TO:
Honorable Mayor and Members of the City Council
THROUGH:
Bruce Moe, City Manager
FROM:
Carrie Tai, AICP, Community Development Director
Talyn Mirzakhanian, Planning Manager
SUBJECT:Title
(Continued Item) Public Hearing to Consider the 6th Cycle Housing Element Update (HEU) and Associated Initial Study/Negative Declaration (Community Development Director Tai).
ADOPT RESOLUTION NOS. 22-0014 AND 22-0015
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Recommended Action
RECOMMENDATION:
Staff and the Planning Commission recommend that, after receiving public input, the City Council adopt attached Resolution No. 22-0014 adopting the Negative Declaration for the 6th Cycle Housing Element; and adopt attached Resolution No. 22-0015 adopting the 6th Cycle Housing Element.
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BACKGROUND:
After a number of City Council meetings and public hearings, the City Council continued its consideration of the 6th Cycle Housing Element Update in order to: (1) provide additional opportunities for public comment, and (2) study the Sites Analysis and Inventory more closely. In addition to the City’s standard public notices pursuant to State and local regulations, staff has provided additional notice far beyond required public noticing requirements to publicize this meeting, including but not limited to notifying the Manhattan Village Senior Villas affordable housing development and posting the notice at the Joslyn Community Center. At the City Council’s request, this report provides supplemental analysis regarding the Sites Analysis and Inventory. Attachment 1 includes links to the reports from the prior meetings.
DISCUSSION:
The most challenging task in the preparation of the 6th Cycle Housing Element concerned Appendix E, the Sites Analysis and Inventory, which describes the methodology by which the City can accommodate its Regional Housing Needs Allocation (RHNA) targets and provides an inventory of the sites identified to meet the housing need. The purpose of the Sites Inventory and Analysis is to create a pool of potential site options from which the City will choose during the formal rezoning process that follows (identified as Program 2 in the Housing Element). To reiterate, the maps included in the analysis, which identify sites that could accommodate additional capacity, solely demonstrate the overall pool of qualifying sites; but not all of these sites will ultimately be rezoned. Furthermore, the City’s responsibility is limited to accommodating (i.e. rezoning), but not building, the total allocated units.
The requirement to include an inventory of land suitable and available for residential development to meet the locality’s regional housing need by income level is not a new requirement in State Housing Element law. In fact, the City was required to prepare site inventories in all prior Housing Element cycles, including the 5th cycle in 2013, to accommodate the City’s 5th Cycle RHNA allocation of 38 housing units.
Since the adoption of the 5th Cycle Housing Element, however, there have been many changes to respond to the State’s overall lagging housing production. The State’s RHNA for each county and city increased dramatically (the City’s RHNA increasing to 774 units), and the State legislature adopted a number of laws starting in 2017 that drastically changed existing criteria, and added new criteria related to the sites inventory. This means that in addition to the sites identified in the 5th Cycle Housing Element, the City must identify more housing capacity while being strictly limited in finding appropriate sites by the new criteria stemming from the legislation outlined below. This has resulted in the site-selection process for the 6th Cycle Housing Element being exceedingly more complex as compared to previous cycles.
Below is a summary of those laws (SB= Senate Bill and AB= Assembly Bill):
• Design and development of the site inventory (SB 6, 2019)
• Requirements in the site inventory table (AB 1397, 2017 AB 1486, 2019)
• Capacity calculation (AB 1397, 2017)
• Infrastructure requirements (AB 1397, 2017)
• Suitability of non-vacant sites (AB 1397, 2017)
• Size of site requirements (AB 1397, 2017)
• Locational requirements of identified sites (AB 686, 2018)
• Sites identified in previous housing elements (AB 1397, 2017)
• Non-vacant site replacement unit requirements (AB 1397, 2017)
• Rezone program requirements (AB 1397, 2017)
As described in the 6th Cycle Housing Element and previous staff reports, the City’s RHNA allocation includes a total of 774 units, with a requirement to plan for 322 units for very-low-income households, 165 units for low-income households, 155 units for moderate-income households, and 132 units for above-moderate-income households.
