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HomeMy Public PortalAbout10C) 9.A. Attachment CETATF OF CAI IFORNIA -RI LSINFSS TRANSPORTATION AND HOLIS1N Y DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT DIVISION OF HOUSING POLICY DEVELOPMENT 1800 Third Street, Suite 430 P.O. Box 952053 Sacramento, CA 94252-2053 (916) 323-3177 FAX (9 16) 327-2643 December 16, 2009 Mr. Joseph M. Lambert Community Development Manager City of Temple City 9701 Las Tunas Drive Temple City, CA 91780-2249 Dear Mr. Lambert: RE: Review of Temple City's Revised Draft Housing Element ATTACHMENT C ARRO1 D SCHWAR7FNPW',FR QnvPmnr �yNVNrrY o e7� r 0 °+treoaK`n� Thank you for submitting Temple City's revised draft housing element received for review on October 19, 2009. The Department is required to review draft housing elements and report the findings to the locality pursuant to Government Code Section 65585(b). A telephone conversation with you on December 10, 2009, facilitated the review. The revised draft element addresses some of the statutory requirements described in the Department's November 18, 2008 review. However, revisions are still needed for the element to comply with State housing element law (Article 10.6 of the Government Code). In particular, the element still does not include a complete analysis of sites to accommodate the regional housing needs allocation. The enclosed Appendix describes these and other revisions needed to comply with State housing element law. If you have any questions or would like assistance in revising the element, please contact Mario Angel, of our staff, at (916) 445-3485. Sincerely, 45 •6 !W't.Cif athy reswell Deputy irector Enclosures APPENDIX CITY OF TEMPLE CITY The following changes would bring the City of Temple City's housing element into compliance with Article 10.6 of the Government Code. The pertinent Government Code is cited for each recommended change. Housing element technical assistance information is available on the Department's website at www.hcd.ca.aov. Refer to the Division of Housing Policy Development and the section pertaining to -State Housing Planning. Among other resources, please refer to the Department's latest technical assistance tool Building Blocks for Effective Housing Elements (Building Blocks) at httr)://www.hcd,ca.gov/hpd/housinq element2lindex.php, and the Government Code addressing State housing element law. A. Housing Needs, Resources, and Constraints 1. Include an inventory of land suitable for residential development, including vacant sites and sites having the potential for redevelopment, and an analysis of the relationship of zoning and public facilities and services to these sites (Section 65583(a)(3)). The inventory of land suitable for residential development shalt be used to identify sites that can be developed for housing within the planning period (Section 65583.2). Sites inventorv: The element was not revised to address the statutory requirements as outlined in the prior review (enclosed). Tables D-2, D-3 and D-6 must include parcel - specific information including parcel number or unique reference, parcel size, zoning, general plan designation, describing existing uses for any non -vacant sites and a calculation of the realistic capacity of each site. In addition, the element must include a general map of identified sites for reference purposes only. Potential for Second -Unit Development: The element was not revised to address the statutory requirements as outlined in the prior review (see prior review). Downtown Specific Plan: The element indicates sites in the Downtown Specific Plan (DTSP), adopted in 2002, represent one of the City's primary strategies for accommodating its regional housing needs allocation (RHNA) for lower-income households. However, to demonstrate the potential and suitability of these sites, the element must: Demonstrate density and capacity estimates reflecting the impact of land -use and site improvement requirements. The element indicates sites listed in Table D-2 can accommodate 70 dwelling units at a density of 45 units per acre (page D-7). However, the element does not indicate how these densities can be achieved. For example, the element states the allowable density is determined through a conditional use permit (CUP) process (page D-8). Given the City's site inventory relies heavily on sites that require a CUP, the element should analyze the impact of the CUP on housing certainty, supply and affordability. The analysis should focus on whether the CUP requirement allows development of units as indicated in Tables D-2, D-3 and D-6, the impact of not having any minimum density standards, and analyze the impacts on cost and supply of affordable housing. For additional statutory requirements, see Finding A-2 (page 3). -2 - In addition, the element indicates the EC zoned sites within the DTSP have potential for uses other than residential (i.e., commercial/retail uses, Table B-5). For mixed-use or commercial sites allowing residential uses, the capacity analysis should also account for potential development of non-residential uses and could consider any performance standards mandating a specified portion of a mixed-use site as non- residential (i.e., first floor, front space as commercial). Projected residential development capacity should not, for example, assume residential -only development on all mixed-use or commercial sites and could consider recently constructed and approved -developments. - - - -- - - Table D-2 indicates all six EC zoned sites are smaller than one-half acre in size. While it may be possible to build housing on a very small parcel, the nature and conditions necessary to construct the units often render the provision of affordable housing infeasible. As described in the prior review, the analysis should describe existing and/or proposed policies or incentives the City will offer to facilitate small lot development and/or lot consolidation opportunities (see prior review). • While the element provides very general descriptions of existing uses of sites (Table D-2), it must evaluate the extent to which existing uses may impede additional residential development. For example, the element indicates four of the six parcels have existing single-family homes occupied by office and medical -related uses and other sites have restaurant and auto repair uses. The element, however, provides no information about the appropriateness of these sites or the potential for the uses to be discontinued or redeveloped. For additional information on addressing this statutory requirement, refer to the prior review and the sample analysis on the Building Blocks' website at http:/fwww.hcd.ca.aovfhod/housing element2/SIA zoning.oh0nonvancant. Pr000sed Rezonina to Accommodate Identified Shortfall: The element proposes to rezone sites to accommodate the identified shortfall of 244 units (page D-15). To demonstrate the suitability of these sites to accommodate the City's remaining RHNA for lower-income households, the element must include a complete analysis, as follows: The element