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HomeMy WebLinkAboutSP 203A; Costa do Sol; Specific Plan (SP)IV Qty 4 fcrfeW Hautag ftp-tat A REPORT TO THE PI 1VMM. COMMISSION Item No. P.C. AGENDA OF: JANUARY 3, 1996 Application complete date: July 6, 1995 Project Planner: Jeff Gibson Project Engineer: Mike Shirey SUBJECT: SP 203(AVCT 92-OlfAWUD 92-OKAVSDP 93-04(A) . COSTA DO SOL Request for recommendation of approval of a Negative Declaration, amendment of a Specific Plan, revision of a Tentative Map, amendment of a Planned Development Permit and Site Development Plan to: (1) Add to Specific Plan 203, the Villa Loma and Laurel Tree combined affordable housing projects as potentially available to satisfy the inclusionary housing requirements for residential projects within the specific plan; (2) re-subdivide Condominium Lot No. 115 into 7 single-family lots; (3) redesign the recreational vehicle parking area and the recreational open space lot; and (4) satisfy inclusionary housing requirements through participation in the Villa Loma project, all on property generally located east of Paseo del Norte, north of Camino de las Ondas, and south of Palomar Airport Road, in the PC Zone in Local Facilities Management Zone 20. I. RECOMMENDATION That the Planning Commission ADOPT Planning Commission Resolution Nos. 3862, 3863, 3864, 3865, 3866 RECOMMENDING APPROVAL of the Negative Declaration, SP 203(A), CT 92-01(A), PUD 92-01(A), and SDP 93-04(A), based on the findings and subject to the conditions contained therein. II. INTRODUCTION This application would change the property's approved Tentative Map, Planned Development Permit, and Site Development Plan by replacing 40 residential condominium units in the eastern portion of the project site with 7 single-family lots, redesign the RV storage area and the recreational lot, and provide the required affordable housing at Villa Loma. In addition, the proposal includes a amendment to the Affordable Housing Section of Specific Plan 203. The amendment would establish two potential locations, Villa Loma and Laurel Tree combined affordable housing projects, for satisfaction of inclusionary housing requirements associated with residential projects within the specific plan. The project is consistent with all City codes, policies, and ordinances as well as Specific Plan 203. There are no unresolved project issues associated with this residential subdivision. SP 203(A)/CT 92-01(A)/PUD 92-01(A)/SDP 93-04(A) - COSTA^O SOL JANUARY 3, 1996 PAGE 2 III. PROJECT DESCRIPTION AND BACKGROUND On November 3,1993, the Planning Commission recommended approval of a Tentative Map (CT 92-01), Planned Development Permit (PUD 92-01), Site Development Plan (SDP 93- 04), and Hillside Development Permit (HDP 92-10) to, subdivide, grade, and construct 112 single-family homes and 40 - one, two, and three bedroom condominium units on the gradually sloping lot located east of Paseo del Norte and directly north of Camino de las Ondas. On March 31, 1994 the City Council unanimously approved the project. The property has since been purchased by Greystone Homes Inc., and they are requesting an amendment to the approved project which consists of the following changes: 1. Replacement of 40 condominium units and a small recreational area in the eastern portion of the site with 7 single-family homes on lots ranging in size from 7,067 to 16,692 square feet; 2. Redesign of the RV storage area and open space recreational lot; and 3. Incorporation of a provision to allow the project's 21 required affordable housing units to be located at an off-site location (Villa Loma). The parcel totals 29.2 gross acres and has been recently graded according to the original approved project (CT 92-01). It is located in the Coastal Zone, the Planned Community Zone (PC), and has a General Plan Land Use designation of Residential Medium (RM). There would be a centrally located active recreational facility containing a pool, spa, basketball court, and a children's play area, in addition to a recreational vehicle storage area to serve the entire project. A portion of the approved project's 40 condominium units were designated for on-site affordable housing. The developer is now proposing to eliminate all of the condominium units and provide the project's required affordable housing units through the purchase of Affordable Housing Credits in the already approved and constructed Villa Loma affordable housing project located along El Camino Real. Villa Loma currently has 184 Affordable Housing Credits available for purchase by developers in the Southwest Quadrant. This request triggers the requirement to amend the project's Site Development Plan and Specific Plan 203. The staff Combined Project Review Committee, per City Council Policy 57, evaluated the request to purchase credits, determined that the project met the appropriate policy criteria, and made the recommendation that the request be approved by the Housing Commission. On November 9, 1995 the Housing Commission reviewed the proposal to purchase credits in Villa Loma, and recommended denial of that proposal to the City Council. Recently adopted City Council Policy 58 requires that the Planning Commission review and recommend approval of any requests to purchase credits in Villa Loma, therefore, the request is being processed with this application. In addition, on November 15, 1995, the Planning Commission reviewed and approved a request for a minor amendment to the project's Planned Development Permit (PUD 92- SP 203(A)/CT 92-01(A)TOD 92-01(A)/SDP 93-04(A) - COSTATX) SOL JANUARY 3, 1996 PAGE 3 02(B)) which consisted of the following changes to the single-family portion of the project: 1. A change to the approved single-family floorplans; and. 2. A change to the approved single-family architectural elevations. The approved floorplans and building elevations consist of one and two-story, single-family homes ranging in size from 1,767 square feet to 2,546 square feet, with two and three-car attached garages. The architecture is contemporary with tile roofs, and stucco exteriors. The homes on the seven (7) new single-family lots would have the same floor plans and architecture as approved by the Planning Commission on November 15th. The proposed project is subject to the following adopted land use plans and regulations: A. Carlsbad General Plan; B. Specific Plan 203; C. Carlsbad Municipal Code, Title 21; . 