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HomeMy WebLinkAbout2005-05-12; Housing Commission; MinutesMinutes of: Time of Meeting: Date of Meeting: Place of Meeting: HOUSING COMMISSION 6:OO P.M. May 12,2005 CITY COUNCIL CHAMBERS CALL TO ORDER Chairperson Scarpelli called the Meeting to order at 6:OO p.m. PLEDGE OF ALLEGIANCE Commissioner Smith led the Pledge of Allegiance. ROLL CALL Present: Absent: Commissioners: Dons Ritchie Edward Scarpelli Bobbie Smith Renee Huston Margaret Schraml Staff Present: Housing and Redevelopment Director: Debbie Fountain Senior Planner: Mike Grim APPROVAL OF MINUTES Minutes of March 24,2004, were approved with six corrections. VOTE: 3-0 AYES: 3-0 NOES: None ABSTAIN: None HOUSING ELEMENT PUBLIC WORKSHOP Mike Grim, Senior Planner, will be giving the presentation along with Veronica Tam from Cotton Bridges Associates. She is one of the consultants that is assisting the City in the preparation of the Housing Element. Mr. Grim said he will be giving an overview of housing programs and state law requirements, and also housing element processing options. More specifically, we will discuss why the Housing Element is being changed. That leads us to an examination of our existing housing programs, some of the new state law requirements that have come into effect this last five years that have had major impacts on the structure of the Housing Element, and then resulting from those requirements, some of the new housing programs that staff is going to be looking at this cycle. Then we will discuss the Housing Element processing options. Because we are within the SANDAG region, we do have some options as far as how we process the Element. There weren’t any questions 6om the last workshop that weren’t answered at that workshop. So there aren’t any outstanding issues coming from that workshop. Tonight we will discuss some of the next steps. We will end with how the element is going to be processed and also opportunities for more public input. Ms. Veronica Tam presented why we need to change the Housing Element. State law does require the City to update the Housing Element once every five years. It is a mandate that every few years you need to look at the Housing Element because housing is a very volatile market and it changes very rapidly, unlike other types of developments within the city. Therefore, every five years the city is supposed to review what is being provided in terms of housing services and programs and decide if they are working, effective and continue to be appropriate. If they are not, the HOUSING COMMISSION MINUTES MAY 12,2005 PAGE 2 of 12 program needs to be revised in order to meet the current needs and the projected needs. We also need to respond to the changing market conditions. There are also many new changes in the state law. Periodically new regulations will come out requiring different local jurisdictions to change things on the housing arena. When we are looking at the Housing Element, we need to review the laws and whether the city is meeting the law and what to do in meeting the new requirements. Ms. Tam said she will go over the major reason we are changing the Housing Element. In the current Housing Element, the strategy took a toolbox approach. It has a list of many different options of programs or activities or funding sources that the City may pursue or explore. It is difficult because when the City evaluates the performance in the past five years, you have to look back at every single tool in the toolbox to see whether something was done or not. It becomes a very cumbersome process. We have decided to focus on the things we need to do, the things we know we are going to do, and how we are going to do it. This will make it much more specific and also objective oriented with some goals attached to it. The Inclusionary Housing Program and the Housing Trust Funds have been very successful. It was recently cited in a state study that Carlsbad’s Inclusionary Housing Program is one of the most successful in the state. Also, we need to add new programs to address the constraints and opportunities the City may have right now. Regarding the new State laws, Ms. Tam will cover four of the major areas since 2001 when the Housing Element was adopted. Since that time, there has been development in the State Legislature that would impact the Housing Element. One relating the adequate sites, farm worker housing, emergency shelters and transitional housing, and also housing for persons with disabilities. Those are the major changes in the State law we have to address in this particular Housing Element. In November of 2004 a new law was passed, AB2348, which studies adequate sites. It relates to what the City’s responsibility and obligation is to the share of the region’s growth. Each city is assigned a share of the regional growth. That particular process, Mr. Grim will discuss later. When a city receives a share of that growth, the State wants the city to identify where there are sites that afe hgh enough in density to accommodate the number of housing units needed to be addressed. When a city has higher density, the city is more likely to be able to develop affordable housing. In meeting Carlsbad’s share, you have to demonstrate that you have vacant or underutilized sites that are adequate in zoning and densities. In Carlsbad, that means at least 20 units per acre may be able to meet the very low and low income-housing obligation. Sites that are zoned at 12 to 15 units per acre may be