CC 05-14-2024 Item No. 1. Housing Element_Staff PresentationCC 05-14-2024
#1
Housing Element
Presentation
City Council
May 14, 2024
6th Cycle Housing Element
Update Adoption
CC 05-14-2024 Item No. 1
Agenda
Housing Element Overview
Outreach Summary
RHNA/Priority Sites
Policies and Strategies
HCD Review and Comments
Environmental Review
Associated GP amendments
Planning Commission Recommendation
Next steps
Housing Element Overview
What is a Housing Element? Why Update it?
What is a Housing Element?
State-mandated Element
of City’s General Plan
Why update it now?
Required to be updated
every 8 years by law
Update by when?
By Jan. 31, 2023 (deadline
passed)
Update it? How?
Study and plan for housing
needs in community
between 2023-2031, across
all income levels
Who certifies compliance?
CA Dept of Housing and
Community Development
(HCD)
HE Contents
Housing Needs
Assessment
Demographic
Trends
Housing
Market Trends
Special Needs
Groups
Constraints to
Housing
Development
Resources and
Sites Inventory
Policies and
Programs
Governmental
and Non-
Governmental
Market Trends
Environmental
Infrastructure
Zoning and
Capacity
ADUs and
Mobile
Homes
Inventory of
Sites
Review of
Previous
Housing Element
Implementation
Identify
2023- 2031
Programs
Assessment of
Fair Housing
Outreach
Fair Housing
Issues
Site Inventory
Analysis
Contributing
Factors
Other updates
Conforming General Plan changes:
Land Use and appendices – Internal consistency
Mobility and appendices – address environmental
assessment/mitigations
Conforming Rezoning – Specific plan, map and text
State law requirements – Health and Safety Element
Other – necessary to implement HE programs (e.g.
Objective design standards for housing
developments)
6th Cycle vs. 5th Cycle
RHNA 4x higher in Cupertino--4,588 vs. 1,064
Few remaining undeveloped sites, reliance on
redevelopment to meet RHNA
62 properties, 36 development sites
70% of properties 50 units/acre or more
New legislation adds requirements in:
Developing policies/programs
Greater accountability to produce housing
Site selection
Less discretion approving housing developments
Affirmatively Furthering Fair Housing (AFFH)
More outreach and inclusion
Noncompliance
What can happen if City does not have a certified
Housing Element?
Loss of local land use and zoning control – Builder’s
Remedy projects
Lawsuits and attorney fees
Ineligibility for grant funding
Financial penalties, court issued fines
Streamlined ministerial approval of projects
Court receivership appointing an agent to bring
City’s Housing Element into compliance
Affirmatively Furthering Fair Housing (AFFH)
AB 686 (2018) defines AFFH as:
“taking meaningful actions, in addition to combating discrimination,
that overcome patterns of segregation and foster inclusive communities
free from barriers that restrict access to opportunity based on protected
characteristics.”
