Loading...
HomeMy WebLinkAboutPC Staff Report - Housing Element adoption_01-27-2023TOWN OF LOS ALTOS HILLS January 27, 2023 Staff Report to the Planning Commission SUBJECT: Consideration of a resolution recommending to the City Council adoption of the Housing Element of the General Plan for the period of 2023-2031 and determination that adoption of said element is exempt from the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15061(b)(3). FROM: Sofia Mangalam, Planning Director RECOMMENDATION: That the Planning Commission take the following actions: 1.Conduct a public hearing; 2.Adopt a Resolution determining that the proposed Housing Element Update is exempt from CEQA and recommending to the City Council adoption of the Housing Element of the General Plan for the period of 2023-2031. BACKGROUND State law requires that a housing element be included in a jurisdiction’s general plan as one of the seven mandatory "elements," or chapters, which express the community's values, goals, and vision for the future. The housing element must be adopted in substantial compliance with state housing element law, located in Government Code section 65580 et seq. The Town of Los Altos Hills (Town) has prepared a draft update to the Housing Element of the General Plan to Affirmatively Further Fair Housing (AFFH) and accommodate the 489-unit Regional Housing Needs Allocation (RHNA) for the 2023-2031 Housing Element cycle. The content of the draft 2023-2031 Housing Element is structured for consistency with the requirements set forth in state law. In addition to responding to requirements of state law, the Housing Element also demonstrates the Town’s strategy to meeting the Town’s locally determined housing needs, and that these needs are addressed through policies and programs outlined within the Housing Element. Public review and input have been a critical component of this 6th cycle Housing Element Update. Prior to adopting their housing elements for every planning cycle, municipalities including the Town are required to submit the draft housing element to the State Department of Housing and Community Development (HCD) at least 90 days prior to adoption. HCD is required by sta te law to make findings and provide comments on the draft element, and municipalities are required to consider these findings prior to adopting the housing element. Once adopted, the housing element must be submitted back to HCD for post-adoption findings and certification. The Town timely submitted its draft housing element to HCD on October 27, 2022. Town staff met with HCD staff during a preliminary meeting on December 22, 2022 and received verbal feedback. HCD provided formal comments on January 25, 2023, via comment letter (Attachment 2). The current draft housing element before the Planning Commission contains revisions that addresses all of HCD’s comments described above, and as shown in Attachment 3 to this report. Item 4.1 Staff Report Planning Commission Page 2 Housing Element Update 2023-2031 January 27, 2023 Based on these revisions, the draft Housing Element is in substantial compliance with state housing element law and staff recommends the Planning Commission make a recommendation to the City Council for adoption. The City Council public hearing to consider adoption is scheduled for January 30th, 2023. If the Town fails to adopt the Housing Element by January 31st, 2023, the Town will be subject to certain consequences and statutory penalties, including loss of grant receipt opportunities as detailed in the next section. One notable consequence is the triggering of the “Builder’s Remedy” should the Town not timely adopt a housing element. The term “Builder’s Remedy” is used to describe the situation where a local agency is required to approve an affordable housing development project (at least 20% lower-income or 100% moderate-income) that does not comply with its general plan or zoning standards. The “Builder’s Remedy” arises from the Housing Accountability Act (HAA), contained in Section 65589.5 of the California Government Code. Under this HAA provision, in order for the Town to deny an affordable housing development (at least 20 percent lower-income housing or 100 percent moderate-income housing) or emergency shelter project, or to impose any conditions of approval which would render it infeasible, the HAA requires the Town to make one of five findings summarized as follows: 1. The Town has met or exceeded its RHNA for the proposed income categories in the development. 2. The housing development or emergency shelter would have a specific adverse impact on public health and safety, and there is no other feasible method to mitigate or avoid the impact without making the development unaffordable. 3. The denial or condition is required to meet state or federal law, and there is no feasible method to comply without making the development unaffordable. 4. The project is proposed on land zoned for agriculture or resource preservation that is surrounded on at least two sides by land being used for agriculture or resource preservation or there are not adequate water or sewage facilities to the serve the project. 