able to address the moderate income. In finding adequate sites, we need to look at the zoning and the land use controls to make sure Carlsbad has sites within those categories to meet those housing units. In regard to farm worker housing, one particular requirement of the Housing Element is the city must facilitate and encourage the development of a variety of types of housing, including those for special needs such as farm workers, homeless, and persons with disabilities. With farm worker housing the State law states that if you permit agricultural as a use, then you have to permit farm worker housing by rights; particularly if it is 12 units or less. We will discuss later why we have to change the Housing Element in response to this requirement. Housing for persons with disabilities was enacted in 2002, SB520. The Housing Element must address constraints to developing housing for persons with disabilities. The State wants the city to look at its procedures, development codes, building codes, and whether they act as a constraint to housing development or preserving housing with persons with disabilities. One part of the State law states the city must facilitate and encourage the development of a variety of types of housing for persons with special needs including the homeless. The State law does require the city to identify adequate sites to accommodate housing for emergency shelters and transitional housing, but it doesn’t necessarily state how the city will accomplish that. We will suggest an approach in your Housing Element for meeting this particular requirement regarding housing for the homeless. HOUSING COMMISSION MINUTES MAY 12,2005 PAGE 3 of 12 Mr. Grim continued with the RHNA, the Regional Housing Needs Assessment, which is based on growth forecasts from the State Department of Housing and Community Development. They assign the region a fair share of their projected growth. For January 2003 through 2010, seven and a half year period, the region’s fair share is about 107,000 units. That was actually larger then our growth forecasts, but the State HCD decided since we are a fast growing region, they wanted to bolster that number. The end result is that trickled all the way down so our numbers are much higher than we would have ordinarily anticipated. Once that bulk number is assigned to the region, the SANDAG Board decides how to allocate these numbers to each of the nineteen jurisdictions. That process is referred to as the Regional Housing Needs Allocation. The intent of the RHNA process is to ensure there is not an over-concentration of housing affordable to lower income households within the region. In other words, they want to have as much dispersion of affordable housing as the market will bear. SANDAG, after a lot of negotiations, finally decided on the RHNA allocation on February 25, 2005. The delay of this allocation process and then the subsequent discussions staff has to have to figure out how to accommodate RHNA is the main reason this Housing Element Workshop was delayed from the January date. It didn’t make any sense to come talk about programs when we didn’t even know what our targets would be. To break it down, the total allocation given to Carlsbad after the seven and a half year number and converting it to the five-year cycle, is 6,315 units. We arrived at that number because the State HCD directed us how to figure out that seven and a half to five year conversion number. We subtracted the amount of production we had in each of the income groups to see the resulting numbers of units. The four income groups are broken down as follows: 0 0 0 0 The very low is less then 50% of the area-wide median income. The low-income housing would be 5 1% to 80%. Moderate income would be 81% to 120%. Above moderate or sometimes called other is above 120%. This would be market rate housing. The numbers are 1,793; low is a little over 1,000; moderate is just under 1,500; above moderate is 2,000. Typically when we look at the RHNA allocations, because of the density requirements that Ms. Tam spoke of, we lump very low and low together. In essence, our RHNA calculations target 2,800 units for lower income and about 1,500 units for moderate. This is an estimate of our growth. It is okay for our housing goals to be less then that estimate. It is more of an indication we have adequate sites to actually accommodate that growth. Our first step was to take a look at the existing land use designations within Carlsbad, since we have relatively low densities compared to urban environments, and see which ones would satisfy which income groups according to the state law. Our residential high density allows development up to 23 units an acre so we can definitely accommodate the lower income with the residential high density. The medium high density allows up to 15 units an acre, which targets that moderate-income range of 12 to 15. Our first step was to assess how much vacant land we have in the RH and RMH designations and if we have enough to accommodate this. We found definitively we do not have a lot of high density land left in Carlsbad. Therefore, we had to look elsewhere. The next step was to assess the high-density lands that are developed, and decide if they are under-developed such that we could actually add some more housing to them. Maybe put in some programs to encourage people to redevelop their sites, add a couple of more units, and after studying that, we have some underutilized sites. However, there are some constraints