HomeMy WebLinkAboutItem 4.1 Attachment 3City of Los Altos Hills
Housing Element Update
Response to 1-25-23 HCD Letter
January 26, 2023 Draft
#Chapter Topic Comment Summary of Response/Revisions Page #
1 Review and Revision Review and
Revision
The review requirement is one of the most important features of the element update. The review of past
programs should describe progress in implementation of previous actions, including results compared to
objectives and evaluate the effectiveness of actions to make appropriate adjustments in the current planning
period. Specifically, the prior element included Program 19 (Support Foothill College). This Program was
geared toward promoting housing variety and affordability, housing mobility and inclusion into the Town
given the lack of multifamily zoning. Yet, the current element does not evaluate past commitments, progress
or effectiveness and merely states a new program is included. For example, the Program committed to
amend the general plan and zoning to permit multifamily as well as meeting with developers and applying
for funding to encourage affordable multifamily development.
The element omits the depth and importance of this commitment and did not discuss or evaluate the
effectiveness of multifamily zoning, lack of alternative measures taken and outreach efforts. To address this
requirement, the element must fully describe past commitments, progress in implementation, evaluate
effectiveness and then discuss appropriate adjustments in the current planning period. Given the apparent
lack of effectiveness and success in developing multifamily choices and affordability, this analysis should
particularly focus on zoning for a variety of housing types, including multifamily and discuss significant
actions to promote housing choice, affordability, and mobility to facilitate inclusion beyond the regional
housing need allocation (RHNA) and beyond complying with related state laws (e.g., ADU law and SB 9).
Updated 5th Cycle Program 19 to note that the City did not rely on
Foothill College to meet the RHNA, that it nearly met the RHNA, and
that coordination with Foothill did not occur until 2021, and did not
amend the General Plan to allow MF development. New Program A-
1 amends the GP, creates a MF overlay zone, and other programs
ensure promotion and technical assistance with the owners and
developers.
Added new Appendix C - Owner, Developer Interest that includes a
variety of materials demonstrating recent owner and developer
interest in development of housing on LAH RHNA sites and similar
projects in the region. The list includes Foothill-DeAnza College 2021-
2022 Board Priorities, examples of infill housing on school and
religious facility sites, and references to recent State legislation and
funding to promote and expedite housing on such sites. The March
21, 2022 letter from Governor Newsom Letter Recommended
Projects for the 2021-22 Higher Education Student Housing Grant SB
169 appropriate of $500 million for the Higher Education Student
Housing Grant Program, $25 million to community colleges to
support planning grants, and intent to appropriate $750 million for
each of the next two fiscal years.
24, 164, 165,
Appendix C
(new), page C-1
2 Housing Needs,
Resources, and
Constraints
Income and Racial
Concentration of
Affluence (RCAA):
The element briefly mentions incomes in the Town compared to the region as well as the entire Town’s
status as a RCAA. The element should include specific analysis of income and RCAA at a regional level (Town
compared to the broader region). The analysis should at least address trends, conditions, coincidence with
other fair housing factors (e.g., race, highest resource, overpayment), effectiveness or absence of past
strategies (e.g., lack of publicly assisted housing and lack of multifamily zoning), local data and knowledge
and other relevant factors. The element must add or modify meaningful programs based on the outcomes of
this analysis, including actions to improve housing mobility within and beyond Town boundaries (not limited
to the RHNA).
Noted that Los Altos Hills is comparable regionally as almost the
entire Bay Area is considered an RCAA per the HCD AFFH maps. Also
comparing regionally, the median income for Santa Clara County is
also above the $125,000 threshold, most of the surrounding areas
are high or highest resource, and have a white majority. Referenced
Housing mobility programs G-3 and F-2 and inclusion of multifamily
housing which allows housing mobility by meeting the needs of
lower income households in need of affordable rental units.