1. Chapter 21.45, Planned Development; 2. Chapter 21.53, Section 21.53.120 - Site Development Plan - "Affordable Housing", and Chapter 21.85, Inclusionary Housing Ordinance; D. City Council Policy for Small Lot Single Family Homes; E. Title 20, Subdivision Ordinance; F. Mello II Segment of the Local Coastal Program; G. Growth Management (Local Facilities Management Plan Zone 20). IV. ANALYSIS The staffs recommendation of approval for this project was developed by analyzing the project's consistency with the applicable State and local policies, regulations, and standards. The following analysis section discusses compliance with these requirements in the following format: 1. Table depicting consistency or compliance with regulations and standards; and, 2. Discussion of project specific planning issues. SP 203(A)/CT 92-01(A) JANUARY 3, 1996 PAGE 4 __ JrTJD 92-01(A)/SDP 93-04(A) - COSTATXD SOL A. CARLSBAD GENERAL PLAN The proposed project is consistent with the policies and programs of the General Plan. The table below indicates how the project complies with Elements of the General Plan which are particularly relevant to this proposal. GP ELEMENT Land Use Housing Open Space Noise Circulation Parks & Rec. Public Safety DISCUSSION Proposed residential density of 4.14 du/net acre is consistent with GP designation of RM 4-8 du/net acre and growth control point of 6 du/net acre. The project would be compatible in intensity, architecture, and scale with surrounding residential development. As required in an Affordable Housing Agreement, the project would provide 21 dus as affordable to lower income households in an approved and constructed offsite combined affordable housing project (Villa Loma). 1. Constrained lands are protected in a .62 acre open space lot; and 2. City Wide Trail Link No. 37 is aligned along the west side of the project. Noise Study indicates no traffic noise impacts from 1-5 and Paseo Del Norte. Required roadway improvements, including the local street leading to the 7 single-family lots as shown on the tentative map. Proposed project is required to pay park-in-lieu fees. Proposed project is required to provide sidewalks, street lights, and fire hydrants, as shown on the tentative map, or included as conditions of approval. B. SPECIFIC PLAN 203 The proposal to replace the approved residential condominium units on Lot No. 115 with 7 single-family lots does not affect the project's compliance with Specific Plan 203. The proposed development still complies with the specific plan since the plan implements the General Plan which allows the small lot single-family land use in the Residential Medium (RM) designation. Small lot single-family development is consistent with the remainder of the approved project which also includes 112 single-family lots. The developer is also requesting that the project's affordable housing requirements be satisfied at the Villa Loma combined inclusionary housing project located on El Camino Real in the Southwest Quadrant. This request requires an amendment to the Affordable SP 203(A)/CT 92-01(A)/PUD 92-01(A)/SDP 93-04(A) - COST>o SOL JANUARY 3, 1996 PAGES Housing Section of Specific Plan 203. The amendment (SP 203(A)) would establish two potential locations, Villa Loma and Laurel Tree, for satisfaction of inclusionary housing requirements associated with residential projects within Specific Plan 203. Villa Loma and Laurel Tree are both located outside of the Specific Plan boundaries. The amendment brings Specific Plan 203 and the project into compliance with the Inclusionary Housing Ordinance, Section 21.85.070(6). This ordinance requires that a specific plan designate sites for the location of inclusionary housing units, including any off-site inclusionary projects, which would include Villa Loma and Laurel Tree. A project's participation in either of these two off-site combined inclusionary housing projects would be subject to an Affordable Housing Agreement and final approval by the City Council. C. CARLSBAD MUNICIPAL CODE, TITLE 21: 1. Planned Development Ordinance, Chapter 21.45: Specific Plan 203 and the Planned Community Zone (PC) both designate Chapter 21.45 as the implementing ordinance for the property. The proposed amendments to the Planned Development Permit comply with the Planned Development Ordinance as follows: a. The local cul-de-sac street serving the 7 single-family lots is curved and would have curb, gutter, and sidewalks on both sides, and have 36 feet of paving. This exceeds the 30 foot minimum private street width standard. The local street would be constructed to full public street width standards and have underground utilities. These public street improvements would be adequate to serve the vehicular traffic demand of 17 Average Daily Trips generated by this portion of the project. b. The amended project would provide a mixture of one and two-story homes which have varied roof lines, and a variety of front building elevations and front yard setback. c. Adequate recreational vehicle storage space would be provided in one area and be sufficiently screened from the public right-of-way and surrounding properties with fencing and landscaping. d. The single-family homes would have two and three-car garages which would meet the parking and storage requirements, and guest parking would be provided on both sides of the streets. e. A 10 foot landscaping setback would be provided adjacent to Hidden Valley Road and Camino de las Ondas. In addition, a six foot high masonry wall in conjunction with heavy landscaping would be provided along the northern property line to buffer the project from Poinsettia Community Park to the north. The community park also contains a 20 to 25 foot landscaped setback adjacent to the common property between the two land uses. SP 203(A)/CT 92-01(A) JANUARY 3, 1996 PAGE 6 \/ttD 92-01(A)/SDP 93-04(A) -COSTJTOO SOL f. The proposed single-family residential land use is similar in height, architecture, and building materials to the multi-family residential development to the south. In addition, the adjacent property to the east is planned for residential development, therefore, the proposed small lot single- family development would be compatible with the surrounding neighborhood. g. The project complies with the standards of the Planned Development Ordinance as follows: Private Street & Driveway Width Lot Size Building Separation Street Setback Parking: Resident: RV Storage Storage Space REQUIRED 30 Feet 3,500 sq. ft. 10ft. 10 to 20 Feet 2 Covered Spaces per Home 2,380 sq. ft. 480 cubic Feet Per Unit PROPOSED 30 to 36 Feet of Paving 7,067 - 16,692 sq. ft. 20 to 60 ft. 20 to 59 Feet 7 - 2 or 3 Car Garages 13,575 sq. ft. 2 and 3 Car Garages Recreational Space A. Common B. Private 11,900 sq. ft. 11,900 sq. ft. 17,971 sq. ft. 53 lots with 15 ft. X 15 ft. Rear Yards 2. Site Development Plan - "Affordable Housing", Chapter 21.53, and Inclusionary Housing Ordinance, Chapter 21.85: The developer is proposing to provide the project's required affordable housing units through the purchase of Affordable Housing Credits in Villa Loma. There are currently 184 Affordable Housing Credits in Villa Loma available for purchase by developers in the Southwest Quadrant. This entire project would have an inclusionary housing requirement of 21 dwelling units which leaves a balance of 163 credits in Villa Loma. Recently adopted City Council Policies No. 57 and 58 require that a staff Combined Project Review Committee evaluate requests to purchase credits and that the Planning Commission and the Housing Commission make a recommendation to the City Council on the purchase/sale of any Affordable Housing Credits in Villa Loma. The Inclusionary Housing Ordinance designates the City Council as the final decision-maker on this matter and it is their exclusive prerogative SP 203(A)/CT 92-01(A)OTD 