5. The project is inconsistent with both the zoning ordinance and the land use designation as specified in any general plan element. However, the Town cannot make this finding if it has not adopted a housing element in substantial compliance with state law. Recent development proposals in the City of Santa Monica provide an example of implementation of the Builder’s Remedy. Santa Monica’s housing element was found to be out of compliance between February 2022 and October 2022. During that time, developers proposed 16 projects within the city “totaling over 4,500 new units of housing, with more than 800 of these designated as affordable for low-income households.” (Source: webpage link) NOTICING/PUBLIC OUTREACH As adoption of the Housing Element constitutes an amendment to the Town’s General Plan, there are certain public hearing and noticing requirements that apply under state law. The Town has complied with these requirements as noticing was provided in compliance with Government Code sections 65355 and 65090. Specifically, the public was advised of this Public Hearing in the following ways: Planning Commission Page 3 Housing Element Update 2023-2031 January 27, 2023 • Newspaper (Daily Post)– January 16, 2023 • Public Posting Places – January 17, 2023 • Mailing to property owners who own property within a 500-foot radius of the sites identified in the Housing Element– January 17, 2023 • Town Website: www.losaltoshills.ca.gov – January 17, 2023 • Social Media: January 19 and 23, 2023 To date, staff has received a few public comments which has been added as supplemental to the packet. DISCUSSION CA Government Code Title 7, Division 1, Chapter 3, Article 10.6 [65580 – 65589.11] regulates the use and requirements of housing elements in California. The state law requires that the local jurisdictions update its General Plan Housing Element every eight (8) years. State law further requires the current update for jurisdictions in the Association of Bay Area Governments (ABAG) region to comply by January 31, 2023. The Town’s 2023-2031 Draft Housing Element was prepared with the benefit of community, Planning Commission, and City Council input and discussion at five (5) public workshops over the course of the one-year preparation period. Joint workshops on the draft Housing Element were held by the City Council and the Planning Commission. On October 27, 2022, the Town submitted the draft Housing Element to HCD for its review. In December 2022, Town staff reached out to HCD to discuss Town’s draft Housing Element. Town and HCD staff met on December 22, 2022, over virtual meeting to discuss the draft Housing Element, and received initial comments from HCD. Based on these initial comments, Town staff revised the draft Housing Element to include additional information and analysis in order to timely and comprehensively address HCD’s comments. The revisions were also sent to HCD for review on January 9, 2023. On January 23, 2023, the Town published the changes to the Draft Housing Element on the Town website. The Town received two (2) comment letters during this public review period. Subsequently, the Town received formal comment letter from HCD on January 25th, 2023 (Attachment 2). In response to HCD comments set forth in the letter and additional public input received during this time, Town staff further revised the draft Housing Element to incorporate additional information and analysis. These changes are presented in redline as shown in Attachment 4, Final Draft Housing Element. Summary of New Requirements for Housing Element Components The following section summarizes the required components of Housing Element Updates per State law, new requirements included since the prior 5th cycle Housing Element Update (2015-2023), and penalties for non-compliance with Housing Element Laws. The section also includes a summary of public meetings related to the 6th cycle Housing Element Update prior to today’s meeting. Planning Commission Page 4 Housing Element Update 2023-2031 January 27, 2023 Required Components of a Housing Element Pursuant to Government Code Section 65583, local governments are required to include the below items as components in their Housing Elements, and subsequent updates thereto. Newly required components introduced as part of the 6th Cycle are included in blue below and discussed in further detail within the “New Requirements for the 6th Cycle Housing Element Update” Section below. 1. Housing Needs Assessment: Examine demographic, employment and housing trends and conditions and identify existing and projected housing needs of the community, with attention paid to special housing needs (e.g., large families, persons with disabilities). This Section includes a community’s Regional Housing Needs Allocation (RHNA) as determined by a community’s regional planning body in partnership with HCD. 2. Evaluation of Past Performance: Review the prior Housing Element to measure progress in implementing policies and programs. 3. Housing Sites Inventory: Identify locations of available sites for housing development or redevelopment to demonstrate there is enough land zoned for housing to meet future need at all income levels. The standards for designating adequate sites were substantially changed from the sixth cycle, particularly for non-vacant sites. 4. Community Engagement: Implement a robust community engagement program that includes reaching out to individuals and families at all economic levels of the community plus historically underrepresented groups. 5. Constraints Analysis: Analyze and recommend remedies for existing and potential governmental and nongovernmental barriers to housing development. 6. Policies and Programs: Establish policies and programs to be carried out during the 2023- 2031 planning period to fulfill the identified housing needs. 