5.2.c Coordinate With Cal-Water to Ensure Adequate Water Supply – HCD comment: Confirm existing supply is adequate for RHNA sites, and when coordination will occur.

Woodside response: Appendix G Adequate Sites Analysis (Page G-5) states: “Water service and dry utilities are available throughout the community”. Additional information is available in the 2020 Urban Water Management Plan – Bear Gulch, including measures for water use and supply in drought years.

Recommended revision: Add to the implementation column for this policy in Table 3-6:
“and during the application process for developments fulfilling the RHNA.” • Program H6.2 Rehabilitate the Existing Housing Stock – HCD comment: add metrics to all programs, provide outreach.” Woodside response:

Item A Page 45 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 29
Recommended revisions: to the Program Measures column for policy “a.” add the words “Number of units approved”. Add to the same column for policy “b.” “Number of variances approved” Add to the same column for policy “c.” “Number of meetings held”. Add to the same column for policy “d.” “Number of programs utilized”.

Information about rehabilitation resources are on the Town website page Housing Resources.
• Program H6.2.b Provide Exceptions and Variances –
HCD comment: Clarify if program requires discretionary actions and qualifications for approval.

Town Response:

Recommended revision: add the following to the narrative of this section after the first sentence: “Municipal Code Section 153.940 sets forth the discretionary approval process for variances by the Planning Commission. Findings for approval are listed as the basis for the Commission decision.”
• Program H6.2.c Evaluate Development Standards in the Western Hills – HCD comment: Add what will be the revised development standards by the completion date.

Woodside response:.

Recommended revision: add the words including “minimum lot sizes” to the first sentence. Add a second sentence: “Complete the review by 2025.” • Program H6.2.d Utilize Rehabilitation Programs –
HCD comment: Include outreach and if information is available on website.

Woodside response: See information and revisions discussed in HCD Comment B3. above. • Program H6.3 Promote Sustainability Including Energy Efficiency HCD comment: Include outreach, timing for program a. and how efficiency will be encouraged.

Woodside response: Table 3-6 Program b. Program Measures column states information will be provided to encourage efficiency. See response above to recommended text to be added under Comment 7 Special Needs Housing and Energy Conservation.

2. Sites Analysis
HCD Comment
• The sites analysis is incomplete. Adequacy of sites and zoning not established. • Program H2.1a Higher Density Zoning Near Freeway – program must meet by-right requirements and accommodate lower income RHNA.
• Program H3.2a Rezone Town Sites – must meet rezone requirements. Clarify if sites are the same as sites near the freeway.

Town Response:
• Sites Analysis - The HCD Excel Sites Inventory spreadsheet contains the information on adequacy of sites and zoning.
• Program H2.1a Higher Density Zoning Near Freeway
Item A Page 46 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 30
Recommended revision: Revise the narrative of this policy to eliminate the Farm Hill site due to the open space covenant. [Add info on inclusion of Town-owned sites per Council direction] Also revise the narrative to add a third sentence: “The ordinance will allow the developments meeting the density standards to be a permitted use.” Revise Table 3- 6 to change the completion date for the rezonings from January 31, 2023, to December 31, 2023.

There are two by-right provisions of Section 65583.2 that do not apply to this policy or the sites. The first provides that vacant sites used in prior planning periods as RHNA sites, but not developed, must be rezoned within three years to allow by-right approvals of developments that contain at least 20% affordable housing. The privately owned 773 Cañada site has not been listed as an affordable housing site in prior planning periods making this provision inapplicable. The second by-right provision concerns rezoning of sites for by-right development of affordable housing within three years if the affordable site inventory does not accommodate RHNA allocations for all income levels. Per the revised site inventory set forth in revised Table 3-5, sufficient units for all income categories are identified making this provision inapplicable. • Program H3.2a Rezone Sites- The rezone requirements for by-right approvals are discussed in the above section.

Recommended revision – Eliminate the word “pre-adoption” Add a new second sentence: “The ordinance will allow the developments meeting the density standards to be a permitted use.”

3. Program for Extremely Low-Income Households
HCD Comment
The element must include a program to assist development affordable to extremely low-income households.

Woodside Response
Recommended revision: Add to Goal H3 Support Opportunities for Higher Density Housing, a new “Policy H3.4 Assist with the Development of Extremely Low-Income Housing” and add text under that subheading: “a. Assist with the development of extremely low-income housing through a variety of incentives. In addition to reducing fees and expediting permit processing as set forth in policies H3.3.a and b, consider modification of development standards (e.g., parking on a project basis), and assist non-profit developers with applications for State and federal grant, loan, and tax credit programs for project funding.”

4. Remove Governmental and Non-Governmental Constraints to Housing Production
HCD Comment
Per HCD Findings B5 and B6 provide an analysis of constraints.

Woodside Response
See responses to Findings B5 and B6 above.

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5. Affirmatively Further Fair Housing Opportunities
HCD Comment
Per B1 finding there must be a complete analysis of AFFH with policies that have specific commitments, metrics, and milestones.

Woodside Response
See above revised analysis, summary of existing policies, and recommended new policies.

6. Develop Plan to Incentivize ADUs at Affordable Rent
HCD Comment
HCD provided comments on five programs in the element.

Woodside Response
• Program H1.1.b Outreach to Encourage ADUs
HCD comment: Revise program to specify program timing, frequency of website update, and metrics.

Woodside Response: This policy includes the word “annually” in two places for frequency of outreach, website update, and outreach to organizations. The metric is annual. • Program H1.2.a Prepare and Distribute ADU Brochures
HCD Comment: Quantify frequency of distribution.

Recommended revision: add the word “annually” to the first sentence. • Program H1.2.c Conduct ADU Workshops
HCD Comment: Specify current status of implementation.

Woodside Response:

Recommended revision: replace the existing sentences with the following sentences to Program H1.2.c: “The Town conducted workshops in Fall 2022 for each district.

Information was provided on state and local ADU laws. A total of 135 residents registered for the five ADU Workshops, and, on average, 61 percent attended (82 residents). The Town Council District 2 Workshop had the highest attendance at 70%.

Of the 82 attendees, the comment cards recorded interest in developing 57 ADUs and 3 JADUs.”
• Programs H1.3.a Modify Regulations for Additional ADU’s on Properties Exceeding Two Acres; H1.3.b Remove Barriers to Construct ADU/JADUs; and H1.C.3 Reduce ADU Permit Fees
HCD comment: The word “consider” in each of these policies is not a commitment.

Revise to commit to a specific housing outcome by a date certain.

Recommended revisions: remove the word “consider” in each of these policies in the narrative and Table 3-6. Add the completion date of “by December 31, 2023”, to the narrative and revise the dates in Table 3-6 to 2023, except for program c Reducing Town Permit Fees. For this program make the following revisions to Program H1.3.c: remove the existing sentence and substitute the following sentence: “In 2022 the Town approved a plan to reduce certain ADU fees to remove barriers to construction. The estimated value of the fee reduction over the eight- year planning period is $960,000.” • Program H1.3.d Expedite Permitting for ADUs
Item A Page 48 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 32
HCD comment: Provide objectives including outreach.

Woodside response: The specific objective in the policy is to reduce the processing time from 30 days to 20 days.

Recommended revision: add to the policy the following additional sentence “This standard will be included in the annual mailed information document on ADU’s.” • Program H1.3.e ADU Amnesty Program
HCD comment: Provide proactive outreach and follow up actions.

Recommended revisions: Change the implementation date from 2020 to 2023. Add the following sentences to the policy: “The program will include inspection of units to provide either a completion certification for units that meet code, or list of corrections needed to meet code, with a completion certification after code improvements are completed and inspected. After the program has been approved, information on the program will be included in the annual mailed information document on ADU’s. The effectiveness of the program will be determined by the number of residents using the program.”
D. Quantified Objectives
HCD Comment
Element must include quantified objectives for construction, rehabilitation, and conservation of housing for all income groups. See Building Blocks for guidance.

Woodside Response:

The Building Blocks HCD website has been very helpful in developing the analysis and policies in the first draft element and preparing revisions for the second draft. The requisite analysis asks for the estimated number of units likely to be created by income level. The revised RHNA Table 3-5 and revised policies discussed above comply with this requirement, and the revised estimated number of units to be created exceeds the RHNA. Given the high value wellmaintained nature of existing housing in the community, the majority of units that will meet the housing needs of all income groups will be new construction, and only minor production is anticipated from rehabilitation or preservation, making the sample table in Building Blocks for quantified objectives inapplicable.

E. Public Participation
HCD Comment
In addition to the information provided, the element must include information on how all economic segments were included in the element preparation including circulation of the draft element to low and moderate- income households. The element must summarize public comments and show how they were incorporated into the element.

Woodside Response
The Housing Element Section 3.3 Public Outreach and Engagement Pages 3-4 through 3-9 provides the information requested. All residents received a postcard informing them of the Housing Element process and information workshops. The 21 Elements group conducted Item A Page 49 Town Council Special Meeting January 31, 2023 Woodside Response to HCD Comments 1-31-23 Page 33
workshops on Housing Elements on behalf of the local jurisdictions in San Mateo County which is summarized in this section with a demographic breakdown of attendees of the session on Woodside. Outreach for these sessions included 30 organizations involved in affordable housing production and fair housing advocacy.

F Consistency with the General Plan
HCD Comment
Discuss how internal consistency will be maintained throughout the planning period.

Woodside Response
Recommended revision: Add a new section 1.5 to the Introduction section titled “Consistency with the General Plan”; and add the following sentences to that section: “In addition to the integration of the Safety Element of the General Plan discussed in section 1.4. it is also necessary to ensure that the policies of the Housing Element are consistent with all General Plan elements. This review has occurred as part of the preparation of this Cycle 6 Housing Element, and it will be necessary to amend other elements of the General Plan to be consistent with the Housing Element policies. Ongoing consistency will be maintained as part of the annual Housing Element implementation review.” Item A Page 50 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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1.0 INTRODUCTION

1.1 Introduction
When we plan for housing in our communities – while it is imperative to gather and assess a myriad of data and statistics – it is equally important to reflect for a moment on the very basic concept of why a house – our home – is important. Why do our homes, or should they, make us happy?
“There is pretty strong evidence that the environment in which people live is closely linked to their well-being," says Graham Rowles, professor at the University of Kentucky. "It's sort of like the human animal attachment to territory is built into our DNA." "We have a need for a place that is called home," he adds. Home provides security, control, belonging, identity, and privacy, among other things. "But most of all, it's a place that provides us with a centering—a place from which we leave each morning and to which we return each evening."
So, given that shelter is one of our most basic human needs, ways in which we can increase housing security is intimately tied to increased health, happiness, and the ability to progress.

Children in stable housing move less and do better in school. Healthy, affordable housing reduces stress and disease, thereby benefitting both mental and physical health. Affordable housing frees up funds for food and health care. Affordable housing near employers attracts employees and reduces the environmental and infrastructure impacts of long commutes. A mix of housing options allows all individuals to be secure and contribute to the community.

This Cycle 6 Housing Element will stretch the Woodside community to diversify its housing stock and to increase affordability. The Cycle 5 Regional Housing Needs Assessment (RHNA) allocation was 62 units, which was achieved by constructing ADUs and single-family homes. The Cycle 6 RHNA allocation is 328 units. This creates a challenge in a high land and construction cost environment but also creates an opportunity to increase inclusivity in Woodside.

The Cycle 6 Housing Element must also comply with new housing considerations (e.g., Affirmatively Furthering Fair Housing, AFFH), and new reporting and analysis requirements.

The Housing Element, A Required General Plan Element
In California, each jurisdiction plans for housing by preparing a Housing Element. In Woodside, the first Housing Element was included in the 1970 General Plan (and was three pages long!).

The Housing Element is one of the seven mandatory elements required by the State of California in a General Plan (a blueprint for development and conservation). A Housing Element contains Item A Page 51 Town Council Special Meeting January 31, 2023 ATTACHMENT 1D
HCD Review Draft #2 – January 31, 2023
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goals, policies, and programs for meeting the Regional Housing Needs Allocation (RHNA). RHNA is assigned by the State for each region. Regional governments (for Woodside this is the Association of Bay Area Governments (ABAG)) then assign RHNA allocations to individual municipalities. The Housing Element is updated every eight years, and to be certified by the State, it must be reviewed and approved by local decisionmakers and the California Department of Housing and Community Development (HCD).

The format of this Cycle 6 Housing Element provides summary information in its Chapters to give the reader a broad overview and understanding, and more in-depth and source information is its Appendices.

1.2 Woodside Demographics – Characteristics & Trends
Developing a Housing Element that functions well for the community requires an understanding of its specific housing needs. This section provides an overview of Woodside’s demographics and its changing characteristics, as described more fully in The Housing Needs Data Report: Woodside, prepared by the ABAG/MTC and Baird + Driskell Community Planning. The full report is included in Appendix B.

a. People
Population: Woodside’s population increased by 6.1% between 2000 to 2020, from 5,352 to 5,676. In 2010, the population declined to 5,287 – primarily during the Great Recession, but the overall population trend over this 20-year period has increased. The population of Woodside makes up 0.7% of the population of San Mateo County. The Town’s population has been growing, but less than the Bay Area region overall.

Table 1-1. Population Growth Trends
Geography 1990 1995 2000 2005 2010 2015 2020
Woodside 5,034 5,320 5,352 5,476 5,287 5,617 5,676
San Mateo
County
649,623 685,354 707,163 719,844 718,451 761,748 773,244 Bay Area 6,020,147 6,381,961 6,784,348 7,073,912 7,150,739 7,595694 7,790537 (Table 2 in Housing Needs Data Report, Appendix B)
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Slight Increases in Ethnic Diversity: Woodside’s population is slowly becoming more diverse. In 2019, 79.0% of Woodside’s population was White (vs. 86.1% in 2010); 0.9% was Black/African American (vs. .4% in 2010); 7.3% was Asian (vs. 6.3% in 2010); and 9.1% was Latinx (vs. 4.6% in 2010). People of color continue to comprise a smaller proportion of the Town’s population than in San Mateo County and the wider Bay Area.

Table 1-2. Population by Race, 2000-2019 in Woodside
(Figure 3 in Housing Needs Data Report, Appendix B)
Growing Youth and Senior Populations: In Woodside, the populations of residents 5-34 and 65- 84 have both increased. The population of residents 35-44 have decreased. The median age in Woodside has also increased from 43.4 years old in 2000 to approximately 47 years old in 2019. 5% 6% 7%
90% 86% 79%
9%
0%
20%
40%
60%
80%
100%
2000 2010 2019
Share of Population
American Indian or Alaska Native, Non-Hispanic
Asian/API, Non-Hispanic
Black or African American, Non Hispanic
White, Non-Hispanic
Other Race or Multiple Races, Non-Hispanic
Hispanic or Latinx
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Table 1-3. Population by Age, 2000-2019
(Figure 2 in the Housing Needs Data Report, Appendix B) Household Income Levels: The Area Median Income (AMI)i in San Mateo County is $149,600 (based on a household of 4, effective April 1, 2021). In Woodside, 74.5% of households make more than 100% of the Area Median Income (AMI)1, while 8.0% make less than 30% of AMI, which is considered extremely low-income. In San Mateo County, 30% AMI is the equivalent to the annual income of $54,800 (based on a household size of 4, effective April 1, 2021). Many households with multiple wage earners – including food service workers, full-time students, teachers, farmworkers, livestock care providers, and healthcare professionals – can fall into lower AMI categories due to relatively stagnant wages in many industries.

Regionally, more than half of all households make more than 100% AMI, while approximately 15% make less than 30% AMI. According to State Department of Housing and Community Development data and maps, the Town has a predominance of higher income households compared to the region and is a Racially Concentrated Area of Affluence with high concentrations of higher income White residents.
1 Income groups are based on HUD calculations for Area Median Income (AMI). HUD calculates the AMI for different metropolitan areas, and the nine county Bay Area includes the following metropolitan areas: Napa Metro Area (Napa County), Oakland-Fremont Metro Area (Alameda and Contra Costa Counties), San Francisco Metro Area (Marin, San Francisco, and San Mateo Counties), San Jose-Sunnyvale-Santa Clara Metro Area (Santa Clara County), Santa Rosa Metro Area (Sonoma County), and Vallejo-Fairfield Metro Area (Solano County). The AMI levels in this chart are based on the HUD metro area where this jurisdiction is located. Households making between 80 and 120 percent of the AMI are moderate-income, those making 50 to 80 percent are low-income, those making 30 to 50 percent are very low-income, and those making less than 30 percent are extremely low-income. This is then adjusted for household size.

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Table 1-4. Households by Household Income Level
(Figure 10 in Housing Needs Data Report, Appendix B)
Poverty: People of color are more likely to experience poverty and financial instability as a result of federal and local housing policies that have historically excluded them from the same opportunities extended to Non-Hispanic White residents.ii These economic disparities also leave communities of color at higher risk for housing insecurity, displacement or homelessness. The groups with the highest poverty rates in Woodside are Asian/Pacific Islander residents (nearly 12%) and Non-Hispanic White residents (approximately 4.5%). Latinx residents have the lowest poverty rate (under 3%).iii
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Table 1-5. Poverty Status by Race in Woodside
(Figure 12 in Housing Needs Data Report, Appendix B)
Female-headed Households are more likely to Live in Poverty: In Woodside 46.7% of femaleheaded households with children fall below the Federal Poverty line, while 12.9% of female households without children fall below this line.

Homelessness: Woodside has almost no homeless residents. In 2017 and 2019, when the most recent “snapshot” surveys were conducted, no homeless persons were found to be living in Woodside (down from 2 in 2015, and 6 in 2013). The 2019 count determined that there were 1,512 people experiencing homelessness in San Mateo County, including: 901 unsheltered people living on the streets, in cars, in recreational vehicles (RVs), and in tents/encampments; and 611 sheltered homeless people (in emergency shelters and traditional housing programs).

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Table 1-6. Homeless Count Over Time in San Mateo County (Source: 2019 San Mateo County One Day Homeless County and Survey)

b. Jobs
Employment: Woodside residents most commonly work in the Financial and Professional Services industry (36.3%), followed by Health & Educational Services (26.5%). Since 2010, the number of jobs located in Woodside increased by 520 (32.5%). Generally, having a similar number of jobs and employed residents produces benefits for a community, such as reduced traffic and climate impacts, by allowing people who work in the community to also live there. Both San Mateo County and Woodside are job rich, meaning they have more jobs than employed residents. There are 2,430 employed residents and 3,410 jobsiv in Woodside, resulting in a jobsto-resident workers ratio of 1.4.

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Table 1-7. Resident Employment by Industry
(Figure 9 in the Housing Needs Data Report, Appendix B)

c. Housing and Household Characteristics
Woodside is primarily a Single-Family Residential Community: In 2020, 95% of homes in Woodside were single-family detached; 3% were single-family attached; and 1% were small multi-family (2-4 units). There are no medium or large multi-family units (5+ units) in Woodside.

Woodside’s share of housing stock, consisting of detached single-family homes, is above that of other jurisdictions in the region (95% as compared to 52% in the Bay Area).

New Homes Built: The number of new homes built in the Bay Area has not kept pace with the demand, resulting in longer commutes, higher prices, and greater displacement and homelessness. The number of homes constructed in Woodside increased 2.9% from 2010 to 2020, which is below the housing growth rate for San Mateo County and the Bay Area overall during this time-period (4% and 5% respectively).

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The Housing Stock in Woodside is Aging: The largest number of housing units in Woodside were constructed between 1960 and 1979 and are therefore 40-60+ years old.

Table 1-8. Housing Units by Year Structure Built in Woodside (Figure 19 in the Housing Needs Data Report, Appendix B) High Housing Costs: In 2020, the average sales price of a single-family home in Woodside was approximately $4,855,976. Home prices more than doubled between 2010 to 2020 in Woodside.

With high job growth and low housing growth in the County, the cost of homes in Woodside has increased significantly in the past decade.
305
528
607
332
227
0 100
200
300
400
500
600
700
Built 1939 or
earlier
Built 1940 To
1959
Built 1960 To
1979
Built 1980 To
1999
Built 2000 To
Beyond 2010
Units
value
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Table 1-9. Average Home Sales Prices in Woodside
Source: San Mateo Association of Realtors Annual Reports 2010-2020 Table 1-10. Home Values of Owner-Occupied Units
(Figure 7 in the Housing Needs Data Report, Appendix B) 2%1% 3%4% 6%16% 2% 14%
23%
0%
23% 20%
9%
23% 18% 6% 14% 8%
79%
19% 9%

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

90.0%
Woodside San Mateo County Bay Area
Percent of Owner Occupied Units
Units Valued Less than $250k Units Valued $250k-$500k
Units Valued $500k-$750k Units Valued $750k-$1M
Units Valued $1M-$1.5M Units Valued $1.5M-$2M
Units Valued $2M+
$0
$1,000,000
$2,000,000
$3,000,000
$4,000,000
$5,000,000
$6,000,000
Woodside Average Home Sales Price
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Vacancy Rate: Vacant units make up 10.0% of the overall housing stock in Woodside. The rental vacancy stands at 2.6%, while the ownership vacancy rate is 1.7%. Of the vacant units, the most common type of vacancy is For Seasonal, Recreational, Or Occasional Use.

Low Likelihood of Displacement/Gentrification: Ninety-eight percent (98%) of households in Woodside live in neighborhoods where low-income households are likely excluded due to prohibitive housing costs. According to research from the University of California, 0.0% of households in Woodside live in neighborhoods that are susceptible to or experiencing displacement or are at risk of undergoing gentrification.

Rental Prices: Similar to home values, rents have also increased dramatically in recent years. In Woodside, the largest proportion of rental units rented in the $2,000-2,500 category (37.4%), followed by rents in the $1,500-2,000 category (26%). Overall, rental prices in Woodside increased by 34% from 2009 to 2019. The median rent in 2019 was $2,150.v To rent a typical apartment without cost burden, a household would need to make $86,320 per year.

Table 1-11. Contract Rents for Renter-Occupied Units
(Figure 24 in the Housing Needs Data Report, Appendix B) The Level of Cost Burden Experienced by Residents: The U.S. Department of Housing and Urban Development (HUD) considers housing to be affordable for a household if the household spends less than 30% of its income on housing costs. A household is considered “cost-burdened” if it spends more than 30% of its monthly income on housing costs, while those who spend more than 50% of their income on housing costs are considered “severely cost-burdened”. In Item A Page 61 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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Woodside, 10.8% of households are cost-burdened, spending 30-50% of their income on housing, while 13.5% of households are severely cost-burdened, i.e., using the majority of their income for housing.

Special Needs Residents: The following analysis of special needs groups is based on Appendix B Housing Needs Data Report.

Some population groups have special housing needs that allow for greater mobility and accessibility. In Woodside, the population is aging, and Appendix B Figure 2 shows approximately 1,175 seniors in Woodside or approximately 21% of the total population. 5.3% of all residents have one or more disabilities and may require accessible housing. The most common disabilities in the town are ambulatory (2.6%), hearing (2.3%), and independent living (1.7%).vi Large families are generally served by homes with 3 or more bedrooms, of which there are 1,608 units in Woodside (89% of the housing). Among these 3+ bedroom units, 7% are renter occupied and 93% are owner occupied. Presently, 12.8% of Woodside households are larger households with five or more people. Cycle 5 affordable units (ADUs) were typically one-bedroom units.

Woodside residents require more housing options for seniors, more housing for people with disabilities, and more housing options for larger families that are renting units. Also, 5.6% of households are female-headed families (in Woodside 46.7% of female-headed households with children fall below the Federal Poverty line), which are often at greater risk of housing insecurity, or being at risk of losing their home, requiring more affordable housing. In addition, Cañada College is located within the Town of Woodside, resulting in greater needs for student and faculty housing, both on-campus and in the campus vicinity. While Woodside does not have agricultural land and the associated need for farmworker housing, it does have many large estates where property owners employ landscapers, caretakers, and equestrian managers, all of whom require housing.

Extremely Low-Income Households (ELI)
Number of Households - Housing Element Introduction Section 1.2 Woodside Demographics, Table 1-4 Household Income Levels, shows the percentage of extremely low-income households (less than 30% of Area Median Income-AMI) at 8% compared to 13.3% for the County and 14.7% for the Bay Area (Page 1-6). The 8% ELI Woodside households is comprised of approximately 144 households (1799 total households). HCD’s Housing Element guidance notes that jurisdictions may use their RHNA for very low-income households to calculate their projected extremely low-income households at 50% of the very low-income allocation. The Cycle 6 RHNA allocation to Woodside for extremely low-income households is 45 using 50% of the very low-income households allocation. Therefore, the Town will need to plan for an additional 45 ELI households housing needs over the next eight-year planning cycle.

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ELI Housing Needs – These households can be negatively impacted by the following factors:
• Cost burden – Is defined by a household paying more than 30% of its income on their housing payment. This is particularly important for ELI households as their discretionary income is limited. Per Figure 26-Cost Burden by Tenure, in Appendix B – Housing Needs Data Report (Page 39), six percent of renters are cost burdened (compared to 11.6% for ownership). This burden falls more heavily on lower income households. The Figure 27 – Cost Burden by Income Level (Page 40) - indicates 96% of ELI households are experiencing cost burden.
• Displacement - The table on Page 27– Disproportionate Housing Needs, of the Appendix K.1 - Woodside Fair Housing Assessment, shows eight percent of Woodside residents moved in the past year (compared to 12% County-wide) and the Urban Displacement Project does not identify any Woodside areas vulnerable to displacement. • Housing condition- The table on Page 27 – Disproportionate Housing Needs, of the Appendix K.1 - Woodside Fair Housing Assessment, shows fewer than 1% of households are living in units considered substandard.
• Overcrowding - The table on Page 27 – Disproportionate Housing Needs, of the Appendix K.1 - Woodside Fair Housing Assessment, shows there are no households experiencing overcrowding.
• Affordable unit availability- Per Table G-1 Cycle 6 RHNA (Page Appendix G-10) the Town will have sufficient housing production over the eight-year planning period to house the projected number of ELI households.

1.3 Recent State Housing Laws & Town Implementation
A wide range of new housing and housing-related laws have been adopted since the last Housing Element Update, many of which required changes to Town ordinances. Additionally, housingrelated laws adopted since the last General Plan update added requirements to the Cycle 6 Housing Element. Recent State laws primarily facilitate the development of additional housing by streamlining processes, relaxing development standards, up zoning, and decreasing local control, while other laws require additional reporting and integration with safety standards/planning.