92-01(A)/SDP 93-04(A) - COSTx) SOL JANUARY 3, 19% PAGE? to determine whether or not it is in the public interest to allow the project to participate in a combined project such as Villa Loma. The staff Combined Project Review Committee evaluated the request to purchase credits, determined that the project met the appropriate policy criteria, and made the recommendation that the request to purchase credits be approved. In summary the committee stated that, "Consensus was reached that, while the feasibility argument regarding Costa Do Sol on-site proposal is difficult to validate, the advantages of using existing "excess units" in a quality project supports the request to buy credits. The purchase of credits also recovers City investment in the Villa Loma project as anticipated in the financing plan". The Housing and Redevelopment Department recommended approval of the credit purchase request to the Housing Commission, based on the Combined Project Committee's findings. On November 9,1995 the Housing Commission recommended denial of this project's request to purchase credits in Villa Loma based on the desire to see the affordable units constructed on-site as part of the approved "for-sale" condominium project located on Lot 115 (CT 92-01). City Council Policy No. 58 also requires that the Planning Commission review and make a recommendation to the City Council on requests to purchase credits, and if applicable, place appropriate conditions on the project to implement the credit purchase. The staff Combined Project Review Committee's recommendation/worksheet and a copy of City Council Policy No. 57 and 58 are attached to the staff report. Also based on the findings and recommendations of the Combined Project Review Committee, the Planning Department is recommending that the Planning Commission recommend approval of the request to purchase credits in Villa Loma. To reflect the proposed change from affordable condominium units located on-site to the purchase of Affordable Housing Credits in Villa Loma, the project's Site Development Plan (SDP 93-04) must be amended. This amendment includes a new affordable housing condition in Site Development Plan Resolution No. 3865 in order to implement the Affordable Housing Credit purchase. When a project is approved with the Credit purchase condition, a reservation of the Credits is made for the project. D. CITY COUNCIL POLICY FOR SMALL LOT SINGLE FAMILY HOMES: This City Council policy provides guidelines to encourage the quality development of small- lot (less than 7500 sq. ft.) single-family projects. The intent of the guidelines is to ensure that the homes have building articulation on all four sides and will not appear as "row" housing. They are primarily designed to apply to projects where there is a predominance of two-story units. The project complies with these guidelines as illustrated on Exhibit "A"- "U", dated January 3, 1996. The various homes contain one-story roof elements, proposed side yard setbacks equal or exceed seven feet, structures would be separated by at least 18 SP 203(A)/CT 92-01(A)/PUD 92-01(A)/SDP 93-04(A) - COSTA DO SOL JANUARY 3, 1996 PAGE 8 feet, the homes would have offsetting building planes on all four sides, and all have varying roof elements. E. SUBDIVISION ORDINANCE, TITLE 20: The proposed resubdivision of Condominium Lot No. 115 into 7 single-family lots would comply with the requirements of the Subdivision Ordinance, Title 20 as follows: 1. Full public street improvements would be provided on the local cul-de-sac street leading to the 7 single-family lots, and along the Hidden Valley Road and Camino de las Ondas street frontages. These improvements would include curb, gutter, sidewalks, and underground utilities; 2. The residential lots would meet the 35 to 45 foot lot frontage requirement. The residential development complies with all city policies and standards, including yard setbacks and building height, without the need for variances from development standards; 3. Adequate sight distance for vehicles would be provided at the intersection of the proposed local cul-de-sac street and Hidden Valley Road; 4. The proposed change from 40 multi-family condominium units to 7 single-family units reduces the project's Average Daily Trips, and results in less demand on the surrounding traffic circulation system. The local cul-de-sac street leading to the 7 single-family lots would have 36 feet of paving and connect to Hidden Valley Road which is a non-loaded collector street. The proposed street system is adequate to handle the project's pedestrian and vehicular traffic and accommodate emergency vehicles; 5. The 7 single-family lots would gravity sewer south into the existing sewer system located in Camino de las Ondas which leads to the North Batiquitos Sewer Pump Station. The reduction of dwelling units from 40 to 7 also lessens the demand on the existing sewer system; 6. Adequate drainage facilities would also be provided. The lots would drain into the cul-de-sac street which drains into Hidden Valley Road, and then north into the existing drainage system that flows towards Batiquitos Lagoon. The drainage requirements of Specific Plan 203, City ordinances, and Mello II have been considered and appropriate drainage facilities have been designed and would be secured. In addition to City Engineering Standards and compliance with the City's Master Drainage Plan, National Pollution Discharge Elimination System (NPDES) standards will be satisfied to prevent any discharge violations; 7. The existing graded building pad for Lot No. 115 is adequate to accommodate the single-family homes and RV storage area without significant additional grading; SP 203(A)/CT 92-01(A), JANUARY 3, 1996 PAGE 9 iWD 92-01(A)/SDP 93-04(A) - COSTTTOO SOL 8. The design of the subdivision provides, to the extent feasible, for future passive or natural heating or cooling opportunities in the subdivision, in that primary building orientation, including the placement and separation of the homes, in combination with the proposed variety of floor plans and the dominant wind/solar radiation patterns, will allow utilization of natural heating and cooling opportunities; and, 9. The exactions imposed on the Developer are to mitigate impacts caused by or reasonably related to the project, and the extent and the degree of the exaction is in rough proportionality to the impact caused by the project. These exactions include public facility and circulation impact fees, and street frontage, sewer, and drainage improvements to meet the demand created by the subdivision. F. MELLO II SEGMENT OF THE LOCAL COASTAL PROGRAM: The proposal to replace the approved residential condominium units on Lot No. 115 with 7 single-family lots does not affect the project's compliance with Mello II. The original project, CT 92-01, has a valid Coastal Development Permit issued by the Coastal Commission and Lot No. 115 has already been graded. There would be no significant changes to the approved drainage facilities, and erosion control and landscaping has been provided as part of the grading for the original project. The proposed change from