101-102
3 Housing Needs,
Resources, and
Constraints
Identified Sites and
Affirmatively
Furthering Fair
Housing (AFFH)
The element includes some general discussion and conclusions that identified sites for lower-income
households, while concentrated on three sites in a proposed multifamily housing overlay, do not exacerbate
existing patterns of development in the Town. In addition, the element should include analysis to support
these conclusions, including the number of units per site by income group for each of the AFFH categories
relative to the existing patterns (number of households), impacts on patterns of disproportionate housing
needs (e.g., overpayment, overcrowding, displacement) and expanding on the reasoning for apparently
isolating the RHNA for lower-income households. Further, if the inventory continues to isolate the RHNA for
lower-income households in certain areas, the element must have commensurate programs related to
housing mobility and new opportunities in higher opportunity areas (beyond RHNA and throughout the
Town) to promote inclusion and AFFH throughout the Town.
Added bar charts and accompanying analysis showing the percent of
RHNA Units that fall into the respective AFFH categories in
comparison to the existing city patterns.
90, 94, 98, 102,
104, 113, 117
4 Housing Needs,
Resources, and
Constraints
Local Data and
Knowledge
The element does not address this requirement. The element must include local data, knowledge, and other
relevant factors to discuss and analyze any unique attributes about the Town related to fair housing issues.
The housing element should complement federal, state, and regional data with local data and knowledge
where appropriate to capture emerging trends and issues, including utilizing knowledge from local and
regional advocates and service providers. For example, the element could include information from code
enforcement officers related to housing conditions, lack of public investment in affordable housing and
relationships with the college.
Added language to Fair Housing Enforcement and Outreach Capacity
that based on the AFFH data viewer and stakeholder input that there
is limited local data or local knowledge of fair housing and
discriminatory issues and service needs in LAH.
87
1
Item 4.1 Attachment 3
City of Los Altos Hills
Housing Element Update
Response to 1-25-23 HCD Letter January 26, 2023 Draft
#Chapter Topic Comment Summary of Response/Revisions Page #
5 Housing Needs,
Resources, and
Constraints
Contributing
Factors to Fair
Housing Issues
Based on the outcomes of a complete analysis, the element should re-assess contributing factors and
prioritize those factors then formulate appropriate policies and programs.
Added new programs regarding housing mobility and reprioritized
based on the high need for multifamily or affordable rental units in
the Town.
122-123
6 Housing Needs,
Resources, and
Constraints
Extremely Low
Income (ELI):
While the element reports on households by income and mentions ELI households, it must analyze the
housing needs of ELI households to formulate appropriate policies and programs. The analysis should
address trends, tenure, overpayment, overcrowding and other characteristics and examine resources,
disproportionate housing needs and the magnitude of the gap in addressing housing needs. Based on the
outcomes of the analysis, the element should add or modify programs as appropriate
Added Table 38 outlining the rates of overpayment by tenure for
extremely low income households in the Town. Included how the
specific need for extremely low income households for multifamily
or affordable rental units are being met through Programs A-1, A-2,
A-5, A-6, A-7, and G-2 by creating a multifamily overlay and
incentivizing affordable ADU production. Included Table 39 showing
that no ELI households in Los Altos Hills experience overcrowding.
77-78
7 Housing Needs,
Resources, and
Constraints
Realistic Residential
Capacity
While the element notes a lack of past trends or experience with multifamily development, it must still
include a methodology for calculating residential capacity and account for land use controls and recent
experience, including affordability.
To address this requirement, the element could utilize a minimum density and no further analysis is
required. Otherwise, the element could examine trends in the broader region in comparable zones by listing
developments by zones, allowable and built density and affordability. In addition, since the element is
utilizing an overlay zone, uses in the base zoning are still allowed and the methodology should account for
the likelihood that development will occur or not occur according to the uses allowed by the base zoning. For
example, the element could explain interest in multifamily development and add or modify programs to
establish incentives for multifamily development and evaluate (mid-planning period) the effectiveness of the
new zone in promoting multifamily development, including appropriate responses if the zoning is not
effective. Alternatively, the element could commit to replace the base zoning with a multifamily zone instead
of an overlay zone
The following language was added to Program A-1 that commits to a
mid-cycle review and additional overlay/rezoning as necessary: The
Town will conduct a mid-cycle review of development progress and
the effectiveness of the new zone in 2027. Should the mid-cycle
review find that the zone is not effective, the Town will either
identify additional incentives for existing sites, or additional sites for
the overlay zone or rezoning
Program A-1 was also modified to note the 20 du/acre minimum
density of the overlay zone.