While the most applicable recent State laws for Woodside have been the new ADU laws, and SB 9 (which allows for ministerial density increases in single-family neighborhoods), other State housing laws must also be tracked and analyzed for applicability. A review of these recent laws is included below. These laws are intended to facilitate development of additional housing and the creation of more inclusive, resilient communities.
a. New Laws Pertaining to Accessory Dwelling Units (ADUs) Over the last five years, State law has set new Statewide development standards for ADUs, marking a more top-down planning approach to housing production. The Town has shown an uptick in the construction of ADUs following the adoption of these laws, excepting the lull in 2020—the first year of the COVID-19 pandemic when contractors were scarcer. As the pandemic lingered, however, increased space at home became paramount (e.g., for extended family living Item A Page 63 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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quarters, rental income generation, home office space and home school space), and the increase continued in 2021.

AB 2299, SB 1069, and AB 2406 – Streamlining Affordable Housing Projects. In 2016, the Legislature adopted AB 2299, SB 1069, and AB 2406 that required streamlining of the approval process for ADUs, removal of barriers to their construction, and expansion of a jurisdiction’s capacity to provide more affordable housing units in the State. The bills also authorized “junior accessory dwelling units” (JADUs) in single-family zones.

To ensure consistency with these State requirements, a formal ADU code amendment change was recommended by the Planning Commission on February 15, 2017 (PC Resolution 2017-005) and approved by the Town Council on March 28, 2017 (Ordinance 2017-585). Woodside implemented these laws on their State effective date. The Town also adopted a JADU ordinance (Ordinance 2018-597), although AB 2406 was voluntary.

AB 68, AB 881, and SB 13 – Changes in Requirements and Approval Timelines for ADUs. In 2019, the Legislature adopted AB 68, AB 881 and SB 13 which amended existing requirements for ADUs including the maximum setback allowed on new and existing structures, minimum parking requirements, minimum sizes for ADUs, ministerial approval for ADUs, and a shorter timeline for approval. An ADU of 800 square feet, 16 feet in height with minimum side and rear setbacks of 4 feet, is permitted by-right on all single-family residential parcels.

To address these changes, the Planning Commission adopted a Resolution of Intention and Recommendation to the Town Council (PC Resolution 2020-001) to amend the Woodside Municipal Code (WMC). The Town Council adopted the changes to the WMC on July 14, 2020 (Ordinance 2020-610). Woodside implemented these laws on their State effective date.

AB 671 – Incentives for ADUs. In 2019, the Legislature adopted AB 671 which requires a local agency to include a plan in its Housing Element that incentivizes and promotes the creation of ADUs that can be offered at affordable rent for very low, low-, or moderate-income households.

The bill requires the Department of Housing and Community Development (HCD) to develop a list of existing State grants and financial incentives for operating, administrative, and other expenses in connection with the planning, construction, and operation of ADUs with affordable rent, as specified. The bill required HCD to post that list on its internet website by December 31, 2020.

The Cycle 6 Housing Element will include a program for incentivizing and promoting the creation of ADUs that can be offered at affordable rent for very low, low-, or moderate-income households.

AB 345 – ADUs: Separate Conveyance
Existing law authorizes a local agency by ordinance to allow an ADU to be sold or conveyed separately from the primary residence to a qualified buyer if certain conditions are met, including that the property was built or developed by a qualified nonprofit corporation and that the property is held pursuant to a recorded tenancy in common agreement.

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AB 345 requires local agencies to allow an ADU to be sold or conveyed separately from the primary residence to a qualified buyer, and imposes an additional condition on a tenancy in common agreement to include specified information, including a delineation of all areas of the property that are for the exclusive use of a cotenant, delineation of each cotenant’s responsibility for the costs of taxes, insurance, utilities, general maintenance and repair, and improvements associated with the property, and procedures for dispute resolution among cotenants before restoring to level action.
b. Decline of Single-family Zoning
Single-family zoning is now the focus of zoning reform, with the following bills approved in 2021.

SB 9 – Ministerial Units and Lot Splits. In 2021, the Governor signed SB 9 into law, allowing a property owner to split most any single-family lot into two and further allows the development of two units on each resulting lot with ministerial and objective design review only. SB 9 is effective for all local jurisdictions in the State on January 1, 2022.

On December 14, 2021, The Town of Woodside adopted an Urgency Ordinance and took a first reading of an identical regular ordinance to bring the WMC Subdivision and Zoning ordinances into compliance with SB 9 (Ordinance No. 2021-622 and Ordinance 2022-624). The second reading for Ordinance No. 2022-624 was conducted on January 11, 2022. The Town also adopted simple Objective Design Standards for SB 9 projects (Resolution No. 2021-7464) on December 14, 2021.

On February 22, 2022, the Town Council introduced revisions to the Town’s adopted SB 9 Ordinance concerning SB 9 projects in Very High Fire Severity Hazard Zones (qualifying that SB 9 projects which meet fire mitigation measures can be approved in the VHSFHZs) and habitat (slight wording change, from “land” to “site”).

SB-10 – Density. In 2021, the Governor signed SB 10 into law, allowing jurisdictions to zone any parcel for up to 10 units of residential density, at a height specified in the ordinance, if the parcel is located in a transit-rich area or an urban infill site (located in a city with boundaries that include some portion of either an urbanized area or urban cluster, as designated by the U.S. Census Bureau). The bill specifies that this rezoning would not be a project subject to the California Environmental Quality Act (CEQA), but that subsequent development proposals may be subject to CEQA. The bill prohibits a legislative body from subsequently reducing the density of any parcel subject to the ordinance. The bill would prohibit a residential or mixed-use residential project consisting of 10 or more units that is located on a parcel zoned pursuant to the provisions of the bill from being approved ministerially or by right or from being exempt from the CEQA. c. Affordable Housing
Previously, under the State’s Density Bonus Law for 100% affordable housing projects, a jurisdiction was required to allow an increase in density and provide up to three incentives or Item A Page 65 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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concessions to a development with certain levels of affordable units. AB 1763 expanded upon this.

AB 1763—Density Bonuses. In 2019, the Legislature adopted AB 1763 which requires jurisdictions to provide a density bonus to development projects that restrict 100 percent of their units as affordable to lower and moderate-income households.

The Town is currently in the process of developing its mandated Density Bonus Ordinance. d. Environmental Justice
Environmental justice in local planning addresses the fact that low-income communities and communities of color often bear a disproportionate burden of pollution and associated health risks. Environmental justice seeks to correct this inequity by reducing the pollution experienced by these communities and ensuring their input is considered in decisions that affect them. “Environmental justice” is defined in California law as the fair treatment of people of all races, cultures, and incomes with respect to the development, adoption, implementation, and enforcement of environmental laws, regulations, and policies (Cal. Gov. Code, § 65040.12, (e)).

SB 1000 – Environmental Justice in Local Land Use Planning. In 2016, the Legislature adopted SB 1000, requiring local governments to identify environmental justice communities (called “disadvantaged communities”) in their jurisdictions and address environmental justice in their general plans. This new law has several purposes, including to facilitate transparency and public engagement in local governments’ planning and decision making, reduce harmful pollutants and the associated health risks in environmental justice communities, and promote equitable access to health-inducing benefits, such as health food options, housing, public facilities, and recreation.

No disadvantaged communities are identified within or in the vicinity of Woodside. (SB 535 Disadvantaged Communities Map, using CalEnviro Screen 3.0 results (June 2018 Update)); therefore, an Environmental Justice Element is not required for the Town of Woodside. e. Housing Crisis
SB 330 – Housing Crisis Act of 2019. Effective January 1, 2020, and through its expiration on January 1, 2025 (five years), California Senate Bill SB 330 (the Housing Crisis Act of 2019 – Government Code 659411.1) expands or amends existing State legislation, including the Permit Streamlining Act and Housing Accountability Act, with the broad goals of facilitating increased production of new residential units, protecting existing units, and providing for an expedited review and approval process for housing development projects through submittal of a “preliminary application.”
The Town of Woodside did not deny any housing development project during the planning period (2015-2023).

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f. Streamlining
The Permit Streamlining Act was enacted in 1977 to expedite the processing of permits for development projects (Government Code § 65921). The Permit Streamlining Act achieves this goal by (1) setting forth various time limits within which State and local government agencies must either approve or disapprove permits; (2) providing that these time limits may be extended once (and only once) by agreement between the parties. In 2017, SB 35 took this one step further by linking the streamlining and discretionary versus ministerial review to RHNA status.

SB 35 – Streamlined Approval Process for Affordable Housing. In 2017, the Legislature adopted SB 35 which expedites approval of qualified zoning-compliant projects in a local jurisdiction that falls short of its Regional Housing Needs Allocation (RHNA) target, until its RHNA goals are met.

The bill allows a qualified multifamily housing development project to be approved via a ministerial approval, rather than a conditional use permit, if it satisfies a detailed list of objective planning standards.

The Town of Woodside met its prorated RHNA requirements as of June 25, 2019, and June 1, 2022, and was therefore not subject to SB 35 Streamlining (SB 35 Statewide Determination Summary, Appendix C).
g. Housing Project Denial
The Housing Accountability Act (Gov. Code, § 65589.5), also known as the “Anti-NIMBY Law,” was first adopted in 1982 to prevent local governments’ – and local communities’ – resistance to affordable housing from creating barriers to the development of affordable housing and emergency shelters. It limits local governments’ ability to disapprove applications for affordable housing projects and emergency shelters, allowing such disapprovals only in certain circumstances and based on very specific factual findings. The applicant (i.e., the developer), persons who would be eligible to live at the proposed development, and housing advocacy organizations, including trade associations, may bring lawsuits challenging local governments’ violations of the Act. SB 167 increased the denial test.

SB 167 – Revisions to the Housing Accountability Act. In 2017, the Legislature adopted SB 167 which requires findings of inconsistency if a housing development is denied, that are now based on a preponderance of evidence rather than substantial evidence in the record. If the local agency considers the housing development to be inconsistent, not in compliance, or not in conformity, the local agency is required to provide the applicant with written documentation identifying the provisions and rational for denying the project within a specified time-period. If documentation is not provided within this time-period, the application is deemed consistent, compliant and in conformity with the applicable plan, program, policy, ordinance, standard, requirement, or other similar provision.

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h. Housing Element Analyses
Recent legislation has substantially strengthened the obligations of the Housing Element, including requiring a more in-depth analysis of the sites inventory and potentially exclusionary patterns and practices.

AB 1397— Inventory of Land for Residential Development. In 2017, the Legislature adopted AB 1397 which revises what may be included in a jurisdiction’s inventory of land suitable for residential development. The changes require parcels on a jurisdiction’s Housing Element site list to have “realistic and demonstrated potential” for development during the planning period.

Parcels on the list are required to have sufficient water, sewer, and dry utilities infrastructure to support housing development, or be included in a jurisdiction’s existing General Plan program or other mandatory plan – including a public or private utility provider’s plan—to secure sufficient infrastructure to support housing development.

AB 686 – Affirmatively Furthering Fair Housing (AFFH). In 2018, the Legislature adopted AB 686 which introduced a duty to affirmatively further fair housing into California state law.

Affirmatively furthering fair housing is defined as taking meaningful actions that “overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity” for communities of color, persons with disabilities, and others protected by California law. It requires the state, cities, counties, and public housing authorities to administer their programs and activities related to housing and community development in a way that affirmatively furthers fair housing, and not take any action that is materially inconsistent with this obligation. It adds a requirement for an AFFH analysis to the Housing Element for plans that are due beginning in 2021. The analysis is required to examine issues such as segregation and resident displacement, as well as the required identification of fair housing goals. i. Employee Housing Act
The Employee Housing Act is set forth in Health and Safety Code Section 17000 and is administered and enforced by the San Mateo County Department of Environmental Health Services. The Act regulates housing that is provided by an employer to employees and establishes standards for the construction and maintenance of employee housing. The regulations apply to facilities housing five or more employees. The Town does not currently have employee housing facilities but has established policies in the event a private property owner desires to construct a facility.
j. Housing Element Reporting Requirements
Each jurisdiction is required to create an annual report on the status and progress in implementing the housing element of its general plan using forms and definitions adopted by the California Department of Housing and Community Development (HCD). The report must be Item A Page 68 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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submitted to HCD and the Governor’s Office of Planning and Research on or before April 1 of each year.

AB 879 – Additional Information required in Housing Element Annual Planning Reports. In 2017, the Legislature adopted AB 879 which requires that additional information be provided in the Annual Planning Reports (APRs), including:

1. Number of housing development applications received during the prior year;

2. Number of units included in all development applications received during the prior year;

3. Number of units approved and disapproved during the prior year; and,

4. Listing of sites rezoned to accommodate that portion of the city or county’s share of the regional housing need for every income level that could not be accommodated on specific sites.

The bill also requires a jurisdiction, in its analysis of governmental constraints, to include an analysis of any currently authorized, locally adopted ordinances that directly impact the cost and supply of residential development.

The Town of Woodside provides the required information in the Housing Element Annual Planning Report (APR) that is required to be submitted to the Housing and Community Development Department (HCD) by April 1st of each year. This report is presented to the Town Council in January and is transmitted to HCD immediately after, well in advance of the April 1st deadline each year. j. Surplus Land
The Legislature is facilitating the use of available public land for development of housing.

SB 791 – Surplus Land Unit. In 2021, the Legislature adopted SB 791 which establishes the Surplus Land Unit within the Department of Housing and Community Development. The Unit facilitates the development and construction of residential housing on surplus land, owned by local jurisdictions. The bill authorizes the Surplus Land Unit to facilitate agreements between housing developers and local agencies that seek to dispose of surplus land; provide advice, technical assistance and consultive and technical service to local agencies with surplus land and developers that seek to develop housing on surplus land; and collaborate with specified state agencies to assist housing developers and local agencies with obtaining grants, loans, tax credits, credit enhancements and other types of financing that facilitate the construction of housing on surplus land.
k. Real Property: Discriminatory Restrictions
The Legislature is working to revise discriminatory language in real estate documents and Codes, Covenants and Restrictions (CC&Rs)
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AB 1466 – Real Property: Discriminatory Restrictions. AB 1466 requires a county recorder, title insurance company, escrow company, real estate broker, real estate agency, or association that delivers a copy of a declaration, governing document or deed to a person who holds an ownership interest in property to also provide a Restrictive Covenant Modification form with specified procedural information. The bill requires the county recorder of each county to establish a restrictive covenant program to assist in the redaction of unlawfully restrictive covenants.

1.4 Housing and Safety – Integration of the Housing Element with the Local Hazard Mitigation Plan (LHMP) and the Safety Element
Housing policies focus on the provision of safe and sanitary housing to meet existing and future needs of the community. The Housing Element can help strengthen community resilience by ensuring that the location and design of new or improved housing complies not only with existing building codes, but with potential hazards in mind. Opportunities to strengthen or replace structures identified as vulnerable to hazards can be promoted through existing maintenance or rehabilitation programs, and particularly through policies regarding nonconforming, substantially damaged, or substantially improved properties. Recent legislation requires the integration of the Housing Element with the Safety Element with the Local Hazard Mitigation Plan.

SB 1241 – Coordination with the Department of Forestry and Fire Protection. SB 1241, adopted in 2012, requires local agencies to coordinate with the Department of Forestry and Fire Protection to ensure uses of land and policies in State Responsibility Areas and Very High Fire Hazard Severity Zones will protect life, property and natural resources from unreasonable risks associated with wildland fires; and identify methods and strategies for wildland fire risk reduction and prevention within state responsibility areas and very high fire hazard severity zones.

The local agency is required to review and, if necessary, revise the Safety Element upon each revision of the Housing Element or Local Hazard Mitigation Plan, but not less than once every eight years.

The objective of aligning the Housing Element and the Safety Element, or Local Hazard Mitigation Plan, is to ensure that additional housing is planned for areas that are most suitable for development, while considering local conditions. Wildfire risk and availability of infrastructure are some of the factors that will need to be considered.

The State’s Land Use Priorities include (1) Promoting infill; (2) Protecting natural and working landscape and recreation areas; and (3) Encouraging efficient development patterns adjacent to existing developed areas, that are served by transportation and that minimize ongoing costs Item A Page 70 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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associated with Natural Disasters.

SB 379 – Climate Adaptation. In 2015, the State Legislature adopted SB 379 requiring local cities and counties to include climate adaptation and resiliency and new information relating to flood and fire hazards in the Safety Element of their General Plans. Specifically, § 65302(g)(4) of the Government Code was revised to require that cities and counties update their Safety Elements to address climate adaptation and resiliency strategies applicable to their jurisdiction. The updates are required at the next update of their Local Hazard Mitigation Plan (LHMP), on or after January 1, 2017.

To meet the requirements of SB 379, the Safety Element (or the LHMP where information is incorporated by reference) must include:

1. A Vulnerability Assessment identifying the risks that climate change poses to the local jurisdiction, and the geographic areas at risk from climate impacts.

2. A set of goals, policies, and objectives based on a Vulnerability Assessment for the protection of the community. This should consider ways to address social equity and look for opportunities to collaborate across jurisdictions.

3. A set of feasible implementation strategies to carry out the goals, policies, and objectives, such as avoiding or minimizing the wildfire hazards associated with new uses of land, developing early warning systems, and relocating public facilities outside of at-risk areas.

SB 1035 – Coordination with Safety Element and LHMP. In 2018, the Legislature adopted SB 1035, requiring the Safety Element to be reviewed and revised as necessary to address climate adaptation and resiliency strategies and would require, after these revisions, the local agency to review and, if necessary, revise the Safety Element upon each revision of the Housing Element or Local Hazard Mitigation Plan, but not less than once every 8 years, to identify new information related to flood and fire hazards and climate adaptation and resiliency strategies.

SB 99 – Emergency Access. In 2019, the Legislature adopted SB 99 requiring jurisdictions, upon the next revision of the Housing Element on or after January 1, 2020, to review and update the Safety Element to include information identifying residential developments in hazard areas that do not have at least 2 emergency evacuation routes. SB 99 requires that upon the next revision of the Housing Element on or after January 1, 2014, the Safety Element be reviewed and updated as necessary to address the risk of fire for land classified as State Responsibility Areas and land classified as Very High Fire Hazard Severity Zones. This review is required to consider advice included in the Office of Planning and Research’s most recent publication of “Fire Hazard Planning”, General Plan Technical Advice Series.

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AB 747 – Evacuation Routes. This bill, upon the next revision of a local hazard mitigation plan on or after January 1, 2022, or beginning on or before January 1, 2022, if a local jurisdiction has not adopted a local hazard mitigation plan, would require the safety element to be reviewed and updated as necessary to identify evacuation routes and their capacity, safety, and viability under a range of emergency scenarios. This bill would authorize a city or county that has adopted a local hazard mitigation plan, emergency operations plan, or other document that fulfills commensurate goals and objectives to use that information in the safety element to comply with this requirement by summarizing and incorporating by reference that other plan or document in the safety element.

SB 379, SB 1035, SB 99, and AB 747 all require that the Housing Element update be coordinated with an update to the Safety Element or Local Hazard Mitigation Plan (LHMP). Local jurisdictions without an LHMP must update their Safety Elements beginning on or before January 1, 2022.

The Town of Woodside recently updated and adopted (November 16, 2021) its Local Hazard Mitigation Plan as part of the San Mateo County Multijurisdictional LHMP (2021), Appendix D.

1.5 Consistency with the General Plan
In addition to the integration of the Safety Element of the General Plan discussed in section 1.4. it is also necessary to ensure that the policies of the Housing Element are consistent with all General Plan elements. This review has occurred as part of the preparation of this Cycle 6 Housing Element, and it will be necessary to amend other elements of the General Plan to be consistent with the Housing Element policies. Ongoing consistency will be maintained as part of the annual Housing Element implementation review.
i The Area Median Income (AMI) is the middle spot between the lowest and highest incomes earned in San Mateo County. The AMI for the county is $104,700 for a single person, $119,700 for a household of two, and $149,600 for a family of four.
ii Moore, E., Montojo, N. and Mauri, N., 2019. Roots, Race & Place: A History of Racially Exclusionary Housing the San Francisco Bay Area. Hass Institute. iii Some demographic groups do not have reported poverty rates or may have over/underestimated rates as a result of having a limited sample for the particular group. iv Employed residents in a jurisdiction are counted by place of residence (they may work elsewhere) while jobs in a jurisdiction are counted by place of work (they may live elsewhere). v Note that contract rents may differ significantly from, and often being lower than, current listing prices. vi Root Policy Research, Fair Housing Assessment, Woodside (2022), p 20.

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3.0 CYCLE 6 (2023-2031) HOUSING ELEMENT
Introduction
Access to secure and affordable housing continues to impact various population demographics in California. Households continue to spend a significant portion of their incomes on housing.

Increased housing prices and limitations to affordable housing has created a growing inequality and limited advancement opportunities for many Californians. Increasing numbers of Californians experience homelessness due to the increase in housing costs. Locally, San Mateo County and the wider Bay Area, has increased high wage job growth, but housing construction has occurred at a fraction of the pace, creating a local housing shortage for low to moderate wage earners, and some of the highest home ownership and rental costs in the nation.

State Legislators have passed numerous bills in recent years to facilitate construction of more housing units in an effort to increase access to housing for a broader range of Californians. The State aims to increase housing supply and access for households of various income levels, by imposing significant increases to mandated housing unit allocations for all jurisdictions throughout the State, and by encouraging development in all parts of jurisdictions. The State’s Housing and Community Development Department (HCD) through the Association of Bay Area Governments (ABAG), allocated the number of units needed for the RHNA 6 among the region’s counties and specific jurisdictions.

3.1 Cycle 6 RHNA Allocation
For Cycle 6 (2023-2031), Woodside’s assigned Regional Housing Needs Allocation (RHNA) is 328 units. The assigned units are distributed by income level: 90 units for Very Low-Income households, 52 units for Low-Income households, 52 units for Moderate-Income households, and 134 units for Above-Moderate-Income households (based on income levels for a family of 4 in San Mateo County, April 1, 2021).
i
In past Housing Element cycles, the Town of Woodside met requirements for Very Low-Income to Moderate-Income units through the development of Accessory Dwelling Units (ADUs). Given the

5.3 times increase in the RHNA allocation from the previous Cycle and recent Woodside property owner ADU construction numbers, the Cycle 6 Housing Element will not be able to rely solely on ADUs to reach its affordable unit allocations. Additionally, HCD requires local jurisdictions to plan for varied housing types, including but not limited to, residences, ADUs, and medium to high density housing units. This Housing Element needs to include ADUs, single family residence (SFRs), subdivisions, accessible units, and rezoned property (to increase allowable housing density). To achieve the RHNA allocation requirements, this Plan provides policy direction to amend local development regulations that allow for diverse housing unit types accessible at various income levels. HCD Housing Element Guidance recommends the inclusion of a buffer of additional units above the base RHNA allocation to ensure the allocation is achieved. The Town has planned for a Item A Page 73 Town Council Special Meeting January 31, 2023

ATTACHMENT IE
HCD Review Draft #2 – January 31, 2023
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20% buffer over the 328 unit RHNA allocation so that, should some expected housing types/developments not be completed, the Town will still be able to reach its target number of units; therefore, this Housing Element includes a Plan for the construction of 393 units (328+20%) (Table 3-1).

Table 3-1. RHNA 6 Cycle Housing Targets
Very Low
Income
Low Income Moderate
Income
Above
Moderate
Income
Total
ABAG Regional
Housing Needs
(2023-2031)
90 52 52 134 328
Housing Needs
+ 20% Buffer
108 62 62 161 393
Changes in Distribution between Cycles 5 and 6: The required distribution of the ADU income affordability in Cycle 6 has changed. The distribution for Cycle 5 counted 70% of ADUs accessible to Very Low-Income households; 15% of ADUs accessible to Low-Income households; 10% of ADUs accessible to Moderate-Income households; and 5% of ADUs accessible to Above ModerateIncome households. Cycle 6 distribution has changed and is more evenly distributed between Very Low-Income (30%), Low-Income (30%), and Moderate-Income (30%), with 10% of the ADUs counted as Above Moderate-Income housing units. This distribution is based on research and findings developed by 21 Elements and ABAG (Appendix E). a. Increasing the Supply of ADUs and other Housing Unit Types In Cycle 6, HCD requires that the Town include rezoning and changes to development standards that facilitate the development of various housing types, which can include mid to high density housing, increases in ADU development, and more opportunities for land divisions that can accommodate additional housing units. Given changes to Woodside’s development standards and processing requirements between 2017 and 2021, the Town saw an increase in the development of ADUs. During the three highest recent years (2018, 2019 and 2021), the Town issued building permits for an average of 17 ADUs (Appendix I), while increasing ADU permit issuance to 20 units in 2021, with significant increases expected based on increased interest, and Housing Element Programs that will reduce barriers to ADU and JADU construction along with increases in the number of ADUs allowed on properties with fewer constraints. The Town includes Programs to reduce development standard barriers, increase outreach, and possibly reduce fees to facilitate the increase in ADU production before 2031. In addition to increased ADU production, the Town’s Item A Page 74 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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RHNA targets would be met through a combination of subdivisions, development of vacant and underutilized lots, new higher density housing at Cañada College (part of the San Mateo County Community College District), and new higher density housing projects on privately-owned property. [Add Town-owned parcels if directed by Council to add] In consultation with HCD, and pursuant to the ABAG Technical Memorandum "Using ADUs to Satisfy RHNA", the following affordability distribution for ADUs is used:

Table 3-2. Affordability of ADUs
Income Levels Allocation of Units by Income Category
Very Low Income 30%
Low Income 30%
Moderate Income 30%
Above Moderate Income 10%
TOTAL 100%

3.2 Town Collaboration with 21 Elements
The Town of Woodside, with all jurisdictions in San Mateo County, have shared resources during the past and current Housing Element updates within a group in San Mateo County known as 21 Elements, named for the 21 Jurisdictions in San Mateo County. Over the past several years, 21 Elements continually meets to discuss new housing policies introduced by the State to ensure each jurisdiction meets its housing unit targets. 21 Elements includes consulting resources provided by Baird + Driskell Community Planning, a firm with long ranging experience in State Housing laws. 21 Elements collected information from jurisdictions throughout the State that have worked with HCD and that now have certified Housing Elements, sharing “lessons learned”. 21 Elements helps guide the process—providing best practices, technical information, and consultation with HCD on important requirements/deadlines and legislative updates.