larger scale multi-family residential structures to smaller scale single-family homes further reduces potential visual impacts when the project is viewed from the public roadways, therefore, the changes are consistent with the Mello II Segment of the Local Coastal Program. G. GROWTH MANAGEMENT: The proposed project is located within Local Facilities Management Plan Zone 20 in the Southwest Quadrant. The project's total dwelling units would be reduced by 33 units and result in less impact on public facilities. The impacts on public facilities created by the project and compliance with the adopted performance standards are summarized as follows: FACILITY City Administration Library Waste Water Treatment Parks Drainage Circulation Fire IMPACTS 413.7 sq. ft. 220.6 sq. ft. 120 EDU .83 ACRES BASIN 3 1,190 ADT Station # 4 COMPLIANCE WITH STANDARDS Yes Yes Yes Yes Yes Yes Yes 203(A)/CT 92-01(A^lSP JANUARY 3, 1996 PAGE 10 'UD 92-01(A)/SDP 93-04(A) - COSTA DO SOLTA1 FACILITY Open Space Schools Sewer Collection System Water Distribution System IMPACTS 4.3 ACRES CUSD 120 EDU 26,400 GPD COMPLIANCE WITH STANDARDS Yes Yes Yes Yes V. The project is 53.3 dwelling units below the Growth Management Dwelling unit allowance of 17232 dwelling units for the property. ENVIRONMENTAL REVIEW The project site is located within the boundaries of Specific Plan 203 which covers the 640 acre Zone 20 planning area. The direct, indirect, and cumulative environmental impacts resulting from the future residential development and buildout of Specific Plan 203 have been discussed and evaluated in the certified Final Environmental Impact Report (EIR 90- 03) for the plan. Additional project level studies for the original Tentative Map (CT 92-01) were conducted, including a geotechnical/soils investigation, biological analysis, traffic study, archaeology evaluation, sewer study, and a drainage study. These studies provided more focused and detailed project level analysis and indicated that additional environmental impacts beyond what was analyzed in Final EIR 90-03 would not result from development of the property. The requested changes in the Tentative Map (CT 92-01(A)), Planned Development Permit (PUD 92-01(A)), and Site Development Plan (93-04(A)), including the reduction in the number of total dwelling units from 152 to 119 units, would not create any additional environmental impacts that have not otherwise been evaluated in the Final EIR that covers the property. The reduction in the total number of dwelling units further reduces any potential visual, air quality, traffic, public service, and resource impacts that may result from implementation of the project. Since a Final EIR was certified for Specific Plan 203 and the requested amendments to CT 92-01 are consistent with the plan, the CEQA Guidelines under Section 15182, "Residential Projects Pursuant to a Specific Plan", states that if a public agency has prepared an EIR on a specific plan after January 1, 1980, no EIR or Negative Declaration need be prepared for a residential project undertaken pursuant to and in conformity to that specific plan. Additional environmental review for the minor amendment to the Affordable Housing Section of Specific Plan 203 was conducted, and based on an Environmental Impact Assessment, die Planning Director has determined that no significant environmental impact will result. Subsequently a Negative Declaration was issued for the project, dated September 5,1995. The designation of Villa Loma and Laurel Tree as combined affordable SP 203(A)/CT 92-01(A)TOD 92-01(A)/SDP 93-04(A) - COSTA DO SOL JANUARY 3, 1996 PAGE 11 housing projects as potentially available to satisfy inclusionaiy housing requirements for residential projects within Specific Plan 203 is consistent with the Inclusionaiy Housing Ordinance. In addition, there is no physical development involved with the affordable housing designations, therefore, the minor amendment does not create any environmental impacts. CEQA compliance and all environmental impacts associated with the physical development of the two combined affordable housing projects has already been evaluated and considered during the project approval process. Laurel Tree has been approved by the City Council and Villa Loma is partially constructed. ATTACHMENTS 1. Planning Commission Resolution No. 3862 2. Planning Commission Resolution No. 3863 3. Planning Commission Resolution No. 3864 4. Planning Commission Resolution No. 3865 5. Planning Commission Resolution No. 3866 6. Location Map 7. Background Data Sheet 8. Local Facilities Impact Assessment Form 9. Disclosure Form 10. Council Policy No. 57 11. Council Policy No. 58 12. Project Review Committee Results, dated October 31, 1995 13. Full Size Fjdiibits "AH-"U", dated, January 3, 1996. JG:kr RALOMAR AWORT RD CAMMO DE LAS OMMS COSTA DO SOL CT 92-01 (A)/PUD 92-01 (A)/ SDP 93-04(A)/SP 203(A) BACKGROUND DATA SHEET CASE NO: CT 92-01(AWUD 92-OKAVSDP 93-04(AVSP 203(A) CASE NAME: Costa Do Sol APPLICANT: Grevstone Homes Inc. REQUEST AND LOCATION: 7 single-family homes LEGAL DESCRIPTION: Parcel 2 of Map 6136. City of Carlsbad, filed and recorded San Diego County Recorder's office. July 6. 1977 APN: 214-140-40 Acres 29.2 Proposed No. of Lots/Units 119 Lots GENERAL PLAN AND ZONING Land Use Designation Residential Medium Density Allowed 6 du/acre Density Proposed 4.14 Existing Zone PC Proposed Zone N/A Surrounding Zoning and Land Use: (See attached for information on Carlsbad's Zoning Requirements) Zoning Land Use Site PC Vacant North PC/CUP Community Park Vacant South RD-M Multi-Family East RD-M-Q Vacant West PC Multi-Family PUBLIC FACILITIES School District Carlsbad Water District Carlsbad Sewer District Carlsbad Equivalent Dwelling Units (Sewer Capacity) 120 EDU Public Facilities Fee Agreement, dated April 28. 1995 ENVIRONMENTAL IMPACT ASSESSMENT Negative Declaration, issued N/A Certified Environmental Impact Report, dated Final EIR 90-03. September 14. 1993 Other, N/A JGJcc CITY OF CARLSBAD GROWTH MANAGEMENT PROGRAM LOCAL FACILITIES IMPACTS ASSESSMENT FORM (To be Submitted with Development Application) PROJECT IDENTITY AND IMPACT ASSESSMENT: FILE NAME AND NO: COSTA DO SOL - CT 92-01(A)/PUD 92-01(A)/SDP 93-04(A)/SP 203(A) LOCAL FACILITY MANAGEMENT ZONE: JO GENERAL PLAN: RM ZONING: PC DEVELOPER'S NAME: GREYSTQNE HOMES INC. ADDRESS: 495 EAST RINCON.SUITE 115. CORONA. CA 91719 PHONE NO.: J714) 273-9494 ASSESSOR'S PARCEL NO: 214-140-40 QUANTITY OF LAND USE/DEVELOPMENT (AC., SQ. FT., DU): 29.2 GROSS ACRES/119 ESTIMATED COMPLETION DATE: N/A A. City Administrative Facilities: Demand in Square Footage = 413.7 B. Library: Demand in Square Footage = 220.6 C. Wastewater Treatment Capacity (Calculate with J. Sewer) N/A D. Park: Demand in Acreage = 0.83 E. Drainage: Demand in CFS = N/A Identify Drainage Basin = N/A (Identify master plan facilities on site plan) F. Circulation: Demand in ADTs = 1190 (Identify Trip Distribution on site plan) G. Fire: Served by Fire Station No. = NO. 4 H. Open Space: Acreage Provided - 4.3 I. Schools: YES (Demands to be determined by staff) J. Sewer: Demand in EDUs - 120 Identify Sub Basin - N/A (Identify trunk line(s) impacted on site plan) K. Water: Demand in GPD - 26.400 L. The project is 53.3 units below the Growth Management Dwelling unit allowance. JGkc of Carlsbad Rlainning Department DISCLOSURE STATEMENT APPLICANTS STATEMENT Of DISCLOSURE OF CERTAIN OWNERSHIP INTEREST ON ALL APPLICATIONS WHICH WILL REQUIREDISCRETIONARY ACTION ON THE PART of THE cmr COUNCX. OR ANY APPOINTED BOARD. COMMISSION OR COMMITTEE. (Pl««a« Prim) *•-.. -. - -J The following information must be disclosed: 1 Applicant APR 2 8 1235 List the names and addresses of all persons having a financial interest fn the application. 