Cupertino - High or Highest Resource for Access to
Opportunities
Housing anywhere in City would regionally AFFH
Must look to accommodate persons who currently do not
reside in City
Meeting RHNA alone does not equate to satisfying AFFH
(HE-1.3.6: Missing Middle Strategy)
Three community meetings focused on AFFH held May-
September 2022
Outreach Summary
Outreach Summary
2021
Jt. Study Sessions
(Apr & May)
Comm. Mtgs (Aug
& Dec)
CC Mtg (Sept)
HC Mtg (Dec)
Jan – Jun
2023
Jul – Dec
2022
CC Mtgs (Aug, Nov)
PC (July)
CEP-SAC mtgs (Jul,
Sep, Oct)
Comm. Mtg (Jul, Sep)
Jan – Jun
2022
PC mtgs (Jan, Feb,
Apr, May, June)
CC mtgs (Mar)
HC mtg (Jun)
CEP-SAC mtgs (Mar,
Apr, May, Jun)
Comm. Mtg (May)
Jan –Mar
2024
CC Mtg (Jan)
1st Draft to HCD (2/3)
Comments from HCD
(5/4)
CC Mtg (Jul)
Comm. Mtgs (Aug, Sep)
3rd Draft to HCD (2/26)
Revised 3rd Draft to
HCD (3/28)
Conditional
Certification letter from
HCD (4/10)
Jul – Dec
2023
2nd Draft to HCD (10/16)
Revised 2nd Draft to HCD (11/30)
Comments from HCD (12/15)
RHNA/Sites Inventory
ABAG RHNA
State-wide Housing Needs
Determination made by HCD
for each region within State
Cupertino in 9
County ABAG region
City’s RHNA ~1% of ABAG
region’s RHNA and ~3.5%
of county RHNA
Income Group Units % of total
Very Low Income
(<50% of AMI)1,193 26.0
Low Income
(50%-80% of AMI)687 15.0
Moderate Income
(80%-120% of AMI)755 16.5
Above Moderate Income
(>120% of AMI)1,953 42.5
Total 4,588 100
Affordable
Units = 2,635
City’s 6th Cycle RHNA
Buffer ~ 35% particularly for lower income levels recommended to ensure city does
not have to update sites inventory before next HE update for “no net loss” purposes.
RHNA + Buffer accommodates over 6,200 units.
Pipeline
State law allows credit for approved projects,
referred to as pipeline
Cupertino allowed ~2,450 units as pipeline
Lower income: 633
Moderate income: 49
Above moderate income: 1,770
Identify sites to accommodate balance of RHNA
plus buffer
Pre-HE Submittal Inventory
Started with all potential sites throughout the City which:
Met HCD size criteria: 0.5 – 10 acres
Outside of fire hazard and geologic hazard zones – more
environmental impacts
Owner interest a factor
Due to recent development approvals, allow:
More housing west of De Anza Blvd & south of 85
Less housing east of De Anza Blvd
Locate housing sites to counteract declining school enrollment
Avoid displacement of existing residents through redevelopment
of residential properties
Policy Framework
State laws: link land use and transportation (AB 32
and SB 375)
Regional plans (Plan Bay Area 2050 and Regional
Transportation Plan) align with state law
AB 2011 (eff. July 1, 2023): Allows Residential
development on Commercial-Office Corridors
regardless of Zoning:
Density and building height varies depending on lot
size and width of transportation corridor
Identifies min. development standards
Ministerial, exempt from CEQA
Current Site selection strategy
With Council direction in July 2023, site selection
strategy adjusted based on:
New State law realities – AB 2011/SB6
Proximity to transportation – AB32/SB375
Aligning with regional plans – PBA2050 & RTP
City’s existing policies – LU-1.1 & CAP
Consultant experience based on likelihood of site
acceptance by HCD
Size of sites – 0.5 acres (min.) to 10 acres (max.)
Development potential of site
Current
Housing
Element
Priority
Housing
Sites
Capacity compared to RHNA
RHNA
Category
2023-2031
RHNA
Pipeline
Capacity
Residential
Site
Capacity
with Rezone
Mixed Use
Site
Capacity
with Rezone
Projected
ADUs
Total
Capacity Surplus
Very Low 1,193
633 833 596 116 2,178 298
Low 687
Moderate 755 49 360 436 57 909 154
Above
Moderate 1,953 1,770 662 695 19 3,166 1,213
Total 4,588 2,452 1,855 1,727 192 6,226 1,638
Programs and Policies
Required Programs and Policies
Programs to provide Adequate Housing Sites
Programs to Assist Lower-Income Housing
Development
Programs to Address Housing Constraints
Programs to Conserve, Improve and Expand
Housing Stock
Programs to Affirmatively Further Fair Housing
Programs to Preserve ”at risk” Units
Programs for ADUs/Second Units
Housing Policy Areas
Programs to provide
Adequate Housing Sites:
Identify sites to
accommodate RHNA
Create new land use
designations to ensure RHNA
can be accommodated
Programs to Assist Lower-
Income Housing
Development:
Support Grant applications;
Provide technical support;
Issue NOFA for BMR
Affordable Housing Funds
Housing Policy Areas (cont.)