Technical assistance provided by 21 Elementsto assist with each jurisdiction’s HCD certification of Housing Element Cycle 6 includes, but is not limited to, the following:
 Analysis of ADU Affordability: Utilized research from a Statewide survey of ADUs, conducted by the Center for Community Innovation at the University of California, Berkeley, and prepared a memo that assists Bay Area jurisdictions to determine appropriate income level affordability distribution among constructed ADUs (Appendix E).  Cost Constraints Analysis: Collected information about costs of constructing different types of housing units in the 21 San Mateo jurisdictions. Jurisdictions submitted Item A Page 75 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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information about fees charged for reviewing and building housing units as well as other fees, such as those charged for road maintenance and by school districts.  Stories: Collected stories of people throughout San Mateo County regarding the challenges they face in finding and continuing to live in housing that is and remains affordable. The personal stories brought individual human experiences to the forefront of the many issues.  Affirmatively Furthering Fair Housing (AFFH): Retained the services of Root Policy Research to prepare ‘Affirmatively Furthering Fair Housing’ analyses for each jurisdiction (Section 3-4). Root Policy Research also assembled information on State and federal fair housing laws to ensure jurisdictions are tracking all compliance requirements.  Virtual Tours with HCD: Completed Virtual Tours with HCD providing Woodside with the opportunity to share possible approaches for meeting its housing allocation targets, to discuss any challenges it is facing, and to get input on what HCD would be looking for in different parts of the Housing Element.

3.3 Public Outreach and Engagement
After receiving RHNA allocations, the Woodside Town Council established a RHNA Subcommittee consisting of members of the Planning Commission and Town Council to discuss the challenges of the RHNA allocations and strategies to meet the housing goals; suggesting sites for rezoning to meet housing target types and numbers spread across income categories and demographics based on the various environmental, fire hazard, and infrastructure constraints within the Town.

In addition to the publicly noticed RHNA Subcommittee meetings, the Planning Commission and Town Council conducted several meetings that included the review and discussion of this Housing Element. All public outreach and engagement meetings are outlined in Table 3-3 below (Appendix H):

Table 3-3. Public Engagement Summary
Date: Virtual
Meetings and
Webinars:

Town Council: Planning
Commission:

RHNA
Subcommittee:

December 15,
2020
RHNA Meeting
April 14, 2021 ‘Let’s Talk
Housing!’ (LTH)
Introduction
with Woodside
Break-out
Session
June 8, 2021 RHNA 5 Progress
& RHNA 6
Allocation
June 16, 2021 RHNA 5 Progress &
RHNA 6 Allocation
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October 13, 2021 LTH: “Why
Affordability
Matters”
October 26, 2021 Joint TC/PC/ASRB
Study Session on
SB 9
October 27, 2021 LTH: “Housing &
Racial Equity”
November 4, 2021 ADU Workshop
with Woodside
Break-out
Session
November 10,
2021
LTH: “Housing in
a Climate of
Change”
November 17,
2021
SB 9 Code
Amendment,
Subdivisions
December 1, 2021 LTH: “Putting it
all Together for
a Better Future”
December 1, 2021 SB 9 Code
Amendment, Zoning
December 14,
2021
SB 9 Code
Amendment,
Subdivisions &
Zoning
January 12, 2022 Cycle 6 Housing
Element
January 25, 2022 Mayor appoints a
RHNA
Subcommittee
February 2, 2022 Housing Study
Session
February 16, 2022 Housing Study
Session
February 17, 2022 RHNA
Introduction
February 24, 2022 RHNA Planning
March 2, 2022 Review Draft HE
Chapters 1 and 2
March 8, 2022 Review Draft HE
Chapters 1 and 2
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March 10, 2022 Final RHNA
Recommendation
March 16, 2022 Review RHNA
Subcommittee
Recommendation
March 22, 2022 Review RHNA
Subcommittee
Recommendations
April 25, 2022 Review of Draft
HE Chapter 3
May 10, 2022 Review of Chapter
3 and complete
draft Housing
Element to
release for a 30-
day public
comment period
May 18, 2022 –
July 1, 2022
(44-day Public
Comment Period)
July 12, 2022 Formal Response
to Comments
December 13,
2022
Review HCD
Comment Letter
and Response to
Comments memo
January 10, 2023 Review HCD
response
regarding Townowned sites
January 31, 2023 Review revised
Housing Element
documents for
submittal to HCD
for second review
a. Countywide Meetings conducted by 21 Elements – ‘Let’s Talk Housing!’ With a countywide perspective and an understanding of the State Housing and Community Development Department’s (HCD) legal requirements, 21 Elements helps jurisdictions work together to satisfy legal mandates to address the county and region’s housing crisis.

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During Spring of 2021, 21 Elements conducted a series of ‘Let’s Talk Housing!’ workshops introducing members of the public to requirements for a State certified Housing Element, including discussions on topics such as the necessity for varied housing types in all jurisdictions. 21 Elements assembled San Mateo County jurisdictions into six different meeting groups.

Woodside, Atherton, Daly City, Pacifica, Half Moon Bay, and the unincorporated County joined together for a session on April 14, 2021. This meeting provided opportunities to learn from and listen to community members about their housing needs, helping to make sure everyone is involved in shaping the Town’s and other jurisdictions’ futures.

As part of the April 14, 2021, meeting, each municipality conducted its own “break-out” session to encourage participants to share their housing related views, ideas, concerns, and solutions. At Woodside’s session, members of the public raised issues regarding the complexity of regulations they encounter, and the time involved. Many mentioned that residents are mostly drawn to Woodside because of its rural character and natural environment yet noting challenges to building in the Town given its many environmental constraints. Other comments included the need to streamline the development process and encourage the Town to work with the County Department of Environmental Health to adopt regulations allowing alternative septic technologies. Community members discussed whether the Town would change its approach to meeting RHNA targets solely through ADUs. Participants acknowledged the challenge of maintaining the Town’s rural character while also meeting the housing needs of all sectors of the community, including fire fighters and teachers, who often travel long distances to their employment in Woodside and the wider region.

The April 14, 2021, ‘Let’s Talk Housing!’ meeting was advertised via the Town website, 21 Elements website, posting at Town Hall and the Library, NextDoor Woodside, and by mailed postcard to all residents (Figure 3-1). At a countywide level, 21 Elementsindicates that six introductory ‘Let’s Talk Housing!’ meetings were held and 1,024 registered for the series. Of those who registered, the majority identified as White (66%) or Asian (15%) and were 50 years or older; nearly half were 50 to 69 years old and almost a fifth were over 70. Almost half lived over 21 years in their homes and three-fourths owned their homes.

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Figure 3-1. The Announcement for First Public Outreach Meeting and Woodside Break-Out Session conducted on April 14, 2021, was posted on the Town Website.

A second set of workshops in the form of issue-based webinars (Figure 3-2) was conducted during the Fall of 2021, including:
 Why Affordability Matters: Why housing affordability matters to public health, community fabric and to county residents, families, workers, and employers;  Housing and Racial Equity: Why and how our communities have become segregated by race, why it is a problem and how it has become embedded in our policies and systems;  Housing in a Climate of Change: What is the connection between housing policy and climate change and a walk through the Housing & Climate Readiness Toolkit; and,  Putting it All Together for a Better Future: How design and planning for much-needed new infill housing can be an opportunity to address existing challenges in our communities.

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Figure 3-2. The Announcement for the ‘Let’s Talk Housing!’ issue-specific Webinars and Discussions, conducted between October 13, 2021, – December 1, 2021, was sent to all Town residents.

The Town of Woodside also participated in a meeting conducted jointly with the County of San Mateo and several other San Mateo County jurisdictions on ‘Developing Second Units’ held on November 4, 2021 (Figure 3-3). The Town provided an overview of the process for developing ADUs in Woodside and provided participants with a copy of the PowerPoint prepared for the presentation. Questions focused on the number of ADUs permitted by lot size in the Town.

Woodside joined 21 Elementsfor a facilitated series of listening sessions held between September and November 2021 to hear from various stakeholders who operate countywide or across multiple jurisdictions. The four sessions convened more than 30 groups including fair housing organizations, housing advocates, builders/developers (affordable and market-rate), and service providers, to provide observations on housing needs and input for policy consideration.

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Figure 3-3. The Town participated in a Workshop on Constructing Second Units/ ADUs, conducted on November 4, 2021.
b. RHNA Subcommittee Meetings
On January 25, 2022, the Town’s Mayor appointed a RHNA Subcommittee with members from the Planning Commission and Town Council to review and discuss sites that could accommodate increased housing densities providing units that are accessible to various household types, Item A Page 82 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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including but not limited to, public service workers, families working in the local area, and citizens with disabilities. All meetings were publicly noticed and open for public participation, to discuss strategies that encourage more affordable housing units, and various types of housing units in Woodside that are necessary to meet the RHNA targets.

The Subcommittee conducted meetings on February 17, 2022, February 24, 2022, and March 10, 2022. The Subcommittee considered criteria for selecting sites, such as underutilized land with few hazard constraints (e.g., earthquake faults, flood zones, constrained access routes in high fire zones, etc.), better access to services and transportation corridors, and most importantly, sites that may be able to access sewer, as most of Woodside properties must use onsite septic systems for effluent disposal. The Subcommittee also reviewed the demographic trends in the community considering special needs groups such as seniors, residents with disabilities, service personnel of Town Center businesses, and students attending Cañada College. c. Planning Commission and Town Council Housing Element Update Meetings The Town completed public hearings with the Planning Commission and Town Council as identified in Table 3-3 above, and described further in Appendix H.

The hearings included review of sites to be rezoned for increased density. In consultation with property owners of possible sites for increased density, some sites were removed (e.g., Stanford University and Woodside Road properties) from consideration given the lack of interest in developing increased housing densities from those property owners.

During the hearings, Town residents expressed significant concerns with sites proposed for increased density, citing concerns related to traffic, design, and changes to community character.

Town residents expressed a desire to meet RHNA targets with increased development of ADUs.

The Town Council acknowledged resident concerns, while recognizing different housing types are necessary, therefore including Programs that provide opportunities for different housing types that are accessible to people of varied income levels
d. Key Takeaways from the Town Meetings
The Town’s outreach and engagement process recognized the need to balance the community’s desire to maintain the Town’s rural character, with a need to provide housing for all members of the wider community; and for the Town to do its part in creating regulations that can accommodate the development of, and access to, various types of housing.

3.4 Affirmatively Furthering Fair Housing (AFFH)
Cycle 6 Housing Elements shall remove barriers to segregation, choose and locate housing sites accessible to residents in the wider community, and establish policies and programs that provide Item A Page 83 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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tools to overcome historic patterns of segregation. This focus on creating a more “level playing field” for housing access to all members of the community is referred to as “Affirmatively Furthering Fair Housing” (AFFH). This section summarizes the AFFH analysis prepared for Woodside and San Mateo County by the firm Root Policy Research (Appendix K). a. The Requirement to Affirmatively Furthering Fair Housing In 2018, the State of California established a mandate requiring all California jurisdictions to affirmatively further fair housing. The AFFH obligation is similar to the federal obligation in the 1968 Fair Housing Act which requires the Federal Department of Housing and Urban Development (HUD) to administer its programs and activities related to housing and urban development in a manner that furthers the purposes of the Fair Housing Act. In the bill that established the AFFH mandate, the State updated housing element requirements to include an assessment of fair housing practices, and an analysis of the relationship between available sites for housing development and increased housing access opportunities.

AB 686 requires all public agencies to “administer programs and activities relating to housing and community development in a manner that affirmatively furthers fair housing and take no action inconsistent with this obligation”. Not only does the law prohibit discrimination; it requires “inclusion” to overcome historic patterns of segregation.

The Federal Housing Act prohibits discrimination of people based on protected classes: race, color, ancestry/national origin, religion, disability, sex, and familial status. California law1 also extends protections based on age, sexual orientation, gender identity or expression, genetic information, marital status, military or veteran status, and source of income (including federal housing assistance vouchers).
b. History of Segregation in the Region
According to the San Mateo County Historical Association, San Mateo County’s early non-white population worked in a variety of industries, including logging, agriculture, food service, hospitality, and entertainment. Shipbuilding during and after World War II attracted many 1 California’s Planning and Zoning Law (Gov. Code, § 65000 et al.) prohibits jurisdictions from engaging in discriminatory land use and planning activities. Specifically, Government Code section 65008, subdivision (a), deems any action taken by a city or county to be null and void if such action denies to an individual or group of individuals the enjoyment of residence, landownership, tenancy, or any other land use in the state due to illegal discrimination. Under the law, it is illegal to discriminate based on protected class such as race, color, religion, sex, gender, gender identity, gender expression, sexual orientation, marital status, national origin, ancestry, familial status, age, source of income, disability (including individuals in recovery for drug or alcohol abuse, whether or not they are actively seeking recovery assistance), veteran or military status, or genetic information.

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residents to the Peninsula, including the first sizeable migration of African Americans to the Bay Area (Appendix K). Enforcement of racial covenants forced non-white residents into segregated neighborhoods usually located near less desirable neighborhoods near areas of high pollution and few public services.

The private sector contributed to segregation through activities that discouraged or prohibited integrated neighborhoods, often by using restrictive covenants and real estate redlining practices.

Woodside properties included recorded land deeds specifying only “members of the Caucasian or White race shall be permitted” to occupy sold homes.

A timeline of major federal Acts and court decisions related to fair housing, zoning and land use is included in Figure 3-4.

Figure 3-4. Public and Legal Actions that Influence Fair Access to Housing.

As shown in the timeline, exclusive zoning practices were common in the early 1900s. Courts struck down only the most discriminatory and allowed those that would be considered today to have a “disparate impact” on classes protected by the Fair Housing Act (1968). c. Woodside Fair Housing Assessment
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The firm Root Policy Research assisted San Mateo jurisdictions in preparing their ‘Affirmatively Furthering Fair Housing’ (AFFH) analyses. The full report for the Town of Woodside, along with the Countywide report, is included in Appendix K.

This section summarizes the primary findings from the Fair Housing Assessment prepared for the Town of Woodside, including the following sections: fair housing enforcement and outreach capacity, integration and segregation, access to opportunity, disparate housing needs, contributing factors, and the Town’s fair housing action plan. These findings include:
 The Town can improve the accessibility of fair housing information on its website and resources for residents experiencing housing discrimination.  Compared to the county overall, Woodside has limited racial and ethnic diversity:

Countywide, racial/ethnic minorities account for 61% of the overall population; however, in Woodside, they account for 21%.
 Economic diversity is also limited: 75% of households in Woodside earn more than 100% of the Area Median Income (AMI) compared to 49% in the county overall. Nearly all census block groups in the town have median incomes above $125,000 and households experiencing poverty is low throughout Woodside.
 Persons with disabilities is analyzed in Appendix B Housing Needs Report and summarized in Section 1 of the Housing Element. Woodside has proportionately fewer households with disabilities (5%) than the County as a whole (8%), but this proportion is likely to increase as the population ages. The most common disabilities in the town for all ages are ambulatory (2.6%), hearing (2.3%), and independent living (1.7%)  Woodside households are predominately Married Couple Households at 74.8 % with Female Headed Households representing 5.6% of the households (compared to 10.1% County-wide)., but 46.7% of the female headed households in Woodside fall below the Federal Poverty Line.
 Countywide, racial, and ethnic minority populations are disproportionately impacted by poverty, low household incomes, cost burden, overcrowding, and homelessness compared to the non-Hispanic White population. Additionally, racial, and ethnic minorities are more likely to live in areas with low to moderate resources and be denied for a home mortgage loan.
 Woodside is entirely contained within a single census tract—the standard geographic measure for “neighborhoods” in U.S. Census data products. As such, the Town does not contain any non-White racial/ethnic concentrations or concentrations of low-income wage earners.
 In the regional context, Woodside represents an area for a population with increased opportunities, while having minimal accessibility to low- and moderate-income households.
 Persons with disabilities is analyzed in Appendix B Housing Needs Report and summarized in Section 1 of the Housing Element with a statement that Woodside has proportionately fewer households with disabilities (5%) than the County as a whole (8%), but this Item A Page 86 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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proportion is likely to increase as the population ages. The most common disabilities in the town for all ages are ambulatory (2.6%), hearing (2.3%), and independent living (1.7%) In summary the Town experiences low levels of racial and economic diversity, disability, and female headed households compared to the County. The aging of the population and the large percentage of female headed households below the poverty line are potential areas of concern for future policies regarding fair housing, integration, and segregation.

The Town of Woodside RHNA Plan meets 67% of its affordable housing requirements through the development of Accessory Dwelling Units (ADUs). ADUs are constructed throughout the community and are available to all sectors of the community, in support of AFFH goals. The Housing Element includes broader housing types, including higher density housing at Cañada College and on one privately owned property. [may be amended to add town site(s) per 1-31-23 Council direction]
d. Contributing Factors to Fair Housing Issues
One of the major methods of creating affordable housing in Woodside is through development of ADUs. Resident survey information concerning ADUs demonstrates strong support for this approach. The Town will continue to support ADU creation supplemented by rezoning of one site [may be amended to add town site(s) per 1-31-23 Council direction] for higher density housing and supporting higher density housing at the Cañada College site. Potential factors that may make implementing these solutions difficult include the following:
• Limited local job opportunities.
• Limited access to frequent and widespread public transportation. • Lack of access to sewer infrastructure.
• Limitation on density from existing zoning.
• Difficulty in obtaining public or private financing to offset the costs of affordable units. • Timing of the Cañada College capital improvement program. • Limited site capacity due to environmental constraints such as fault zones, fire hazards, and slopes.

These factors are addressed by the discussion of sites in Section 3.8- Strategies to Meeting RHNA Cycle 6, and policies in Section 3.9- Housing Program and Action Plan – Guiding Principles, Goals, Policies, and Programs.

3.5 Governmental and Non-Governmental Constraints on Housing The following is a description and analysis of the various potential constraints on the production of a variety of housing types to meet the housing needs of all income levels as required by Item A Page 87 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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Government Code 65583(a)(5). Where appropriate, policies to overcome the constraints are included in the descriptions.
• Land Use Controls Constraints – Appendix F - Housing Development Constraints, Development Costs, and Zoning Analysis, provides an analysis of constraints due to land use controls. As explained in Section 3.6, Sites Inventory and Assessment to Accommodate Housing Units, substantial portions of the community are affected by natural hazards including fault traces, landslides, severe fire hazards, streams, and flooding. These hazards combined with State open space and environmental preservation goals, and historic community values for a low-density environment discussed in the Wildland Urban Interface section of Appendix F, support the low-density zoning limitations with single family residences.
• Land Use Controls Effect on Cost/Feasibility/Timing – Appendix F and Appendix F-1 also have information on development cost and the limitations on housing development based on high land and construction costs. High construction costs are found throughout the Bay Area and are due to high labor and materials costs that cannot be significantly lowered by local housing policy. High land costs in Woodside are partly a function of a desirable environment due to the beauty of the area and its low density, combined with quality schools and proximity to high paying employment. Increasing density of zoning throughout the community could decrease per unit land cost but is inconsistent with environmental goals and constraints. Per Policy H2.1a - Provide Opportunities for Higher Density Housing with Access to High Resource Areas, the Town will rezone a site [may be amended to add town site(s) per 1-31-23 Council direction] for higher density housing and has previously established a multi-family zone allowing higher densities. The Town’s ADU and SB9 ordinances are a form of density increase throughout the community within the context of existing zoning as they add additional units in all zones regardless of zoning lot size minimums. Appendix F has information regarding the timing for development approvals and the time frames for Woodside are comparable or better than other San Mateo County jurisdictions and indicate a reasonable expectation of approval certainty. Woodside development fees are comparable to other San Mateo jurisdictions as a percentage of development costs.
• Past and Present Programs to Remove Governmental Constraints – The ADU, SB9, and Multifamily Residential Development (MFRD) overlay district ordinances are previously adopted policies for removing density constraints. The ADU ordinance will be amended as needed to remain in compliance with state law. Additional new policies for removing constraints are the modification of regulations and expediting permits for ADUs set forth in Policy H1.3; rezoning properties for higher density in Policy H3.2; incentivizing higher density housing in Policy H3.3; and providing adequate utilities per Policy H5-2. • Density and Development Standards – Density and development standards for each zone are discussed in Appendix F.

MFRD Zone – this multi-family zone currently provides for a density of 18 units per acre.

Allowed uses are multifamily residential and ADUs. Development standards are summarized in Table C of Section 153.110 of the Municipal Code, and are analyzed for Item A Page 88 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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potential constraints in Appendix F. Policy H3.2b will be added to Policy H3.2, Rezone Properties to Allow Increased Housing, to revise the MFRD zone unit maximum density to 2,200 square feet per unit (from current 2,400 square feet per unit) to meet Government Code Section 65583.2 regarding the default density of 20 units per acre for housing affordable to lower income households. The other standards in the MFRD zone including parking, setbacks, height, and pervious area are appropriate.

Special Conservation Planning (SCP) Zone -This zone has a minimum lot size of five to 10 acres. This zoning category is reserved for areas of high environmental sensitivity (Fire zone, earthquake zone, streams, soil instability, flooding) as discussed in Appendix F (Page F-6), providing increased constraints for higher density development.

The Community Commercial (CC) Zone – This zone is intended for commercial rather than residential uses. However, single-family, ADUs, supportive, transitional, and emergency shelter housing residential uses are permitted. This is a non-discretionary permit process but not by-right (CEQA analysis is still required). There is a limited amount of commercial zoning in the community and these areas are not significant opportunities for residential use.

Measure J Height Restrictions – These restrictions are set forth in Appendix F. Measure J was a citizen initiative that has limited application to parcels zoned commercial that front on Woodside Road. There are no plans to seek an amendment to this policy constraint because it is uncertain whether voters would approve the amendment, and because the limitations apply to so few parcels that it only minimally affects the Town’s ability to promote housing development.
• Fees and Exactions – Woodside fees for single-family and small multifamily (ADUs) are set forth in Appendix F. These fees are shown on a per unit basis, as a percentage of development cost, and compared to other jurisdictions in San Mateo County. Building permit fees for ADUs were recently reduced to encourage ADU development. Per the Town’s Fee Schedule, development fees (entitlement planning fees and building fees) are either flat fees or based on estimated building value, so the per unit fees for large multifamily units will be approximately the same as ADU unit estimates. Fees are available on the Town website per the transparency requirements of Government Code Section 65940.1, with a link to the fees in the Planning Department section. • Local Processing and Permit Procedures – Development approval for single-family and multifamily residential units require Architectural and Site Review Board (ASRB) review.

Applications for ASRB review are available on-line with information on submittal requirements. Development standards are clearly described in the zoning ordinance.

These permits take a reasonable amount of time to obtain as set forth in Appendix F, Table F4 Permit Processing Times (Page F-5), and therefore do not create uncertainty for approval. The permit costs as a percentage of the development cost are reasonable in comparison with other San Mateo County cities as set forth in Appendix F Table F-3, (Page F-4).

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• Compliance With State Density Bonus Law - Government Code Section 65915 sets forth the requirements for approval of density bonuses that may be requested if a portion of a project is affordable to low-and-moderate income households. Per new program H3.3.c (within policy “Incentivize Higher Density Housing”) the Town will develop a Density Bonus ordinance in 2024 setting forth the standards and application of density bonuses per State law.
• On/Offsite Improvements – Subdivision improvement requirements are set forth in Chapter 152, Article X of the Municipal Code. Modifications to the standards may be approved by the Planning Commission if it finds the alternative standards are in the public interest. The minimum street widths in Section 152.115 Table A are reasonable with 40- foot minimum width for rural roads, 60 foot minimum for collectors, and 80 foot minimum for arterials. Sewage disposal for most of the town consists of septic tanks and drain fields which is a lower cost solution than sewer, but difficult to support on many parcels in Town due to site constraints. Geotechnical, grading, and erosion control requirements are consistent with the Town’s hilly terrain. Overall, on/offsite improvement requirements do not add unreasonable costs that would constrain the supply and affordability of housing. • Codes and Enforcement – Building and Zoning codes are set forth in Chapters 150 and Chapter 153 of the Municipal Code. The Town periodically adopts the most recent version of the State Building Codes. The adopted code includes Chapter 7A – Materials and Construction Methods for Exterior Wildfire Exposure which may add to the cost of construction but is required due to the substantial risk of wildfire. Code enforcement procedures are commonly initiated in response to a complaint made to the Town and are carried out by the Town Community Preservation Officer and Town Attorney’s Office, if necessary. The codes and enforcement activities are customary and do not pose constraints on housing cost and supply.
• Constraints on Housing for Persons with Disabilities – Persons with disabilities may be housed in supportive housing. The definition of supportive housing includes housing that was previously referred to as group homes providing long term housing with supportive services for persons with disabilities. Supportive housing is permitted in all single-family residential zones per Municipal Code Section 153.100 Zoning Districts, Table A-1 Permitted Uses in Residential and Commercial Zoning Districts. There are no special restrictions for this type of housing different from the restrictions and standards of the single-family residential zoning districts. The definition of family in the Municipal Code is: “An individual, or group of two or more persons occupying a dwelling and living together as a single housekeeping unit in which each adult resident has access to all parts of the dwelling.” This definition allows supportive housing of groups. The Housing Element includes a program to allow supportive housing in multi-family zones per the discussion of “Zoning for a Variety of Housing Types” above.
• Other Local Ordinances – The Town does not have other ordinances that would impact the cost and supply of housing such as inclusionary requirements for affordable housing or growth controls.
• Nongovernmental Constraints – These potential constraints include land costs, construction costs, and the availability of financing. Development costs including land and Item A Page 90 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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construction costs are discussed in Appendix F-1. The section above: “Land Use Controls Effect on Cost/Feasibility/Timing” discusses how development costs might be reduced through land cost reductions with higher density zoning and approval of ADUs. Financing for development in Woodside is available at the same availability as the County as a whole.

There are no mortgage deficient areas or underserved groups. To the extent that special governmental financing is needed for the development of affordable units at the Cañada College site, there are policies for the Town to assist the San Mateo Community College District with obtaining this financing per Policy H3.1 – Support New Independent Housing at Cañada College.

3.6 Sites Inventory and Assessment to Accommodate Housing Units Woodside’s RHNA targets for Cycle 6 require the Town to identify sites where rezoning could occur to accommodate increased housing densities and varied housing types, as well as units that are accessible by disabled persons.

Identifying potential sites to accommodate increased higher density housing development, requires evaluation of all parcels throughout Woodside.

The State of California is the largest State in the Country by population and third largest by size, and is therefore widely diverse in topography, flora and fauna habitat conditions, economic viability, conservation opportunities, population demographics, access to adequate infrastructure, and housing types. Given the various competing interests, Woodside’s location intersects with many important competing State goals.