7. AFFH: Analyze and address significant disparities in housing needs and access to opportunity by proposing housing goals, objectives, and policies that aid in replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws. New Requirements for the 6th Cycle Housing Element Update Pursuant to recent State legislation, the following items are now required as part of the Housing Element Update process: • Affirmatively Furthering Fair Housing, AFFH. Assembly Bill 686 (AB 686), passed in 2018, created new requirements for jurisdictions to affirmatively further fair housing. According to AB 686, affirmatively furthering fair housing means to take “meaningful actions, in addition to combating discrimination, which overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics” and is Federally mandated by the 1968 Fair Housing Act. The four main goals are to: • Address significant disparities in housing needs and in access to opportunity • Replace segregated living patterns with truly integrated and balanced living patterns • Transform racially and ethnically concentrated areas of poverty into areas of opportunity • Foster and maintain compliance with civil rights and fair housing laws Planning Commission Page 5 Housing Element Update 2023-2031 January 27, 2023 • Public Comment on Draft Revisions. Assembly Bill (AB) 215 (2021), requires local governments to make the first draft revision of their housing element update available for public comment for at least 30 days. Further, if any comments are received, a local government must take at least ten additional business days to consider and incorporate public comments into the draft revision before submitting to HCD for review and comments. HCD must review the draft and report its written findings to the local government within 90 days of receiving the first draft submittal for each housing element revision or within 60 days of its receipt for a subsequent draft amendment or adoption. Penalties for Non-Compliance During the 6th cycle, jurisdictions face a number of new consequences for not having a certified Housing Element. Under legislation enacted in recent years, if a city does not comply with State housing law, HCD may refer the jurisdiction to the Attorney General. Significant fines may be imposed if a city does not comply with a court order for one year. A court finding a Housing Element inadequate may limit local land use decision-making authority until the jurisdiction brings its Housing Element into compliance, or local governments may lose the right to deny certain projects. Conversely, an HCD-certified housing element is presumed to be in substantial compliance with state law and makes cities eligible for, or with higher priority for, numerous sources of funding, such as Local Housing Allocations, Affordable Housing and Sustainable Communities Grants, SB 1 Planning Grants, CalHOME Program Grants, Infill Infrastructure Grants, Pro-Housing Design funding, Local Housing Trust Funds, and Regional Transportation Funds (such as MTC’s OneBayArea Grants). Draft 2023-2031 Housing Element Overview The City Council and Planning Commission previously reviewed the draft Housing Element during public hearings held on October 3 and October 26, 2022. The following section summarizes the contents of the Town’s Housing Element Update for the 2023-2031 Planning Period. Further revisions to the draft Housing Element in response to HCD comments are included in Attachment 4 and shown in redline. Attachment 3 includes response to the comment letter and reference to the revisions made. HOUSING NEEDS ASSESSMENT As part of the Housing Element Update process, the Town is required to analyze the existing and projected housing needs of the Town, including its fair share of RHNA requirements. The Town’s analysis of housing needs is required to include an assessment of detailed demographic data including population age, size, and ethnicity; household characteristics; overpayment trends; housing stock conditions; units in need of replacement or rehabilitation; and needs of special needs populations including the elderly, persons with disabilities, unhoused persons, extremely low- income households, and farmworkers. Utilizing the Housing Needs Data Report provided by ABAG, the 6th cycle Housing Element Update outlines the following housing needs of the Town. Planning Commission Page 6 Housing Element Update 2023-2031 January 27, 2023 Summary of Housing Needs An analysis of the needs in Los Altos Hills indicates an increased need for housing affordable to a variety of income levels, a lack of multi-family housing to address regional needs, and potential increased need for services and programs for the elderly population. Additionally, compared to Santa Clara County, the Town has much higher income levels and home values. The Town is including a number of programs in response to the needs assessment and changing needs of the Town and region. This includes Program A-3, which assesses Town-owned properties for their potential use as housing for special needs populations including elderly persons, lower-income households, and persons with disabilities. Program E-7 addresses the needs of elderly households by continuing to provide financial support for the Community Services Agency and Los Altos Senior Center which provide resources for senior residents in the Town. To encourage an increase of diversity in housing stock, the Town is including Program A-1 to create an overlay zone on parcels for multi-family uses at a density of at least 30 du/acre for