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HomeMy WebLinkAbout11/17/2020 Item 16, Codron Council Agenda Correspondence City of San Luis Obispo, Council Memorandum Date:November 17, 2020 TO:Mayor and Council FROM: Michael Codron, Community Development Director Prepared By:Rachel Cohen, Associate Planner VIA:DerekJohnson, City Manager DJ SUBJECT:Item #16-REVIEW OF THE 6TH CYCLE HOUSING ELEMENT UPDATE AND A NEGATIVE DECLARATION OF ENVIRONMENTAL IMPACT th Staff received the following questions, regardingItem #16 –Review of the 6Cycle Housing Element Update and Negative Declaration of Environmental Impact.The questions arelisted below with staff’s response shown in italics: 1)Program 3.10 being added(see packet page 235). Has SLO had an instance of affordable housing being lost without its being replaced? This program is in response to a new state law that requires that any affordable housing proposed for removal whether it is deed restricted or not, to be replaced. For example: if a developer proposes to demolish a building that has three residential unitsand construct a new building with 10 residential units they must provide rental rate information\[of the original three units\]over the last five years. If the units meet any affordable income levels, the developer must replace those units either as a part of their project or on another site. 2)What is a Low Barrier Navigation Center(seePacket page 235, bottom of page)? The Housing Element Appendix J includes various definitions including Low Barrier Navigation Center, which states: “Housing First, low-barrier, service-enriched shelter focused on moving people into permanent housing that provides temporary living facilities while case managers connect individuals experiencing homelessness to income, public benefits, health services, shelter, and housing (California Gov. Code §65660).” 3)Program 8.23appears to allowhousing in Open Space,specifically EMPLOYEE housing, (i.e.ag or farmworker housing), not just any kind of housing, correct? You are correct that this specifically relates to employee housing and any proposal would need to comply with all applicable development standards, including being located with the City’s URL to access services. There are sites zoned C/OS and AG that could potentially host housing but the majority of those are located outside the URL. Item #16 –Review of the 6th Cycle Housing Element Update and Negative Declaration of Environmental ImpactPage 2 4)Packet page 236(middle of the page) states in part that “HCD provided comments that the City has not successfully shown how affordable units will be developed...”Is this correct and specific to the City of San Luis Obispo? This comment was directed specifically to the City of SLO and is in regard to our inventory/capacity table in Appendix E. It is important to note that our HCD analysts are not very familiar with our City, local housing market conditions or our history of providing low income housing on a variety of sites, including sites not previously identified in our inventory, with our housing partners. We have provided HCD with many examples of how we have accomplished low income housing on a variety of sites but they continue to request those units be provided on sites of a certain size and density, consistent with state law. In response, staff has modified the inventory specific to low income to be consistent with HCD direction and state law. 5)Programs 2.17 through6.23(see Packet page 236) include language such as “housing project,” “eliminate public hearings for housing projects” and “no discretionary review.” What is a “housing project”exactly?These programs use very strong language, can we reword the language in these programs and still meet HCD approval? A housing project is any project that includes housing. Program 2.17 is required by state law and only applies to those specific sites identified in the Housing Element Table E-2 that have been in previous Housing Element Cycles. Programs 2.18, 6.22, and 6.23 have been recommended to achieve certification by HCD. Specifics around review process thresholds and streamlining of Programs 2.18, 6.22, and 6.23 will come back before the Planning Commission and City Councilfor consideration at a later date.City Council may change the language of Programs 2.18, 6.22, and 6.23, but staff does not recommend this as the implementation of these programs would be a future effort that that would include public, Planning Commission, and City Councilreview and consideration. 6)Packet page 238, the paragraph under Table 2confirms that HCD has not indicated that the City needs to re-zone any land to accommodate the RHNA numbers, correct? Yes, that is correct. 7)Packet page 239, second bulletappears to contain a typo-December 10,2020. This should read December 10, 2019, correct? Yes, that is correct. 8)When did all these new programsget added and did the public get adequateopportunity to review and comment on them? Are the additions required by law, or by HCD in order to qualify or it is the same thing? Most of the new programs are required by state law and the remainder are recommended by HCD to achieve certification once the Housing Element is adopted by Council. All the changes,except those listed on packet page 245,were publishedas part of the revised Item #16 –Review of the 6th Cycle Housing Element Update and Negative Declaration of Environmental ImpactPage 3 Housing Element Updateon October 28, 2020prior to release of the CAR on November 5, 2020 for public feedback. Staff has not received any comments regarding those changes. As discussed above, the programs listed on page 245 were added per state law or recommended to achieve certification. Again, implementation of programs 2.18, 6.33, and 6.23would be a future effortthatwould include public, Planning Commission, and City Councilreview and consideration. 9)EliminatingPolicy 10.2 -local preferenceappears to undermine our Climate Action Plan's goal of reducing commuting andmeetourgreenhouse gas emission reduction goals. Considerkeeping Policy 10.2 and add the below bolded language. 10.2 Local Preference to Reduce Commuting. Encourage, and where legally allowed, consistent with the City's Climate Action Plan, provide incentives fornew housing development to give preference in the following order: 1) individuals who are employed in business that are located in geographic areas that are customarily included in the City’s annual jobs-housing balance analysis, 2) individuals residing in the County, and 3) finally to individuals from outside the County. In reviewing the City’s Housing Element, HCD shared concerns with Policy 10.2 and stated in itsformal responseletter that, “This policy \[10.2\] potentially erects barriers and preventsaccess to housing opportunities, particularly to individuals from outside of the City, and shouldbe removed.”AlthoughPolicy 10.2 is proposed for removal from the Housing Element, it does not mean that the City could not pursue other local preference opportunities on a case by case basis, where legally allowed, to support housing for local individuals. Removing this policy from the Housing Element does not dimmish the City’s ability to achievea reduction in greenhouse gas emissions becauseother key City documentssuch asthe Circulation Element and the newly adopted CAP provide policies and programs that support efforts around commutingandpromotingmulti-modal transportation.