With such competing goals for the State of California, identifying sites for increased housing density is a challenge, with very high fire hazard zones, steep topography, limited access to sewer, and environmentally protected habitats (e.g., stream corridors that contain habitats for endangered or threatened species such as the San Francisco Garner Snake and California Red legged Frog) widespread through the Town of Woodside. Housing development in Woodside is additionally constrained by geologic conditions such as known and inferred earthquake faults, including the San Andreas Fault, and active landslide areas in the Western Hills.

This Housing Element includes an analysis of land best suited to accommodate increased housing density in areas with minimal environmental constraints, locations outside of high fire zones that have limited emergency access, access to sewer, and adjacenciesto arterial roads identified in the Town’s General Plan Circulation Element. Further information on areas unsuitable for housing due to natural features that create the potential for natural disasters can be found in the General Plan Natural Hazards and Safety Element.
a. Biological, Geotechnical, and Infrastructure Constraints in Woodside The Town of Woodside includes environmentally sensitive areas with longstanding State protections, most notably within stream/riparian corridors. The following maps were reviewed Item A Page 91 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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to identify potential constraints relating to fault zones, flood zones, steep slopes and fire hazard in the Western Hills, and environmentally sensitive areas.

Figure 3-5. Fault Zones in the Town of Woodside.

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Figure 3-6. Flood Zones in the Town of Woodside.

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Figure 3-7. Western Hills and Environmentally Sensitive Areas Item A Page 94 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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b. Vacant Lands
The Town of Woodside includes vacant parcels that could be developed for single-family residences and ADUs under current zoning. However, many of these parcels have significant development constraintsfor high density housing such as topography, steep slopes, soils stability, high fire risk zone, and earthquake fault proximity, and large-scale septic tank suitability. c. Sewer Capacity
Two-thirds of the parcels in Woodside utilize private on-site septic systems for effluent waste disposal. The rest of Town (yellow areas as depicted on Figure 3-8) utilizes septic systems. Only a third of the parcels in Town are served by sewer. All sewage from Woodside flows to the Wastewater Treatment Plant in Redwood City.

Areas of Woodside that are served by or are eligible to connect to sewer are in the central, northern, and eastern parts of Woodside. No sewer service is available in the western or southern portions of the Town.

Since the 1960’s, the Town has been directly responsible for the creation of two public sanitary sewer districts, as follows:

Redwood Creek/Fair Oaks Sewer Assessment District: On May 23, 1968, the Town established the Redwood Creek Trunk Sewer Assessment District (RCS) with sewer capacity established through the Fair Oaks Sewer Maintenance District (FOSD). The RCS includes the Redwood Creek Trunk Assessment Area and the Glens Sewer Collection System Area. The RCS was primarily formed because of health and safety concerns that exists within the Woodside Glens, which had a history of failing septic systems dating back to 1959. The contractual capacity for the RCS was and continues to be 150,000 gallons per day. There are approximately 550 existing connections (pink and purple areas on Figure 3-8).

Town Center Sewer Assessment District: The contractual capacity of the Town Center Sewer Assessment District (TCAD) is 100,000 gallons per day. This District is producing 40,000 gallons per day; therefore, 60,000 gallons per day capacity remains. The Town owns and operates the infrastructure in Town. The Town contracts with the West Bay Sanitary District to provide engineering and maintenance services. There are approximately 180 existing connections (green areas on Figure 3-8).

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Figure 3-8. Town Sewer Areas and Districts
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d. Affirmatively Furthering Fair Housing (AFFH)
The Town of Woodside has higher land values and is less diverse than San Mateo County as a whole (Section 1.1(a), Demographics). The Town was developed as a single-family residential community. Originally, many of the homes were second homes for people living in San Francisco who spent part of their time on the Peninsula where they enjoyed warmer weather. Woodside’s early subdivisions date back to 1887 (then part of San Mateo County). Many of the subdivisions, like other parts of the Peninsula, the State, and the country, had racially restrictive covenants, preventing people of color from purchasing homes. While the U.S. Supreme Court in 1948 ruled such racially restrictive housing covenants unenforceable, many of the patterns that they created remain and continue to influence the characteristics of the Town today.

AB 686, passed in 2018, requires jurisdictions to overcome patterns that restrict access to some members of the community. It requires that jurisdictions promote inclusive communities, further housing choices, and address racial and economic disparities through all government programs, policies, and operations. The Cycle 6 Housing Element, for the first time, requires jurisdictions to ‘Affirmatively Further Fair Housing’, which means jurisdictions are required to set up programs and opportunities to remove barriers to integration and create housing opportunities for all people, so that all people benefit from ‘high opportunity resources’ such as good schools, parks, services, and other amenities.

For identifying sites for affordable housing, AB 686 requires that sites either be located throughout the community, so that neighborhoods of low-income housing are not created; or if clustering is recommended, jurisdictions need to provide a rationale for why concentrating affordable units in a particular location will benefit residents because of proximity to good schools, libraries, parks, and other facilities.

HCD’s best practices for selecting sites to accommodate the lower income RHNA include the following considerations:
 Proximity to transit;
 Access to high performing schools and jobs;
 Access to amenities, such as parks and services;
 Access to health care facilities and grocery stores;
 Locational scoring criteria for Low-income Housing Tax Credit (TCAC) Program funding;  Proximity to available infrastructure and utilities;
 Sites that do not require environmental mitigation; and,  Presence of development streamlining processes, environmental exemptions, and other development incentives.

The considerations listed above are similar to the siting and amenity considerations raised by many of San Mateo County’s Service Providersii, which include the following:

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 Near transit-oriented sites, and either near governmental services, or with access to supportive social services, grocery stores, and pharmacies;  Near parks, or having parks integrated into the development. This is particularly important for youth;
 Near Community Centers. This is particularly important for youth;  Near good schools and senior centers;
 High-walkability neighborhoods;
 ADU accessible facilities;
 Parking; and
 Public bathrooms.

For Woodside, ADUs, including JADUs, are built throughout the community which meets this objective of providing affordable housing in all parts of the community to affirmatively further fair housing (Figure 3-9). This geographic dispersion of new units avoids concentration of affordable units in one area and promotes integration and access to opportunities and resources.

It is anticipated that SB 9 units may also be built throughout the community. Woodside passed an SB9 Ordinance in December 2021 and is considering amending this Ordinance to encourage SB9 applications as part of the policies for the next Housing Element cycle. For sites with higher density housing projects, the AFFH “lens” requires that sites be selected to offer opportunities and benefits to the people living in them, as discussed above in Areas of Opportunity in Woodside.

The concept of Affirmatively Furthering Fair Housing and its application to Woodside is discussed in more detail in Section 3.4, with additional background provided in Appendix K.

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Figure 3-9. Location of Single-Family Residences and ADUs for which Building Permits were issued during Cycle 5 (2015-2021).
e. Areas of Opportunity within Woodside
The RHNA Subcommittee considered some of the following factors in assessing possible sites for affordable housing:
 More level Terrain: Sites that are not dominated by steep terrain, outside of fault zones, have fewer environmental constraints and generally require less engineering and therefore offer less expensive project construction.

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 Proximity to Transportation Corridors: Woodside does not have mass transit therefore proximity to key corridors such as I-280, Hwy. 84, Cañada Road, and Sand Hill Road, were considered because of the convenience they provide for all residents, including residents of affordable housing development.
 Willing Property Owners: To enhance the likelihood that the sites would be developed with affordable housing, the RHNA Subcommittee focused on sites with property owners that were interested in having their properties rezoned.

While most of the Town utilizes septic systems, the RHNA Subcommittee also considered availability of sewer, to reduce the amount of land that would need to be dedicated to a septic system for multiple units, as described in the discussion of Sewer Capacity above. f. Adequate Sites Inventory
Housing Elements are required to include an inventory of land suitable and available for development of housing within the planning period and that are sufficient to provide for the jurisdiction’s share of the regional housing need for all income levels and housing unit types. “An effective Housing Element provides the necessary conditions for conserving, preserving and producing an adequate supply of housing affordable at a variety of income levels and provides a vehicle for establishing and updating housing and land-use strategies to reflect changing needs, resources and conditions….The Housing Element establishes a jurisdiction’s strategy to plan for and facilitate the development of housing over the five-to-eight-year planning period (eight-year period for Woodside) by providing an inventory of land adequately zoned or planned to be zoned for housing and programs to implement the strategy”.iii For Woodside, as discussed in Section 3.1, the Town’s RHNA number is 328 units, which is then distributed by income level. A 20% buffer is added per HCD guidance which represents an additional 65 units for a total of 393 units. A combination of new single-family homes, ADU’s where there are existing and new residences, subdivisions, pipeline projects, and higher density housing at Cañada College and one privately-owned property, [Town owned sites may be added here per 1-31-23 Council direction] are anticipated to meet the RHNA allocation, while providing varied housing types that are accessible to a wider demographic, including people with disabilities.

Identifying Adequate Sites: The ‘Adequate Sites Inventory’ identifies enough sites for increased density in conjunction with programs that will allow for more ADUs and medium density development enabling the Town to meet the RHNA allocation targets (Appendix G – Adequate Sites Inventory). The inventory consists of a summary Table G-1 Proposed RHNA Plan, and a more detailed HCD Excel Spreadsheet Inventory. The inventory is shown graphically in Figure G-2 – Housing Sites and Environmental Constraints. The inventory is required to include the “realistic and demonstrated potential” for identified sites to accommodate housing development. The detailed HCD Excel Spreadsheet Inventory identifies each property by its address/Assessor Parcel Number (APN) and the ability to be served by utilities.

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The 773 Cañada Road site requires a connection to an existing sewer district. The estimated cost of installing sewer for 773 Cañada is $125,000 which is a minor cost for a development estimated to cost $27 million (at $500 per square foot development cost as estimated by Appendix F-1, excluding land cost). For the ADU/JADU units assumed in Table 3-5 Proposed RHNA Plan, the sites will have existing infrastructure serving the existing residences that will serve the ADUs as well.

The cost of expanding septic tanks or leach fields to accommodate ADUs will vary on a parcel-byparcel basis and cannot be defined as a constraint at this time.

Town owned sites may be added here per 1-31-23 Council direction Per Government Code Section 65589.7 the Town will provide a copy of the Housing Element to all utility service providers following its approval by the Town Council. Utility providers are required to prioritize service to developments that provide affordable housing. g. Special Needs Housing
Government Code Sections 65583 (c) (4)(A), (c) (1) and 65583.2(c) require the assessment of zoning and site availability for a variety of special needs housing including emergency shelters, transitional housing, supportive housing, low barrier navigation centers, single room occupancy units, farmworker housing, and manufactured housing. Emergency shelters, transitional housing, supportive housing, and low barrier navigation centers are forms of housing for the homeless, some with accompanying services that assist with employment training, substance abuse counseling, and transition to permanent housing.

Per Section 1.2 - Homelessness - Woodside has almost no homeless residents. In 2017 and 2019, when the most recent “snapshot” surveys were conducted, no homeless persons were found to be living in Woodside (down from 2 in 2015, and 6 in 2013). However, State housing laws require cities to provide zoning that supports these housing types. The following is an analysis of the zoning and site availability for each of these housing types. • Emergency Shelters – Are a permitted use in the Community Commercial (CC) zone (Municipal Code Section 153.100 Zoning Districts, Table A-1 Permitted Uses in Residential and Commercial Zoning Districts). The areas with this zoning are developed with commercial buildings and the opportunity for establishing a shelter would be within a vacant tenant space already constructed to commercial development standards. Parking for these existing commercial uses support what would be needed for shelter employees. • Transitional/Supportive Housing – Is permitted in all single-family residential zones per Municipal Code Section 153.100 Zoning Districts, Table A-1 Permitted Uses in Residential and Commercial Zoning Districts. There are no special restrictions for this type of housing different from the restrictions and standards of the single-family residential zoning districts. Supportive housing includes group homes.

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• By-Right Permanent Supportive Housing – Per Government Code Section 65583.2, by-right housing means housing that is permitted without discretionary approvals and does not require CEQA analysis. Per Government Code Section 65651, by-right supportive housing must be allowed in multi-family zones if certain restrictions regarding affordability are met.

The current zoning per Municipal Code Section 153.100 Zoning Districts, Table A-1, does not allow supportive housing in the Multi-Family Residential Development Overlay (MFRD) zone. The Housing Element contains a new policy in Policy 4.3 – Provide for Emergency Shelter and Transitional Housing, to amend the Municipal Code to allow supportive housing as a by-right use in the MFRD zone provided the conditions for affordability per State law are met.
• Low Barrier Navigation Centers – Is another form of supportive housing that provides supportive services. Navigation centers typically provide longer terms of stay than emergency shelters, making them more like supportive housing, and they are considered a form of supportive housing for the purpose of zoning compliance. These facilities are also a by-right use for multi-family zones per Government Code 65660. This use was added to the new Policy 4.3.
• Single Room Occupancy (SRO) units – Are similar to a hotel use and are often a converted hotel or motel. No such facilities are present in Woodside and are not listed as a permitted or conditionally permitted use. Per Section 153.107 of the Municipal Code “Uses not listed in the table under any case category, shall not be permitted under this chapter unless the Planning Commission determines that the use is similar to the uses listed in the table.” For the purpose of a Planning Commission determination, SRO facilities will be considered a commercial use allowed in the Community Commercial zone. New policy 4.3 includes a program to amend the Municipal Code to add SRO units as a permitted use in the Community Commercial zone.
• Housing for Farmworkers – The Employee Housing Act, Health and Safety Code Section 17021.5, requires housing for six or fewer employees to be treated as a single-family residence and a permitted use. Housing of up to 12 units or 36 beds is a permitted use in zones that allow agricultural uses. Policy 4.3 includes a provision for the definition of a single-family home to include farmworker housing for up to six employees. Agricultural uses are permitted in all residential and commercial zones except multi-family residential.

Policy 4.3 describes farmworker housing as a permitted use in all zones except multi-family residential.
• Manufactured Housing – Is a permitted use in all single-family zones.

3.7 Energy Conservation Opportunities
The housing needs analysis required by Government Code 65583(a) includes a requirement to analyze the opportunities for energy conservation in residential development. The Town of Woodside has adopted the most recent Title 24 CALGreen Building Code that includes energy conservation measures. Section A4.602 is a table of measures that will be implemented for new development that includes enhanced durability, construction waste reduction/recycling, pollutant controls, insulation, and Energy Star appliances. Planning policies that assist with Item A Page 102 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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conservation include policies to meet the RHNA housing needs for all income groups, encouraging ADUs, establishing the multifamily MFRD zone, and rezoning of properties for higher density.

3.8 Strategies to Meeting RHNA Cycle 6
This Housing Element includes Programs designed to meet the Cycle 6 RHNA allocation targets.

The Programs balance the needs for increased access to housing by various demographics, various housing types, resilience in a heavily wooded Town that is subject to wildfires and other constraints, and resident concerns with increased housing densities. The Plan includes Programs for a mix of housing types to meet the Cycle 6 RHNA allocation. These different housing types and the levels of development anticipated during this Plan period are described below. a. Accessory Dwelling Units & Junior Accessory Dwelling Units The Town of Woodside encouraged and supported the development of ADUs in the Cycle 5 Housing Element. The Town issued 36 permits for ADUs during the 1999-2006 Housing Element cycle; 28 permits for ADUs during the 2007-2014 Housing Element; and 82 permits for ADUs (as of December 21, 2021) during the 2015-2023 Housing Element, for a total of 146 ADUs during the last three RHNA cycles.

The Town is characterized by steep slopes with many environmental constraints. Approximately two-thirds of the existing dwellings utilize septic systems. ADUs have been a critical component of the effort to create affordable housing, as they can be connected to the same septic systems with minimal expansion or connect to existing sewer lines serving a primary residence; and can use the same driveway as the primary home.

In more recent years, the Town has given greater focus to the development of JADUs. JADUs are limited to 500 square feet; constructed within an existing residence, utilize an existing bedroom; and have an internal connection to the residence and an independent entrance. They can utilize bathrooms that are part of the main residence or those that are within the JADU. The size of JADUs make them affordable, and since they utilize existing bedrooms, they do not require expansion of septic systems.

ADUs and JADUs will continue to be a significant source of affordable housing in Woodside. The Woodside community overwhelmingly supports the development of ADUs and JADUs as a primary means of addressing the State’s affordable housing mandate, given the Town’s rural character, equestrian heritage, and its many environmental constraints. With each ordinance adopted by the Town that reduces barriers to JADU and ADU construction, the Town has seen increased interest, application submittals, and permitting of such units (Appendix J). b. SB 9 Projects
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SB 9 was passed by the Governor on September 16, 2021, requiring local jurisdictions, as of January 1, 2022, to ministerially approve Parcel Maps allowing the division of all single-family residential lots into two lots under certain circumstances, which are referred to as SB 9 Lot Splits, and the construction of two residential units up to at least 800 square feet on all single-family residential lots. The Town adopted an SB9 Ordinance in December 2021.

SB 9 units provide another source of housing in Woodside and throughout the State. Property owners that add one or more 800 square-foot SB9 Units to their property may rent out the units, which is a source of affordable housing. In response to the enactment of SB 9, the Town adopted Ordinance 2022-624 (amended by Ordinance 2022-625), and Resolution 2021-7464 establishing subdivision, zoning, and design standards for ministerial approval of SB 9 lot splits. A significant number of existing lots in Woodside cannot be divided under existing minimum lot size requirements. Therefore, SB 9 lot splits can result in ministerially approved smaller parcels, making it substantially easier and more attractive for property owners to subdivide their lots and construct smaller units that will be more affordable. In the past year since the State’s approval of SB 9, there has been some interest expressed from property owners in SB 9 lot splits in Woodside.

SB 9 is a new state law, so there is minimal recent experience on how many SB 9 lot split applications might be received, so the Table 3-5 Proposed RHNA Plan does not include units produced from SB9 lot splits.
c. Land Divisions
The Town’s earliest subdivisions date from 1887, when the land was part of San Mateo County.

Now, most of the Town has been built out as a primarily single-family residential community with large areas of open space and parkland around it. As a result, the Town receives very few applications for land divisions which range from splitting one lot into two to seven lots. d. Higher Density Housing
Woodside is developed as a single-family residential community; however, to meet the Cycle 6 targets for affordable housing, the Town has identified parcels for higher density housing at Cañada College, and on one privately-owned parcel. Town owned sites may be added here per 1- 31-23 Council direction
Woodside has several groups that could be served by a broader range of housing types: faculty and staff at Cañada College; service workers at the Town Center; and the growing senior population in Woodside, or parents of those living in Woodside that desire independent housing units. Seniors require a range of housing options. Woodside’s steep topography and windy roads can result in isolation as seniors lose physical mobility and/or the ability to drive. With the increased threat of wildfires and other natural disasters, mobility issues also pose increased challenges for safe evacuation. To provide opportunities for residents to ‘age-in-community’, this Item A Page 104 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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Plan locates higher density housing outside of the Western Hills with its high fire risks and severely limited evacuation routes.

Default Affordable Density:

In Woodside, HCD considers the “default density” to qualify units as affordable to lower and moderate-income households, to be a minimum of 20 units per acre. Sites that could accommodate 20 units per acre would add variety to the existing housing stock. A proposed higher density housing project at Cañada College, totaling approximately 75 units, would meet this density requirement. A Program has been included to streamline the entitlement process established during Cycle 5 for the Multi-Family Residential Development (MFRD) Overlay Zone (also established in Cycle 5).

Higher Density Rezoning:

A privately owned site at 773 Cañada Road is included in the RHNA Plan for rezoning to 20 units per acre (Figure 3-1). The property owner is actively exploring higher density development on the lower portion of this parcel, as well as lower density single-family development on the upper portion of the parcel.

Town owned sites may be added here per 1-31-23 Council direction.

A Multi-family Residential district (MFRD) Overlay Zone was added to Cañada College in Cycle 5, along with development standards and an entitlement process to provide an opportunity for multi-family housing development that did not previously exist in the Town. In Cycle 4, the Town assisted in facilitating the construction of (60) affordable faculty and staff housing units (Cañada Vista, 22 units/acre) at the College. During Cycle 5, the College concentrated on a new 85,000 square foot Kinesiology & Wellness Center.

In July 2022, the San Mateo County Community College District adopted the 2022 Districtwide Facilities Master Plan (FMP), which was developed to guide short- and long-term planning for the District’s three campuses. The District is now actively seeking funding for student and family housing at its campuses. As a first phase, the District is in the process of applying for a State grant to support housing at the College of San Mateo campus. If successful, the District would move to a second phase to obtain grant funding to support student and family housing at one of its other two campuses, including Cañada College. The second phase application submittal could take place as soon as July 2023. The District has indicated that 75-80 units at Cañada College is a reasonable assumption.

All sites identified for potential rezoning would require public hearings allowing for public input on specific development standards that can accommodate the identified densities. Further details for the site to be rezoned are provided in Figure 3-11.

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Figure 3-10. Opportunity Sites for Multi-Family Housing. [Amend this map to define any Townowned sites to be retained] [Amend Figures 3-11 thru 3-12 below to eliminate or retain Town-owned sites per Council direction]
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Sites to be Rezoned to Higher Density:

Town-owned Sites
Figure 3-11. Raymundo Drive Site. [Delete or retain this site map and description per Council direction]
The Town-owned Raymundo Drive parcel is 1.770 acres (San Mateo County Assessor estimate).

The site is relatively flat. Seismic conditions are a potential constraint.

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Figure 3-12. High Road Site. [Delete or retain this site map and description per Council direction]
The Town-owned High Road parcel is 1.055 acres (San Mateo County Assessor estimate). Potential constraints include topography, drainage and soil conditions.

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Private Property – 773 Cañada Road
Figure 3-13. 773 Cañada Road Site.

The 773 Cañada Parcel is privately-owned and is 4.807 acres (San Mateo County Assessor estimate). The property owner is actively exploring higher density development on the lower portion of this parcel, as well as lower density single-family development on the upper portion of the parcel. The development would require new sewer service. The site is adjacent and eligible to connect to the Town Center Sewer District
e. The Proposed RHNA Plan
The Proposed RHNA Plan is a mix of unit types that together can meet the Cycle 6 RHNA allocation of affordable housing units. The Proposed RHNA Plan includes a suite of housing prototypes and development opportunities, including: ADUs/JADUs (based on the results of a 2022 community survey), new single-family homes, , land divisions (approved, active, and pending), ‘pipeline’ ADUs and single-family homes (i.e., development that has not yet received a Building Permit final by June 30, 2022, which exceed RHNA 5 requirements), very low and low income multi-family housing at Cañada College, and higher density housing on one private property – as shown in Table 3-5.

Table 3-5 Proposed RHNA Plan [Insert table approved by 1-31-23 Council direction] Item A Page 109 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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This plan is the same as Table G-1 in Appendix G Adequate Sites Inventory.

Low and
Very Low
Income
Moderate
Income
Above
Moderate
Income Total
Current Zoning Sites
Vacant Single-Family Sites 106 106
Non-Vacant Single-Family sites 46 46
Pipeline Projects* 4 4
Cañada College 75 75
ADUs 96 48 16 160
Rezoning Sites
773 Cañada Site 16 11 27
Total 171 64 187 422
RHNA Allocation - Base 142 52 134 328
RHNA Buffer @ 20% 28 10 27 65
Total RHNA + Buffer 170 62 161 393
Surplus/Deficit +1 +2 +26 +29
* Pipeline units are units that have active applications for approval in the Town Planning Department.

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Table 3-5. Proposed RHNA Plan [Delete this table – replaced by table above] Item A Page 111 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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f. The Relationship between Available Sites for Housing Development, and Development of Concrete Actions to AFFH:

The Town of Woodside is committed to affirmatively furthering fair housing options in the community, in accordance with State and federal law.

During recent Housing Element cycles, the Town’s focus for providing affordable housing has been to encourage the development of ADUs. ADUs and particularly smaller ADUs (studios and onebedroom units) have been the housing type that has been the most affordable. All of Woodside is mapped as a ‘High Resource Area’iv, and construction of ADUs is permitted and encouraged in all parts of the Town. By facilitating development of units throughout the Town, the Town takes an active role in affirmatively furthering development of and access to fair housing. Figure 3-9 shows the distribution of both SFRs and ADUs in the community during Cycle 5 (2015-2021).

In the Cycle 6 Housing Element, the Town will continue to aggressively promote the development of ADUs but is also planning for and encouraging a broader mix of housing types, including JADUs, and high-density housing at Cañada College and one private property. Town owned sites may be added here per 1-31-23 Council direction Thisrange of housing types will increase housing choices for seniors, single-parent households, employees of Town Center businesses; property maintenance workers, caretakers, equestrian managers, people with disabilities, and students teachers, teacher families and employees at Cañada College. The Town’s Housing Program and Action Plan (Section 3.9) incorporates the following:
 Encourages residents to develop ADUs; and make ADUs and JADUs or extra bedrooms available to students at Cañada College and service providers in the community; and,  Identifies two parcels for higher density housing development.  Town owned sites may be added here per 1-31-23 Council direction

3.9 Housing Program and Action Plan – Guiding Principles, Goals, Policies, and Programs The Cycle 5 Housing Element Programs were effective in helping the Town reach the RHNA targets for the cycle (Chapter 2, Table 2-5). RHNA targets for Cycle 6 significantly increase the housing unit targets from Cycle 5, as discussed above, requiring the Town to administer new programs and rezone to reach the new housing targets. The Town will increase opportunities for different housing types by having unit square footage maximums equivalent to current allowances for ADUs (up to 1,500 square feet). This Housing Element expands housing types available for different demographics. The Town balances the objective to make all parts of the community accessible with the need to encourage development of housing in areas with fewest environmental constraints and hazards.

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A. Guiding Principles
Guiding Principle 1: Provide adequate housing for all persons regardless of race, color, ancestry/national origin, religion, income, age, disability, sex, sexual orientation, gender identity or expression, genetic information, marital status, familial status, military, or veteran status, and/or source of income.

Guiding Principle 2: Assure a variety of housing types within the context of the Town's General Plan and existing physical constraints.

Guiding Principle 3: Integrate new housing types while maintaining the Town’s rural character and equestrian heritage.

Guiding Principle 4: Provide opportunities for housing to meet the needs of those families and individuals who wish to live in a rural setting—in quiet residential areas which provide privacy, separation from traffic, undisturbed terrain, extensive vegetation, and opportunities to keep horses and other animals.