The Sites Analysis for the 2021-2029 planning period has identified capacity for 377 total units. The analysis also specified that there is adequate supply of land to accommodate the moderate-income and above moderate-income RHNA allocation, respectively; therefore, the City is not required to create new opportunities for those income categories. However, the City can realistically accommodate only 81 of the 487 lower-income (low- and very low-income) units. The Sites Analysis and Inventory is required to demonstrate how the City will meet the remaining RHNA for lower-income units (406 units), and a buffer of at least 15% of the lower-income allocation (approximately 73 units) as recommended by HCD. To meet all (old and new) sites inventory criteria in State law, and given that the City does not have vacant land, staff and the consultant used the following methodology to identify sites with potential for redevelopment in accordance with the lower-income RHNA allocation, as follows:
1. Sites were filtered by building age and included those with buildings more than 30 years old to meet building age criteria. Building age is a major factor influencing property valuation and land value. The age of housing is often an indicator of housing conditions. (AB 1397)
2. Sites that are under-valued (with an assessed land-to-improvement (LTI) ratio less than one) were identified. Improvement values less than one indicate that the site has redevelopment potential, as the assessed value of the land is greater than the assessed improvement value. (AB 1397)
3. Sites that are considered underbuilt were identified by analyzing commercially-zoned sites where the current floor area ratio compared to the maximum allowable floor area ratio is less than 100 percent. This indicator helps identify opportunity sites from a redevelopment perspective, as such land is considered to be underbuilt. (AB 1397)
4. Then, staff factored in resource access by evaluating sites within “Opportunity Areas”, which are defined by HCD and the California Tax Credit Allocation Committee (TCAC) as areas whose characteristics have been shown by research to support positive economic, educational, and health outcomes for lower-income households. (AB 686)
5. Sites were then further narrowed down through on-the-ground research that looked at the potential to consolidate sites to meet HCD size criteria, and especially for lower-income sites, the feasibility of the redevelopment of the existing use. This includes accounting for net new units on sites with existing residential units, knowledge of existing long-term leases and existing known vacancies, and also local knowledge of any known developer interest that has been revealed through developer discussions with City staff. (AB 1397)
The Sites Inventory in Appendix E resulted from the above-mentioned complex effort. The Sites Inventory identifies collections of sites along major corridors - Rosecrans Avenue, Sepulveda Boulevard, and Aviation Boulevard in the General Commercial (CG) and Planned Development (PD) zoning districts. Note that some of the sites identified in the inventory are in fact a collection of independently-owned parcels that, if consolidated, could meet the State’s size criteria. Below is a brief description of each of these collections of sites:
• Rosecrans Avenue Sites - Five sites identified along Rosecrans Avenue and Parkview Avenue, which total approximately 26 acres in size and could accommodate a lower-income capacity of 519 units. Existing land uses on these sites include commercial office and retail buildings, a parking lot, and country club.
• Sepulveda Boulevard Sites - Twenty-five sites identified along Sepulveda Boulevard, which total approximately 22 acres in size and could accommodate a lower-income capacity of 438 units. Existing land uses on these sites include a mix of commercial office and retail buildings, animal hospital, vehicle service and repair.
• Aviation Boulevard Sites - Four sites identified along Aviation Boulevard, which total 2.71 acres in size and could accommodate a lower-income capacity of 52 units. Existing land uses on these sites include a mix of commercial office and retail buildings, and vehicle service stations.
Because the majority of the City is developed with close-knit, multi-family areas and single-family neighborhoods, the concentration of all eligible sites along these major corridors at prescribed densities means that the capacity can be accommodated in relatively few areas. As these areas are already located along corridors, they have the most direct access to regional roadway connections and services. These sites meet all of the State’s criteria for lower-income capacity including but not limited to access to resources, size, and potential for redevelopment. These areas along the major corridors, which collectively amount to 50.9 acres and could accommodate 1,018 lower-income units, are described in Appendix E and were presented at the February 1, 2022 meeting. Appendix E also includes a handful of potential sites with existing zoning designations of Residential, Single-family (RS) or Residential, Multi-family (RM), solely because these sites met the criteria and could accommodate lower-income capacity if rezoned. These residentially-zoned sites amount to 3.96 acres and could accommodate 26 lower-income units.
The collective capacity of all identified sites discussed above and specified in Appendix E amounts to 1,044 units (or 54.92 acres), where the City’s deficit is significantly lower at 479 units (or 23.95 acres). Therefore, the City is not required to rezone all of these sites - just a selection.
Subsequent to the adoption of the Housing Element, and to set the implementation of Program 2 in motion, Planning staff will venture into a series of public meetings with property owners, stakeholders, the Planning Commission and City Council to not only identify which collections of sites will be rezoned to accommodate the lower-income capacity and buffer, but to also prescribe the development standards that would be applicable to the sites in order to achieve the densities outlined in the Housing Element.
LEGAL REVIEW:
The City Attorney has reviewed this report and determined that no additional legal analysis is necessary.
CONCLUSION:
The City is mandated by the State to update the Housing Element of the General Plan for this eight-year planning period (2021 - 2029). In accordance with all State regulations, the 6th Cycle Housing Element, as presented to City Council, analyzes community housing needs in terms of affordability, availability, adequacy and accessibility, and describes the City's strategy and programs to address those needs. Subsequent to adoption, the City is required to implement the programs and policies as outlined in the Housing Element over the course of the planning period, albeit with Program 2 (rezoning) having to be completed by October 2022.
Accordingly, subsequent to adoption, staff will be returning to the City Council with the corresponding code amendments and rezoning efforts, as required to set the programs and policies in motion and in compliance with the timeframes outlined in the Housing Element.
ATTACHMENTS:
1. Links to Additional Documents (Web-Links Provided)
2. PowerPoint Presentation