The Town certified, adopted and submitted its Housing Element for the 2023-2031 Housing Cycle to the California Department of Housing and Community Development (HCD) for its review on January 31, 2023. Comments were received from HCD on April 4 - here is a link to the letter received from HCD. Staff is reviewing the letter and identifying next steps.
HCD's letter notes that the Town's certified and adopted Housing Element for the Sixth (6th) Cycle addresses many of the statutory requirements described in HCD's October 2022 review; however, additional revisions are necessary to substantially comply with State law. The letter outlines the changes necessary to bring the Town's housing element into compliance with the law. Among the topics in the letter are:
- requests for more analysis of the various programs and objectives from the 5th Cycle Housing Element;
- analysis related to concentrations of race and familial status geographically within the Town as well as analyzing the differences between the Town and surrounding region;
- analysis related to local unique attributes that impact the Town's ability to provide fair housing;
- analysis related to extremely-low income households and an examination of their tenure (renters and owners);
- an evaluation of sites identified as developable and their capacity for development of low income housing;
- demonstrate zoning that accommodates housing for lower income households in sufficient number to meet the State mandate;
- list all identified SB 9 sites and demonstrate the likelihood of redevelopment, including a demonstration of interest from the property owners;
- reconcile ADU trends with HCD records;
- analyze and demonstrate realistic opportunities for multi-family zoning development;
- identify actions to be taken to facilitate and encourage the development of a variety of housing types for all income levels, including multi-family rental housing, factory built housing, mobile homes, etc.
Overall, the letter asserts that the Town has failed to submit a Housing Element that substantially meets the requirements of State law. The Element does not identify adequate sites to accommodate the Regional Housing Needs Allocation (RHNA). In addition to more detailed analysis, the Town's next iteration must identify the shortfall by income group, acreage, allowable densities, and appropriate development standards and meet all by-right requirements, including, but not limited to permitting multifamily uses by-right where 20 percent or more of the units are affordable to lower income households.
Over the next several 6-8 months, the Town will work to address the issues raised and ensure that the Town's Housing Element is comprehensive enough to meet the State's requirements. The Town has initiated the required California Environmental Quality Act (CEQA) review process for the Housing Element and soon will begin steps toward development of the policy objectives set forth in the Housing Element. These include development of Objective Design Standards, Updates to the Town's Accessory Dwelling Unit (ADU) Ordinance, creation of an Inclusionary Zoning Ordinance and Development Fee, and updates to the Town's Land Use and Zoning to ensure consistency with the Housing Element Policies and Objectives. All of these efforts will involve a public review process via community workshops, Public Hearings, and review by the Planning Commission prior to submission to the City Council for consideration. This work will be concurrent with the Town's CEQA review and review of revisions to the Housing Element for the next submittal to the State. To stay abreast of these meetings and issues, please be sure to sign up for the Town's News Flashes and Public Notices.
For more than two years, the stakeholders, community, and Town officials have been engaged in a planning and public engagement process for the 6th Cycle Housing Element. That process will continue for the better part of 2023 as we seek to develop a Housing Element that meets the Town's assigned RHNA of 348 new housing units across all income levels over an 8-year period.
On April 19 at the Regular City Council Meeting, the City Council will hear the feedback from the Ad Hoc City Council Subcommittee on Housing. The Subcommittee was tasked with identifying criteria that could be used by the Council when evaluating and selecting housing opportunity sites for the Housing Element. On May 17, at the Regular City Council Meeting, the City Council will receive a Report from the Planning Department on their review of the April 4 HCD Letter and necessary next steps in the Housing Element update process.
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