Guiding Principle 5: Provide adequate and safe housing for households of varied income levels.

Guiding Principle 6: Allow housing development that is subordinate, sensitive, and complementary to the natural environmental setting and specific site conditions, including sites designated and rezoned for medium to high density housing with full consideration of environmental/service constraints.

B. Goals, Policies and Programs
Goal H1: Increase Opportunities for Development of Accessory Dwelling Units (ADUs) and Junior Accessory Dwelling Units (JADUs)
Policy H1.1 - Collect Information on Use of ADUs and JADUs, and Provide Outreach to Residents to Encourage Development of ADUs and JADUs
PROGRAMS:
a. ADU Survey
Update the existing ADU Survey, a required submittal during permitting of all new ADUs, detailing occupancy and rental costs of the unit(s).

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b. Outreach to Encourage ADUs
Conduct outreach to all residents to promote ADUs, and JADUs, by mailing postcards annually and posting details on the Town website, explaining the benefits of ADUs and JADUs, including multigenerational living/family support, caretaker housing, and sources of income. Additionally, the Town will continue to reach out to organizations and host public meetings on an annual basis to “demystify” past circulated assumed barriers to ADU and JADU construction.

Policy H1.2 - Promote ADUs and JADUs as an Opportunity for Affordable Housing to Promote an inclusive and Equitable Community
PROGRAMS:
a. Prepare and Distribute Brochures on ADUs and JADUs
Prepare and distribute annually a brochure explaining opportunities and design ideas for ADUs and JADUs. The brochure shall be reviewed on a bi-annual basis to ensure it remains up to date with new code changes.
b. Obtain and Distribute information from Companies that Specialize in ADU Construction The Town shall solicit and obtain information from companies that specialize in ADU construction and transmit the information to residents through various outlets, such as updates on the Town website, quarterly or bi-annual mailings to residents, and public inquiries made with Planning Department staff.
c. Conduct ADU Workshops by New Town Council Districts
The Town conducted workshops in Fall 2022 for each district. Information was provided on state and local ADU laws. A total of 135 residents registered for the five ADU Workshops, and, on average, 61 percent attended (82 residents). The Town Council District 2 Workshop had the highest attendance at 70%. Of the 82 attendees, the comment cards recorded interest in developing 57 ADUs and 3 JADUs.
d. Revise ADU Ordinance Per State Law
Periodically amend the ADU ordinance to be consistent with State law.

Policy H1.3 – Continue to Remove Barriers to Construct ADUs and JADUs Item A Page 114 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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PROGRAMS:
a. Modify Local Regulations to Permit Additional ADUs on Properties Exceeding Two Acres Adopt an ordinance for new development standards to allow additional ADUs (i.e., more than two ADUs) that meet basic setbacks on properties exceeding two acres. Complete by December 31, 2023.
b. Modify Local Regulations that Remove Barriers to Constructing ADUs and JADUs Adopt an ordinance to revise development standards that create barriers to developing ADUs and JADUs. This may include allowing ADU septic systems, utilities, and ADUs themselves on slopes between 35% and 50% and areas required to remain in a Natural State. Complete by December 31,2023.
c. Reduce Town Permit Fees for ADUs and JADUs
In 2022 the Town approved a plan to reduce certain ADU fees to remove barriers to construction.

The estimated value of the fee reduction over the eight- year planning period is $960,000. d. Expedite Processing for ADUs and JADUs
Expedite processing for ADUs and JADUs from the Permit Streamlining deadline of 30 days to 20 days. This standard will be included in the annual mailed information document on ADU’s. e. Develop Amnesty Program
Develop an Amnesty Program to legalize ADUs and JADUs constructed without permits prior to 2020, that meet current health and safety regulations, which includes an elimination of penalty fees. Publicize this program to encourage broad participation. The program will include inspection of units to provide, either a completion certification for units that meet code, or list of corrections needed to meet code, with a completion certification after code improvements are completed and inspected. After the program has been approved, information on the program will be included in the annual mailed information document on ADU’s. The effectiveness of the program will be determined by the number of residents using the program. f. Monitor ADU Production
After two years following the adoption of the Housing Element, assess the number of applications for ADUs and JADUs approved and compare to the annual estimate of 20 units per year in Table 3-5 Proposed RHNA Plan. If the actual number of applications approved is less than 20 units annually, review measures to increase ADU production.

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Goal H2: Affirmatively Further Fair Housing (AFFH):

Policy H2.1 - Provide Opportunities for Varied Housing Types with Access to High Resource Areas Amenities (schools, libraries, retail, restaurants, and services), and Transit Routes, including Bus Stops, Designated Bicycle Lanes, and Safe Routes to School Pathways.

PROGRAMS:
a. Establish Higher Density Zoning near Freeway Access
Adopt an ordinance allowing higher density housing of up to 20 units/acre on one privately owned parcel (773 Cañada Road). This site is conveniently located on an arterial near freeway access to reduce commute distances and thus greenhouse gas emissions. The ordinance will allow the developments meeting the density standards to be a permitted use. [Add Town-owned site? Per Council direction]
b. Revisit the SB9 Development Standards
Revisit the SB9 development standards to encourage more SB9 Units, which would be smaller than main residences, with size limitations similar to ADUs (the maximum ADU size in Woodside is 1,500 square feet), thereby creating more affordable units. c. Promote SB 9 Lot Splits
Provide information to property owners on SB9 lot split standards, and survey their interest in pursuing lot splits, as part of the annual information postcards mailed for ADU information in Policy H1.2.a
d. Increase SB 9 Density Limits
Review the SB 9 ordinance to allow homes with size limitations similar to ADU limits in the ADU ordinance.
e. Pursue Public Transit
Continue to request the extension of public transit routes to Woodside on an annual basis.

Policy H2.2 Provide, Develop, and Maintain Public Information Regarding Housing Availability PROGRAMS:
a. Provide Rental Availability Information
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The Town will continue to provide information on its website as a resource for listings of affordable rentals.
b. Promote Public Participation
The Town will solicit additional input at rezoning hearings. c. Support Equal Opportunity Housing Organizations
The Town supports a variety of equal opportunity housing organizations including HIP Housing and the Housing Endowment and Regional Trust (HEART) and provides links to housing resources on its website, as outreach to protected classes based upon race, age, gender, family status, and religion.
d. Provide Referrals to Fair Housing Resources
The Town has and will provide links to housing resources on its website, including links to two investigative and enforcement agencies: the U.S. Department of Housing and Urban Development, and the State Department of Fair Housing and Employment. These agencies provide resources and a means for resolution of fair housing complaints, including filing complaints related to discrimination against protected classes. e. Provide Multi-Lingual Information
The Town will distribute fair housing information in languages other than English, in handouts that will be distributed with ADU applications, and for display at Cañada College, Woodside Library, and Town Hall.
f. Provide Information for Non-Profit Housing Assistance Organizations The Town will add information to the Town website on housing complaints enforcement and contact information for non-profit information and enforcement organizations, including Project Sentinel, Legal Aid Society of San Mateo County, and the Community Legal Services of East Palo Alto. Include this information in the handouts developed for ADU applications.

Goal H3: Support Opportunities for Higher Density Housing Policy H3.1 Support New Independent Housing at Cañada College PROGRAMS:
a. Administer and Support new Independent Housing at Cañada College The Woodside Town Council approved the Multi-Family Overlay Zone at Cañada College on January 27, 2015. The College District has prepared a Districtwide Facilities Master Plan for its three campuses that includes the construction of new housing, including independent units for families and individuals that attend or work at the College. The Town shall administer any Item A Page 117 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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permitting and/or local regulatory changes necessary to facilitate the development of the housing units and provide any additional resources it can to help ensure the desired housing is constructed. The Town will assist the District in obtaining local non-profit, state and/or federal financing to allow a portion of the units to be affordable to very low income (50 units) and low income (25 units) persons. The specific timing of this assistance and this program will be determined with the District based on the District’s facilities master plan implementation schedule but is expected within the RHNA Cycle 6 planning period. b. Streamline Cañada College Housing Development Entitlement Collaborate with the San Mateo County Community College District to streamline the entitlement process for housing development at Cañada College. The target housing goals are at least 75 units, of which 50 are very low income and 25 are low income, to implement the Cycle 6 RHNA.

Policy H3.2 Rezone Properties Allowing Increased Housing Density PROGRAMS:
a. Rezone Sites Identified in the Housing Element, Table 3-5 Complete rezoning of sites identified in the Housing Element, Table 3-5, to allow for higher density residential development. The ordinance will allow the developments meeting the density standards to be permitted uses.
b. Amend Multi-Family Residential Zone
Amend the Municipal Code MFRD zone to decrease the maximum lot size from 2,400 square feet to 2,200 square feet to increase the density in this zone from 18 to 20 units per acre.

Policy H3.3 Incentivize Higher Density Housing
PROGRAMS:
a. Consider Reducing Fees for Higher Density Housing
Review Town permit fees for higher density housing to determine if fees can be reduced to further remove barriers to construction. The outcome of the review may be the reduction of fees for projects that are in multifamily (MFRD) zones, or achieve 20 units per acre, to assist with the creation of affordable units to meet the Cycle 6 RHNA. The review will be completed by the end of 2023.

Item A Page 118 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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b. Expedite Processing for Higher Density Housing
Expedite processing for higher density housing including ADUs, JADUs, and developments of 20 units per acre from the Permit Streamlining deadline of 30 days to 20 days. Applicants for higher density housing will be informed of this policy when inquiries are made for higher density sites and as part of the ADU page on the Town website.
c. Density Bonus Ordinance Adopt a density bonus ordinance to implement the State density bonus law.

Policy H3.4 Assist with the Development of Extremely Low-Income Housing a. Assist with the development of extremely low-income housing through a variety of incentives.

In addition to reducing fees and expediting permit processing as set forth in policies H3.3.a and b, consider modification of development standards (e.g., parking on a project basis), and assist nonprofit developers with applications for State and federal grant, loan, and tax credit programs for project funding.

Goal H4: Promote the Availability of Housing for Special Needs Groups Policy H4.1 - Promote Affordable Housing Opportunities for Persons with Disabilities of all types, not limited to Physical Disabilities
PROGRAMS:
a. Continue Access to Housing for people with Disabilities Continue to enable people with disabilities to access their homes through Town development standard exceptions for accessibility modifications and other available programs. Continue to recommend that the County direct CDBG funds to support its Housing Accessibility for Persons with Disabilities program at the Center for Independence of Individuals with Disabilities. The Town will direct inquiries for house modifications for people with disabilities to the County program.

Public information regarding the program is available on the Town’s website. The Town will develop and implement a Reasonable Accommodation Procedure to inform disabled persons of their rights and remedies under the federal Fair Housing Act and Americans with Disabilities Act, including Town code exceptions and referrals to County and non-profit resources for resolution of discrimination complaints, and funding resources for home modifications. The procedure will be developed and added to the existing Housing Resources webpage by the end of 2023 and will be added to the annual mailout of information regarding ADUs. b. Amend Zoning Ordinance to Expand Exceptions for People with all types of Disabilities Item A Page 119 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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The Town will amend and expand the existing Municipal Code section 153.204 -Exceptions for Minor Improvements for Disabled Access – to include ADUs. c. Group Homes
Continue to allow group homes with six (6) or fewer persons in all residential districts, as required by State law. Group homes are considered supportive housing and are allowed in all residential districts pursuant to Welfare and Institutions Code Section 5116. Supportive housing of six or fewer residents is a permitted use in the Town’s zoning code. The Town will develop a supportive housing zoning classification in 2024 for facilities that exceed six residents as a conditional use including objective approval standards.

Policy H4.2 - Promote Affordable Housing Opportunities for Service Personnel, People with Disabilities, Caretakers, Equestrian Mangers/Employees, and Public Sector Employees PROGRAMS:
a. Private Sector Employee Housing
Revise the Town Housing Resources webpage to provide information on the provisions of the Employee Housing Act and contact information for the San Mateo County Department of Environmental Health Services as the regulator of the law. Provide this information to property owners as part of the annual mailout for ADUs information. b. Employee Housing
Promote opportunities for affordable housing to local employees (e.g., housing match services), which also reduces greenhouse gas emissions.

Policy H4.3 Other Special Needs Housing
PROGRAMS:
a. Cooperate with Agencies Providing Emergency Shelter
The Town shall cooperate with agencies providing emergency shelter and transitional housing for the homeless, victims of domestic violence, and those in immediate crisis. Support includes the permitted use zoning for these facilities in the Community Commercial zone. b. Supportive Housing in the Multi-Family Residential Development Overlay Zone (MFRD) Item A Page 120 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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Amend the Municipal Code Section 153.110.E-Review Process, to allow supportive housing as a by-right use in the MFRD zone provided the conditions of State law for affordability restrictions are met.
c. Low Barrier Navigation Centers
Amend the Municipal Code to identify Low barrier navigation centers as a form of supportive housing as defined by State law, that are by-right use for multi-family zones per Government Code 65660.
d. Single Room Occupancy Units (SRO)
Amend the Municipal Code to add SRO units as a permitted use in the Community Commercial zone.
e. Farmworker Housing
Amend the Municipal Code to add farmworker housing as a residential use allowed in all residential and commercial zones except MFRD and define single-family zoning to include farmworker housing of up to six employees; and farmworker housing up to 12 units or 36 beds as a permitted use in zones allowing agricultural uses per the Employee Housing Act (Health and Safety Code 17021.5.
f. Senior Amenities
Continue to pursue a housing project for seniors.

Goal H5: Plan for a Resilient Community:

Policy H5-1: Minimize Damage from Natural Disasters
PROGRAMS:
a. Update the Very High Fire Hazard Severity Zones (VHFHSZ) Map Update the Town’s Fire Hazard Map on an ongoing basis to be consistent with CalFIRE maps. b. Improve Emergency Access and Response in the Very High Severity Fire Hazard Zones Utilize resource materials developed as part of the Local Hazard Mitigation Plan (LHMP) and work with the Woodside Fire Protection District (WFPD) to identify potential Emergency Vehicle Access Item A Page 121 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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(EVA) routes where only one access point currently exists on streets within WUI areas. Ensure visible street signs and accommodate projects providing adequate water supplies for fire suppression.
c. Facilitate and Encourage Neighborhood Preparedness
Encourage neighbors to organize and work with the Town’s Emergency Preparedness Committee, the Woodside Fire Protection District, and Citizens Emergency Response Team (CERT) annually to prepare for natural disasters, including planning for evacuation of people and animals, developing go-bags, and setting up communication networks among neighbors. Include information to the annual mailout to property owners about the CERT program and preparedness resources available on the Town’s Emergency Services page.

Policy 5.2 - Provide Adequate Utilities
PROGRAMS:
a. Provide Sewer Service to Address Waste Disposal Failures Continue to support sewer system access to those areas experiencing septic failure, when contiguous to a sewer district.
b. Prioritize Sewer for Higher Density Residential Development Encourage sanitary service districts to prioritize sewer allotments for higher density residential development for affordable housing.
c. Coordinate with CAL-Water to ensure Adequate Water Supplies Work with the Town Engineering Department to ensure housing units and projects are proposed in areas with adequate water supplies for domestic use and wildfire suppression.

GOAL H6: Conserve & Rehabilitate the Existing Housing Stock & Develop New Housing Stock Policy H6.1 - Conserve the Existing Housing Stock
PROGRAMS:
a. Apply California Building Code
The Town shall continue to apply the California Building Code to preserve the existing housing stock and historic structures.
b. Maintain and Improve Housing
Item A Page 122 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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Maintain the character and quality of existing housing, which is in good condition, and improve the character of housing wherever substandard structures are found. c. Enforce Housing Standards
The Town’s code enforcement staff and building inspector will continue to follow up on complaints regarding housing conditions. Violations will be brought into conformance in a timely manner. The emphasis is on maintaining the existing housing stock. If circumstances dictate (e.g., low-income households, or limited income seniors), the property owner will be referred to the County to determine if funds for housing improvements are available.

Policy H6.2 - Rehabilitate the existing housing stock
PROGRAMS:
a. Continue to Encourage and Facilitate Home Rehabilitation Continue to encourage and facilitate the rehabilitation and/or expansion of existing housing units. b. Provide for Exceptions and Variances
Continue to provide for setback exceptions and variances to recognize limitations on existing structures to allow remodeling or small additions rather than demolition and construction of new structures. Municipal Code Section 153.940 sets forth the discretionary approval process for variances by the Planning Commission. Findings for approval are listed as the basis for the Commission decision.
c. Evaluate Development Standards in the Western Hills
Using the model developed in The Glens, evaluate opportunities to relax development standards, including minimum lot sizes, to provide property owners with more flexibility. Complete this review by 2025.
d. Utilize Rehabilitation Programs
Encourage the private sector to rehabilitate and construct new housing through the Town's policies and programs and inform low- and moderate-income residents about the County's Rehabilitation Loan Program. The Town’s website contains information about County rehabilitation programs under the “Housing Resources” page.

Policy H6.3 - Promote Sustainability Including Energy Efficient Housing PROGRAMS:

Item A Page 123 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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a. Promote and Enforce Energy Efficiency and Sustainability Continue to require compliance with Title 24 of the State’s building regulations. In addition, disseminate energy conservation information available from other agencies, such as PG&E's solar subsidy program and energy audits. Require compliance with the Solar Mandate which requires installation of photovoltaic panels on all new residences (houses, condominiums, and apartment projects) up to three stories to offset their use of electricity. b. Encourage Energy Efficient Building Design and Materials Continue to encourage the inclusion of energy saving siting, features, and materials in the retrofit of existing units, the construction of new units, and the development of new subdivisions. Require compliance with all fire regulations.

C. Action Plan for Program Implementation
As required by State law, Section 65583(c) of the Government Code, an Action Plan has been established to implement the goals, policies, and objectives contained in the Housing Element.

Table 3-6 is Woodside's Action Plan for Program Implementation identifying schedule, status, and departments responsible for implementation of programs designed achieve the Housing Element objectives.

Item A Page 124 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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Table 3-6. Action Plan for Program Implementation
The Housing Element programs proposed for the Cycle 6 reporting period (2023-2031), including targets and implementation, are included below.

Number Program Lead Implementing
Agency/Dept.

Funding Source Program
Measure(s)
Targets Implementation Analysis/Factor*
GOAL H1: Increase Opportunities for Development of Accessory Dwelling Units (ADUs) and Junior Accessory Dwelling Units Policy H1.1 – Collect Information on Use of ADUs and JADUs, and Provide Outreach to Residents Encouraging Development of ADUs and JADUs
a. ADU Survey Planning General Fund Response rate 100% response rate
Update the Survey
by the end of 2023
and distribute
annually
Provide to
applicants – ongoing
ADU
Survey/Factor
#3
b. Outreach to
Encourage ADUs
Planning General Fund Response rate Mailings to all
residents and
annual meetings
Ongoing and
annually
Appendix
E/Factor #3
Policy H1.2 – Promote ADUs and JADUs as an Opportunity for Affordable Housing -Inclusive and Equitable Community a. Prepare and
Distribute
Brochures on
ADUs/JADUs
Planning General Fund Number of
new ADUs and
JADUs
applications
approved
Meet RHNA targets
for ADUs and
JADUs
Complete Brochure
by end of 2023 and
distribution is
ongoing and annual
Appendix E/
Factor #3
Item A Page 125 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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Number Program Lead Implementing
Agency/Dept.

Funding Source Program
Measure(s)
Targets Implementation Analysis/Factor*
b. Obtain and
Distribute
Information
from Companies
that Specialize in
ADU
Construction
Planning/Building General Fund Number of
residents
reached/
participating
All Woodside
residents aware of
and potentially
benefitting from
information
Complete by the
end of 2023, with
annual updates
Appendix E/
Factor #3
c. Conduct ADU
Workshops by
New Town
Council Districts
Planning General Fund Number of
residents
participating
All Woodside
residents aware of
and potentially
benefitting from
information
Completed October
2022.

Appendix E/
Factor #3
d. Revise ADU
Ordinance
Planning General Fund Revision of
ordinance
All Woodside
residents aware of
and potentially
benefitting from
information
2023 for initial HCD
recommendations;
on-going as law
changes
Appendix E/
Factor #3
Policy H1.3 – Continue to Remove Barriers to Constructing ADUs and JADUs a. Modify Local
Regulations to
Permit
Additional ADUs
on Properties
Exceeding Two
Acres
Planning General Fund Increase
development
of new ADUs
Meet RHNA targets
for ADUs and
JADUs
Complete by the
end of 2023
Appendix E/
Factor #3
Item A Page 126 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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Number Program Lead Implementing
Agency/Dept.

Funding Source Program
Measure(s)
Targets Implementation Analysis/Factor*
b. Modify Local
Regulations to
Remove Barriers
to Constructing
ADUs and JADUs
Planning General Fund Increase
development
of new ADUs
and JADUs
Meet RHNA targets
for ADUs and
JADUs
Complete by the
end of 2023
Appendix E/
Factor #3
c. Reduce Town
Permit Fees for
ADUs and JADUs
Planning General Fund
Estimated
$960,000 cost
Town’s ability
to increase
financial
subsidies for
ADU and JADU
permit fees
Reduce fees as
financially feasible,
and review on an
annual basis to
determine if fees
can be further
reduced

Completed 2022 Appendix E/
Factor #3
d. Expedite
Permitting for
ADUs and JADUs
Planning/Building General Fund Reduce Town
plan check
time from the
State Permit
Streamlining
deadline of 30
days to 20 days
Meet the 20-day
plan check target
for all ADUs and
JADUs
Begin January 2023
Ongoing
Appendix E/
Factor #3
e. Develop
Amnesty
Program for
ADUs and JADUs
Planning General Fund Number of
residents using
program
Permit 100% of
existing nonpermitted ADUs
Complete by the
end of 2023
Appendix E/
Factor #3
Item A Page 127 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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Number Program Lead Implementing
Agency/Dept.

Funding Source Program
Measure(s)
Targets Implementation Analysis/Factor*
f. Monitor ADU
Production
Planning General Fund Number of

ADU/JADU
applications
processed
Meet RHNA target End of 2025 Appendix E/
Factor #3
Goal H2: Affirmatively Further Fair Housing (AFFH)
Policy H2.1 – Provide Opportunities for Varied Housing Types with Access to High Resource Areas Amenities (schools, libraries, retail, restaurants, and services), and Transit Routes, including Bus Stops, Designated Bicycle Lanes, and Safe Routes to School Pathways a. Establish Higher
Density Zoning
Near Freeway
Access
Planning General Fund Ordinance
adoption
Meet the RHNA
target
Complete by
December 31, 2023
Appendix
G/Factor #1 &
3 b. Revisit SB9 Unit
Development
Standards;
Inform residents
of program
Planning General Fund Ordinance
adoption;
number of
postcards and
electronic info
distribution
Revisit SB9
development
standards to
encourage more
SB9 Units
Complete ordinance
review by the end of
2024. Annual
distribution of info
and survey of
intertest
Appendix
G/Factor #1 &
3 c. Provide Public
Transit
Planning/
Public Works
General Fund Response from
SamTrans
Seek bus routes in
Woodside
Annually Appendix F/
Factor #3
Policy H.2 Provide, Develop, and Maintain Public Information Regarding Housing Availability a. Provide Rental
Availability Info
Planning General Fund Number of
inquiries
Lower income
residents
Annually and ongoingAppendix B/
Factor #1,2,
&3
Item A Page 128 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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Number Program Lead Implementing
Agency/Dept.

Funding Source Program
Measure(s)
Targets Implementation Analysis/Factor*
b. Promote Public
Participation
Planning General Fund Number of
meetings
All residents Hearings on
rezonings
Appendix H/
Factor #2
c. Support Equal
Opportunity
Housing
Organizations
Planning General Fund Number of
referrals
All residents Create links on Town
website
Appendix
K/Factor #1
d. Provide Referrals
to Fair Housing
Resource’s
Planning General Fund Number of
referrals
All residents Add links on Town
website
Appendix
K/Factor #1
e. Provide multiLingual InfoPlanning General Fund Creation of multi-lingual
documents
All Residents 2024 Appendix B/
Factor #2
f. Provide Info on
Non-profit
Housing
Organizations
Planning General Fund Creation of
information
All residents 2024 Appendix
K/Factor #1
Goal H3: Support Opportunities for Higher Density Housing Policy H3.1 – Support New Independent Housing at Cañada College a. Administer and
Support new
Independent
Housing at
Cañada College
Planning/Town
Administration
General Fund Collaboration
with SMCCC
75 or more units
constructed
During RHNA Cycle 6
period
Appendix
G/Factor #2 &
3 Item A Page 129 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
3-58
Number Program Lead Implementing
Agency/Dept.

Funding Source Program
Measure(s)
Targets Implementation Analysis/Factor*
b. Streamline
Cañada College
Housing
Development
Standards
Planning General Fund Ordinance
adoption
75 or more units
constructed
End of 2024 Appendix
G/Factor #2 &
3 Policy H3.2 – Rezone Properties Allowing Increased Housing Density a. Rezone Sites
Identified in the
Housing
Element, Table
3-5
Planning General Fund Meet RHNA
targets
Meet RHNA targets Complete by
December 31, 2023
Appendix
G/Factor #2 &
3 b. Amend MFRD
zone maximum
lot size to 2,200
square feet = 20
du/ac
Planning General Fund Ordinance
adoption
Meet RHNA targets 2024 Appendix
G/Factor #2 &
3 Policy H3.3 – Incentivize Higher Density Housing
a. Consider
Reducing Town
Permit Fees for
Higher Density
Housing
Planning General Fund Town’s ability
to increase
financial
subsidies for
ADU and JADU
permit fees
Reduce fees as
financially feasible,
and review on an
annual basis to
determine if fees
can be further
reduced

Complete by the
end of 2023
Appendix
F/Factor #2 &3
Item A Page 130 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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Number Program Lead Implementing
Agency/Dept.

Funding Source Program
Measure(s)
Targets Implementation Analysis/Factor*
b. Expedite
Processing of
Higher Density
Housing
Planning/Building General Fund Reduce Town
plan check
time from the
State Permit
Streamlining
deadline of 30
days to 20 days
Meet the 20-day
plan check target
for all ADUs and
JADUs and
developments of 20
units per acre”.