Added discussion of the higher education student grant and
development examples on similar community colleges, including on
the Canada campus and College of the Canyons in Santa Clarita.
Information was also added to Appendix C.
168-9
8 Housing Needs,
Resources, and
Constraints
Suitability of
Nonvacant Sites
The element identifies nonvacant sites to accommodate the regional housing need for households of all
incomes. not adequate to demonstrate the suitability of these sites. A complete analysis should describe the
methodology used to determine the additional development potential within the planning period. The
methodology must consider factors including the extent to which existing uses may impede additional
residential development, including market demand for the current uses, leases or other indicators of
turnover in uses.
The methodology for determining the realistic capacity of the RHNA
sites was added and considers factors of market demand, current
uses, and notes that the infill opportunities do not assume, intend or
require any changes to existing uses or buildings+H2.
176-178
9 Housing Needs,
Resources, and
Constraints
Suitability of
Nonvacant Sites
Additionally, HCD received several public comments related to the lack of availability of identified sites such
as owners of both the Foothill College site and the St. Nicholas Catholic School site explaining no interest in
residential development in the planning period. While expressed interest in development is not necessarily
required for sites to be used in the Town’s sites inventory, statements made by these property owners seem
to indicate that residential development on these sites is highly unlikely in the planning period, especially at
the densities and affordability levels indicated in the element. The element should address this lack of owner
interest in development and provide alternative sites as needed to accommodate the Town’s RHNA.
Added Appendix C and reference to the materials that demonstrate
recent owner and developer interest in the RHNA sites and similar
projects in the region and throughout the State including billions in
State funding for housing on school sites. The HEU was revised in
response to comments from Foothill College on the public review
draft. The appendix includes a letter from Foothill that accepts the
revised HEU including the planned rezone of the college site.
176,177
10 Housing Needs,
Resources, and
Constraints
Suitability of
Nonvacant Sites
Finally, while the element notes that greater than 50 percent of the lower-income RHNA is identified on
vacant sites, upon a complete analysis of identified sites, it [if] this conclusion changes, specific actions are
necessary if the housing element relies upon nonvacant sites to accommodate more than 50 percent of the
RHNA for lower-income households. For your information, the housing element must demonstrate existing
uses are not an impediment to additional residential development and will likely discontinue in the planning
period. Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be
presumed to impede additional residential development and will not be utilized toward demonstrating
adequate sites to accommodate the RHNA
The sites inventory has greater than 50% of lower-income RHNA
identified on vacant sites and the conclusion has not been changed.
Additional information was added regarding the existing uses and
ability to redevelop in Appendix C and in the sites inventory.
179-180,
Appendix C.
Finding also
reflected in
resolution
2
City of Los Altos Hills
Housing Element Update
Response to 1-25-23 HCD Letter January 26, 2023 Draft
#Chapter Topic Comment Summary of Response/Revisions Page #
11 Housing Needs,
Resources, and
Constraints
Large Sites Sites greater than ten acres are deemed inadequate to accommodate housing for lower-income households
unless it is demonstrated that sites of equivalent size and affordability were successfully developed during
the prior planning period or other evidence demonstrates the suitability of these sites. The element currently
discusses how smaller portions of larger sites will be used toward the lower-income RHNA. However, the
element should discuss how these smaller portions will be established and add or modify programs to
encourage appropriately sized parceling or site planning. For example, the analysis could describe interest
and plans from property owners or comparable developments in nearby communities.
Added clarification that the Foothill College and St. Nicholas School
sites will benefit from the rezoning to allow MF development that
can support existing uses and facilities. Two additional comparable
development examples were added.
Added Program A-11 regarding large sites that commits to assisting
in placement, subdivision, and outreaching to site owners biennially.