just based on realism for that. In other words, if there is a property on Garfield with one home and you could get a second home on the property, it is unlikely that second home would be affordable housing even though it would be achieving that 20 units an acre. We also have redevelopment areas, which we have allocated excess dwelling units, we added 1,000 units to the village. Since that is a mixed-use area and since it does allow for housing, we can count those units towards our allocation. Also, State law allows us to count the second dwelling units in equal proportion to what we built last HOUSING COMMISSION MINUTES MAY 12,2005 PAGE 4 of 12 cycle; whether they be restricted for affordability or not. Staff has reviewed this and the numbers are still rough. We wanted to review it to see if we are getting anywhere close to our RHNA allocations and what our needs are. Our first strategy was to use existing designated land, but that did not achieve our goal. Our next step would be to look at areas that are currently under the planning process; for instance, Robertson Ranch. This would allow us to see if we could make any adjustments wih the master plan there to accommodate some of these adequate sites designations. Obviously if we can’t do it with the existing land and we can’t do it with future master plan areas or future development projects or redevelopment areas, and we are limited with regard to what we can do with mixed use areas, than the next alternative, which we are really trying to avoid, is going into an existing neighborhood and talung a vacant site and up zoning that. We do have some strong concerns about community character and compatibility with the neighborhood and how that would impact the residents. Also, most of the existing residents wouldn’t like having a high-density designated site in their neighborhood. The State allows the City to have up to 50% of its RHNA allocation as non-residential projects, basically mixed use projects. That is why we have divided the chart into two categories, residential and non-residential. Our targeted future sources for the residential site for lower income is our existing land, which we only get 340 units of a yield out of. We have spoken with the master plan developers for Robertson Ranch and made some minor adjustments to their land use plan, which is going through the process, and we yielded about 470 units. Depending on the disposition of a fbture school site that might even go up to 600 units. There is a future project in Zone 25, the northern end of the city between El Camino Real and College, that is currently undeveloped and we are working with the master plan developer. We may be able to get in the mid 200’s as far as units for there. We also spoke with a developer for La Costa Tome Square who had a stand-alone piece that was not part of the actual development; it was across the street. They were originally intending to put in a medical office there. We discussed with them our issues with regard to providing high-density housing, and they volunteered to put in high density housing in that location too. That is 100 units. Counting our second dwelling units, the 125 which we used last time around, we can get the 1,400 total, which is about 50% of our yield. On the non-residential side, the Village Redevelopment Area has been allocated 1,000 units in our excess dwelling unit bank. Reviewing the Ponto Redevelopment Vision Plan, we believe there are at least a couple of hundred units in mixed-use areas we will be able to count towards our RHNA. For industrial mixed use, the airports and the new land use plan that is proposed for that may have some constraints. We believe that along the fringe areas, we can target some industrial sites that would allow mixed use. This also fits into SANDAG’s Smart Growth Program where they are trying to get housing and jobs co-located to reduce traffic. Also as far as underdeveloped residential, we are estimating approximately another hundred units; taking into consideration the constraints such as sites being too small. For moderate income, once again we need to get about 1,400 units. Our existing RMH lands estimates a little over 1,000 from them. Another 80 units can be estimated from the RMH designated lands in Robertson Ranch. We are also speaking with one of the major commercial landowners in the city about potentially having some mixed use in their site. That can yield Carlsbad about 180 units. As you can see, we are barely achieving the numbers. If any of these don’t come to hition or don’t yield the numbers we are hoping for, staff and the City will have some tough choices ahead to try and find additional sites we can designate. We are simply densifjmg the area. We are not mandating that affordable housing be built there. Whether it be affordable or not, density in and of itself, tends to cause some neighborhood issues. It will be a delicate issue if these numbers don’t come to be. Ms. Tam continued by saying one of the issues the City needs to address is the farm worker housing. Currently, the City amended the City ordinance to address the farm worker housing issue to allow temporary farm worker housing in all non-residential use zoning to file a conditional use permit. Typically that is fine except in the RA area because it is really residentiaVagricultura1. When you have an agricultural area that permits that type of function, but you permit farm worker housing, that is not consistent with state law. The state law states if you