indicates many of the sites have existing residential uses, including multifamily residential units, but provides no information about the appropriateness of these sites or the potential for the uses to be redeveloped. The element should demonstrate the appropriateness of these sites as detailed in Finding A-1. Please note, for sites with residential uses, the inventory could generally describe structural conditions or other circumstances and trends demonstrating the redevelopment potential to more intense residential uses. Please note, Program 1 to rezone sites to accommodate the identified shortfall must address the statutory requirements of Government Code Sections 65583(a)(3) and 65583.2 to make sites available for 100 percent of the remaining lower-income housing need, with sites zoned toep rmit owner -occupied and rental multifamily uses by right during the planning period at a minimum of 20 dwelling units per acre and 16 dwelling units per site. For additional information, please refer to Finding B-1. -3 - Sites with Zonino for a Varietv of Housing Tvoes (Emeraencv Shelters): While the element indicates the C-3 zone contains several buildings which could be renovated, rehabilitated or converted to an emergency shelter, it should discuss whether any vacant C-3 zone sites are available to demonstrate the adequacy of this zone to accommodate at least one new emergency shelter in the planning period (see prior review). 2. Analyze potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and focal processing and permit procedures. The analysis shall also demonstrate local efforts to remove governmental constraints that hinder the locality from meeting its share of the regional housing need in accordance with Section 65584 and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters identified pursuant to paragraph (7) (Section 65583(a)(5)). Permit Processing: As indicated in Finding A-1, densities for sites identified in Table D-2 are established through the CUP process (page D-8). This process must be analyzed as a constraint and this analysis should identify findings of approval for the CUP and their potential impact on approval certainty, timing, and cost. The City may need to include a program to address this permitting requirement. Additional review and complex discretionary findings can add significant time and uncertainty to the approval process and consequently can impact the cost and supply of housing, particularly housing affordable to low- and moderate -income households. Consequently, the element must demonstrate this process is not a constraint or include a program to remove or mitigate this permitting requirement. B. Housing Programs Identify adequate sites which will be made available through appropriate zoning and development standards and with public services and facilities needed to facilitate and encourage the development of a variety of types of housing for all income levels. Where the inventory of sites, pursuant to paragraph (3) of subdivision (a), does not identify adequate sites to accommodate the need for groups of all household income levels pursuant to Section 65584, the program shall provide for sufficient sites with zoning that permits owner -occupied and rental multifamily residential use by right, including density and development standards that could accommodate and facilitate the feasibility of housing for very low- and low-income households (Section 65583(c)(1)). As noted in Finding A-1, the element does not include a complete sites analysis and therefore, the adequacy of sites and zoning were not established. Temple City has a minimum identified shortfall of 224 units to accommodate its RHNA for lower-income households (page D-15). However, pending complete analysis of sites as indicated in Finding A-1 to demonstrate appropriateness of allowable densities and existing uses within the DTSP, the element may need to commit to rezoning additional I" acres to accommodate the shortfall. Program #1 (page 2-18) proposes to amend the R -C zone and establish a new R4 residential zone to "permit multifamily housing by right at a density of 30-36 housing units per acre." As noted in the prior review (enclosed), Program #1 must be revised to make sites available in accordance with subdivision (h) of Section 65583.2. In addition, the element should be revised as follows: P_roaram #6 - Second Units (Page -2--27): The element_was_revised to indicate-theCity will prepare prototypical plans and promote their availability. However, as the City is relying on second units to accommodate a significant portion of its RHNA for lower- income households, these actions alone do not appear sufficient to demonstrate the adequacy of this strategy. For example, while the element estimates development of 80 units during the planning period, the historic average has only been approximately five units per year. The element should include additional actions to encourage and facilitate the development of second units. For example: • The City could provide fee waivers and fast -tracking of second -unit applications. These actions must be early enough in the planning period to provide realistic opportunities for second -unit development. Establish an annual monitoring program that will evaluate the program's effectiveness in promoting second -unit development commensurate with the City's regional housing need. If the results of the monitoring indicate development standards unduly impeding second -unit development or development is not consistent with the projected capacity assumptions in the housing element, the program should commit Temple City to immediate action to amend its second -unit ordinance and housing element to remove identified constraints and adopt more effective incentives. 2. Assist in the development of adequate housing to meet the needs of extremely low-, very low-, low-, and moderate -income households (Section 65583(c)(2)). The element was revised to include quantified objectives for extremely low-income (ELI) households under existing programs (i.e., Program #6 — Second Units; Program #7 — Density Bonus; and Program #8 — Redevelopment). However, these programs were not otherwise revised to specifically assist in the development of housing for ELI households. To address this requirement, the element could revise programs to prioritize some funding for the development of housing affordable to ELI households, and/or offer financial incentives or regulatory concessions to encourage the development of housing types, such as single -room occupancy units, which address the needs of this income group. In addition, the element was not revised to address how the City's programs address the needs of lower-income renters overpaying (page A-18) and living in overcrowded conditions (page A-21), as detailed in the prior review. The City should either demonstrate how existing programs address this need or identify additional programs. For example, the element could include programs to facilitate the development of units with three or more bedrooms (see prior review).