Begin July 2023
Ongoing
Appendix
F/Factor #2 &3
c. Adopt Density
Bonus
Ordinance
Planning General Fund Ordinance
adoption Affordable
development
project
2024 Appendix
F/Factor #2 &3
Policy 3.4 Assist with Development of Extremely Low-Income Housing a. Provide
incentives
including
Development
standards
modification
Planning General Fund Projects
assisted Non-profit housing
developers
On-going Appendix
F/Factor #2 &3
Goal H4: Promote the Availability of Housing for Special Needs Groups Policy H4.1 – Promote Affordable Housing Opportunities for Persons with Disabilities of All Types, not Limited to Physical Disabilities a. Continue to
Enable Access to
Housing for
Planning General Fund People with
Disabilities
ability to find
Apply existing
codes allowing
exceptions to
Ongoing
Develop procedure in
2023
Appendix B/
Factor #1,2 &
3 Item A Page 131 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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Number Program Lead Implementing
Agency/Dept.

Funding Source Program
Measure(s)
Targets Implementation Analysis/Factor*
People with
Disabilities.

Develop a
Reasonable
Accommodation
Procedure
accessible
housing
development
standards to allow
access for people
with disabilities
b. Amend Zoning
Ordinance to
Expand
Exceptions for
People with
Disabilities to
include ADUs
Planning General Fund People with
Disabilities
ability to find
accessible
housing
Amend codes to
provide units
accessible by
people with any
type of disability
including ADUs
Complete by the
end of 2025
Appendix B/
Factor #1,2 &
3 c. Group Homes
permitting
procedures
Planning General Fund Develop
supportive
housing
zoning
classification
for facilities
exceeding six
residents
Continue to permit
Group homes
2024 Appendix F/
Factor #1 & 2
Policy H4.2 – Promote Affordable Housing Opportunities for Students, Service Personnel, People with Disabilities, Caretakers, Equestrian Managers/Employees, and Public Sector Employees Item A Page 132 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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Number Program Lead Implementing
Agency/Dept.

Funding Source Program
Measure(s)
Targets Implementation Analysis/Factor*
a. Private Sector
Employee
Housing
Resources
Planning General Fund Information
added to
Town website
and property
owner
mailouts
Woodside employees 2024
Appendix B/
Factor # 3
b. Employee
Housing
Planning General Fund Number of
local workers
able to access
housing in
Town
Promote
opportunities for
affordable housing
to local employees
(e.g., housing
match services)
Ongoing Appendix B/
Factor # 3
Policy 4.3 – Other Special Needs Housing
a. Cooperate with
Agencies
Providing
Emergency
Shelter
Planning General Fund Interest from
Agencies
Permit housing
types that meet
Zoning, and health
and safety
development
regulations
Ongoing Appendix B/
Factor #3
b. Amend Muni
Code for
Supportive
Housing in
MFRD Zone
Planning General Fund Code
amendment
Supportive housing
organizations
2025 Appendix F/
Factor #3
Item A Page 133 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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Number Program Lead Implementing
Agency/Dept.

Funding Source Program
Measure(s)
Targets Implementation Analysis/Factor*
c. Amend Muni
Code for Low
Barrier
Navigation
Centers
Planning General Fund Code
amendment
Supportive housing
organizations
2025 Appendix F/
Factor #3
d. Amend Muni
Code for SRO
Units in
Commercial
Zone
Planning General Fund Code
amendment
Lower income
residents
2025 Appendix F/
Factor #3
e. Amend Muni
Code to Allow
Farmworker
Housing
Planning General Fund Code
amendment
Lower income
farmworkers
2025 Appendix F/
Factor #3
f. Senior
Amenities
Planning General Fund Town
consideration
of standards
for different
types of senior
housing
Provide viable
options for seniors
living in Woodside
Complete by the
end of 2026
Appendix B/
Factor #3
Goal H5: Plan for a Resilient Community
Policy H5-1 - Minimize Damage from Natural Disasters
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Number Program Lead Implementing
Agency/Dept.

Funding Source Program
Measure(s)
Targets Implementation Analysis/Factor*
a. Update the Very
High Fire Hazard
Severity Zones
(VHFHSZ) Map
Planning/
Engineering
General Fund Update local
maps within 3-
6 months of
new VHFHSZ
maps released
by CAL Fire
Update Town maps
consistent with CAL
Fire map updates
Periodically on an
ongoing basis
Appendix F/
Factor # 2 &5
b. Improve
Emergency
Access and
Response in the
Very High Fire
Hazard Severity
Zones
Planning/Building/
Engineering
General Fund Identify areas
in WUI with
only one point
of access and
work with the
Fire District to
improve
evacuation
routes
Permit increased
evacuation points
proposed
Ongoing Appendix F/
Factor # 2 &5
c. Facilitate and
Encourage
Neighborhood
Preparedness
Building/
Woodside Fire
Protection District
General Fund Ensure
residents from
every CERT
District go
through CERT
training
Ensure Woodside
neighborhoods are
prepared for
natural disasters
Ongoing and annual Appendix F/
Factor # 2 &5
Policy H5-2 – Provide Adequate Utilities
a. Provide Sewer
to Address
Waste Disposal
Failures
Engineering Sewer Hook-up
fees
Provide
information for
connecting to
sewer to
residents
Address failures in
a timely manner
Ongoing Appendix F/
Factor # 2
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Number Program Lead Implementing
Agency/Dept.

Funding Source Program
Measure(s)
Targets Implementation Analysis/Factor*
contiguous to
sewer districts
experiencing
septic failure
b. Prioritize Sewer
for Higher
Density
Residential
Development
Engineering Sewer Hook-up
fees
Coordinate
with all sewer
districts to
accommodate
sewer service
for higher
density
residential
development
Provide sewer
service for higher
density residential
development
Complete by the
end of 2023
Appendix F/
Factor # 2
c. Coordinate with
Cal Water to
ensure
Adequate Water
Supplies
Engineering General Fund Coordinate on
timing for
implementing
capital projects
Ensure adequate
water supply for
sites with increased
housing densities
Ongoing, and during
application process
for developments
fulfilling RHNA
Appendix F/
Factor # 2
Goal H6: Conserve and Rehabilitate the Existing Housing Stock and Develop New Housing Stock Policy H6.1 – Conserve the Existing Housing
a. Apply California
Building Code
Building General
Fund/Permit
Fees
Ongoing Appendix B/
Factor #4
b. Maintain and
Improve
Housing
Building General
Fund/Permit
Fees
Ongoing Appendix B/
Factor #4
Item A Page 136 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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Number Program Lead Implementing
Agency/Dept.

Funding Source Program
Measure(s)
Targets Implementation Analysis/Factor*
c. Enforce Housing
Standards
Building General
Fund/Permit
Fees
Code
enforcement
progress
addressing
corrections to
unsafe living
conditions
Address Code
Enforcement cases
in a timely manner
to protect
adequate public
health and safety
living conditions
Ongoing Appendix B/
Factor #4
Policy H6.2 – Rehabilitate the Existing Housing Stock
a. Continue to
Encourage and
Facilitate Home
Rehabilitation
Planning/Building General
Fund/Permit
Fees
Number of
permits
approved
meeting code
requirements
to maintain
existing
housing units
Provide clear and
publicized
checklists for
housing upgrades
Ongoing Appendix B/
Factor #4
b. Provide
Exceptions and
Variances
Planning General
Fund/Permit
Fees
Number of
variances
approved
Review Exception
and Variance
proposals in a
timely manner
Ongoing Appendix B/
Factor #4
c. Evaluate
Development
Planning General Fund Number of
meetings held
with residents
Provide residents
with options to
upgrade their
existing properties
Complete by the
end of 2025
Appendix F/
Factor # 2
Item A Page 137 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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Number Program Lead Implementing
Agency/Dept.

Funding Source Program
Measure(s)
Targets Implementation Analysis/Factor*
Standards in the
Western Hills
of Western
Hills.
that do not
increase hazards or
the ability to safely
evacuate during
emergencies
d. Utilize
Rehabilitation
Programs
Planning County/Federal
Programs
Number of
programs
utilized
Provide
information on
existing programs
available that can
subsidize home
improvements
Ongoing Appendix B/
Factor #4
Policy 6.3 - Promote Sustainability Including Energy Efficiency a. Promote and
Enforce Energy
Efficiency and
Sustainability
Planning/Building General
Fund/Permit
Fees
Adopt by
reference all
new building
code cycles
with increased
energy
efficiency
regulations
Ensure all new
housing meets
minimum energy
efficient
requirements as
updated by the
State
Ongoing State
Law/Factor #2
b. Encourage
Energy Efficient
Building Design
and Materials
Planning/Building General
Fund/Permit
Fees
Provide
information
about
resources and
technology
available for
Require all new
housing to meet
State mandate
energy efficiency
requirements
Ongoing State
Law/Factor #2
Item A Page 138 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 – January 31, 2023
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i The State Median Income for a Family of 4 in San Mateo County is $149,600 (2021 San Mateo County Income Limits, as defined by HUD, effective April 1, 2021)
ii 21 Elements Listening Session with Service Providers, November 15, 2021. iii HCD Memorandum, Housing Element Site Inventory Guidebook, June 10, 2020, p. 3. \*Analysis/Factor Column- The appendix containing the analysis of data that supports the policy is listed first/then the factor the policy addresses per State law as follows:

1. Contributing factors to fair housing issues.

2. Specific commitment, milestones, metrics, and geographic targeting.

3. Housing mobility, new housing choices, affordability in high opportunity areas.

4. Place based strategies for community preservation.

5. Displacement protection.

Number Program Lead Implementing
Agency/Dept.

Funding Source Program
Measure(s)
Targets Implementation Analysis/Factor*
increased
energy
efficiency
Item A Page 139 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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APPENDIX F. Housing Development Constraints, Development Costs, and Zoning Analysis
Housing Development Constraints
Housing development constraints mentioned by members of the public during the public engagement process include the high cost of land in Woodside; permit costs; project design and construction costs; existing regulations; lack of ability to connect to sewer or accommodate an onsite septic system; and associated studies required to comply with the Building Code, such as geotechnical analyses.
 Natural Hazards: Natural hazard areas are widespread throughout Woodside, which include, but are not limited to: Very High Fire Hazard Severity Zone (VHFHSZ); steep slopes; underlying active and dormant landslides; heavily wooded areas; earthquake fault zones, including the San Andreas Fault; expansive soils; and FEMA flood zones.  Environmentally Sensitive Areas: General Plan designated streams and buffers on either side of them (25 feet from the top of bank or 50-feet from the center line of the stream, whichever is further) are protected throughout the Town as sensitive riparian areas and wildlife corridors. General Plan designated streams; blue-lined streams on USGS maps; and other non-designated drainage channels may be subject to Regional, State, and Federal environmental regulations. In addition to designated streams and drainage channels, other bodies of water and land areas include habitat for local flora and fauna, furthering constraints on local housing development.
 Land Costs: The cost of land in Woodside ranges from a low of $150,000 to a high of $2,000,000 for lots that are one acre or less (Appendix F.1)i . Land costs are an impediment to
building affordable housing projects in Woodside. Partnerships between landowners and housing developers could be created to address land costs and development of higher density units.
 Construction Costs: The total development costs in San Mateo County for a small singlefamily residence (2,600 square feet) is $2,487,000. The total development cost for a large single-family residence (5,000 square feet) is $3,610,000 (Appendix F.1. Exhibit 1). Project costs vary by geography, topography, site conditions, finish level, and contractor type, and time among other factors.
 Fees: Fees in Woodside, including entitlement, building permit, and impact fees are approximately $70,957 for single-family residences, with a range in the county of $6,760 to $104,241. Fees in Woodside for “small multi-family” (main residence with one or more ADUs) are $82,764, with a range in the county from $6,824-$167,210, as indicated in Table F-1, below. Data on fees was provided by jurisdictions in San Mateo County and summarized by 21 Elements.

Item A Page 140 Town Council Special Meeting January 31, 2023

ATTACHMENT IF
HCD Review Draft #2 - January 31, 2023
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 Availability of Sewer: Approximately 60-70 percent of the properties in Woodside utilize septic systems. The Town is served by two sewer districts. The Town Center Assessment District has available capacity in the central area of Woodside. The Redwood Creek Assessment District currently has limited available capacity. Sewer service may be extended to eligible properties contiguous to sewer districts. Lack of access to sewer is a development constraint for properties served by septic. The Town is exploring both expansions to the sewer districts and negotiations for additional sewer capacity.  Septic Feasibility: The San Mateo County Environmental Health Department primarily regulates installation of septic systems. The primary difference between County and Town regulations is that the Town Municipal Code does not permit septic systems in slopes >35%, while the County allows septic systems in slopes up to 50%. Meeting the space requirements for traditional systems can be a constraint to developing additional units on parcels.  Height Restrictions in the Town Center (Measure J): A citizen initiative passed in 1988 (Measure J) restricts building height in the Town Center: “…buildings on commercially zoned parcels immediately adjacent to Woodside Road may not be constructed or altered to exceed one story facing Woodside Road. They may include a basement, as defined in Section 9-

2.105(g) of the Municipal code on June 1, 1988.” This measure does not affect residential properties but is a constraint to adding housing over commercial buildings in the Town Center Community Commercial District.

Development Costs
A Summary of Development Costs and Fees for San Mateo County and its jurisdiction is included in Appendix F.1.
21 Elements surveyed local jurisdictions and summarized fees by jurisdiction as shown in Tables F-1 through F-4, below. Jurisdiction fees (entitlement fees, building permits, impact fees) contribute to the overall cost of development, as indicated below.

Table F-1. Total Fees (includes entitlement, building permits, and impact fees) per Unit Single Family Small Multi-Unit Large Multi-Unit
Atherton $15,941 No Data No Data
Brisbane $24,940 $11,678 No Data
Burlingame $69,425 $30,345 $23,229
Colma $6,760 $167,210 $16,795
Daly City $24,202 $32,558 $12,271
East Palo Alto $104,241 No Data $28,699
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Foster City $67,886 $47,179 $11,288
Half Moon Bay $52,569 $16,974 No Data
Hillsborough $71,092 No Data No Data
Millbrae $97,756 $6,824 $55,186
Pacifica $33,725 $40,151 No Data
Portola Valley $52,923 No Data No Data
Redwood City $20,795 $18,537 $62,696
San Bruno $58,209 $72,148 $39,412
San Mateo $99,003 $133,658 $44,907
South San Francisco $81,366 $76,156 $32,471
Unincorporated San Mateo $36,429 $27,978 $10,012
Woodside $70,957 $82,764 No Data

Table F-2. Total Fees per Unit - Distribution of Fees Charged by San Mateo County Jurisdictions Single Family Small Multi-Unit Large Multi-Unit
Quartile 1 $27,136 $20,897 $14,533
Median Fee Charged $55,566 $36,355 $28,699
Quartile 3 $71,058 $75,154 $42,160
Interquartile Range $71,057 $75,153 $42,159
Total Range $97,481 $160,387 $52,684

Item A Page 142 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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Table F-3. Total Fees as a Percentage of Total Development Costs

Single-Family
Residence
Small Multi-Family
(SFR with ADUs in
Woodside) Large Multi-Family
Atherton 0% No Data No Data
Brisbane 1% 1% No Data
Burlingame 3% 4% 3%
Colma 0% 17% 2%
Daly City 1% 4% 2%
East Palo Alto 4% No Data 4%
Foster City 3% 6% 2%
Half Moon Bay 2% 2% No Data
Hillsborough 3% No Data No Data
Millbrae 2% 8% 7%
Pacifica 1% 5% No Data
Portola Valley 1% No Data No Data
Redwood City 1% 2% 8%
San Bruno 2% 8% 5%
San Mateo 4% 14% 6%
South San
Francisco 3% 9% 4%
Unincorporated
San Mateo 1% 3% 1%
Woodside 2% 9% No Data
Note: The above table was calculated using average soft costs (including an average of jurisdiction charged fees) and average land costs for the County. A more precise determination of fees as a percentage of total development costs can be calculated using jurisdiction specific land costs and fees.

Item A Page 143 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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Table F-4. Permit Processing Times (in months)

ADU
Process
Ministerial
By-Right
Discretionary
By-Right
Discretionary
(Hearing
Officer if
Applicable)
Discretionary
(Planning
Commission)
Discretionary
(City Council)
Atherton 1 to 2 1 to 3 2 to 4 N/A 2 to 4 2 to 6
Brisbane 1 to 2 2 to 6 N/A N/A 4 to 12 6 to 14
Burlingame
1 to 2 2 to 3 2 to 3 N/A
3-4 standard
project; 12
major project 13 months
Colma 1 to 2 1 to 2 1 to 3 2 to 4 N/A 4 to 8
Daly City 1 to 2 2 to 4 N/A N/A 4 to 8 8 to 12
East Palo Alto 1 to 3 8 to 12 6 to 14 20 to 40 20 to 40 20 to 40 Foster City 1 to 2 1 to 2 1 to 2 3 to 6 6 to 12
Half Moon Bay 1 to 2 2 to 4 3 to 6 4 to 12 6 to 15
Hillsborough - - - - - -
Millbrae 0 to 2 3 to 6 1 to 3 3 to 8 3 to 8 4 to 9
Pacifica 1 to 2 2 to 3 4 to 5 5 to 6 5 to 6 7 to 8
Redwood City 2 to 3 3 to 4 N/A 8 to 10 12 to 18 18 to 24 San Bruno 2 3 to 6 N/A 3 to 6 9 to 24 9 to 24
San Mateo 4 to 8 1 to 2 4 to 7 N/A 9 to 12 9 to 13
South San Francisco 1 1 2 to 3 2 to 3 3 to 6 6 to 9
Unincorporated San
Mateo 1 to 3 3 to 6 4 to 9 6 to 12 6 to 18 9 to 24
Woodside 1 to 2 1 to 2 N/A N/A 2 to 6 3 to 8

Item A Page 144 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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Zoning Analysis
Existing Zoning – Single-Family
The Town of Woodside has seven six single-family residential zoning districts including: SingleFamily Residential (R-1); Suburban Residential (SR); Rural Residential (RR); Special Conservation Planning - 5 acre minimum (SCP-5); Special Conservation Planning – 7.5 acre minimum (SCP-7.5); and Special Conservation Planning - 10-acre minimum (SCP-10). and Multi-Family Residential Development (MFRD) Overlay Zone.

The SCP Zones, which can be developed with housing, are characterized by several constraints, which include steep slopes, unstable slopes, high fire hazard, earthquake fault zones, low soil permeability, high ground water, expansive soils, and areas within the 100- or 500-year flood zone. To protect public health and safety and minimize the effects of hazards on more constrained properties, the following zoning classifications for SCP Districts minimum lot sizes were developed based on the number of identified constraints throughout each area:

SCP-5 1-2 constraints
SCP-7.5 3 constraints
SCP-10 4+ constraints
Existing Zoning – Multi-Family
The Town’s multi-family zoning is the Multi-Family Residential Development Overlay Zone (MFRD). The development standards for this zone are summarized in Municipal Code Table C Section 153.110. The following is an analysis of the key standards that may constrain muti-family development:
• Currently applies only to the Cañada College property. • Lot coverage by buildings is limited to 60% of the lot area. • Maximum unit density is one unit per 2,400 square feet of lot area, or approximately 18 units per acre (less that the 20 units per acre suburban standard for affordable housing per State law).
• Building height is restricted to 35 feet, or approximately three stories. • Parking standard requires one space per bedroom.
• Permitting process requires both Architectural and Site Plan review and Planning Commission approval of a use permit with findings.

Special Housing Types
Emergency Shelters are permitted in the Community Commercial (CC) zoning district.

Transitional Housing is permitted in all residential districts, except the Multi-Family Residential District (MFRD) Overlay Zone. It is also permitted in the Community Commercial (CC) District.

Item A Page 145 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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Manufactured Homes (Mobile Homes) are permitted in all residential zoning districts, except the Multi-Family Residential District (MFRD) Overlay Zone.

Residential Care Homes are allowed within all residential districts, except the Multi-Family Residential District (MFRD) Overlay Zone.

Since Room Occupancy Units are not specifically mentioned in the Zoning Code; however, Junior Accessory Dwelling Units (JADUs) are allowed in single family (owner-occupied) dwellings.

Proposed Zoning
The Town of Woodside is proposing a new higher density single-family zone or multi-family zone district to accommodate projects of 10 units/acre (MFRD-10). Multi-Family sites identified in the RHNA Plan will be rezoned prior to January 31st, 2023. within one year following the approval of the Housing Element.

Wildland Urban Interface (WUI)
The Town of Woodside, as a Wildland Urban Interface (WUI), intersects with a variety of interests and State of California goals. It is situated between the California coast and more urbanized areas.

The Town’s character has long preserved equestrian and other livestock uses, while being located in a County and region that has experienced an influx of people from various parts of the nation and world due to the mild climate, significant job growth (more recently in the higher paying technology sector), widespread acceptance of various cultures, and natural beauty. The State has many competing goals, such as preservation of natural resources and habitats for endangered species, water conservation among increasing climate change and droughts, and housing for the increasing population. Woodside’s location serves as an intersection of all State goals, which historically was focused on conservation of environmental resources. Pressures for increased housing development in an area with various existing natural and infrastructure constraints make the Town of Woodside less viable for increased housing densities than nearby communities within the Bay Area Peninsula. Simply changing zoning for increased housing throughout Woodside is not a viable option without sacrificing commitments to other State goals.

Therefore, while zoning changes for increased housing density is important to meet State objectives, sites for such increases in density are not abundant. i Baird + Driskell retained Century Urban, LLC to prepare a research memo on San Mateo and Santa Clara Counties Development Costs and San Mateo County Unit Mix (April 7, 2022). Land costs for Woodside are based on minimal data points, so actual costs may be higher.

Item A Page 146 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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APPENDIX G. Adequate Sites Inventory
The Housing Element must include an inventory of land suitable and available for residential development to meet the Town’s regional housing need by income level. The site inventory is then used to identify and analyze specific sites that are available and suitable for residential development to determine the jurisdiction’s capacity to accommodate residential development to meet the Regional Housing Needs Allocation (RHNA). The available and suitable sites are referred to as adequate sites.

The Town’s Cycle 6 RHNA Allocation
The Town’s Cycle 6 RHNA base allocation is 328 units. The State Department of Housing and Community Development (HCD) guidelines recommend including a buffer of additional units to adequately plan to meet the allocation. Woodside has elected to include a 20% buffer in addition to the base allocation. The buffer equals 65 units for a total of 393 planned units (see Table G-1).

The Town’s Cycle 5 RHNA Allocation
In previous RHNA cycles, the Town met its affordable housing allocations through the development of ADUs.

ADUs have been an effective housing type to supply affordable units in the Town’s rural residential setting which has been planned and developed in a manner that conserves environmentally sensitive areas, including habitats for endangered and threatened species, such as the California Red Legged Frog and San Francisco Garner Snake. As a rural residential community with significant environmental constraints, the Town anticipates that ADUs will continue to provide a majority of the affordable housing units within the Town of Woodside.

The community overwhelmingly supports increasing the production of ADUs; therefore, the Housing Element Programs seek to identify ways to increase ADU and JADU production, including but not limited to, allowing additional ADUs where feasible, reducing regulatory constraints, conducting ADU workshops (completed October 2022), developing an amnesty program for units built without permits prior to 2020, and developing information materials to promote ADU development.

The location of both single-family residences (53) and ADUs (82) for which building permits were issued in Cycle 5 (through 2021), are identified in Figure G-1.

Item A Page 147 Town Council Special Meeting January 31, 2023 ATTACHMENT 1G
HCD Review Draft #2 - January 31, 2023
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Figure G-1. The Location of Single-Family Residences and ADUs for which building permits were issued during RHNA Cycle 5 (2015-2021)
Item A Page 148 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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Woodside Site Inventory
In order to identify sites to accommodate additional housing for Cycle 6, the Town of Woodside prepared a full Site Inventory in accordance with the California Department of Housing and Community Development’s (HCD) Site Inventory Guidebook (Government Code Section 65583.2).

Characteristics and Mapping of Vacant and Underutilized Sites The Town identified a total of 152 Vacant and Underutilized sites in its Site Inventory (see Table G-1). Of these sites, 106 are Vacant, 46 are Underutilized (Non-vacant single-family), and four units are single-family projects in the approval pipeline. Vacant sites do not have improvements. Underutilized sites have some structures and improvements such as sheds, solar panels, animal enclosures, vineyards, parking lots or driveways, or old barns, but do not have a single-family residence, other type of residential unit, or substantial improvement(s). In some cases, the Underutilized parcels adjoin a parcel with a single-family residence and are used for additional yard space.

The Town’s consultant used Google Maps, which shows improvement footprints, and Google Satellite Imagery, to identify level of improvements on the different sites. ‘Ground-truthing’ of sites and their improvements was conducted by Town staff, to the extent that improvements were visible from public roadways. Several additional sites were added based on the site visits.

As discussed in the following section, the site inventory was updated and sites were categorized by affordability level, taking into account the State policy that sites under a half-acre or larger than 10 acres may not be suitable for affordable housing. Figure G-2 shows Vacant and Underutilized sites with environmental constraints and suitability for various income levels.

Item A Page 149 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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Figure G-2. Housing Sites and Environmental Constraints [update map per Council direction] Item A Page 150 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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HCD Reporting Requirements for Site Inventory
HCD requires the submittal of the Site Inventory on a specific HCD Excel Site Inventory spreadsheet. This form is posted on the Town website, along with the 2023-2031 Housing Element. The spreadsheet consists of three tables (tabs). Table A includes general characteristics, such as parcel size, zoning (Column G), maximum density (Column I), infrastructure (Column L), and income level distribution (Columns P, Q and R), and additional parcel characteristics, e.g., site improvements, slope, etc. (Column T).

Infrastructure (Column L)
With respect to infrastructure, sewer service is the primary limiting factor for higher density development in the community. Between 60-70 percent of all residential parcels within Woodside rely on septic systems (or would rely on septic systems if developed). Sites within or immediately adjacent to Sewer Districts may be connected if certain criteria are met. Water service and dry utilities are available throughout the community; therefore, with sewer service being the limiting factor, if the site is within or immediately adjacent to a sewer district, it is listed as “Yes-Current” for sewer service in Column L of the Site Inventory.

Distribution Methodology by Income Level (Columns P, Q and R) This section describes how income levels are distributed in the Site Inventory.

All single-family residential parcels, by right, are allowed one single-family residence, an 800 square foot ADU, and a Junior ADU – for a total of 3 units.

Single-family residences in Woodside are all identified as Above Moderate-Income units; therefore, each single-family residential property was allocated one Above Moderate-Income unit.