designate something as HOUSING COMMISSION MINUTES MAY 12,2005 PAGE 5 of 12 agricultural use, you have to permit temporary farm worker housing for less then 12 units of beds by right. That is the adjustment we have to suggest in your Housing Element. The Housing Element would not specify how the City will change the zoning ordinance, but it does state you will adjust your zoning ordinance to meet the State law and establish a timeline as to when you have to do that. Typically, it is within one year of the adoption of the Housing Element when you should be completing the zoning changes in order to meet the requirement. In some communities where you have a large homeless issue, the requirement would be more stringent for emergency shelters and transitional housing. There is no specific state law that states exactly how you have to address this particular issue. By case law, some jurisdictions, like the City of San Diego, have been sued on this particular matter and they have to specifically identify sites. For a jurisdiction like Carlsbad where homelessness is not a huge issue, then there are ways to deal with it. Particularly the City has demonstrated that it has the ability to provide for emergency shelters and transitional housing since you have one operating in the City and you do provide financial assistance. We are going to continue this particular practice, but in the Housing Element we may have to add additional commitments as to how the City will be working with non-profit agencies in addressing the homeless issues. With regard to housing for persons with disabilities, the State is looking for something called reasonable accommodations. The State wants to see what the City’s reasonable accommodation procedures are. Some cities adopt an ordinance codifjmg the procedures. Some cities have written policies wih their administrative policies. If a person needs to install a ramp in order to make the home accessible, or if somebody needs to add a room because he or she has become disabled and needs to have a ground-floor bedroom, that type of improvement or modification to the home does not meet the City’s development code or building standards. Some cities consider that an ADA improvement, and it is automatically exempt as long as it has been approved. Some other jurisdictions treat it as a staff review and there isn’t a need to go through the Planning Commission or the public hearing in order to do that. Reasonable accommodations could go as far as if a person is unable to come into the office to fill out the fom, the City would send a staff member to their home. The State is also looking to see if you have particular building codes in preventing the building for housing for persons with disabilities. This would be if you had very high parking standards for senior housing. Many seniors or disabled people do not necessarily drive and therefore you would not need as high of a parkmg standard. As part of the Housing Element, we will look at those conditions or regulations within the City and then suggest some modifications if necessary. Also, we will indicate if the City needs to establish some procedures regarding reasonable accommodations. There are two choices in terms of completing the Housing Element. Typically most cities when updating the Housing Element, send it to the State for a review. The Housing and Community Development Department is responsible for reviewing the Housing Element for compliance with State law. At the end of the review, they will issue a letter of Finding of Compliance or Lack of Compliance. It is up to the City at that time to decide to what extent that will be addressed. Having a letter from the State indicating you have a Housing Element that complies with State law gives you more legal protection in the case of a lawsuit. In 1995 the State passed legislation to allow SANDAG jurisdictions to go through something called Self Certification. It is an elaborate process where jurisdictions within the San Diego region develop a system to show within a Housing Element the important thing is the performance. If the City can demonstrate performance, then you should be able to show the letter of the law has been met. That is the essence of the SANDAG Self Certification process. If the city is able to meet the performance goals established for the community during the past Housing Element cycle or current Housing Element, then you will be eligible to Self Certify your Housing Element stating the Housing Element is in 111 or substantial compliance of State law. That does not mean you do not have to write a Housing Element that meets the letter of the law. You do not have to go through the State’s review. That is the route the City of Carlsbad will be going. The City has met the performance goals for the current Housing Element cycle. The goals concentrate on the very low and extremely low income group. Since the City has demonstrated that through the City’s Inclusionary Housing Program, which was cited in a 2003 study by San Jose State University that the city is one of the most successfd Inclusionary Programs in the State. A lot of the lower and extremely low HOUSING COMMISSION MINUTES MAY 12,2005 PAGE 6 of 12 income housing units did result from that Inclusionary Housing Program. Because of the efforts the City has made in the past, the City is eligible to Self Certify. The next step of the Housing Element is for the City to draft the Housing Element. Then complete the Environmental clearance, which typically