168, 169,
Appendix C, 209
12 Housing Needs,
Resources, and
Constraints
Senate Bill 9
(Statutes of 2021)
Projections:
The element is projecting 32 units that will be developed based on the passage of SB 9 (Statutes of 2021) to
accommodate a portion of its above moderate income RHNA. To utilize projections based on SB 9 legislation,
the element must; 1) include a site-specific inventory of sites where SB 9 projections are being applied; 2)
include a nonvacant sites analysis demonstrating the likelihood of redevelopment and that the existing use
will not constitute as an impediment for additional residential use and; 3) include programs and policies that
establish zoning and development standards early in the planning period and implement incentives to
encourage and facilitate development. The element should support this analysis with local information such
as local developer or owner interest to utilize zoning and incentives established through SB 9.
Added sb9 sites inventory table in appendix a and reference on Page
172.
A-5, 172
13 Housing Needs,
Resources, and
Constraints
Accessory Dwelling
Units (ADU):
The element uses the Association of Bay Area analysis of ADU rents. However, these assumptions should
also consider the Town’s survey information and market rents from comparable and nearby communities
and projections and affordability assumptions should consider other relevant factors such as availability of
the units for rent.
Summarized the Town's 2021 ADU survey results and clarified that
the HEU used the more conservative and statistically significant
ABAG income distribution rates for Town projections.
170
14 Housing Needs,
Resources, and
Constraints
Availability of
Infrastructure
While the element includes some discussion of water and sewer capacity, it should specifically address
whether sufficient total capacity is available or planned to accommodate the RHNA and modify Program B-8
(Infrastructure) as appropriate based on the outcomes of the analysis.
Added capacity of sewer systems and number of connections to
show that the Town has available or the ability to secure water and
sewer services for units anticipated in the Housing Element 163-64
3
City of Los Altos Hills
Housing Element Update
Response to 1-25-23 HCD Letter January 26, 2023 Draft
#Chapter Topic Comment Summary of Response/Revisions Page #
15 Housing Needs,
Resources, and
Constraints
Environmental
Constraints
While the element generally describes potential environmental constraints, it must still describe how these
conditions relate to the St. Nicholas Catholic School and Twin Oaks Court Sites. In addition, the element
should discuss any other known environmental or other conditions (e.g., shape, contamination, easements,
accessibility) that could preclude or impact housing development on identified sites in the planning period.
Added clarity on which constraints were considered and noted that
all of the parcels have access, no known contamination, and that the
shape of the parcels would not preclude or impact development on
the site. Added areas of 40% slope and existing utility easements to
Twin Oaks analysis.
Language added includes "Site-specific constraints, including
environmental constraints, are noted in the site description of each
site. Steep slopes, easements, and any other known constraints were
considered in the calculation of the realistic capacity. The capacity of
the sites were reduced from the maximum capacity to accommodate
for known constraints on the sites. No other environmental or other
constraints are known.
Analyzed constraints considered in realistic capacity calculations for
Foothill College include areas along Adobe Creek on Foothill College
campus where no development would be permitted within 25 feet,
and the need to accommodate development without displacing
existing uses. Topographic constraints for St. Nicholas School and
Twin Oaks considered in the realistic capacity of both sites and the
yields were reduced from the maximum capacity to account for
areas with steep slopes. Twin Oaks parcels contain a number of
utility easements and small potion of the site with over 40 percent
slope that were also accounted for in a reduction from the maximum
capacity.
Foothill College, St. Nicholas School, and Twin Oaks all have no
known contamination, and access and the shape of the parcels
would not preclude or impact development."
179-181
16 Housing Needs,
Resources, and
Constraints
Electronic Sites
Inventory
For your information, pursuant to Government Code section 65583.3, the Town must submit an electronic
sites inventory with its adopted housing element. The Town must utilize standards, forms, and definitions
adopted by HCD. Please see HCD’s housing element webpage at https://www.hcd.ca.gov/planning-and-
community-development/housing-elements for a copy of the form and instructions. The Town can reach out
to HCD at sitesinventory@hcd.ca.gov for technical assistance
Electronic sites inventory to be submitted with adopted HE.N/A
17 Housing Needs,
Resources, and
Constraints
Zoning for a Variety
of Housing Types
Employee Housing: The element includes a program to amend zoning to permit employee housing similar to
single-family uses pursuant to Health and Safety Code section 17021.5. However, the element should also
discuss compliance with Health and Safety Code sections 17021.6 and 17021.8 and add or modify programs
if necessary. For example, Section 17021.6 requires employee housing consisting of no more than 12 units or
36 beds to be permitted in the same manner as other agricultural uses in zones allowing agricultural uses.