Programs to Address Housing
Constraints:
Adopt Objective standards,
Continue fee waivers for
affordable units and/or 100%
affordable projects;
Evaluate Parking standards
Programs to Conserve,Improve
and Expand City Housing Stock:
Create new R4 Zoning District;
Promote options for multi-
generational households &
house sharing;
Continue to implement a BMR
program
Disallow conversion of multi-
family to Single Family homes;
Use CDBG funds for
conservation/ improvements
Housing Policy Areas (cont.)
Programs to Affirmatively Further Fair Housing:
Upzone sites adequately to allow accommodation
of RHNA;
Support teacher housing and ELI projects;
Continue to support the development of ADUs and
adopt "missing middle" housing policies, which
offer opportunities with modest increases in density
(HE Strategy-1.3.6)
Housing Policy Areas (cont.)
Programs to Preserve ”at risk”
Units:
Programs to meet with
affordable housing operators
annually
Programs for ADUs/Second
Units:
Continue to offer streamlined
pre-approved plans;
Evaluate and participate in
local and regional efforts on
ADU programs
HCD Review and Comments
Process with HCD
February 3, 2023: 1st submittal to HCD
May 4, 2023: 16 page letter #1 received
October 16, 2023: 2nd submittal to HCD
Informal meeting with HCD resulted in Revised
2nd draft submitted to HCD on Nov. 30, 2023
December 15, 2023: 5 page letter #2 received
February 26, 2024: 3rd submittal to HCD
Informal meeting with HCD staff resulted in Revised
3rd draft submitted to HCD on March 28, 2023
April 10, 2024: CONDITIONAL COMPLIANCE LETTER
RECEIVED FROM HCD
Revisions to address HCD comments
Second draft (Oct/Nov) – substantial rewrite of first
draft based on HCD comments from May
All analysis (review of prior housing element, fair housing,
needs and constraints analysis) revised
Sites inventory updated based on Council direction and
consultant advice
Existing policies and strategies revised
New policies and strategies added in first draft revised or
replaced/added to address state law, HCD comments, AFFH
Third draft (Feb/Mar) – targeted edits to second
draft based on HCD comments
Related to sites and sites inventory
Refinements to missing middle strategy
Environmental Assessment
Settlement/Environmental Assessment
February 2023: California Housing Defense
Fund/YIMBY Law sue City for noncompliant HE by
adoption deadline
January 2024: Stipulated Judgment entered into
Established schedule to complete HE update in
compliance with State law
Gov’t Code Sec. 65759(a)
CEQA does not apply to actions to bring HE into
compliance with Court Order.
Environmental Issues Analyzed
Aesthetics
Air Quality
Biological Resources
Cultural and Tribal
Cultural Resources
Energy
Geology and Soils
GHG Emissions
Hazards and Hazardous
Materials
Hydrology and Water
Quality
Land Use and Planning
Noise
Population and Housing
Public Services, Parks,
and Recreation
Transportation
Utilities and System
Services
Wildfire
Any significant environmental impacts are avoided, minimized, rectified,
reduced or eliminated, and/or compensated.
The General Plan incorporates policies and strategies to protect,
preserve, and/or enhance environmental resources.
The following topics were evaluated in environmental assessment:
Environmental Assessment Conclusions
EA builds off 2015 General Plan EIR
–Mitigation Measures for air quality, biological resources, hazardous
materials, transportation, and utilities and services systems.
Cupertino Municipal Code Chapter 17.04, Standard Environmental
Protection Requirements
–In 2019, Municipal Code codified 2015 GP EIR mitigation measures as
environmental protection requirements for all construction projects.
2024 General Plan Policies and Strategies
–Policies and strategies updated to reflect current best management
practices to ensure that future development continues to reduce
impacts from construction and operation phases (e.g. Mobility Element)
Environmental Assessment Conclusions
Program-level significant and unavoidable impacts
for air quality, greenhouse gas emissions, and
transportation (vehicle miles traveled).