9/7/9 2. Owner List the names and addresses of all persons having any ownership interest in the property involved. AS. 3. If any person identified pursuant to (1) or (2) above is a corporation or partnership, list the names and addresses of ail individuals owning more than 10% of the shares in the corporation or owning any partnership interest in the partnership. 4.If any person identified pursuant to (1) or (2) above is a non-profit organization or a trust, list the names and addresses of any person serving as officer or director of the non-profit organization or as trustee or beneficiary of the trust FRM0001 12/91 2O75 Las Palmas Oriv« • Carlsbad, California 92OO9-1576 • (619) 438-1161 Disclosure Statement Page 2 5. Have you had more than $250 worth of business transacted with any member of City staff, Boards, Commissions, Committees and Council within the past twelve months? 'es No j/_ If yes, please indicate person(s)Yes P«r»cn « defined at: 'Any individual, firm. copartnereNp, joint venture, mormon, •oclal club, fraternal organization, corporation. ertate, truat receive syndicate, fti* and any other county, city and county, city municipality, diatriet or other political uibdMeion, or any other group or combination acting w unit' (NOTE: Attach additional pagM aa n«c«ss«ry.) Signature of Owner/date Print or type name of owner /x^ applicant/date Print or type name of applicant FRM0001 12/91 CITY OF CARLSBAD COUNCIL POLICY STATEMENT Policy No. 57. Date Issued Effective Date Cancellation Date _ Supersedes No. General Subject: Specific Subject: AFFORDABLE HOUSING Off-site and Combined Inclusionary Housing Projects Copies to: City Council, City Manager, City Attorney, Department and Division Heads, Employee Bulletin Boards, Press, File. BACKGROUND The City's Inclusionary Housing Ordinance (CMC Chapter 21.85) establishes certain requirements under which residential developers must provide housing that is affordable to lower-income households as a condition of project approval and permit issuance. The Ordinance provides that inclusionary units "should be built on-site and, wherever reasonably possible, be distributed throughout the project site." The Ordinance also provides that "circumstances may arise... in which the public interest would be served by allowing some or all of the inclusionary units associated with one project site to be produced and operated at an alternative site or sites." This alternative is described as a "Combined Inclusionary Housing Project" or "Combined Project". The Ordinance, hi addressing Combined Projects, states that "it is the exclusive prerogative of the final decision making authority of the City to determine whether or not it is hi the public interest to authorize the residential sites to form a Combined Inclusionary Housing Project." PURPOSE It is the purpose of this policy to establish the criteria which will be utilized hi order to make the necessary finding that off-site satisfaction of an inclusionary housing requirement, when proposed through a Combined Project, is in the public interest. POLICY The following criteria will be applied in order to make the necessary public interest finding. Each criteria is defined in terms of specific questions which, when affirmatively answered, would support an off-site option: Page 1 of 4 Policy No. 57 CITY OF CARLSBAD Date Issued Effective Date COUNCIL POLICY STATEMENT Cancellation Date Supersedes No. _ General Subject: AFFORDABLE HOUSING Specific Subject: Off-site and Combined Inclusionary Housing Projects Copies to: City Council, City Manager, City Attorney, Department and Division Heads, Employee Bulletin Boards, Press, File. 1. Feasibility of the On-site Proposal. > Are there significant feasibility issues due to factors such as project size, site constraints, and competition from multiple projects that make an on-site option impractical? >• Will an affordable housing product be difficult to integrate into the proposed market development because of significant price and product type disparity? >• Does the on-site development entity lack the capacity to deliver the proposed affordable housing on-site?. 2. Relative Advantages/Disadvantages of the Off-site Proposal >• Does the off-site option offer greater feasibility and cost effectiveness than the on-site alternative, particularly regarding potential local public assistance and when applying the City's Affordable Housing Financial Assistance Policy. > Does the off-site proposal have location advantages over the on-site alternative, such as proximity to jobs, schools, transportation, services; less impact on other existing developments, etc.? * Does the off-site option offer a development entity with the capacity to deliver the proposed project? * Does the off-site option satisfy multiple developer obligations that would be difficult to satisfy with multiple projects? Page 2 of 4 CITY OF CARLSBAD COUNCIL POLICY STATEMENT Policy No. 57 Date Issued Effective Date Cancellation Date _ Supersedes No. General Subject: Specific Subject: AFFORDABLE HOUSING Off-site and Combined Inclusionary Housing Projects Copies to: City Council, City Manager, City Attorney, Department and Division Heads, Employee Bulletin Boards, Press, File. 3. Advancing Housing Goals »• Does the off-site proposal advance and/or support City housing goals and policies as expressed in the Housing Element, CHAS and Inclusionary Housing Ordinance? It is likely that off-site proposals will involve "mixed" results with the application of the above criteria. The "public interest" finding shall be made when a Combined Project Review Committee made up of the City Manager, City Attorney, Community Development Director, Financial Management Director, Planning Director, Housing & Redevelopment Director, and the Mayor (ex-officio), reaches consensus that a proposal substantially and affirmatively satisfies the above criteria and that this conclusion can be appropriately documented through the use of a Combined/Off-site Project Evaluation Assessment Worksheet. (Attachment 1). PROCEDURE 1. Projects with an inclusionary housing obligation will be processed according to the requirements of the Inclusionary Housing Ordinance. 2. Project approvals must be conditioned with the option to propose an off-site method (i.e., Combined Project) of satisfying the inclusionary obligation. A project proposing an off-site option may or may not also propose an on-site option. 3. Prior to final map or issuance of building permits, applicants must submit an Affordable Housing Agreement as described in the Inclusionary Housing Ordinance which specifically describes any off- site proposal. 