Included language that the Town will comply with the Employee
Housing Act sections 17021.6 and 17021.8 with regards to Employee
Housing and updated Program E-8 to reference Government code
sections 17021.6 and 17021.8.
142, Program E-
8
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City of Los Altos Hills
Housing Element Update
Response to 1-25-23 HCD Letter January 26, 2023 Draft
#Chapter Topic Comment Summary of Response/Revisions Page #
18 Housing Needs,
Resources, and
Constraints
Zoning for a Variety
of Housing Types
Emergency Shelters: The element notes emergency shelters are permitted in the R-A zone but should also
clarify these uses are permitted without discretionary action. In addition, the element lists several
development standards that may impact capacity and the analysis should account for these factors. The
element should also include specific commitment to amend development standards which appear to be
constraints or contrary to state law including spacing or proximity provisions, bed limits and parking
requirements. Finally, if intending to identify a new zone, the element should discuss potential capacity and
include specific commitment to amend zoning appropriately, including development standards that comply
with Government Code section 65583, subdivision (a)(4). Finally, statute was recently amended to specify
how to demonstrate suitable sites and sufficient capacity to accommodate the need for emergency shelters.
Future submittals may need to address these requirements. For more information and applicable timing, see
HCD’s AB 2993 memorandum at https://www.hcd.ca.gov/sites/default/files/docs/planning-and-
community/ab2339- notice.pdf.
Clarified emergency shelters do not require discretionary approval
(no CDP or other discretionary permits), and that standards will be
amended in Zoning Code to further compliance with applicable state
law.
130, 137-138,
187, 202
19 Housing Needs,
Resources, and
Constraints
Land Use Controls While the element generally describes land-use controls and identifies constraints on development, it then
concludes the new multifamily overlay zone will address these constraints. However, the element should
discuss the constraints on existing allowable uses and add or modify programs as appropriate. In addition,
the element, based on public feedback (p. 9) notes the line contour formula may be a constraint but should
include specific analysis as a potential constraint. This analysis should also discuss story poles. The analysis
should address impacts on housing supply (number of units), cost, feasibility, timing and ability to achieve
maximum densities
Added the following to the existing section analyzing the story pole
policy: The cost of story poles is does not add significantly to
development in the Town. Story poles cost from $2,000 to $4,000
dollars along with a nominal rental fee. They do not constrain the
supply of housing, cost, or timing and ability to achieve maximum
density on lots. The Town typically requires Story Poles to be up 10-
day before a public hearing. Story poles are not anticipated to be
required for multifamily developments in the Town.
The line contour formula is analyzed and discussed in the Lot Unit
Factor section. The Town has created a simplified version of the
formula and posted it on the Town’s website. This allows the public
to more easily understand the Lot Unit Factor and works to minimize
any constraint it may pose to development.
9, 149, 138
20 Housing Needs,
Resources, and
Constraints
Land Use Controls In addition, the Town does not contain any provisions for development on sites less than one acre, severely
impacting housing choices since Town incorporation (p. 112) and there are no multifamily units in the Town.
Essentially, there is a lack of a variety of minimum lot sizes and allowable densities. The lack of a variety of
lot sizes and densities can impact housing supply, choices and affordability. As a result, the element should
include analysis of the impacts of a large lot land use pattern and include programs as appropriate such as
establish zoning for a variety of lot sizes and densities regardless of RHNA. These programs should further
commit to appropriate development standards to facilitate intended densities.
Added the following: Despite the minimum lot size, there are
approximately 500 lots that are smaller than one acre in the Town.
The Town has approved new homes and other accessory uses on
eight lots between 2015-2022 through its CDP process. This includes
new residences on lots that are 0.9, 0.42, and 0.963 acres in size.
