Santa Cruz YIMBY advocates for abundant housing at all levels of affordability to meet the needs of a growing population in Santa Cruz County. We support sustainable growth, including along transportation corridors and activity centers and a commitment to lower Vehicle Miles Traveled by housing people near services and jobs.
We submit the following comments on the Santa Cruz County 6th cycle draft Housing Element of November 3, 2023. We appreciate the work of county planning staff on the many changes to the Housing Element over the past months. We have focused these comments on areas highlighted by HCD in the letter dated October 23, 2023.
Affirmatively Furthering Fair Housing
HCD: “Sites Inventory and AFFH: The analysis must explain whether sites are isolated by income group and discuss whether the distribution of sites improves or exacerbates conditions. If sites are isolated or exacerbate conditions, the element should identify further program actions that will be taken to promote inclusive and equitable quality of life throughout the community (e.g., new affordable housing opportunities in higher opportunity areas, housing mobility).”
- The County has added analysis related to Racially Concentrated Areas of Affluence (RCAA) but not substantially planned for more affordable housing in RCAA census tracts.
- The Housing Element HE still plans for 85% of affordable housing in high/highest access to opportunity regions as shown on TCAC/HCD Maps only ~ 5% of affordable housing is planned for racially-concentrated areas of affluence (RCAA).
- At least two census tracts (1208 and 1222.02) are both high/highest resource areas and RCAA, but have only above-moderate units planned. These two census tracts are primarily made up of low density, single family residential homes. Census tract 1222.02 in Aptos includes a grocery store and elementary school.
- Affordable units should be incentivized for these areas, including through missing middle housing.
Sustainability Update/Development standards as constraints
HCD: Land Use Controls “The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types. The analysis should analyze land use controls independently and cumulatively with other land use controls. The analysis should specifically address requirements related to floor area ratio (FAR) and lot coverage limits in the R-UM (Urban Medium) zone. The analysis should address any impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints.”
- We remain concerned about the delayed adoption of the Sustainability Update/LCP. In order for the Housing Element to be substantially compliant by the deadline of December 15, 2023, either the LCP must be approved or the Housing Element must be reworked to reflect the currently approved LCP zoning and General Plan Land Use standards and sites.
- The County has added more to the Appendix HE-D on constraints. Much of the addition focuses on the Sustainability Update, but as noted above, that has not yet been adopted.
- Declaring that there is no constraint to production is not a sufficient analysis; nor is a comparison to other nearby jurisdictions, e.g. from Appendix HE-D:
- “The Zoning Code does not pose an unnecessary constraint to the development of affordable housing.”
- “Parking requirements are low enough to not pose a constraint;” and
- “Residential Development standards, such as building height, parking requirements, floor area ratio (FAR), lot coverage and setbacks, are typical of those applied in other suburban California jurisdictions.”
Processing and Permit Procedures
HCD: Local Processing and Permit Procedures: ”Lastly, the element should analyze the total processing times of developments for potential constraints, as multifamily developments take an unusually long time for final approval (greater than twelve months) and add programs as appropriate to streamline local permit processing and procedures.”
- The County’s development process is summarized in the Constraints section of the Housing Element and has been expanded in this later version of the Housing Element.
- The County has not provided data to substantiate their claims for processing times in Appendix D Constraints. HCD’s Housing Element Dashboard shows the County as “slower” in both the Submitted-Entitled portions of the timeline. (The county appears to have <10 projects in the Entitled-Permitted portion)
- The County should identify the source for the numbers in Appendix H-D (page 44) and commit to showing its compliance with the Permit Streamlining Act by providing up to date statistics on processing times on the website.
HCD: Approval Times: “The element must include analysis of the length of time between receiving approval for a housing development and submittal of an application for building permits. The element must address any hinderance on the development of housing and include programs as appropriate.”
The County does not include any programs to address hindrance related to approvals.