Possible to have less-than-significant impacts in these
areas for future projects that meet project-level
thresholds.
No additional mitigation measures are available at
this phase of project approval (i.e. adoption of HE
and associated amendments)
Associated General Plan
Amendments
Other General Plan Amendments
Chapter 3, Land Use and Community Design Element
and Appendix A, Land Use Designations:
Text changes to address state law requirements &
Housing Element requirements
Figure changes – reflect density and heights reqd. for
developing Priority Housing Sites
Chapter 5: Text changes to minimize environmental
impacts resulting from development
General Plan Land Use Map – conforming changes
Planning Commission
Recommendation
Planning Commission Recommendation
April 29, Planning Commission recommended adoption
of draft resolution on a 3-2 vote (Sharf and
Madhdhipatla: no) with minor change to remove a site
not allowed as a Priority Housing Site by HCD
Missing middle strategy and parkland dedication fee
study discussed. HCD requirements to address AFFH and
housing constraints
8 members of public spoke – topics included
validity of RHNA numbers,
missing middle strategy and
parking impacts,
specify income restrictions for
BMR AHF Funds for residential
rehabilitation projects,
policies should cover
programs for seniors,
prevailing wage requirements
for development projects, and
questions about
environmental review
Next Steps
Timeline and Next Steps
April 2024
Letter from
HCD – 4/10
HC Study
Session – 4/25
PC rec. – 4/29
Summer 2024
Fall 2024June 2024
First reading – 6/18
May 2024
CC adoption
– 5/14
PC rec. On
zoning – 5/28
Mar 2025
Complete rezoning
Prepare objective
design standards
Adopt objective
design standards
APR submitted
Ignore slides from here on out
HE Overview
What is a Housing Element?
State-mandated Element of City’s General Plan
Why update it now?
Required to be updated every 8 years by law
Update it? How?
Study and plan for housing needs in community
between 2023 & 2031, across all income levels
Update by when?
By Jan. 31, 2023 (deadline passed)
HE Overview
6th Cycle Housing Element update covers
2023-2031 Planning Period
Certification deadline: Jan. 31, 2023 (passed)
Six jurisdictions in Santa Clara County (15
cities/1 county) still do not have compliant
Housing Elements
38 of 109 ABAG jurisdictions not in compliance
58 of 197 SCAG jurisdictions still out of compliance
R1 lots
adjacent to
commercial
could
develop with
R2 standards
~240 lots
R1 corner
lots that
could
develop
with R2
standards
~1,440 lots
R1 lots
adjacent to
commercial
& corner lots
that could
develop with
R2 standards
~1,680 lots
What’s happened so far?
Community meetings – Aug & Dec 2021
AFFH focused meetings:
May 2022 – Unhoused, Veterans & individuals with disabilities
Jul 2022 – Students and Seniors
Sept 2022 – Cash-poor/House rich and workers
Council directs staff to submit Draft HE to HCD – Nov 2022
Draft HE submitted to HCD – Feb 4, 2023
New Consultant approved – Mar 2023
NOP for EIR sent to OPR’s clearinghouse – Apr 2023
EIR scoping meeting – April 18, 2023
Comments received from HCD – May 4, 2023
Public Meetings
Over 30 public meetings since Fall 2021
Joint Study Sessions: HC/PC/CC - April/May 2021 (2
mtgs).
Community meetings:May 2022-Sept 2023, (5mtgs)
City Council: Sept 2021 – July 2023 (9 mtgs)
Housing Commission: Dec 2021, Jun/Jul 2022 (3 mtgs)
Planning Commission: Jan 2022 – Jul 2022 (6 mtgs)
Community Engagement Plan – Strategic Advisory
Committee* – Mar 2022 – Oct 2022 (8 mtgs)
* Two councilmembers, HC Chair and PC Chair
RHNA Buffer
Why do you need a RHNA Buffer?
SB166 (2017): No net loss law
Mandates that jurisdictions must maintain
adequate site inventory to accommodate
remaining unmet RHNA by each income
category at all times
How much is recommended?
