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
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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).