ADUs and SB9 units are allowed on lots less than one acre in size.
Note that the created of a
135
21 Housing Needs,
Resources, and
Constraints
Land Use Controls Finally, the element lists various standards to implement Government Code sections 65852.21 and 66411.7
(SB 9) but should also analyze those standards, compliance with the law and add or modify programs as
appropriate to comply with state law
The HEU notes that the Town is working on a permanent SB 9
ordinance. While the Town has already received 4 applications under
the current regulations, the Town will remove or revise the current
requirement that new units on new parcels be occupied by lower
income households as that could unnecessarily restrict overall
production.
139
22 Housing Needs,
Resources, and
Constraints
Fees and Exaction: The element lists total development fees for single-family and multifamily development but should also list
the various fees that comprise the total fees per unit. For example, the element should list and evaluate the
various impact fees per unit for impacts on housing cost.
Added the three impact fees per the Towns Fee Schedule PDF 151
5
City of Los Altos Hills
Housing Element Update
Response to 1-25-23 HCD Letter January 26, 2023 Draft
#Chapter Topic Comment Summary of Response/Revisions Page #
23 Housing Needs,
Resources, and
Constraints
Processing and
Permit Procedures:
While the element generally describes processing and permitting procedures, it must still list and evaluate
the site development permit and design review, including typical approval findings, typical number of
hearings if applicable, and timing and then evaluate impacts on housing supply, cost, feasibility and approval
certainty
Added the following information: Under current zoning code
requirements, all single-family residential developments are required
to obtain a site development permit and generally may be reviewed
and approved in one fast-track/planning commission public hearing.
Residential projects are required to comply with development
standards such as setback, maximum development/floor area
requirements, and height. The Town does not conduct design review
separately and does not impose discretionary design review
standards. For projects proposed on lots less than one acre or those
that do not comply with development standards, a conditional
development permit or variance would be required pursuant to a
public hearing before the Planning Commission. In either situation, it
generally takes one hearing for a new residence to be approved. No
findings of approval are required for fast-track/planning commission
site development permit approvals.
146
24 Housing Needs,
Resources, and
Constraints
Constraints on
Housing for
Persons with
Disabilities:
The element concludes the Town has a definition of family that does [NOT] pose a constraint to housing for
persons with disabilities. However, the element should evaluate its potential impacts, including impacts on
unrelated persons. For example, the element could explain the application of provisions such as “close social
or economic or psychological commitments to each other” and whether that impacts unrelated persons.
Retain, Revise, Remove - The definition will be revised to remove
subjective language that could be misinterpreted as a requirement
that would limit unrelated individuals from forming a household.
19, 148, 201
25 Housing Needs,
Resources, and
Constraints
On/Off-Site
Improvements:
The element generally describes some on-site improvements but identify the actual standards and any off-
site improvements applied to typical development then analyze impacts on housing costs and add or modify
programs if appropriate.
Added that the required on-site improvement is infrastructure
connections and that no other on or off-site improvements are
required. Clarified that the maintenance of the Master Path Plan is
done through the pathway fee.
151
26 Housing Needs,
Resources, and
Constraints
Codes and
Enforcement:
The element explains that code enforcement is generally reactive in response to complaints but should also
discuss which building code is utilized (e.g., 2022) and identify and analyze any local amendments for
impacts on housing costs.
Added language identify building codes and adopted reach codes.
"The Town has adopted the 2022 editions of the California Building,
Fire, Plumbing, Mechanical, Electric, and Health and Safety Codes.
Local amendments include adopted Reach Codes for low rise
residential building. The adopted Reach Code requires all new
construction to be fully electric, with the exception of cooking
appliances and outdoor cooking, fireplaces, and pool/spa heating,
and be electrical vehicle ready. Reach codes establish higher
standards for new construction to provide environmental and health
benefits to the community and do not pose a significant cost
constraint or impede housing development."
151
27 Housing Needs,
Resources, and
Constraints
Other Local
Ordinances:
The element must analyze any locally adopted ordinances that directly impacts the cost and supply or
residential development (e.g., inclusionary requirements, short term rentals, growth controls).