4. Off-site proposals in the form of a draft Affordable Housing Agreement will be reviewed by the Combined Project Review Committee and it will be determined if the necessary findings can be made by staff. Page 3 of 4 CITY OF CARLSBAD COUNCIL POLICY STATEMENT Policy No. 57_ Date Issued Effective Date Cancellation Date _ Supersedes No. General Subject: Specific Subject: AFFORDABLE HOUSING Off-site and Combined Inclusionary Housing Projects Copies to: City Council, City Manager, City Attorney, Department and Division Heads, Employee Bulletin Boards, Press, File. 5. Staffs findings and recommendation, including the Combined/Off-site Project Assessment Worksheet, will accompany the Affordable Housing Agreement to the Housing Commission for action. 6. Prior to final map or issuance of building permits, the proposed Affordable Housing Agreement will be considered by City Council along with the recommendation of staff and Housing Commission. 7. .City Council will be the final decision making authority in determining whether an off-site proposal is in the public interest and permitting this option. Page 4 of 4 \NOCOFF-SITE ANJ1COMBINED INCLUSIONARY HOUSli ASSESSMENT WORKSHEET ROJECT BACKGROUND 1 . Off-site or Combined Project Name: 2. Applicant Name and Address: 3. Description of Project with Inclusionary Housing Obligation: 4. Proposed On-site Project Description (if any): 5. Proposed Off-site Project Description: 6. Description of On-site Project Constraints: SUMMARY OF ASSESSMENT CRITERIA ASSESSMENT CRITERIA 1 . Feasibility of the On-site Prooosal. a. Are there significant feasibility issues due to factors such as project size, site constraints, and competition from multiple projects that make an on-site option impractical? Brief Narrative: b. Will an affordable, housing product be difficult to integrate into the proposed market development because of significant price and product type disparity? Brief Narrative: c. Does the on-site development entity lack the capacity to deliver the proposed affordable housing on-site? Brief Narrative: ASSESSMENT CONCLUSION (Check appropriate box) DOES NOT SUPPORT SUPPORTS OFF-SITE OFF-srre PROPOSAL INCONCLUSIVE PROPOSAL ATTACHMENT "1" TO COUNCIL POLICY STATEMENT NO. 57 ^JMMARYOF ASSESSMENT CRTTERIA 2. Relative Advantaqes/Disadvantaaes of the Off- site Proposal. a. Does the off-site option offer greater feasibility and cost effectiveness than the on-site alternative, particularly regarding potential local public assistance and when applying the City's Affordable Housing Financial Assistance Policy? Brief Narrative: b. Does the off-site proposal have location advantages over the on-site alternative, such as proximity to jobs, schools, transportation, services; less impact on other existing developments, etc.? Brief Narrative: c. Does the off-site option offer a development entity with the capacity to deliver the proposed project? Brief Narrative: d. Does the off-site option satisfy multiple developer obligations that would be difficult to satisfy with multiple projects? Brief Narrative: 3. Advancing Housing Goals a. Does the off-site proposal advance and/or support City housing goals and policies expressed in the Housing Element, CHAS and Inclusionary Housing Ordinance? Brief Narrative: ASSESSMENT CRITER^ ASSESSMENT CONCLUSION (Check appropriate box) DOES NOT SUPPORT OFF-SITE PROPOSAL INCONCLUSIVE SUPPORTS OFF-S/7E PROPOSAL Page 1 of 4 CITY OF CARLSBAD COUNCIL POLICY STATEMENT Policy No. 58 Date Issued September 12. 1995 Effective Date Sept. 12. 1995 Cancellation Date Supersedes No. General Subject:AFFORDABLE HOUSING Specific Subject: Sale of Affordable Housing Credits Copies to: City Council, City Manager, City Attorney, Department and Division Heads, Employee Bulletin Boards, Press, File. PURPOSE To establish a policy to be followed by City Council and City staff in selling Affordable Housing Credits, controlled by the City, to developers who will use the Credits to satisfy obligations to provide affordable housing pursuant to the City's Inclusionary Housing Ordinance (CMC Chapter 21.85). BACKGROUND In the development of the 344-unit affordable housing project known as Villa Loma in the Southwest Quadrant of the City, the developers and the City created a project which may be treated as a Combined Project as defined in the City's Inclusionary Housing Ordinance. With City Council approval, Combined Projects allow "some or all of the inclusionary units associated with one residential project site to be produced and operated at an alternative site". The "alternative site" becomes a Combined Project. Villa Loma was conceived and developed with City participation based on the creation of 184 excess affordable housing units which would be available to satisfy other developers' inclusionary housing obligations thus making it a potential Combined Project. City financial participation in the project was also based on the concept of recovering costs through the sale of the excess units. Furthermore, Villa Loma was structured to give the City control of these units (Affordable Housing Credits or "Credits") and their sale to potential Combined Project participants. Therefore, it is necessary to establish a policy to guide the City in the effective implementation of these Affordable Housing Credit sales transactions. POLICY Two basic factors will be considered in a Credit sale transaction - the financial aspect, which is the Credit pricing — this determines cost to a purchaser and revenue to the City; and the affordable housing aspect, which is the use of this mechanism to satisfy a developer's obligation under the Inclusionary Housing Ordinance. Based on these considerations, the following will guide Credit sales: Page 2 of 4 CITY OF CARLSBAD COUNCIL POLICY STATEMENT Sept. 12. 1995 Policy No. 58 Date Issued Effective Date Sept. 12. 1995 Cancellation Date Supersedes No. General Subject:AFFORDABLE HOUSING Specific Subject: Sale of Affordable Housing Credits Copies to: City Council, City Manager, City Attorney, Department and Division Heads, Employee Bulletin Boards, Press, File. Price. The Credit price will be determined according to the following formula which divides the local financial contribution provided to the Villa Loma project by the total number of Credits available. The local financial contribution consists of all City financial assistance provided to the project (either as loans or expenditures for land including accrued interest on such amounts for the period of time they are outstanding); and the local developer contribution to the project provided in order to satisfy an affordable housing obligation): Affordable Housing Credit Pricing Formula Local Financial Contribution + Number of Affordable Housing Credits Available City Contribution $4.2 Million* Developer Contribution (Aviara Land Associates) .9 TOTAL $5.1 Million 184 Unit Price of Affordable Housing Credits (Rounded to nearest $1.000)* $28,000* * To be adjusted with the addition of interest. Terms of Purchase and Sale, The commitment to purchase and sell Credits will be accomplished through an Affordable Housing Agreement as required by the Inclusionary Housing Ordinance. This Agreement will contain the terms of the Credit sale and will acknowledge the satisfaction of an affordable housing obligation through participation in a Combined Project (Villa Loma). Page 3 of 4 CITY OF CARLSBAD COUNCIL POLICY STATEMENT Policy No. 58 Date Issued Sent. 12. 