involves a negative declaration because we are not recommending any zone changes at this time. Then we will initiate a 30-day public review on the Housing Element. Following that, comments received during the 30 day public review will be incorporated into the final Housing Element. It will then go before the Planning Commission, the Housing Commission and the City Council for adoption. The tentative dates are as follows: 0 0 0 The drafi Housing Element will be done by July. The Housing Element will be put up for 30-day public review. Adoption of the Housing Element should take place in September or October of 2005. Technically the Housing Element is supposed to be completed by June 30, 2005, but because of the deadline that was delayed due to the RHNA process, very few cities are able to meet that deadline. Only one city, the City of La Mesa, has submitted their Housing Element to the State. Carlsbad should be the third city in the county to have completed the Housing Element. Commissioner Ritchie asked Ms. Tam to explain in more detail the housing for farm workers. Ms. Tam stated there are two types of farm worker housing: permanent farm worker housing and temporary farm worker housing. Permanent farm worker housing is just like any apartment or multi-family housing or single-family home that is permitted if multi-family or single-family homes are permitted. The issue is with the temporary farm worker housing. State law requires when you have a piece of property that is zoned as agricultural and you permit agricultural activities in those zones, automatically you have to permit temporary farm worker housing for less than 12 people. If someone requests to provide farm worker housing on a piece of property that is zoned agricultural and is only for 10 people, the City cannot say it is fhe but you have to go through a CUP process. You have to permit it by right. Currently, the City’s process is it has to go through a CUP process. That is the part that will need to be changed. If it is in commercial or residential zones, that is a different matter. It is only in the R4 there is a problem because it is a permitted use for agricultural use in that area. Commissioner Ritchie asked if we know how many we have at the present time in Carlsbad. Ms. Tam said she does not have that information with her, and she is not sure. Chairperson Scarpelli stated the only farm worker housing that Carlsbad currently has is La Posada, which is in an industrial area. Mr. Grim agreed and said that is considered more of a transitional housing. It also serves as an emergency shelter on occasion. Chairperson Scarpelli said to Ms. Tam that she indicated there would be a problem. He doesn’t quite understand the statement she made. If it is zoned agricultural, then it is a requirement that housing be made available for 12 or less. Why is that a problem? Ms. Tam said the problem is because the City’s RA says the City needs to go through a CUP process. Chairperson Scarpelli said we are obviously going to have to make that adjustment and remove the requirement for the CUP. HOUSING COMMISSION MINUTES MAY 12,2005 PAGE 7 of 12 Ms. Tam said right. Mr. Grim interjected that it might be a semantical issue. In the RA zone it states agricultural labor housing. We don’t have any definitions for farm worker housing, temporary fm worker housing, agricultural labor housing, and such. It is reasonable to presume that if someone wanted a 100-unit farm worker housing structure, we would probably want to take that through discretionary review and take a look at all the impacts. That would certainly still be consistent with State law. This is not dissimilar to what we currently have in other State writing of our local ordinances. In a single-family neighborhood, if you have six or fewer people for a community care facility, whether it be treating someone who is developmentally disabled, alcoholic, any treatment center, it must be an allowed use. The City hasn’t overtly put any of that into our zoning ordinance, but if someone requested that, the staff is fully aware we wouldn’t be able to put them through a CUP process. We have to take a look at the details of exactly how much we actually want to put in our code. There might be some minor adjustments. We could even maybe take care of it by definitions and defining that agncultural housing has something of 13 or more people. Chairperson Scarpelli asked to go back to the 12 or less. How is that worked out? Per unit, per building? Ms. Tam said the State is very clear about that. It is usually per building. She has not seen a city that regulates it by building, but I am not clear on that. I don’t think the State legislation is clear on that either. The interpretation is not clear. I will double check on that and get back to you on that. Most of the time we are interpreting it as, if someone proposes a project that involves more then 12 people, then it would be a CUP. If it is for doing a project that is for 12 or fewer, we would consider that as by rights. Whether it is one structure or a group of structures, I don’t think the State law is clear on that. Chairperson Scarpelli said since we have a problem in this area that we haven’t resolved yet in this City regarding the agricultural worker, I would think the City would tend to want to look in a more lenient approach towards it. That is if a farmer who is hiring a 100 farm workers, could he possibly put up 12 separate units on his thousand acres and still comply without a CUP. Commissioner