at least 30 net developable acres. Regional Housing Needs Allocation (RHNA) RHNA requirements are organized into four affordability categories, established according to the Area Median Income (AMI) of a geography. These categories include very low-income residential units, which are affordable to households earning less than 50% of AMI; low-income residential units, which are affordable to households earning between 50% and 80% of AMI; moderate income residential units, which are affordable to households earning between 80% and 120%; and above moderate-income residential units which are affordable to households earning upwards of 120% of AMI. The Town’s is included below in Figure 1. Figure 1: Town’s Regional Housing Needs Allocation (RHNA) RHNA Buffer New “no net loss” provisions of Government Code Section 65863 require the Town to ensure an adequate supply of land resources to be made available for housing development throughout the duration of the 2023-2031 planning period. This means if housing sites identified within the Town’s 6th cycle housing element update are developed with lower residential densities, or residential uses at affordability levels higher than anticipated by the Housing Element, the Town’s Housing Element could be determined to be out of compliance. Accordingly, the Town’s RHNA Planning Commission Page 7 Housing Element Update 2023-2031 January 27, 2023 requirement is further buffered with 74 units (15 % of buffer) to ensure compliance with ”no net loss” provisions (see Fig. 2). Figure 2: Town’s Regional Housing Needs Allocation (RHNA) CONSTRAINTS ANALYSIS In addition to analyzing the existing and projected housing needs of the Town, the Housing Element Update must also identify and analyze potential and actual governmental and nongovernmental constraints to the maintenance, improvement, or development of housing for all income in the community, regardless of protected class. A summary of constraints to the development and improvement of housing in the Town is included below, along with descriptions of local efforts to lessen these constraints as applicable. • In Los Altos Hills, governmental constraints include General Plan Land Use designations, zoning code provisions, enforcement requirements, processing and permit procedures, fees, and on-site and off-site improvement requirements. • The cost of land is very high and creates a constraint on the feasibility of housing projects to provide housing for anyone other than very high-income households. • In Los Altos Hills, seismic hazards, steep slopes, soil instability, and fire hazards provide the greatest threat to the built environment. Infrastructure constraints include the availability and cost of water and sewer services. These constraints may impact the future development of residential units in the Town and can pose a potential constraint to housing development. HOUSING RESOURCES & SITES INVENTORY As part of the 6th cycle housing element update, the Town is also required to identify resources available to the Town for the preservation, rehabilitation, and production of housing throughout the community. For instance, this includes programmatic and financial resources, such as those offered locally or through State or Federal partners. These resources also include land resources within the Town that were identified as eligible for accommodation of the Town’s RHNA Requirements. The Town’s Housing Sites Inventory is summarized below in Figure-2. Land resources identified within the below Inventory Summary are included on the following Map. Planning Commission Page 8 Housing Element Update 2023-2031 January 27, 2023 Map 1: RHNA Sites Inventory Fig. 3. illustrates the residential capacity that is being counted toward the RHNA. The Town has adequate sites at all income levels. The inventory includes a total lower-income capacity of 236 units, exceeding the 197 units to achieve a 15 percent buffer. The inventory accommodates 98 moderate units, 4 units above what is required to achieve a 15 percent buffer. The inventory also supports 254 above-moderate units, exceeding the RHNA plus 15 percent buffer requirement of 242 units. Planning Commission Page 9 Housing Element Update 2023-2031 January 27, 2023 Figure 3: Town’s Housing Sites Inventory Source: Town’s Draft Housing Element POLICIES AND PROGRAMS As required by state Housing Element law, the Housing Element Update includes a set of goals, policies, and implementing programs intended to promote the preservation, r ehabilitation, and production of housing throughout the Town of Los Altos Hills. Goals are long-range, broad, and comprehensive targets that describe future outcomes the Town desires. A policy is a specific instructional guideline that seeks to promote goals. Together, goals and policies are implemented through a series of programs that identify specific, quantifiable actions the Town will undertake during the 6th cycle planning period. The Goals, Policies and Programs in the 2023-2031 Housing Element is shown starting on page 184 of the Housing Element in Attachment 4. Quantified Objectives Housing Element law requires that quantified objectives be developed with regard to new construction, rehabilitation, conservation and preservation activities that will occur during the eight-year Housing Element cycle. Fig 4 summarizes the Town’s quantified objectives for the provision of affordable housing opportunities based on its programs during the eight-year 2023 – 2031 Housing Element cycle. • The New