1995 Effective Date Sent. 12. 1995 Cancellation Date Supersedes No. General Subject: Specific Subject: AFFORDABLE HOUSING Sale of Affordable Housing Credits Copies to: City Council, City Manager, City Attorney, Department and Division Heads, Employee Bulletin Boards, Press, File. Selection of Purchasers. The following procedure will apply to the selection of purchasers and allocation of Credits: 1. Project Review. Staff, through the Combined Project Review Committee (see Council Policy No. 57) will review all applications and approved projects with inclusionary requirements and determine which projects will be recommended to satisfy their obligations through the purchase of Credits. If the number of acceptable projects have affordable housing requirements which exceed the available number of Credits, projects will be ranked and allocated Credits accordingly. Projects will be reviewed and ranked using the following criteria: a) The immediacy of the need to satisfy an affordable housing obligation with respect to the market rate project that is generating the obligation. b) The readiness and capacity of the developer to enter into an Affordable Housing Agreement and perform under its terms. c) The acceptability of the Combined Project as an off-site option in lieu of the satisfaction of the affordable housing obligation on-site with respect to the project that is generating the obligation (see Council Policy No. 57). 2. Electing to Purchase Credits. Developers will be notified of staffs recommendation to permit the purchase of Credits and given the opportunity to accept or reject this option. 3. Reservation of Credits. Developers wishing to use the option of purchasing Credits must have . their projects approved with conditions allowing this option. In addition to Planning Commission approval, the recommendation of the Housing Commission will be required for the Credit purchase option of satisfying the Inclusionary Housing Obligation. When a project is approved (e.g., tentative map) with the Credit purchase condition, a reservation of the Credits is made for the project. Page 4 of 4 Policy No. 58. CITY OF CARLSBAD Date Issued Sept. 12. 1995 Effective Date Sent. 12. 1995 COUNCIL POLICY STATEMENT Cancellation Date Supersedes No. General Subject: AFFORDABLE HOUSING Specific Subject: Sale of Affordable Housing Credits Copies to: City Council, City Manager, City Attorney, Department and Division Heads, Employee Bulletin Boards, Press, File. 4. Affordable Housing Agreement. Within sixty (60) days of the approval of the Credit purchase condition, the developer must deliver to the Housing and Redevelopment Director a signed Affordable Housing Agreement in the form prescribed by the City with a non-refundable deposit in an amount equal to 10% of the total Credit sale price. The Affordable Housing Agreement will be scheduled for City Council consideration and, if and when approved, will be executed by the City. The Affordable Housing Agreement will require payment of the balance of the purchase price upon execution and prior to final map or issuance of a building permit. 5. Failure of Developer to Perform or Denial of Purchase Option. If the developer is unable to perform as required, or is denied the option of purchasing Credits, the Credits will be made available to another project(s), subject to this process. 6. This policy is subject to all other requirements of the Inclusionary Housing Ordinance. OCTOBER 31, 1995 TO: POLICY 57/58 PROJECT REVIEW COMMITTEE FROM: Housing & Redevelopment Director MEETING SUMMARY, OCTOBER 12, 1995, TO REVIEW A REQUEST BY 6REYSTONE HOMES, INC. (COSTA DO SOL) TO PURCHASE AFFORDABLE HOUSING CREDITS IN THE VILLA LOMA PROJECT Attending: Raymond Patchett, City Manager Jim Elliott, Financial Management Director Marty Orenyak, Community Development Director Michael Holzmiller, Planning Director Jane Mobaldi, Deputy City Attorney Evan Becker, Housing & Redevelopment Director After reviewing the role of the Committee, the Committee reviewed and discussed the Housing & Redevelopment Director's recommendation and the "Assessment Worksheet." The Housing & Redevelopment Director indicated to the Committee that the applicant had signed an Affordable Housing Agreement to proceed with their approved on- site affordable project, but was requesting that they be permitted to purchase affordable housing credits as an alternative. The Committee discussed the applicant's claim that a relatively small on-site affordable project would have questionable feasibility. Several members indicated that this could be said of most affordable projects needing subsidies. The Housing & Redevelopment Director indicated that the scale of the project could make subsidy requirements greater and that in the competition for subsidies, including competition from other Carlsbad projects, this project might have a difficult time. It was noted that the homeownership and mixed-income aspects of the on-site proposal were positives. Discussion of the overall status of inclusionary projects in the Southwest Quadrant indicated that almost 500 units could be completed or under construction in 1996 (Villa Loma and Laurel Tree); and that another approved on-site project (Sambi) would be coming forward shortly. Consensus was reached that, while the feasibility argument regarding the Costa Do Sol on-site proposal is difficult to validate, the advantages of using existing "excess units" in a quality project supports the request to buy credits. The purchase of credits also recovers City investment in the Villa Loma project as anticipated in the financing plan. EVAN E. BECKER Housing & Redevelopment Director ar OFF-SITE COMBINED INCLUSIONARY HOU, ASSESSMENT WORKSHEET PROJECT 1. Applicant Name and Address: ureystone Homes, Inc., Ann: Luis Trujillo 495 East Rincon, Suite 115 Corona, CA 91719 2. Off-site or Combined Project Name: Villa Loma Apartments 3. Description of Project with Indusionary Housing Obligation: Costa Do Sol, CT 92-01, is a proposed 152-unit project with a 23-unit affordable housing requirement. (See Attachments 1 & 2) 4. Proposed On-site Project Description (if any): Costa Do Sol, SDP 93-04, is a 40-unrt condominium project combining 23 affordable units and 17 market units. The affordable units range from one to three bedrooms, and would range in maximum price from approximately $72,000 to $109,000. 