HomeMy WebLinkAbout12/10/2025 Item 4a, Lloyd
Dec 10, 2025
City of San Luis Obispo
990 Palm Street
San Luis Obispo, CA 93401
By Email: advisorybodies@slocity.org
CC: attorney@slocity.org; cityclerk@slocity.org; planning@slocity.org
Re: Proposed Housing Development Project “Avila Ranch Project“
Dear San Luis Obispo Planning Commission,
The California Housing Defense Fund (“CalHDF”) submits this letter to remind the City of its
obligation to abide by all relevant state laws when evaluating the proposed 194-unit housing
development project within Phase 4 of the Avila Ranch Development Plan, which includes 18
moderate-income and 12 workforce housing units. These laws include the Housing
Accountability Act (“HAA”) and California Environmental Quality Act (“CEQA”) Guidelines.
The HAA provides the project legal protections. It requires approval of zoning and general
plan compliant housing development projects unless findings can be made regarding
specific, objective, written health and safety hazards. (Gov. Code, § 65589.5, subd. (j).) The
HAA also bars cities from imposing conditions on the approval of such projects that would
reduce the project’s density unless, again, such written findings are made. (Ibid.) As a
development with at least two-thirds of its area devoted to residential uses, the project falls
within the HAA’s ambit, and it complies with local zoning code (via the exception process for
the monument signs) and the City’s general plan. The HAA’s protections therefore apply, and
the City may not reject the project except based on health and safety standards, as outlined
above. Furthermore, if the City rejects the project or impairs its feasibility, it must conduct “a
thorough analysis of the economic, social, and environmental effects of the action.” (Id. at
subd. (b).)
Additionally, the project is exempt from further state environmental review pursuant to
sections 15162 and 15182 of the CEQA Guidelines. Caselaw from the California Court of
Appeal affirms that local governments err, and may be sued, when they improperly refuse to
2201 Broadway, PH1, Oakland, CA 94612
www.calhdf.org
grant a project a CEQA exemption or streamlined CEQA review to which it is entitled. (Hilltop
Group, Inc. v. County of San Diego (2024) 99 Cal.App.5th 890, 911.)
As you are well aware, California remains in the throes of a statewide crisis-level housing
shortage. New housing such as this is a public benefit: it will provide affordable and
workforce housing; it will increase the City’s tax base; it will bring new customers to local
businesses; and it will reduce displacement of existing residents by reducing competition
for existing housing.. While no one project will solve the statewide housing crisis, the
proposed development is a step in the right direction. CalHDF urges the City to approve it,
consistent with its obligations under state law.
CalHDF is a 501(c)(3) non-profit corporation whose mission includes advocating for
increased access to housing for Californians at all income levels, including low-income
households. You may learn more about CalHDF at www.calhdf.org.
Sincerely,
Dylan Casey
CalHDF Executive Director
James M. Lloyd
CalHDF Director of Planning and Investigations
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