Construction objective represents the Town’s RHNA of 125 units for very low- income households, 72 units low-income households, 82 units for moderate-income households, and 210 units for above moderate-income households. • The Rehabilitation objective represents the potential number of units that may require some form of repair or significant maintenance to remain habitable. • The Conservation/Preservation objective reflects the opportunity to maintain ADUs and future below-market rate units as an affordable housing option in Los Altos Hills. Planning Commission Page 10 Housing Element Update 2023-2031 January 27, 2023 Fig 4: Total Quantified Objectives Los Altos Hills, 2023 – 2031 There are 52 programs included in the Draft Housing Element to satisfy the community’s housing needs and meet the requirements of State law. The programs are organized in the six (6) major housing goals described above. AFFH Assembly Bill 686 (AB 686), passed in 2018, created new requirements for jurisdictions to affirmatively further fair housing as part of the Housing Element Update process. These requirements found in Government Code Section 8899.50 are intended to address racial inequalities seen today throughout the Bay Area which developed through historical policies and practices enacted at federal, state, regional and local levels and across the public and private sectors. Accordingly, pursuant to state Housing Element law, the Town must incorporate fair housing considerations into its 6th Cycle Housing Element Update to increase housing opportunities in high resource neighborhoods and bring additional resources to traditionally under- resourced neighborhoods. AFFH issues are analyzed and addressed in detail in AFFH section starting from pages 79 through 120 of the Housing Element. Fig 6 below summarizes the policies and programs required by State Law to demonstrate the Town’s commitment to affirmatively further fair housing as part of the Housing Element Update Process. Planning Commission Page 11 Housing Element Update 2023-2031 January 27, 2023 Fig 6 Fair Housing Issues, Contributing Factors, and Meaningful Action (presented in redline) Planning Commission Page 12 Housing Element Update 2023-2031 January 27, 2023 EVALUATION OF PAST PROGRESS Pursuant to State Housing Element law, the section ‘Review of Past Accomplishments’ in the draft Housing Element summarizes the implementation status of Goals, Policies and Programs from the Town’s 5th cycle Housing Element Update (2015-2023). The Town of Los Altos Hills had a total RHNA allocation of 121 units in the 5th Cycle. As of December 2021, 153 new units had been built, permitted, or approved during the 5th Cycle, exceeding the overall allocation of 121 units. As a whole, the Town of Los Altos Hills was successful in implementing its 5th Cycle Housing Element. The Town has exceeded the RHNA production for the Very Low, Low, and Above Moderate categories, and is anticipated to exceed the Moderate allocation prior to the end of the 5th Cycle. Additionally, significant financial support was provided to non-profit service agencies assisting populations with special needs. Nearly all programs in the 5th Cycle Element were completed or implemented. While the Town has made progress, it recognizes that housing costs in Los Altos Hills continue to be out of reach for most residents of the area. In response, the Town is committing to a comprehensive suite of programs designed to affirmatively further fair housing, increase local housing production, support special needs populations, and create an overlay zone to accommodate multi-family development. These commitments are reflected in the proposed programs and policies in the draft Housing Element. COMMUNITY ENGAGEMENT Consistent with State Law, the Town of Los Altos Hills has conducted ongoing community outreach efforts throughout the 6th Cycle Housing Element Update process. These efforts, inclusive of Planning Commission and City Council Meetings held prior to today are summarized within the AFFH section included within the Housing Element Update and also in the section below. Public Workshops/Joint City Council and Planning Commission meetings The Town held five (5) virtual public workshops as included below to present information on the Housing Element update and to gather public input. The public workshops were held at 6:00 p.m. on weekdays to accommodate a typical work schedule. Materials and video recordings of the presentations were made available on the Los Altos Hills Housing Element web page on the Town’s website for those who could not attend, or who wanted to review the materials and meetings at their leisure. Members of the community participated in the workshops and provided feedback via questions and answers on the potential RHNA sites and the Housing Element update process. • January 19, 2022 – Informational Presentation on the Housing Element Update Process • March 24, 2022 - Potential Sites Inventory • June 20, 2022 - Housing Sites Inventory, and Goals and Programs Planning Commission Page 13 Housing Element Update 2023-2031 January 27, 2023 • October 3, 2022 - Public Draft Review of the Housing Element • October 26, 2022 - Public Draft Review of the Housing Element Other Meetings • One (1) virtual pop-up event was conducted on February 10, 2022, to discuss Housing Element update process. Residents and other interested individuals were provided an opportunity to ask questions of staff regarding the proposed housing element update and the