5. Proposed Off-site Project Description: Villa Loma (formerly La Tenraza) Apartments is a 344-unit apartment development in which all units are restricted and affordable to households with incomes not exceeding 60% of San Diego County Median. The project contains a distribution of 1, 2, 3 and 4 bedroom units. Units are scheduled to be occupied in October, 1995. Villa Loma is being developed by La Terraza Associates, a limited partnership in which Bridge Housing Corporation is the Managing General Partner. Villa Loma was financed with assistance from the City of Carlsbad and the Carlsbad Redevelopment Agency. The assistance was structured in such a way as to create affordable units which would be marketed exclusively by the City to other developers in order to satisfy an affordable housing obligation. Thus, Villa Loma Apartments is a Combined Project according to the Indusionary Housing Ordinance, and developers may propose to participate in this as an "off- site" method of satisfying an affordable housing obligation. Participation in Villa Loma Apartments by the applicant would be in the form of a purchase of Affordable Housing Credits under terms established by City Council Policy Number 58. 6. Description of On-site Project Constraints: (Also see Attachment "3", applicant letter of August 25, 1995). In proposing an on-site affordable project, the applicant has identified constraints which they feel would affect the project's feasibility. These include the uneconomical size of the affordable project; and potential conflict created by the significant price difference between the affordable units and the proposed market units. In addition to these constraints, the applicant feels that the location of the Villa Loma project is superior to their on-site location. WORKSHEET ASSESSMENT CRITERIA 1. Feasibility of the On-site Proposal. a. Are there significant feasibility issues due to factors such as project size, site constraints, and competition from multiple projects that make an on-site option impractical? /ASSESSMENT CONCLUSION (Check appropriate box) DOES NOT SUPPORT OFF-SHE PROPOSAL J^NCWSNE SUPPORTS OFF-SITE PROPOSAL X Attachment "1" to Council Policy Statement No. 57 ASSESSMENT COTERM ASSESSMENT CONCLUSION (Check appropriate box) DOES NOT SUPPORT OFF^SfTE PROPOSAL INCONCLUSIVE SUPPORTS OFF-SHE PROPOSAL WORKSHEET Brief Narrative: The on-site affordable project is of marginal size as a condominium project. Although it is difficult to quantify the economic implications, it will likely be difficult for the market units in this project to absorb the economic subsidy requirement of the affordable units. Based on the estimated restricted purchase prices of the affordable units and an estimated unit cost of $140,000, the applicant will be facing an average subsidy requirement of approximately $40,000 per unit. Unlike rental projects, for-sale units do not have significant subsidy programs available from federal or other sources. The likely sources of subsidy would be the developers and/or the City/Redevelopment Agency. b. Will an affordable housing product be difficult to intearate into the proposed market development because of significant price and product type disparity? X Brief Narrative: The integration of the 23 affordable units into the proposed 40-unit condominium project is a desirable approach, and price disparities, while significant, are less of a concern because all units are for-sale condominium product. The affordable condominiums will be priced well below the single family product which is estimated at the mid $200,000's. The fact that the affordable component is for-sale somewhat neutralizes this disparity between the condominium and detached product. c. Does the on-site development entity lack the capacity to deliver the proposed affordable housing on-site? X Brier" Narrative: The Developer is not experienced in the development of affordable housing and has not established a relationship with an affordable housing developer. 2. Relative Advantages/Disadvantages of the Off- site Proposal. a. Does the off-site option offer greater feasibility and cost effectiveness than the on-site alternative, particularly regarding potential local public assistance and when applying the City's Affordable Housing Financial Assistance Policy? Brief Narrative: The Villa Loma project is under construction and has known feasibility. Villa Loma would likely offer a significantly lower cost to the applicant than the potential subsidy required to construct the on-site affordable units. The applicant's participation in Villa Loma would permit the recovery of City investment provided to the project; conversely, the developer's on-site project would create the demand for additional new subsidy from some source. b. Does the off-site proposal have location advantages over the on-site alternative, such as proximity to jobs, schools, transportation, services; less impact on other existing developments, etc.? X Brief Narrative: The Villa Loma location has advantages over the on-site project in terms of proximity to jobs and project amenities. The proposed on-site project location is at least equivalent in terms of proximity to schools, parks and services. Villa Loma is a self-contained affordable development with little impact on other communities. The on-site proposal could be a source of real or perceived impact on the single-family and condominium communities into which it is integrated. ^P WORKSHEET W ASSESSMENT CRITERIA c. Does the off-site option offer a development entity with the caoacitv to deliver the proposed project? Brief Narrative: The Villa Loma project is beina t. specialized affordable housing developer. d. Does the off-site option satisfy multiple developer obligations that would be difficult to satisfy with multiple projects? Brief Narrative: Villa Loma will likely be satisfy/in project would be one of several (including Laurel the Southwest Quadrant competing for scarce fin obtain funding. The Villa Loma project has alrea subsidy financing. 3. Advancing Housing Goals a. Does the off-site proposal advance and/or support City housing goals and policies expressed in the Housing Element, CHAS and Inclusionary Housing Ordinance? Brief Narrative: The proposal to participate in th( Project supports an affordable project that is targ Element and CHAS larger rental units for low inct the applicant's participation will provide additiona housing development. Although the proposed on-site project is for-sale, affordable units (and perhaps more) in the South housing policy, this may suggest the need to use additional new construction. SUMMARY ASSESSMENT CONCLUSION (Check appropriate box) DOES NOT SUPPORT Of^STTE PROPOSAL INCONCLUSIVE SUPPORTS OFF-S/JE PROPOSAL X Developed and managed by a highly experienced and X j multiple developer obligations. The proposed on-site Tree Apartments and the Sambi/Seaside Heights Project) in ancial assistance. This means that it would be difficult to dy been financed; it would not be competing for remaining X 3 Villa Loma Apartments as a Combined Affordable Housing eted to the highest priority need identified in the Housing ome households. The recovery of City investment through f resources which are needed to assist further affordable it would be following closely the construction of almost 500 west Quadrant. From the standpoint of the City's inclusionary existing 'excess' affordable units before supporting DOES NOT SUPPORT OFF-SITE PROPOSAL 2 INCONCLUSIVE 1 SUPPORTS OFF&TE PROPOSAL 5