For ADU income distribution, the Town utilizes research developed by 21 Elements and ABAG (Housing Element, Appendix E – Draft Affordability of ADUs) in which 30% of ADUs are allocated for Very Low-Income households; 30% are allocated for Low-Income households; 30% are allocated for Moderate-Income households; and 10% are allocated for Above Moderate-Income households. This distribution is referred to as the “30-30-30-10 ADU Distribution”. The distribution is used to allocate ADU units in Tables G-1 and 3-5 – Proposed RHNA Plan but is not included in in the HCD Excel Site Inventory spreadsheet for a site-based allocation.

Optional Information (Column T)
Optional Information included in Column T describes improvements or conditions that are visible from public roadways. In some cases, sites have solid fences, so visibility is limited. In other cases, sites are landlocked or are located along private rather than public roadways, where access is not permitted. Additionally, flag lot configurations preclude visibility of some sites. Given the limited visibility of many sites, the San Mateo County GIS Portal and Google Item A Page 151 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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Earth were also viewed. Where there was apparent instability of some slopes, the Town Geologic Map was also consulted.

Table B of the Woodside Site Inventory spreadsheet identifies one site proposed for higher density rezoning using a new higher density zone that would allow 10 units per acre. [This section may be revised for two or three sites at 20 du/ac per 1-31-23 Council direction] Table C describes allowable density in each of the existing zoning districts where residences are permitted.

Site Considerations
The California Housing and Community Development Department (HCD) encourages consideration of the following factors when considering opportunity sites that can accommodate different income levels and densities:
 Proximity to transit;
 Access to high performing schools and jobs;
 Access to amenities, such as parks and services;
 Access to health care facilities and grocery stores;
 Locational scoring criteria for Low-Income Housing Tax Credit (TCAC) Program funding;  Proximity to available infrastructure and utilities;
 Sites that do not require environmental mitigation;
 Presence of development streamlining processes, environmental exemptions, and other development incentives.

While the State encourages sites be identified to increase housing density in high opportunity neighborhoods, the Town has very limited public transportation, services, business (jobs), and amenities.

General characteristics for suitable sites for increased housing density include sites located outside of highly constrained areas which include underlying landslides, earthquake fault zones, environmentally sensitive areas, and high fire hazard severity zones (VHFHSZ) that do not have easy access to arterial roadways and freeways.

Sixty (60) to 70 percent of properties in Woodside utilize onsite septic systems for sewage disposal; therefore, combined with environmental constraints, possible sites for increased housing density are limited. Sites and areas considered for medium to higher housing densities are properties that have or could access sewer.

Sites for Higher Density Residential Development
To meet the Cycle 6 RHNA Plan, the Town has identified two higher density sites, including:

Cañada College (where the College District anticipates constructing approximately 75 housing Item A Page 152 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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units for students and family and employees that meet very low- and low-income level categories, and has included this in its 2022 Districtwide Facilities Master Plan), and one private property at a higher density rezoning of 20 units per acre. Figure G-2 shows these two sites that could support higher density residential development to meet the Town’s RHNA targets. Figure G-3 shows an excerpt from the San Mateo College Districtwide Facilities Master Plan where higher density housing could be placed on the Cañada College campus. [This section may be revised to add one or two Town owned sites and rezoning at 20 du/ac if Council per council direction on 1-31-23 meeting].

Required Code Changes and Rezoning
A multi-family overlay zone (MFRD Overlay Zone) was added at Cañada College in Cycle 5. The Cycle 6 Housing Element includes a program to reduce the complexity of the entitlement process for this overlay zone.

The one private property included in the RHNA Plan for higher density is included in the Plan as a combination of Moderate and Above Moderate units. The owner of this property is actively exploring development. This site is located at 773 Cañada Road. Rezoning at a higher density of 20 units per acre would be completed in 2023, for the private property. [This section may be per 1-31-23 Council direction]

Item A Page 153 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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Figure G-3 Cañada College Multi-Family Housing Plan
Cycle 6 RHNA Plan
The Cycle 6 Housing Element includes a goal to meet the RHNA allocation, with a 20% buffer for a total of 393 units.

Meeting the Town’s RHNA Allocation
Under current zoning requirements, including new housing at Cañada College, the Town projects the development of 422 [Number to be revised per 1-31-23 Council direction] units based on the HCD Excel Site Inventory spreadsheet. The Housing Element Programs in Chapter 3 outline rezoning of specific sites, and policies that encourage ADU development, to provide varied housing types that will meet AFFH goals and RHNA targets, including the 20% buffer.

The RHNA Plan is described in Table G-1.

Table G-1 Proposed RHNA Plan [Final table to be inserted here per 1-31-23 Council direction] Item A Page 154 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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Low and
Very Low
Income
Moderate
Income
Above
Moderate
Income Total
Current Zoning Sites
Vacant Single-Family Sites 106 106
Non-Vacant Single-Family sites 46 46
Pipeline Projects 4 4
Cañada College 75 75
ADUs @ 15 ADUs Annually 72 36 12 120
Rezoning Sites
773 Cañada Site @ 20 du/ac 16 11 27
Town-owned Site @ 20 units/acre 23 10 33
Total 170 62 179 411
RHNA Allocation - Base 142 52 134 328
RHNA Buffer @ 20% 28 10 27 65
Total RHNA + Buffer 170 62 161 393
Surplus/Deficit None None +18 +18
Assumptions for Table G-1
• There are 106 legally formed vacant parcels of substandard size with zoning that allows for single family residential development in the Town. Under State law, property owners would be allowed to develop one housing unit on each site, so these units have been counted toward the Above Moderate RHNA requirement.
• There are 46 legally formed non-vacant parcels of substandard size with zoning that allows for single family residential development in the Town. These parcels are not in use for winery or animal keeping, but they may contain structures such as outbuildings which do not inhibit development with housing. Under State law, property owners would be allowed to develop one housing unit on each site, so these units have been counted toward the Above Moderate RHNA requirement.
• In July 2022, the San Mateo County Community College District adopted the 2022 Districtwide Facilities Master Plan (FMP), which was developed to guide short- and long-term planning for the District’s three campuses. The District is now actively seeking funding for student and family housing at its campuses. As a first phase, the District is in the process of applying for a State grant to support housing at the College of San Mateo campus. If successful, the District would move to a second phase to obtain grant funding to support student and family housing at one of its other two campuses, including Cañada College. The second phase application submittal could take place as soon as July 2023. The District has indicated that 75-80 units at Cañada College is a reasonable assumption.

Item A Page 155 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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• Pipeline projects which are expected to receive permits within the projection period may also be counted toward RHNA. Any projects currently in review, recently approved, or under construction will also be counted toward RHNA.
• 773 Cañada Road is assumed at 16 units available to households making less than 120 percent of the San Mateo County median income for the Moderate RHNA requirement.

Safe harbors under State law allow the Town to project development of at least 15 ADUs per year over the 8-year planning period. Production trends have increased since 2018 and based on programs in the Housing Element designed to facilitate and promote ADU construction, the inventory assumes 20 ADUs per year over the planning period, for a total of 160. The units have been allocated to RHNA categories consistent with the findings of the regional ADU affordability study prepared by ABAG discussed above and are allocated according to the 60/30/10 distribution assumption. [This section may be revised to 15 du/ac per 1-31-23 Council direction]
Item A Page 156 Town Council Special Meeting January 31, 2023

ATTACHMENT H

REVISED DESCRIPTIONS OF REZONING SITES
773 Cañada Road Site
The 773 Cañada Parcel is privately-owned and is 4.807 acres (San Mateo County Assessor estimate). The property owner is actively exploring higher density development on the lower portion of this parcel, as well as lower density single-family development on the upper portion of the parcel. Development would require new sewer service. The site is adjacent and eligible to connect to the Town Center Sewer District. The site includes an existing single-family home that would be demolished. The home is not currently occupied by a lower income household and is not a historically significant structure.

Item A Page 157 Town Council Special Meeting January 31, 2023 ATTACHMENT 1H
Raymundo Drive Town Owned Site
(Graphic and text to be reinserted in the Housing Element if Town Council approves) The Town-owned Raymundo Drive parcel is 1.770 acres (San Mateo County Assessor estimate).

The site is relatively flat. Potential constraints include lack of sewer service, seismic conditions and a Deed Restriction from the State of California designating the parcel for “public purposes”.

This site is suitable for rezoning to small lot single-family higher density zoning of 20 units per acre, or the multi-family MFRD zone.

Item A Page 158 Town Council Special Meeting January 31, 2023 High Road Site
(Graphic and text to be reinserted in the Housing Element if Town Council approves) The Town-owned High Road parcel is 1.055 acres (San Mateo County Assessor estimate).

Potential constraints include topography, drainage and soil conditions. This site is suitable for rezoning to the MFRD zone for a multi-family development of at least 20 units per acre.

Item A Page 159 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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APPENDIX H. Summary
The Town of Woodside participated in/held a variety of public engagement opportunities soliciting important community feedback on the Housing Element update to meet the Cycle 6 housing targets. Some parts of the process were coordinated by 21 Elements, a consortium of San Mateo’s 21 jurisdictions that work together collaboratively to address Housing Element requirements. The focus of the local Town process was to share the requirements of the Housing Element in a series of public meetings and obtain comments from the public and decision makers about how best comply with the State’s housing mandates. Key events, meetings, study sessions, and informational webinars—both Countywide and local—that provided opportunities for engagement are described below:

Table H-1. Public Engagement Summary
Date: Virtual
Meetings and
Webinars:

Town Council: Planning
Commission:

RHNA
Subcommittee:

December 15,
2020
RHNA Meeting
April 14, 2021 ‘Let’s Talk
Housing!’ (LTH)
Introduction
with Woodside
Break-out
Session
June 8, 2021 RHNA 5 Progress
& RHNA 6
Allocation
June 16, 2021 RHNA 5 Progress &
RHNA 6 Allocation
October 13,
2021
LTH: “Why
Affordability
Matters”
October 26,
2021
Joint TC/PC/ASRB
Study Session on
SB 9
October 27,
2021
LTH: “Housing &
Racial Equity”
November 4,
2021
ADU Workshop
with Woodside
Break-out
Session
November 10,
2021
LTH: “Housing in
a Climate of
Change”
Item A Page 160 Town Council Special Meeting January 31, 2023 ATTACHMENT 1I
HCD Review Draft #2 - January 31, 2023
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Table H-1. Public Engagement Summary
Date: Virtual
Meetings and
Webinars:

Town Council: Planning
Commission:

RHNA
Subcommittee:

November 17,
2021
SB 9 Code
Amendment,
Subdivisions
December 1,
2021
LTH: “Putting it
all Together for
a Better Future”
December 1,
2021
SB 9 Code
Amendment, Zoning
December 14,
2021
SB 9 Code
Amendment,
Subdivisions &
Zoning
January 12, 2022 Cycle 6 Housing
Element
January 25, 2022 Mayor appoints a
RHNA
Subcommittee
February 2, 2022 Housing Study
Session
February 16,
2022
Housing Study
Session
February 17,
2022
RHNA
Introduction
February 24,
2022
RHNA Planning
March 2, 2022 Review Draft HE
Chapters 1 and 2
March 8, 2022 Review Draft HE
Chapters 1 and 2
March 10, 2022 Final RHNA
Recommendati
on
March 16, 2022 Review RHNA
Subcommittee
Recommendation
March 22, 2022 Review RHNA
Subcommittee
Recommendations
April 25, 2022 Review of Draft
HE Chapter 3
Item A Page 161 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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Table H-1. Public Engagement Summary
Date: Virtual
Meetings and
Webinars:

Town Council: Planning
Commission:

RHNA
Subcommittee:

May 10, 2022 Review of Draft
HE for public
comment and
HCD submittal
May 18, 2022 –
July 1, 2022
(44-day Public
Comment
Period)
July 12, 2022 Formal Response
to Comments
December 13,
2022
Review HCD
Comment Letter
and Response to
Comments memo
January 10, 2023 Review HCD
response
regarding Townowned sites
January 31, 2023 Review revised
Housing Element
documents for
submittal to HCD
for second review
Public Engagement– Chronology of Meetings, Study Sessions, and Informational Webinars
Given The Town of Woodside’s Cycle 6 Housing Element need to plan for approximately 5.3 times the amount of housing as the previous Cycle 5, concerns from the community have been expressed on how best to meet the requirement, with a desire to focus on increased ADU production. While ADUs alone may not be able to reach the RHNA target, the Town has engaged the public in a series of meetings, events, and webinars to share ideas and concerns.

A chronology of these events, meetings, study sessions, and informational webinars, is described below:

Item A Page 162 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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Town Council Meeting, December 15, 2020
The Town Council reviewed and discussed the Cycle 6 ABAG RHNA distribution, and its upcoming distribution to individual jurisdictions.

Webinar - ‘Let’s Talk Housing!’ Meeting and Break-out Session, April 14, 2021 The Town of Woodside joined the cities of Atherton, Daly City, Half Moon Bay, and Pacifica, and the Unincorporated areas of San Mateo County, in a community workshop that was designed as a “kick-off” event to introduce the Housing Element process and describe ways for members of the public to get involved. Each municipality conducted its own break-out session to encourage participants to share their housing related views, ideas, and concerns, and solutions.

At Woodside’s Break-out session, members of the public raised issues regarding the complexity of regulations they encounter as they construct housing in Woodside and the time involved. They also mentioned that many were drawn to Woodside because of its rural character and natural environment, while noting the challenge of building in the Town with its many environmental constraints. Other comments included the need to streamline the development process and encourage the Town to work with the County Department of Environmental Health to adopt sewer regulations that allow for alternative septic technologies.

Town Council Meeting, June 8, 2021
Planning staff provided an overview of the Town’s Cycle 5 RHNA (2015-2023) compliance, noting that only nine Moderate Income units were still needed to meet the 62-unit allocation.

Staff further explained that the Cycle 6 (2023-2031) allocation would likely be 328 units, which is nearly 5.3 times the Cycle 5 allocation. Given the current State housing deficit and the Governor’s focus on increasing housing stock at all income levels, staff conveyed that the upcoming Cycle 6 Housing Element would likely receive more scrutiny than past Housing Elements. Staff noted that the Town is working with 21 Elements to ensure all required components are included in the Housing Element update.

Planning Commission Meeting, June 16, 2021
Planning staff forwarded the Town Council Report on the Housing Element to the Planning Commission for its review and comments. Staff indicated that given the much higher RHNA allocation for the Cycle 6 Housing Element, there needs to be more done to aggressively promote ADUs. Ideas to promote ADUs included: ADU workshops and an ADU workbook specifically tailored to Woodside. Staff noted that there can also be targets for niche ADUs, such as encouraging people who have barns to add an ADU for equestrian workers, or developing ADUs for multi-generational living, or aging in place.

Item A Page 163 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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‘Let’s Talk Housing!’ Series of Webinars - October 13, 2021– December 1, 2021 A second set of workshops in the form of issue-based webinars was conducted during the Fall of 2021. The workshops were designed to provide information about key issues affecting affordable housing so that participants would have information and resources to draw from as they work(ed) to find solutions to provide affordable housing in each jurisdiction. The webinars included:
(1) Why Affordability Matters: Why housing affordability matters to public health, community fabric and to county residents, families, workers and employers; (2) Housing and Racial Equity: Why and how our communities have become segregated by race, why it is a problem and how it has become embedded in our policies and systems;
(3) Housing in a Climate of Change: What is the connection between housing policy and climate change and a walk through the Housing & Climate Readiness Toolkit; and,
(4) Putting it All Together for a Better Future: How design and planning for muchneeded new infill housing can be an opportunity to address existing challenges in our communities.

Joint Meeting of the Town Council, Planning Commission, Architectural and Site Review Board (ASRB), October 26, 2021
The Town held a joint public hearing of its Town Council, Planning Commission, and Architectural and Site Review Board (ASRB), for a study session on implementation of SB 9.

Key issues discussed related to: whether or not SB 9 projects are allowed in a high fire severity zone; clarification on demolition of more than 25% of an existing structure; minimum unit size and whether it should be increased from 800 square feet; developing design standards that use “shall” as opposed to “should”; whether the Town can do anything to enforce the affidavit required to be signed by the property owner that they will live in one of the units for three years; parking requirements; setback requirements; HOA/CC&R requirements; septic/sewer availability; topography; tax reassessment after construction; and Proposition 13 tax assessment impacts.

Webinar - Building Second Units, November 4, 2021
With increased interest in building ADUs, and increased numbers of units required by the State for the Cycle 6 Housing Element, the Town of Woodside is getting the word out about opportunities for constructing ADUs in Woodside. On November 4, 2021, the Town of Woodside joined the County of San Mateo and the cities of Brisbane, San Carlos, and East Palo Alto in conducting an informational workshop on constructing second units. Woodside Planning staff presented a PowerPoint on the Town’s process for developing ADUs (second units) and the numbers and types of units permitted on different sized lots. Staff also explained that, as of January 1, 2020, all property owners of single-family parcels are Item A Page 164 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
H-6
permitted to construct an 800 square foot ADU by-right, with ministerial approval, maintaining minimum rear and side setbacks of 4 feet, and a height not exceeding 16 feet.

Property owners are also permitted by-right to construct a 500-square foot Junior ADU (an ADU that utilizes one of the existing bedrooms of the main residence). Participants had questions regarding the type of ADUs that could be built on different sizes of parcels. Staff explained that the Town has generous regulations regarding ADUs, allowing at least one 800 square foot ADU and a 500 square foot Junior ADU by-right. In Woodside, lots that are 1 acre in size or greater are permitted up to two ADUs.

Planning Commission Meeting, November 17, 2021
The Planning Commission considered amendments to Chapter 152 (Subdivisions) to bring the Woodside Municipal Code into compliance with SB9.

Commissioners and members of the public provided a broad range of comments. Some members of the public expressed concerns with increased development in areas with substandard roads in high fire risk areas.

Planning Commission Meeting, December 1, 2021
Planning Commissioners considered amendments to Chapters 151 (Site Development) and 153 (Zoning) to comply with SB9. Residents expressed concerns regarding the setback of these units from barns, given health and safety issues that may arise living immediately adjacent to animal housing.

Town Council Meeting, December 14, 2021
The Town Council reviewed an Ordinance to amend chapters 152 (Subdivisions) and 153 (Zoning) to bring the Municipal Code into compliance with SB9. Much of the Council and community discussion focused on fire risk. The Fire Marshal read a letter dated December 13, 2021, to the Town Council: “The topography of Woodside is capable of producing wind conditions that promote extreme wildfire behavior; these conditions make swift evacuation critical for residents within and adjacent to these areas; many of these areas are adjacent to and amongst unmitigated non-fire resilient open space lands containing extreme fuel loads which only make matters worse. Many residents only have a single route out of the area; a large portion of the roads in these areas are narrow and winding, having the potential to cause life threatening traffic congestion during an evacuation as residents try to leave the area and firefighters try to enter to fight the fire. Allowing additional density in these areas at the levels proposed through SB 9 would result in a threat to the health and safety of residents in that area; due to mountainous terrain within these areas and existing development, there is no feasible way to improve evacuation routes that would sufficiently mitigate the threat to the public safety due to increased density during an evacuation and it is beyond an individual applicant’s ability to satisfactorily mitigate or avoid the specific adverse impact.” Item A Page 165 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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The Council adopted Municipal Code changes that allowed for SB9 Lot Splits and SB9 development consistent with State law.

Planning Commission Meeting, January 12, 2022
Planning staff provided an overview of the Cycle 6 RHNA allocation encouraging recommendations to support achieving the goals of the next Housing Element. Staff noted that by the end of 2021, the Town had exceeded the target number of 62 units by an additional 62 units in Cycle 5, the majority of which (42 units) are Above Moderate units; while 20 are Very Low, Low, and Moderate units. Staff also noted that HCD does not permit these additional units to be carried over to the next Housing Element cycle. (HCD subsequently clarified that units may be counted in the next RHNA cycle if they have not been ”finaled” by June 30, 2022). Staff indicated that 21 Elements is providing guidance and assistance in preparing for the increased requirements for an Adequate Sites Analysis for future housing. The Adequate Sites Inventory must now, e.g., identify each property by its assessor parcel number and describe whether the property either currently has access to sufficient water, sewer, and dry utilities or is scheduled to have such access according to an adopted plan.

Planning staff also provided an overview of new State housing laws, and the Town’s implementation of these laws, and new laws requiring coordination between the Housing Element and the Local Hazard Mitigation Plan (LHMP) or Safety Element.

Town Council Meeting, January 25, 2022
On January 25, 2022, the Town’s Mayor formed a RHNA Subcommittee to discuss and recommend strategies to meet required housing targets for all income levels, and AFFH goals.

The subcommittee conducted meetings on February 17, 2022, February 24, 2022, and March 10, 2022.

Planning Commission Meeting, February 2, 2022
The Planning Commission Study Session included an overview on ADUs, ADU Development Standards, and ADU Affordability.

Planning Commission Meeting, February 16, 2022
The Planning Commission conducted an additional study session to discuss recent State housing mandates and the Town’s compliance with appropriate zoning code changes. The Commission also discussed requirements for the Cycle 6 Housing Element.

RHNA Subcommittee Meeting, February 17, 2022
Item A Page 166 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
H-8
RHNA Subcommittee members received a packet including information about highly constrained areas, vacant land, and parcels that are currently connected to, or have the potential to be, connected to sewer service. The Subcommittee considered criteria for selecting sites, such as more level terrain and access to services. The Subcommittee also reviewed the demographic trends in the community and considered special needs groups such as seniors, and students attending Cañada College. They also considered HCD’s preference that projects be available to all people rather than specific groups, such as seniors or students. The Subcommittee brainstormed about potential sites near the Cañada College, Town Center, and Interstate-280 corridor. In looking at potential sites, the RHNA Subcommittee indicated that rezoning for high density should be conducted with willing property owners, to every extent possible.

RHNA Subcommittee Meeting, February 24, 2022
Planning staff provided an overview of the Virtual Tour with HCD conducted earlier in the day, discussing comments on HCD’s approach to Affirmatively Furthering Fair Housing. It was explained that HCD staff focused on ensuring designated sites for increased housing density will realistically develop if the Town changes regulations to allow increased density. The RHNA Subcommittee acknowledged the challenges to meet the new, increased housing unit targets, while understanding that either ADUs, or high-density housing (20 units/acre) would be the only housing types that could use HCD acceptable income distributions for the Cycle 6 Housing Element Plan. The Subcommittee expressed a need to identify sites that could accommodate high density housing with property owner agreement for such rezoning.

Planning Commission Meeting, March 2, 2022
Planning Commission reviewed drafts of Housing Element Chapters 1 (Introduction, Demographics, Recent State Housing Laws and Town Implementation) and 2 (Analysis of previous Housing Element).

Town Council Meeting, March 8, 2022
The Town Council reviewed comments received from the Planning Commission on Housing Element Chapters 1 and 2 and provided minor additional comments for changes.

RHNA Subcommittee Meeting, March 10, 2022
The RHNA Subcommittee acknowledged the challenge to accommodate a significant increase in housing units in the Town given the various constraints identified and recommend sites that could be rezoned for high density housing with support from the property owners.

Planning Commission Meeting, March 16, 2022
Item A Page 167 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
H-9
The Planning Commission reviewed the recommendations of the RHNA Subcommittee on potential sites for increased housing density. The Planning Commission noted that such increases in housing density would be a significant change to the long-standing goals of Woodside to conserve natural resources, provide accommodations for horses and other livestock, but that it could be difficult to meet new RHNA numbers and AFFH goals without constructing multi-family housing.

Town Council Meeting, March 22, 2022
Staff provided the Town Council with an overview of the recommendations of the RHNA Subcommittee and Planning Commission. There was considerable public concern with rezoning that would allow any high-density housing. Town residents expressed a desire to meet RHNA targets with increased development of ADUs.

The Town Council recognized the concerns expressed from the public while acknowledging the need to meet State mandated housing requirements. The Town Council did not remove any of the sites proposed for higher density development but expressed the desire to provide Housing Element Programs that could increase production of ADUs as a priority before rezoning sites for higher densities.

Planning Commission Meeting, April 25, 2022
The Planning Commission reviewed draft Housing Element Chapter 3 which included Programs to further encourage construction of ADUs and zoning changes to properties near the Town Center to allow for medium density housing referred to as the Missing Middle, which would help achieve AFFH goals. Many residents continued to express concerns with the high-density sites and the proposal for medium density overlays near the Town Center.

The Planning Commission was divided on a recommendation to rezone the identified sites for high-density housing.

Town Council Meeting, May 10, 2022
The Town Council reviewed the draft Housing Element and the RHNA Plan and considered extensive public comment. The Council also reviewed changes to the RHNA Plan submitted by Councilmembers Shaw and Dombkowski. After listening to extensive public comments on both proposals, Councilmembers focused on the RHNA Plan submitted by Shaw-Dombkowski Plan which was more widely supported by the residents than the RHNA Plan recommended by the Planning Commission.

The Town Council made modifications to the RHNA Plan based on public input, and approved release of the Housing Element for a 30-day Public Review and comment period with direction to staff to update the narrative in the Housing Element to align with the Council’s RHNA Plan.

Item A Page 168 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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Public Comment Period on Housing Element (rev. May 18, 2022): May 18, 2022 – July 1, 2022
In accordance with State law, the Town posted the draft Housing Element on the Town website on May 18, 2022; and posted for 44 days (exceeding the 30-day required comment period). During the comment period, the Town also sent courtesy radius notices to all properties within 300 feet of the sites proposed for higher density development.

Town Council Meeting, July 12, 2022
The Town Council reviewed (65) comments received on the draft Housing Element (rev. May 18, 2022) by the comment period deadline of July 1, 2022, at 5pm; and staff’s formal response to comments. Three additional comments, received after July 1, 2022, were transmitted as a staff report attachment. Six comments received after the posting of the staff report we transmitted to the Town Council as desk items. The Town Council also heard and considered a significant amount of public comment at the meeting, including opposition to all of the higher density development sites included in the draft Housing Element. In response to the comments, the Town Council directed staff to revise the RHNA Plan (increase ADU projection to 20 per year, increase the SB9 projection to 16 units/cycle, redistribute the income level for all higher density development sites, delete the “Commercial Corridor” sites from the higher density site list, reduce the 773 Cañada Road site density to 10 units/acre, and change the rezoning from “post-adoption” to “pre-adoption”); add five additional programs described in the staff report; revise Appendix G, Site Inventory, to include additional narrative and a full Site Inventory Map, as attached to the staff report; and conduct a final check of the Housing Element and Appendices to ensure consistency with all other Town Council direction. After revisions were made to the Housing Element per Council direction, the document was submitted to the State Department of Housing and Community Development (HCD) for the first formal review for HCD certification.