Smith stated that is a good question. Mr. Grim agreed that is a good question. Staff would have to take a look at the community character issues, if there are any involved in that. If someone asked me, I would probably say 12 or fewer per agriculturally zoned property because that is what qualifies you or not qualifies you. If someone has 100 acres of RA land and it was one big parcel, we would say you can have one 12-unit site there. Kathleen Wellman complimented staff as she is learning new things each meeting. Is there a way for the City to encourage the owner who has agriculture on their land to have them provide housing? One of our issues is getting the owner of the land to consent to letting agricultural housing on that land. In order for the farm owner to have the profit of the benefit of the agricultural product on his land, he has to produce at least 12 units for his property or parcel. Could the staff also do a study of these particular parcels or properties to see how many you could get on 12 or less on these various parcels? What would the maximum be if we had the authorization of the farm owner? Just like the City does with other studies, where is the potential? How many could we get without the CUP? Many times it is easier to manage a smaller group. They might be from the same town in the interior of Mexico or wherever and it might be easier for the farm worker to do that. Ms. Wellman continued that one of the dificult things is funding. With the new Housing Element being presented, what are other juris&ctions doing to increase methods of fimding for the various low-income housing. Is that part of the Element? Ms. Tam answered, in terms of the incentives, that is certainly something we can discuss with the City. Financial incentives are typically the most enticing. In terms of the potential, I am sure we can find out how many parcels are HOUSING COMMISSION MINUTES MAY 12,2005 PAGE 8 of 12 zoned for R4. In the Housing Element we can discuss an innovative approach. Following some of the development issues in the City of San Diego, last year they tried to shfi the hotel bed tax towards affordable housing. Santa Monica also does this. Some cities do charge commercial development for affordable housing. There are many other ways to increase funding for housing, but the subsidies in the San Diego area have increased so much the city has to do a lot of work in order to meet all the needs. Ms. Wellman stated that Carlsbad does have a strong basis with our hotel industry and we do collect transit occupancy taxes. For now they are going into the general fund, unless some are going for the Chamber of Commerce or to promote Carlsbad and the tourism She asked Ms. Tam to share what jurisdictions are doing that and what the language of their laws are. Part of the inclusionary and density bonuses has worked out well for low- income housing. When we get into homeless housing, we may need some social workers or other staff with salaries to help manage these types of units. Getting staff operational salaries is really hard to come by from my experience. Some creative alternative would be appreciated. In some other jurisdictions where they have changed the law with the people with disabilities, maybe you could provide some samples so we can review that and be able to give input. Mr. Grim added that first of all, properties that are designated agriculture is one of the more complicated twists. A lot of our R4 land is already fully developed with single-family homes. It is not being used for agriculture. So exactly how we are going to address that is questionable. The State law says it is agriculturally designated and being used for agriculture. You need both criteria. Chairperson Scarpelli stated that once it went to Housing and Redevelopment, the zoning changed on those. Mr. Grim said that it actually stayed RA. Chairperson Scarpelli said they are talking about those that are actually being used. Mr. Grim agreed. He said the staff does have sample ordinances from another jurisdiction about reasonable accommodations for disabled persons. HCD has acknowledged that sample ordinance is acceptable to them We routed it through at all of our staff levels and find it acceptable. Ms. Wellman asked if that information could be disseminated. Mr. Grim said yes he would. Margie Monroy, 749 B Magnolia Avenue, Carlsbad. When I came to the first meeting, I asked for a rundown on the new legislation on housing. What I would like to know is what has changed and what will this require the City to do and what will happen if they don’t do it? Cassie Scinterelli, 2727 Lyons Court. My question involves Self Certification by SANDAG. I understand there is pressure by SANDAG to increase the numbers beyond what is included in the Housing Element in all the cities of North County. If you go through the Self Certification process, does that give SANDAG any more leverage to force more housing on us then may be in our Housing Element? Ms. Tam answered she isn’t sure about forcing more housing. The regional housing needs allocation relates to sites. That comes from the State. It does not come from SANDAG. The overall growth, 107,000 comes from the state, and SANDAG’s responsibility is to allocate to the jurisdictions. This involves negotiations and modeling. The City of Carlsbad has been allocated $6,3 15. Ms. Scintirelli asked if that was above and beyond what is in the Housing Element? Ms. Tam said no, that is what has to be addressed in the Housing