~ 25 - 35% particularly for lower income levels to
ensure city does not have to update sites
inventory before next HE update
Land use and Transportation
State laws focus on linking land
use and transportation to align
with AB32 (2006) and SB375
(2008) – Climate Change and
GHG reduction
Regional plans (Plan Bay Area
2050 and Regional
Transportation Plan) align with
state law:
Identifies Heart of the City as
Priority Development Area
Identifies transportation
investment to support
growth to reduce GHG
City’s policies align
AB 2011/ SB 6
SITE DENSITY
Site < one (1) acre 30 du/acre
Site > one (1) acre and Commercial
Corridor right-of-way < 100 feet 40 du/acre
Site > one (1) acre and Commercial
Corridor right-of-way > 100 feet 60 du/acre
Site within one half-mile of Major Transit
Stop (N/A in Cupertino)80 du/acre
AB 2011
Sites
Pipeline Projects
Account for 2,452 units in Draft HE
Likely 1,779 units will be “allowed”at
Vallco (west side only)
Elimination of Hamptons (600 units) from
pipeline
If developed by 2031, City still gets credit
for all built units
Upcoming HE Meetings
April 16: City Council Study Session Overview and
Policy Discussion
April 25: Housing Commission: Study Session
April 29: Planning Commission meeting: PC
recommendation to Council
May 14: City Council meeting Adopt HE, Amend GP
including Environmental Assessment, Rezone Priority
Housing Sites and related Code changes to
implement HE
AB2011
with HCD
size
criteria &
Aug 2022
sites
AB2011
with HCD
size
criteria
with
Housing
Priority
sites
Goals, Policies and Programs
Council Direction July 2023:
In addition to refining site selection
strategy, directed priority for housing
policy areas among the following:
Assist lower income
households
Address constraints
Conserve and
Improve Housing
Stock
Affirmatively Further
Fair Housing
Preserve “at risk”
units
ADUs/Second Units
Santa Clara County 6th RHNA Cycle
Income Group Units % of total
Very Low Income
(<50% of AMI)1,193 26.0
Low Income
(50%-80% of AMI)687 15.0
Moderate Income
(80%-120% of AMI)755 16.5
Above Moderate Income
(>120% of AMI)1,953 42.5
Total 4,588 100
Affordable
Units =
2,635
Cupertino’s 6th Cycle RHNA
Sites -
August
2022
AB2011
with
HCD
size
criteria
Initial HCD comments
Received May 4, 2023
General in nature, but comprehensive
Asks for more analysis in several areas
Some comments do not apply to City (e.g.
manufactured homes/ADUs)
No specific feedback on Sites Inventory,
except pipeline (discussed earlier)
Second Draft HCD comments
Received December 15, 2023
Fewer comments and more specific in
nature
Still asks for more analysis in a few areas,
particularly regarding sites’ development
potential within 6th Cycle timeframe
Some feedback on Sites Inventory, other
than pipeline
Recent informal comments
from HCD
Strengthen Missing Middle Policies for Fair
Housing purposes (Strategy HE 1-3-6)
Provide additional site analysis-Improvement
to Land Value and support for sites where
redevelopment is less certain
Continue to streamline and promote
development of ADUs
Take more proactive approach to ensure
housing is produced
Rezone Sites to Meet the RHNA
Map Detail 1
Map Detail 2
Map Detail 3
Revisions to address HCD comments
Review of Previous Housing Element
More info in implementation of previous actions, including impact on housing for
persons with special needs
Fair Housing Analysis
Expanded discussion on trends, patterns, and data to further fair housing
including displacement risk and fair housing sites analysis
Housing Sites Inventory
Revised site analysis including adding likelihood of development, realistic
capacity, utility providers, small sites analysis, analysis re: ADUs to align with HCD
accepted methodology
Housing Needs Assessment and Constraints
Identified need to comply with State law for several housing types (SROs, shelters)
Expanded discussion regarding permit processing and how current land use
controls are not a constraint and identify constraints such as housing for persons
with disabilities, conversion-risk-estimate, and non-governmental related impacts
Revisions to address HCD comments
Housing Strategies
Revise rezone strategy to ensure compliance with State law and
create new zoning and GP land uses to implement rezone.