Town Council Meeting, December 13, 2022
The Town Council reviewed comments received from HCD and a draft Response to Comments. The extensive HCD list of comments and desired revisions included all aspects of the Housing Element including special needs housing, affirmatively furthering fair housing, assumed density for sites proposed for rezoning, assumed rate of ADU production, and zoning for a variety of housing types. Public testimony was received from residents in opposition to including Town-owned sites that were designated in the Housing Element for higher density zoning for affordable housing. The Town Council directed staff to submit a discussion draft of the RHNA Plan that removed the Town owned sites from the plan.

Item A Page 169 Town Council Special Meeting January 31, 2023 HCD Review Draft #2 - January 31, 2023
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Town Council Meeting, January 10, 2023
The Town Council reviewed comments from HCD that were not supportive of removing the Town-owned sites and the reliance on ADU production assumptions that exceed the historical ADU approval rate. Staff recommended the Council reconsider including at least one of the Town-owned sites, lower the number of assumed ADUs, and increasing the density of sites to be rezoned to meet the RHNA. Additional public testimony was received in opposition to including any of the Town-owned sites in the RHNA Plan. The Town Council directed staff to return with an analysis of the advantages and disadvantages of including each of the Townowned sites and revising the assumption for ADU production.

Town Council Meeting, January 31, 2023
The Town Council reviewed the analysis of options for the inclusion of Town-owned sites in the RHNA Plan, as well as rezoning density and ADU production assumptions. The Town sent courtesy notices to residents and comments from residents were received prior to the Council meeting.

Item A Page 170 Town Council Special Meeting January 31, 2023 Item A Page 171 Town Council Special Meeting January 31, 2023 ATTACHMENT 2
From: Heidi Hess
To: Council Members
Subject: 773 Canada
Date: Monday, January 23, 2023 8:28:08 AM
[CAUTION]: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Council members,
The new proposals for the Housing Element seem to have 773 Canada back in the town's bull's eye. Maybe we have too few people making too little noise to be heard. Our side of town will be disproportionally affected by the changes in the revised Housing Element numbers.

You are well aware of our arguments concerning the reasons 773 Canada is not appropriate for high density housing and yet our concerns seem to be falling on deaf ears. The dwelling numbers continue to rise.

We ask that any high density, lower income development be located away from the existing neighborhood on Palm Circle and you reconsider increasing the density from 10 units/acre to 20 units/acre.

As other sites fall off the town's radar our side of town should not have to pick up the slack.

Our street should not be the one subsumed by high density development. We should have a voice. We are asking to have a voice.

Regards,
Heidi Hess
Item A Page 172 Town Council Special Meeting January 31, 2023 From: Sharon Hall
To: Council Members
Subject: SB9 recommendations
Date: Monday, January 23, 2023 2:01:50 PM
[CAUTION]: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

As a Woodside resident who lives in the Emerald Hills area, I am deeply concerned and disappointed about the town’s response to SB9 to date. I am sorry I was unable to attend the recent Town Council meeting where the town’s response to SB9 was discussed. But, as I understand the current recommendations, they are grossly inequitable, and differentially and negatively affect those of us living in the north end of town.The proposal to put 16 ‘moderate income’ units and 11 ‘above moderate income’ units on the property at 773 Canada is a tremendous increase over what is allowed by current zoning and will differentially and negatively impact those of us living along the Canada corridor in terms of house value and quality of life issues. In the interests of fairness, please reconsider, and look to other parts of Woodside to share the burden.

Thank you,
Sharon Hall
Item A Page 173 Town Council Special Meeting January 31, 2023 From: Jonathan MacSwain
To: Council Members; Brian Dombkowski
Subject: Woodside Housing Element and 773 Cañada Rd
Date: Wednesday, January 25, 2023 1:03:16 PM
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Dear Woodside Town Council Members,
As an adjacent neighbor to 733 Cañada, I have serious and legitimate concerns about this massive proposed development. It will directly affect our property value, quality of life and safety. This last point was poignantly emphasized June 21st, 2022 with the Edgewood fire that not only closed Cañada Rd, but mandated evacuations for ourselves and surrounding neighbors. High-density housing would have compounded the emergency .

I understand that all towns and cities are required to plan for the development of new housing by the state. I recognize the Town Council is working hard to meet this mandate while trying to preserve the natural, rural feel of Woodside. At the December 13th meeting, the Council appeared to be willing to drop the two Town owned sites on High Rd and Raymundo (shown as Runnymede), but showed no interest in dropping 773 Cañada. Representative Brian Dombkowski and Councilmember Paul Gould recognized the inequity of our neighborhood providing all of the housing sites; however, later in the meeting Brian lobbied strongly for the removal of Raymundo but did not mention eliminating 773 Cañada Rd. It would seem now that 733 Cañada has become the sole target and is being earmarked to carry the bulk of the new housing demands. It is completely unfair to our neighborhood, and the neighbors of 733, to be completely saddled with this burden while keeping other sites open. The housing requirements should be spread throughout the town, not focused on one site effectively creating a "Woodside Projects". This is ridiculous approach that will severely, and negatively impact those of us living around this site. Housing needs can be met without concentrating it all in any one location. As a matter of equity, I ask that it be removed from the list of proposed additional high-density locations along with the two Town owned sites.

Thsnk you for your time,
Jonathan MacSwain
Item A Page 174 Town Council Special Meeting January 31, 2023

TOWN COUNCIL SPECIAL MEETING

HOUSING ELEMENT COMMENTS
Paul Goeld, District 4
Town of Woodside
January 31, 2023

HIGH ROAD SITE

HIGH ROAD SITE
N
45 MPH

PGE GAS TRANSMISSION PIPELINE MAP
https://www.pge.com/en_US/safety/h
ow-the-system-works/natural-gassystem-overview/gas-transmissionpipeline/gas-transmissionpipelines.page

BUILDING ENVELOPE APPROXIMATION
From: j
To: Council Members
Cc: Jennifer Li; "Renee Huhs"
Subject: Comments on Revised Sixth Housing Element for January 31, 2023 TC Meeting Date: Sunday, January 29, 2023 9:52:41 PM
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Dear Councilmembers:

We are writing to oppose inclusion of the Raymundo Drive Town-owned site in the Sixth Housing Element to be submitted to HCD. We and our two teenage children have lived on Marva Oaks Drive since 2006, about 500 yards upslope from the proposed Raymundo Drive site; and John lived in Woodside during the late 1960s, when he was in graduate school at Stanford!
Many factors lead us to oppose the Raymundo Drive site. We will address the following today:

1. Insufficient Evacuation Routes. Pages 9-12 of the January 25 BakerTilly Memo Town propose developing 33 three-bedroom, two-car-garage town homes on the 1.77 acre site at the north side of the base of Raymundo Drive.

Almost 200 people (six persons per dwelling unit, perhaps more with a density bonus), plus 66 cars, are proposed for the project, far outnumbering the fewer than 100 people who presently live on Marva Oaks and Raymundo Drives.

Previous testimony has demonstrated an epic disaster would occur in the event of a wildfire, earthquake, and so forth as terrified people, animals etc. poured from the project into the choke point at the intersection of Raymundo and Runnymede Drives, colliding with another stream of terrified people, animals, horses and so forth pouring down from Marva Oaks and Raymundo. This very real risk and the probable non-conformance of the Raymundo site to the requirements of the Local Hazard Mitigation Plan are not articulated properly in HCD Review Draft #2 Page 1-22 nor elsewhere (See SBs 379, 1035, 99 and AB 747)! Accordingly, Raymundo must be excluded!

2. Immediate Negative Impact on Property Values. If Raymundo is included in the approved Cycle 6 Housing Element, we will have to disclose the foregoing insufficient evacuation routes (along with other matters) as material risks should we attempt to sell our property! Think about it: Would you purchase a property on Raymundo/Marva Oaks if you knew the Town had offered the Raymundo Drive site for high-density, low-income development, with all the foregoing risks and other issues (yes, including NIMBYism) this would entail? How much of a

TOWN COUNCIL MEETING
01/31/2023
DESK ITEMS: ITEM A

From: Robert Hollister
To: Jennifer Li; Kevin Bryant; Council Members
Subject: Housing Element comment
Date: Monday, January 30, 2023 9:06:56 AM
Attachments: image001.png

6. Renderings Plan.pdf
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Esteemed Town Council members and Staff,
I am writing in response to the staff report for the special Town council meeting on January 31, 2023 regarding the Town of Woodside Housing Element. You may recall that I have written and spoken before in favor of affordable, ownership housing on Town owned surplus land. I am writing again to restate that support, and to address misinformation that has been spread about Town owned sites.

To be clear from the start, I am in favor of affordable home ownership on all surplus Town sites, not just the High Road and Raymundo sites referenced in the staff report. I live on Laning Drive and would love to see affordable home ownership on Kite Hill just up the road from me. I would love to see it near Barkley Field. I do not have all the information on the restrictions on those sites and trust council and staff to make sure they truly cannot be used for housing, but if they can, I am all for it.

Woodside can create affordable housing that meets the character of our Town. The frequent complaint during this process is that the state is imposing a “one size fits all” approach that does not allow the Town to preserve its character. My observation is that this is not accurate unless one believes that the only type of housing that fits the character of Woodside is accessory dwelling units (ADUs.) I don’t think that is true. There are great examples of small lot homes in Woodside that fit our character. Some of the language used like high density and multifamily is unfortunate as it creates the impression of something very urban. But the Town’s consultant has shown examples of small lot homes that meet the required densities that would fit well in Woodside. I have attached an image of a Habitat for Humanity project in Novato that would also meet the densities and that I would be proud to have in my neighborhood. We do have the opportunity to create housing that is consistent with our Town’s character and we should show that we are willing to do this.

1. The state has actually been remarkably generous in allowing Woodside to assume that of the 15 ADUs planned per year, 30% will be very low income and 30% will be low income. I would be surprised if 60% of ADUs in Woodside are occupied at all let alone at affordable rents, rather than being used as pool houses or rec rooms. Anyone who has lived here for any time knows that is true. I do not support forcing people to rent out their ADUs but I think we should be honest with ourselves and realize the state is allowing us to make an assumption that is not consistent with the reality of ADUs in our Town, and we should accept this graciously.

2. There have been points made about certain sites being unsuitable for development because of earthquake faults or lack of sewer, but as far as I know, no technical studies have been done by qualified experts to show this. In fact, many homes in Woodside rely on septic instead of sewer and there is no reason affordable ownership units cannot also do this. There are also state funds available to pay for infrastructure like sewers that make sites available for affordable housing, so it is possible that sewer extensions might be done at no cost to the Town and might benefit existing residents.

Similarly, no geotechnical or structural engineers have shown any sites cannot be developed safely. Building code would not allow this and in fact buildings that meet today’s codes are generally far safer than older housing stock in Woodside, even if those older houses are farther from the fault. This is particularly true for housing on pilings and steep hills, which are common in Woodside but this is not the case for the Town owned sites.

3. Many residents are concerned about who might occupy affordable housing. This is actually the best reason to utilize the Town owned sites. The Town can select a qualified, non-profit housing organization that has a track record of vetting residents and creating high quality communities. The Town can insist this is ownership, not rental, housing, on Town owned sites. No such control will be exercised over private sites. I also believe that such sites can be included as affordable housing at whatever density the Town chooses, so long as the Town requires they be developed as affordable housing. There is no need to go to 20 units per acre to be “deemed” affordable – if desired, they can be zoned at 15 units per acre but required to be affordable since the Town owns the land.

4. We should bear in mind that very low and low income, in the context of 3 or 4 bedroom homes in Woodside, would mean a family income level of $90,000-150,000 per year. These are not gang members or drug dealers. They are the sort of people that help our community function – construction workers, landscapers, nurses, teachers, retail workers, Town staff. The sort of people that would enrich our community if they could live here.

5. Some are concerned that too much of the density is in the northern part of Woodside. I live in the northern part of Woodside and I do not share that concern. I see us as one Town working together to meet our housing obligations in the best way possible – in our small Town, I don’t believe that we should segment ourselves by “district.” There are something like 1,000 people who live in the northern part of Woodside. A small handful may have been vocal at council meetings but that doesn’t mean they represent all of us. In fact, it is more likely those who do not speak at council have no objections to the inclusion of the north of Woodside sites – and thus they feel no reason to come to these council meetings. We see our council members as exercising their best judgement on our behalf, as is the intention in a republic.

6. There are also concerns about ingress, egress and traffic but again none are based on actual studies. Any project will be reviewed for these issues. The fire marshall will not allow a project to be developed if it creates unsafe conditions for evacuation in an emergency. Excluding sites based on a lay person’s presumption is unreasonable. In fact, nearly all of the Town owned sites are situated near major roads – Woodside Road, Canada Road, etc. and will accessed by most residents without going through the congested center of Town. As I mentioned, I live on Laning Drive and at least 75% of my trips go north on Canada to I-280 or Jefferson, putting less pressure on the Town center. As for access to mass transit, we should simply be honest with ourselves. Nowhere in Woodside has access to mass transit, and this cannot be a reason to exclude a site. The Town owned sites are among the best options we have for adding housing.

Woodside absolutely should create housing that fits our Town character, and I am confident we can do that on the Town owned sites in the form of small lot homes. We would bring welcome diversity to our community. I implore the Town council to make available as many Town owned surplus sites for ownership affordable housing as possible.

Thank you for your consideration and hard work on this challenging issue.

Rob Hollister
Laning Drive
Woodside, CA

From: Anne Paulson
To: Jennifer Wall; Brian Dombkowski; Richard Brown; Chris Shaw; Paul Goeld; Ned Fluet; Town Hall Email Subject: Jan. 31 meeting Item A: Option 3 plan on Housing Element Date: Monday, January 30, 2023 9:59:19 AM
[CAUTION]: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear Town Council members,
In looking at your Housing Element agenda, I noticed an issue with Option 3 of the RHNA plan. This is the idea that you'd rezone the Raymundo site for 20 du/acre, and then require the developer to build single family detached houses. This density, 20 du/acre, is more dense than a typical townhouse density. To get an idea of density, The Redwoods, a newish three story townhouse development in Mountain View on Scarlett off Montecito is 18 du/acre. https://www.livabl.com/2021/05/now-selling-the-redwoods-at-motecito-mountain-view.html The example given on p. 13 of the pdf is a 26'10" by 52'8" house on a 2200 foot lot. That's 1400 sq ft. The picture shows houses maybe 10-12 feet apart, with driveways that would fit a parked car. This is impossible if you do the math.

The consultant forgot that single family houses need roads. I don't know exactly what your fire marshal would require, but a conservative estimate would be 400 sq ft per house (roads twenty feet wide, ~35 foot frontage, a bit more for corners and turning). So now that 2200 sq ft lot is an 1800 sq ft lot. And let's say you allow 4 feet side setback, like ADUs. Now the footprint of the house plus its side setback is 1826 sq ft. On an 1800 sq ft lot. You see the problem.

If you want open space, and you want 2000 sq ft units, you have to build multifamily buildings and allow more height. If it was me, I'd plan for 1000 sq ft units in five four story eightplexes. That would allow for a lot of open space and trees. There are many other options, of course. But you can't build the single family houses with 1400 sq ft footprints. They won't fit.

Sincerely,
Anne Paulson
From: John Hess
To: Council Members
Subject: Fwd: One item for Jan 31 meeting
Date: Monday, January 30, 2023 6:51:41 PM
[CAUTION]: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
---------- Forwarded message ---------
From: John Hess < >
Date: Mon, Jan 30, 2023 at 12:17 AM
Subject: One item for Jan 31 meeting
To: <[email protected]>
Thank you for your thoughtful email to my wife, Heidi. I endorse your position and diligence relative to 733 Canada.

For personal reasons I could not read the council materials until Sunday evening so will be brief.

As a former real estate developer, I am very conscious of the legal implications of zoning entitlements and how contentious issues can become when entitlement changes are sought.

The 733 Canada property is approximately 10 acres. How much of it will be entitled at 20 units per acre? All ten acres would imply 200 units; the five somewhat usable acres imply 100 units, etc.

I assume there will be some Town/owner agreements about intention but the "law of unintended consequences" often prevails as situations change. I have experienced all of the following: Property ownership changes and the new owners expect or demand full entitlement use; Town boards & officials change and have new expectations; Economic & market condition changes must be met; The state's frantic housing demands may even change,
I am sending this email only to you. Share it if you wish.

Thank you. John Hess
From: Holly Nash
To: Town Hall Email
Subject: Fwd: Comments on Revised Housing Element
Date: Monday, January 30, 2023 7:42:14 PM
[CAUTION]: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
> Dear Town Council,
> I am submitting these comments in opposition to the Proposed Housing Element that designates dense housing at the corner of Raymundo Drive and Runnymede. As you know, the Office of the State Fire Marshall has recently revised the fire hazard maps for San Mateo County. The 2022 map of fire hazard severity zones has designated the Open Space Wildland abutting the property in question as "Very High Fire Hazard Severity." State law prohibits the placement of the proposed housing in such zones. Surely, for the safety of all, the Town will eliminate this property from consideration.
> Thank you,
> Holly Nash
>
From: Janelle MacSwain
To: Council Members
Subject: Housing Element draft
Date: Tuesday, January 31, 2023 10:14:29 AM
[CAUTION]: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Good morning,
I am writing in regards to the changes made to the Housing Element draft to be presented at the town council meeting this Tuesday evening 1/31/23. I am highly concerned with the lack of distribution of housing sites planned for woodside with the majority of housing planned for the privately owned 773 Canada site. I believe it is the duty of the council members to represent ALL constituents; however, with this proposed plan it does not appear that the residents near 773 are being represented equally as those in other areas of town. Focusing the housing burden to one area along the edge of the town perimeter is not what the housing law was meant to accomplish. Why were other town sites removed while 773 not only remains on the list but was expanded to have more housing units built? We too, as others have mentioned, are in a high fire area with narrow streets for evacuation. For example the Edgewood fire in June 2022. Additionally, I believe the town should include the parcels that are owned by the town to be part of the housing plan. Again, this housing issue can not and should not be solved by placing the burden on one area. By focusing housing at the edge of the town this will greatly impact the already congested Canada and woodside roads. Please reconsider your areas for the housing to include equity of this shared housing burden, and not focus the majority of housing units to one privately owned site that will no doubt only financially benefit the 773 Canada land owner while negatively impacting the rest of the families who live in that part of the town.

Thank you,
Janelle MacSwain
Woodside Resident
From: Stephanie Discher
To: Jennifer Li; Sage Schaan
Subject: Please distribute for meeting tonight
Date: Tuesday, January 31, 2023 12:36:31 PM
Attachments: Please distribute for meeting tonight.pdf
[CAUTION]: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

This attachment is for the meeting tonight. I plan to speak and explain the map, although it speaks for itself. The Council will need to be able to see this map when I speak tonight.

Please let me know it was distributed.

Thank you so much, Stephanie Discher
PS Sage - Congratulations!

From: Dror Berman
To: Council Members
Subject: Raymundo Drive site
Date: Tuesday, January 31, 2023 4:10:09 PM
[CAUTION]: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear members of the Woodside Town Council,
I look forward to the discussion about whether to include the proposed site at Raymundo Drive as a high-density development in the Cycle 6 Housing Element.

It is evident that the concentration of low-income housing in one area is not only unjust, but also goes against the state’s mandate. If the proposed Raymundo site is approved, it will result in a whopping three low-income projects situated within a mere one square mile. This goes against the state's mandate of evenly distributing such housing throughout the community.

The High road site is a much better alternative. It’s aligned with the state's mandate and will promote equal distribution of low-income housing. It’s also closer to transportation, freeways, and services.

Best,
Dror
--
Dror Berman
Founder, Managing Partner | Innovation Endeavors
InnovationEndeavors.com
From: John Williford
To: Town Hall Email; Council Members
Subject: Runnymede/Raymundo Proposal
Date: Tuesday, January 31, 2023 4:32:11 PM
[CAUTION]: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

We are writing to express our strong objection to the Runnymede/Raymundo housing proposal being considered by the town tonight.

The proposed development would significantly increase fire risk in an already dangerous area, and it would cut off what little escape route is there now for the people and many horses in the area.

The proposed developments for the town in general are unfairly concentrated in this small corner of the town. The proposed site at High Road would produce a more fair and balanced solution for the town.

We and our neighbors have repeatedly made these points to the town, and yet the town staff continues to include Runnymede/Raymundo. Please let us know how the town will address our safety concerns and why it has ignored our fairness concerns. If it continues to be included without addressing these concerns we will be motivated to look for legal options.

John and Katherine Williford
Sent from my iPhone

Steve Lubin Statement to Woodside Town Council
`January 31, 2023
I have repeatedly encouraged The Council to plan for housing on close-in locations which will not add to the car dependance of the Town.

The Council has considered and rejected a site on Haciendas Drive which is well suited for housing.

The Council has rejected a thoughtful proposal from the staff to change the zoning of close-in areas to allow more housing.

Rather than exploring ways that new housing can fit into the fabric of the Town, the Council has sought to place it in isolated locations where it is assured to be stigmatized. All the sites the Council has considered, except High Road, are hard up against the Town limit. High Road isn’t exactly central.

The State is overbearing in dictating the type of housing the Town must provide but it is correct in suggesting that the Town should provide a wider range of housing.

The State is also correct in evaluating sites by vehicle miles travelled.

Sprawl and overdependence on autos are serious problems for the future of the earth, the country and for Woodside. If the Town took pedestrian and bicycle comfort and safety as seriously as it takes providing reserved parking spaces, we could substitute a substantial portion of auto trips with walking and riding, eliminating the need to add to the already excessive amount of paving in town center.

Rather than undertaking real planning, the Council’s consistent choice has been to just stick housing at 773 Cañada Road. Unfortunately, this is just a weak way of avoiding more thoughtful planning. 773 Cañada is 4.8 acres which average over 18% slope.

Current zoning would allow 4 lots.

The property is in a very high-risk fire zone and is an important wildlife habitat. It is distant from any transit opportunities and distant from the town center.

The property has traditionally provided two affordable housing units: the existing house and a trailer occupied by the property manager for the 15 or 20 years before the property was acquired by the current owner. Since no housing for “low” or “very low” affordable units is proposed, the proposed development will cause a decrease in affordable housing units.

Until the current owner took over, the property also provided one of the dwindling number of affordable horse boarding facilities in Town.

The Council is proposing 27 units on this property, 16 for “moderate income” and 11 for “above moderate” income.

In other words, the proposal is to give a bonus of 7 “above moderate” units to reward the developer for providing 16 “moderate units”.

No “low” or “very low” income units are proposed.

What justification does the Council have for rezoning the upper portion of the site. Why is there no mention of rezoning the upper portion when 11 units are included in the Housing Element table? The extra “above moderate” units are not needed at this site. The charts show an excess of “above moderate” units and if they were needed there are plenty of other sites in town for them.

Isn’t the windfall of 15 additional units enough incentive for the developer? Especially since there seems to be no limit on the affordability of the 16 units since the justification for this number is the 20 units/acre density, not actual affordability.

The 7 extra “above moderate” units is an extraordinarily generous bonus.

When I was a Planning Commissioner this type of deal was called “illegal spot zoning”.

If the Council offered this kind of deal in locations which make more planning sense, it could find takers. Why not design zoning which would offer more modest bonuses to everyone in appropriate locations rather than making a sweet deal with one property owner? When the Council redesigned council districts it split Emerald Hills in half, Jim Crow style, diluting our voice in elections.

I cannot feel that it is not a coincidence that our neighborhood has been singled out for the only uncontested candidate for satisfying the Town’s Housing requirements.

For the last 4 years we have had unresponsive representation on the Council. In the 2022 Council election the winning candidate came in third place in our, east of 280, precinct. Clearly our Emerald Hills neighborhood voice has been sidelined.

It would be comforting for our representative to stick up for us the way he did for Raymundo Residents.

For the proposed development to proceed the Town will have to change the “Emerald Lake Hills Specific Plan”.

This plan was written when several of us on Palm Circle were trying to extend the sewer to alleviate our failing septic systems.

There was an outcry from residents up the hill who feared building the sewer would lead to development which would change the rustic character of Emerald Hills.

The result was a provision in the specific plan that sewers could only be used to alleviate health problems at existing houses, that is, not be used to facilitate new development.

With the understanding that only the narrow band of properties along Cañada Road would be served by the sewer, we were allowed to proceed with sewer construction. The overwhelming majority of the funding of the sewer extension came from us.

If the prohibition of serving new development is removed from the specific plan it will open the rest of Emerald Hills to sewer extension and extensive new development.

The Town has recently issued permits on lots in Emerald Hills which were long considered undevelopable. These developments have caused severe flooding on the downhill neighbors.

The Town must carefully consider the long-range consequences of changing this specific plan.

The current 8-year housing cycle will probably not be the end of housing mandates. Will opening the rest of Emerald Hills to sewers provide a path for our neighborhood to be the continuing site for the Town to dump development it does not want in more central locations? This would be patently unfair.

It is probably apparent that I am “a progressive” but the proposed development at 773 Cañada is driving me to go Poletti. It’s not my nature to scream at and threaten the Council but it sure seems like that is what it takes.

We bought 11 Palm Circle in 1978 after saving money by living for 5 years in my parents’ guest house on La Questa Way. This purchase stretched our finances but we went out on a limb to stay in Woodside. The real estate ad called our place a “mini farm” and that is how we still think of it.

I served on the Planning Commission, Trails Committee and ASRB while living on LaQuesta Way.

Thalia and I have, for more than 40 years, dedicated ourselves to maintaining and improving the character of the Town. We both volunteer because we care about our community. We would appreciate the community caring for us.

In 1993 we bought 12 Palm Circle as a retirement plan. It is a source of a significant portion of our income. Changes to its rentability would have a serous impact on our financial wellbeing.

The properties on Palm Circle are quite flat and the steeply sloping hill on 773 Cañada is the backdrop to the back yards of those of us on the north side of Palm Circle and to the adjoining properties on Cañada Road. The hill occupied by the existing house is the view out our living room window. This is personal.

Dense development on 773 will likely involve many more people living close to our backyards. This will cause additional noise and disruption to our peaceful neighborhood.

This is completely unacceptable when no other part of Town is being asked to contribute to the housing plan and when the project will result in a windfall for the developer.

If the Council goes through with the proposed development of 773 Cañada Road we intend to take all actions possible to protect our home, our investment and our neighborhood. The proposal is fundamentally unfair. It is a “taking” from us and a substantial “giving” to the developer.