Element. HOUSING COMMISSION MINUTES MAY 12,2005 PAGE 9 of 12 Ms. Scintirelli asked if that was over the next five years? Ms. Tam answered yes. Ms. Scintirelli asked how many Carlsbad is scheduled to build? Ms. Tam said the City is not actually required to build anythmg. Sites must be made available though. In order to qualify for Self Certification, an affordable housing goal is established. The affordable housing’s goal is usually only a fraction of the Regional Housing Needs Allocation. It doesn’t go beyond that. Ms. Scintirelli asked if she got an answer to her question? Does it give them any more leverage to force housing above and beyond. Mr. Grim said they have talked to staff about smart growth opportunity areas and it is recommended we do that. However, those aren’t really quantified with regard to housing types. The SANDAG’s rule in the Regional Housing Needs Assessment states you have to show adequate sites for that, but they are not forcing us to build housing. The biggest impact that Self Certification does is it does force us to address extremely low income housing, which is something that isn’t part of the Regional Housing Needs Assessment, and as Debbie can attest, it is already being done. If there is any forcing involved in the Self Certification process, it is forcing you to address that lowest income group. Your responsibilities on the very low are commensurately reduced because they know htting that extremely low target, people that are less than 30% of the median income, can be huge with financial incentives and, therefore, the City is devoting their resources to that. Ms. Scintirelli continued with another question regarding the temporary fam worker housing. Is there anythmg in the law that obligates the City to pay for this? Socorro Anderson, 3222 Roosevelt Street. In reference to the Self Certification, does that put the City at a place where they can be challenged more as opposed to not being Self Certified. Mr. Grim said the state of the challenge would still be the same. One of the steps of the Self Certification process is that you are substantially compliant with State law. The biggest difference is that with Self Certification, the City has the opportunity to show how well we are doing in other categories, the extremely low income, and that tends to get lost in a State Certified Element. It is lumped in with the very low income. Because of the way Carlsbad has been doing their housing, we felt the Self Certification was a great way to pull that out and show it. It doesn’t increase our vulnerability. We still will have to make those three findings for Self Certification. So if challenged, we would have to show that those three findings were made adequately and our Element was substantially compliant with law. If it were found to not be compliant or we Self Certified in error, then we would have to go back through the Self Certification process or the court may mandate us to go through a HCD review, State certification, or one of those options. Ms. Tarn commented the major difference between going through the State and doing the Self Certification is with the State’s Certification, in the case of a lawsuit, it would be the litigants responsibility to prove that you did not comply with the law. Because you Self Certify in the case of the lawsuit, then the City would have to be the one that substantiates why the City complies with State law. Mr. Grim countered that the City Attorney’s office has a different reading on that. We have been told that with either one, the reasonable doubt is on us. It would still be the person who was challenging the Element to prove why we didn’t meet the requirements. Ms. Anderson continued that she received an e-mail this morning that Washington is abuzz on tax credits. How is that going to correlate with the affordable housing built here in Carlsbad? HOUSING COMMISSION MINUTES MAY 12,2005 PAGE 10 of 12 Ms. Tam answered that she doesn’t think we would use a lot of low-income housing tax credit. Debbie Fountain, Housing and Redevelopment Director, answered that we have had a number of projects financed through tax credits, but I haven’t heard what the most recent buzz was. Was it to get rid of them or to increase them? Ms. Anderson answered it is to increase them. Ms. Fountain said that would be a good thing. Mario Monroy, 749 Magnolia Avenue in Carlsbad. One of the issues is the handicapped. We were looking in Carlsbad and also in Oceanside and there isn’t any housing that is being built today, especially condominiums, to handle handicapped. Some of us are getting old enough that we cannot handle the stairways. It is not necessarily someone in a wheelchair. I have been told that when you build a flat or a single-level unit, the ordinance requires that you build it to meet the requirements of a handicapped person, which means you need to provide for the wheelchair under the sinks and wider door openings. That increases the cost of building those types of facilities, which are not available at all. The developers don’t seem to want to touch them because they are more expensive. In Carlsbad today the land is selling for $100 a square foot and some places are for sale even hgher. There is a project on Grant Street that is higher. So that is $100 per square foot for the house and the cost of building the handicapped is probably $140 per square foot at least. Because of the parking requirements we have, you need to go to underground parking. That adds another $50 to $60 a square foot