Added "Other Local Ordinances" subsection in Land Use controls
section of constraints. Noted that there are no growth control
measures, only one registered short-term rental unit, and a program
to adopt an inclusionary housing requirement (no greater than 15%)
that will not constrain development. There are no other local
ordinances that constrain development in the Town.
138
6
City of Los Altos Hills
Housing Element Update
Response to 1-25-23 HCD Letter January 26, 2023 Draft
#Chapter Topic Comment Summary of Response/Revisions Page #
28 Housing Needs,
Resources, and
Constraints
Approval Times The element must identify the length of time between receiving approval for housing development and
submittal of application for building permits and discuss any hindrances on construction.
Added the following analysis on permit processing time: Staff
evaluated building permit applied and issued in years 2021 and
2022, and half of the permits received approval in 2 to 6 months
timeframe. This is a expeditious process given that permit
applications are reviewed by Town and outside agencies including
the County fire department and health department for on-site septic
systems proposed. At times, the permit review and issuance are
delayed for some projects due to review needed by such outside
agencies; however, the Town has taken steps to review and improve
the process in coordination with outside agencies to reduce any
hindrances on housing construction. To illustrate, in recent months
the Town has coordinated/worked with SCCFD to improve the
Alternate Materials, Methods of Construction (AMMR) approval
from the Fire Department.
148-149
29 Housing Programs Housing Programs As noted in Finding B3, the element does not include a complete site analysis, therefore, the adequacy of
sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the
Town may need to add or revise programs to address an additional shortfall of sites or zoning available to
encourage a variety of housing types. Additionally, the element should be revised as follows:
(see individual responses below)(see individual
responses
below)
30 Housing Programs Shortfall of Sites The element describes a shortfall of sites and indicates rezoning will occur to accommodate the RHNA. While
the element includes Program A-1 (Availability of Adequate Sites for New Housing to meet the RHNA), it
must specifically commit to acreage, allowable densities, appropriate development standards, anticipated
units and meet all requirements pursuant to Government Code section 65583.2, subdivisions (h) and (i).
Program A-1 commits to zoning at least 30 du/acre for at least 30 net
developable acres.
Added the commitment to include capacity for at least 362 as
identified in the sites inventory.
203-4
31 Housing Programs Program A-3 (Town-
owned Sites)
The Program should go beyond reviewing sites and commit to identify sites, including a schedule of actions
to facilitate development, compliance with the Surplus Land Act and numerical objectives.
Revised to state the program will also identify sites with residential
development potential, in addition to assessing Town-owed
properties, and to take steps to engage in the Surplus Land Act
declaration and disposal process.
203
32 Housing Programs Program E-2
(Emergency
Shelters)
The Program should specifically commit to remove or modify development standards or identify an
additional zone based on a complete analysis as described in Finding B3.
Program amended to commit to modifying emergency shelter
standards so that they comply with
130, 143, 218
33 Housing Programs Program E-4
(Transitional and
Supportive
Housing)
The Program commits to amend zoning to comply with AB 2162 (By-right Permanent Supportive Housing)
but should also specifically commit to permit transitional and supportive housing as a residential use in all
zones allowing residential uses and only subject to those restrictions that apply to other residential dwellings
of the same type in the same zone. These requirements are separate and in addition to AB 2162.
Program E-4 already states the town will "Permit transitional and
supportive housing as a residential use in all zones allowing
residential uses and only subject to those restrictions that apply to
other residential dwellings of the same type in the same zone."
Added to Program E-4 that "The Town will ensure compliance with
all state law regarding transitional and supportive housing. This
includes ensuring transitional and supportive housing is allowed as a
residential use in all zones allowing residential uses and is only
subject to those restrictions that apply to other residential dwellings
of the same type in the same zone."