(Strategies 1.3.2, 1.3.3)
Added strategies to encourage and facilitate:
Mixed use development (Strategy 1.3.5)
Development of non-vacant sites (Strategy 1.3.4)
Development of affordable housing (Strategy 1.3.4, 1.3.5, 1.3.6,
1.3.7, 1.3.8, 1.3.10, 2.3.1, 2.3.2, 2.3.4, 2.3.6, 2.3.7, 2.3.10, 2.3.11, )
Development on small lots (<0.5 acres) (Strategy 1.3.7)
Development on Surplus Properties and Faith Based-Housing
(Strategy 2.5.6)
Live/Work Units (Strategy 2.3.12)
Revisions to address HCD comments
Housing Strategies
Track Housing Production and complete a mid-term evaluation
on production. (Strategy 1.3.12)
Establish priority processing and granting fee waivers or deferrals
for affordable housing developments. (Strategies 1.3.4, 1.3.5,
1.3.7, 1.3.8, 2.3.1, 2.3.9 2.3.11)
Revise programs to AFFH including adding fair housing metrics,
geographic targeting, actions to promote mobility and increase
housing choices ((Strategies 6.1.1, 6.1.2, 6.1.3 and metrics to all
strategies)
Revised to establish incentives beyond ADU law and monitor
affordability (Strategy 1.3.8).
Study rent stabilization and tenant protection ordinances in
California (Strategy 3.3.6)
Revisions to address HCD comments
Housing Strategies
Added strategies to comply with State law concerning:
Emergency Shelters (Strategy 5.1.1)
Low Barrier Navigation Centers and Supportive Housing (Strategy
5.1.4)
Residential Care Facilities (Strategy 5.1.5)
Manufactured Homes (Strategy 5.1.6)
Density Bonus (Strategy 2.3.8)
Accessory Dwelling units (Strategy 1.3.8)
Added actions to encourage missing middle housing
types (Strategy 1.3.6)
including duplexes, triplexes, courtyard apartments
Allowing corner lots in R1 to develop with R2 standards
Allowing R1 lots that abut property that fronts an arterial or major
collector that is zoned and used for commercial or mixed-use
development, to develop using R2 standards
Revisions to address HCD comments
Housing Strategies
Review and revise development standards (Strategy 1.3.9)
Parking, setbacks, lot coverages, height limits, etc. in the new R-4 and PDA
Explore innovative and family –friendly housing options (Strategy 1.3.10)
Promote housing designs and unit mix to attract multigenerational
households
Research possibility of a Home Sharing program that would help to
match “providers” with spare room(s) with “seekers” who are looking
for affordable places to live. Quantified Objectives
Revised objectives for housing rehabilitation and conservation and to
address fair housing.
Consistency with General Plan
Added a program to review for consistency throughout planning period.
Significant and Unavoidable
The General Plan meets regional goals, objectives, and
best management practices for reducing environmental
impacts.
Program-level significant and unavoidable impacts were
determined for air quality, greenhouse gas emissions,
and transportation (vehicle miles traveled).
Program-level significant and unavoidable impacts are
based on:
Unknown project-specific details of future proposed
development projects
Consistency with regional plans that have yet to be
updated
Human behavior
Direction Pre-HE submittal
More interest in accommodating housing west of
De Anza Blvd and south of Highway 85
Less interest in accommodating housing east of De
Anza Blvd due to recent approvals
Locate housing sites to counteract declining school
enrollment
Avoid displacement of existing residents through
redevelopment of residential properties
Affirmatively Furthering Fair Housing (AFFH)
- Cupertino
City is designated High or Highest Resource
regarding Access to Opportunities
Housing anywhere in City would regionally
Affirmatively Further Fair Housing
City must look to accommodate persons who
currently do not reside here
Meeting RHNA alone does not equate to
satisfying AFFH (Missing Middle Strategy)