website was updated to include information from the workshop. • Updates on the status of the housing element update were provided at the following Planning Commission meetings, and public comments were accepted. o February 3, 2022 - Presentation on Housing Needs Data Report by ABAG/MTC o March 3, 2022 - Evaluation of Existing Housing Element Programs o June 15, 2022 - Presentation on Goals, Programs and Policies Housing Element Survey Another component of the outreach effort was the Housing Element survey, posted on the Town’s website from February 2022 to the end of August 2022, and promoted through a myriad of channels for the furthest outreach. The Town received an overwhelming response from 535 individuals. The survey results were thoroughly analyzed, considered for drafting of the Housing Element and added as Appendix B to the Housing Element. Stakeholder Interviews The Town reached out to 31 individuals who represented service providers, nonprofits, and other stakeholders to participate in focus group interviews about the housing needs and issues in Los Altos Hills (13 community stakeholders and 18 local service providers). Out of the 31 individuals and groups that were contacted, 9 people participated in the focus groups (4 community members, 1 Town Senior Committee member, 1 faith-based institution representative, and 3 regional advocacy group representatives). Of those participants, the community members came from a wide range of age demographics, from young professionals to retirees. Included residents also spanned income demographics, from those that have owned property in Los Altos Hills for generations, to those who expressed their families could not afford to live in the Town had it not been for the availability of affordable ADUs. Three focus groups were held on April 18th, 2022, at 12pm, April 19th, 2022, at 6pm, and April 25th, 2022, at 11am. Hosting the focus group at three (3) different times of the day provided a variety of times to accommodate different schedules. In a diligent effort to include all demographic segments of the Los Altos Hills community, the Housing Element team contacted 10 homeless interest groups, eight (8) housing and policy advocates, six (6) representatives from local faith- based and educational institutions, one (1) Town representative, one (1) affordable housing developer and five (5) homeowners and renters from various income levels. SUBMITTAL TO HCD AND REVISIONS Government Code section 65585 provides the process for local jurisdictions to adopt housing elements and HCD to review. Under the statute, local jurisdictions are required to submit a draft housing element to HCD prior to adoption, receive findings and feedback, and prepare revisions Planning Commission Page 14 Housing Element Update 2023-2031 January 27, 2023 and adopt such revised housing element based on findings describing why such housing element is in substantial compliance with state law. Pursuant to Government Code section 65585, the Town timely submitted its draft Housing Element to HCD for review on October 27, 2022, at least 90 days prior to proposed adoption. Subsequently, in December 2022 Town staff reached out to HCD to obtain initial feedback on the draft element. On December 22, 2022, Town staff met with HCD staff and received initial comments. The Town further revised the draft Housing Element based on such initial feedback to include additional information and analysis to address those comments. On January 23, 2023, the Town published the revisions. Subsequently, the Town received formal comment letter on January 25, 2023 and made further revisions to address all of HCD’s comments. As such, the draft Housing Element is now in substantial compliance with state law and it is ready for review and recommendation/action by the Planning Commission and City Council respectively. Attached to the resolution for adoption (Attachment 1) of the Housing Element are Exhibits A and B, demonstrating how the proposed Housing Element conforms with State law. Exhibit A includes Findings of Substantial Compliance and Exhibit B contains HCD Completeness Checklist. ENVIRONMENTAL REVIEW Upon review, staff’s assessment is that the Housing Element update for the Town of Los Altos Hills is exempt from review under the California Environmental Quality Act (CEQA) pursuant to Section 15061(b)(3) and 15283 of the CEQA Guidelines and Section 65584 of the California Government Code. The Housing Element is a policy document which does not provide entitlements to any specific land use project and does not contain policies that have potential to result in any direct or indirect physical changes to the environment. Any individual development projects would further undergo additional environmental analysis at the time of future entitlements. Relatedly, CEQA does not apply to regional housing needs determinations made by the city pursuant to CEQA Guidelines section 15283, which further illustrates the concept that adoption of the Housing Element as a policy-level document only for such housing needs does not result in any environmental impacts. ATTACHMENTS 1. Attachment 1: Draft Resolution with Exhibit A, Findings of Substantial Compliance; and Exhibit B, HCD Completeness Checklist, and Exhibit C, Draft 2023-2031 Housing Element (also shown below as Attachment 4) 2. HCD Review Letter 3. HCD Comments and Responses Matrix 4. Final Draft 2023-2031 Housing Element Update (available online at https://www.losaltoshills.ca.gov/564/Public-Review-Draft)