207
34 Housing Programs Program E-9 (Single
Room Occupancy
(SRO))
The Program should explore and establish additional zoning opportunities given the lack of results in the
prior planning period
Added to Program E-9 "To establish additional zoning opportunities
for a variety of housing types, SROs will be allowed as an accessory
use in the multifamily overlay zone that will be created through
Program A-1. "
Program E-9
and 139
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City of Los Altos Hills
Housing Element Update
Response to 1-25-23 HCD Letter January 26, 2023 Draft
#Chapter Topic Comment Summary of Response/Revisions Page #
35 Housing Programs Future Zones The element should commit to allow uses as appropriate in any future zones, including in the multifamily
zones or other zones that may be created as a result of a complete analysis of zoning for a variety of housing
types. For example, future zoning may need to incorporate transitional and supportive housing and ADUs
Added to Program A-1: The overlay zone and any future zones will
allow for a variety of uses as identified in the constrains analysis of
the Housing Element. This includes allowing for multi-family housing,
SROs, and transitional and supportive housing as required by state
law.
Added to Program E-4: "To establish additional zoning opportunities
for a variety of housing types, transitional and supportive housing
will be allowed, as required by state law, in the multifamily overlay
zone and any future zones that will be created through Program A-
1."
Added to Program E-9 "To establish additional zoning opportunities
for a variety of housing types, SROs will be allowed as an accessory
use in the multifamily overlay zone that will be created through
Program A-1. "
195, 210, 212
36 Housing Programs Development of
adequate housing
to meet the needs
of extremely low-,
very low-, low- and
moderate- income
households
The element must include a program to assist in the development of adequate housing to meet the needs of
lower and moderate-income households, including ELI and special needs households. These actions should
be significant and specific, given the lack of implementation and results in the prior planning periods.
Examples of actions include proactive an annual outreach to developers of affordable housing, assisting with
funding, supporting funding applications, land acquisition, priority processing, fee waivers, concessions and
incentives beyond State Density Bonus Law, assistance with infrastructure and site improvements and
monitoring and adjustment at least annually.
Program A-9 was amended to specifically note the program will
especially to meet the needs of lower, moderate, ELI and special
needs households, and will explicitly include affordable housing
developers in the annual promotion and facilitation, and technical
assistance including infrastructure planning. Programs B-1 already
provides expedited review and permit streamlining. A mid-cycle
review and adjustments has been added to Program A-1.
198
37 Housing Programs Constraints As noted in Findings B4 and B5, the element requires a complete analysis of potential governmental
constraints. Depending upon the results of that analysis, the Town may need to revise or add programs and
address and remove or mitigate any identified constraints
The Town has added specificity and commitments to various
programs to remove constraints to housing development including:
- Committing to providing zoning for at least 362 units and to
providing opportunity for a variety of housing types in the overlay
zone
- Amending the definition of family in Program B-4
- Added specificity to programs E-4 and E-9 regarding opportunities
for SROs, supportive, and transitional housing in the overlay and
future zones
- A mid-cycle review committing to additional incentives or rezoning
in 2027.
- Ensuring emergency shelter standards comply with state law (E-2)
- Ensuring adequate infrastructure is available for development of
sites (B-8)
203, 211, 217-
219
38 Housing Programs AFFH As noted in Finding B1, the element must include a complete analysis of AFFH. The element must be revised
to add goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically
respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and
must be significant and meaningful enough to overcome identified patterns and trends.
Included reference in the Income and poverty sections of the AFFH
explaining how the town derived Programs A-1, A-2, A-5, A-6, A-7, F-
2, F-3, G-2,and G-3 from need demonstrated in this chapter.
Revised Policies 5.2 and 5.8 to address prominent contributing
factors to barriers to fair housing.
91-94, 100, 102,
195
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City of Los Altos Hills
Housing Element Update
Response to 1-25-23 HCD Letter January 26, 2023 Draft
#Chapter Topic Comment Summary of Response/Revisions Page #
39 Housing Programs ADUs While the element includes Program A-7 (ADU Tracking and Monitoring) to monitor ADU production and
affordability and adopt another ADU program, if necessary, the Program should commit to rezoning if
production and affordability is significantly not meeting assumptions in the sites inventory
Program A-7 was modified to commit to a mid-cycle review in 2027
in conjunction with Program A-2. The Town will commit to additional
incentives, sites in the overlay, or rezoning to be completed by Q1
2028.
196
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