and soon you are up to $300 a square foot. Economically, for people to build handicapped accessible units, it will be tough unless the City has some incentives. In addition, you must provide affordable housing, the 15%. It is a challenge, and I am not sure to what degree the City in analyzing the ordinance and so forth looking at the economics of the projects. Ms. Anderson said one more thing she neglected to mention is about the building of commercial with residential. The City needs to take into consideration the difficulty to work and have living quarters right there. It only works if you live and work in the same place, because if you rent an office, and other people live above you and beside you, there are all kinds of problems. The City needs to consider that as well. I have heard a lot of issues in reference to the Anastasia condominiums. They hate the noise of the City and they hate looking out the windows and seeing homeless people on the street. Lee Price, 3355 Mission Avenue in Oceanside, and I represent the disabled community. I work for the Access Center, which helps disabled people in the North County. I don’t know of any ordinance that mandates that you must have the bottom floor accessible. What I am asking for is that you thmk about having a mandatory voluntary program to give the people a right to be able to do what he is talking about. Right now, a person who is disabled that needs a place that is accessible like low counters in front of the sinks, has to reconstruct the house once he buys a house. We are asking you to give them an opportunity to make the decision when the house is being built and to give them an opportunity to be voluntary so they can make the changes. What I am talking about affects us all. I have a video called Universal Design and Visitability. Visitability is the right for a person to be able to come and visit somebody else where there are no steps. This is a voluntary program. If you are interested, I can share this 7-minute video with you. Chairperson Scarpelli asked Mr. Price if he could make that video available, we would appreciate seeing it. Ms. Kathleen Wellman asked if there is any discussion for the future about having single-room occupancy units. I think as we are aging and our homeless population is aging. If you have single-room occupancy, is each room considered a unit for th~s planning? Ms. Tam said for the Regional Housing Needs Allocation purpose, it has to be a housing unit defined by the census as a housing unit. Mainly it has to have individual access. A lot of the assisted living facilities may actually be considered as a housing unit, but if it is a single-room occupancy, typically that is not considered a housing unit so you do not get credit for the Regional Housing Needs Allocation purpose. HOUSING COMMISSION MINUTES MAY 12,2005 PAGE I 1 of 12 Ms. Wellman stated that maybe we could create one that would have that access to meet that requirement and also so we could get credit for the unit. Why can’t we be creative and make it? What could we do to create that? Single- room occupancy would help a lot of people at the lower end of the income, whether they are retired or disabled or just low income. That is a real need. We could do it before we have a hotel that is really old and has to be condemned that turns into single-room occupancy. Do something decent and nice and make it for the Housing Element. We got credit for La Posada over the years and we didn’t build La Posada to get credit for anything, but it has come in that way. We really do need single-room occupancy or that kind of housing. Mike Wishcamper, 4039 Sunnyhill in Carlsbad. I will speak only to the single issue of farm worker housing. There are two issues of farm worker housing that was discussed tonight. One was discussed in more detail then the other, the 12 and other housing. I want to talk about the other, permanent. As I understand the Housing Element requirement of the State law, the City is obligated to identify a location where housing could be for farm workers. I know the City has attempted to do that and indicated that fam worker housing can be placed in locations other than residential after going through the CUP process. I have spent the last two years with a committee looking for such a place. As a practical matter in Carlsbad, I am not sure this place exists in the commercial area. I am not sure there is private land that exists which in fact could be used to house farm workers. The problem we have is that Carlsbad is replete with covenants, conditions, and restrictions on the property, which essentially forbids our ability to use properties for farm worker housing. I hope that will be taken into consideration as you look at that part of the Element, not just with respect to the 12 units, but to the others as well since we have spent such a long time trying to find such a place without success. Ms. Scintirelli said she has been thinking about SRO’s in terms of Carlsbad also, the single-resident occupancy. The beauty of SRO’s is all of these groups we have been talking about, the disabled, the farm workers, the homeless, and the poor can use them. I do think it would behoove Carlsbad to pursue some SRO’s. Another thing about the farm worker housing, I am not sure we should be spending City resources to provide any type of housing for people who are most probably here illegally. One solution and what is driving a lot of the farm worker issues, is not so much the fact that they camp out, but the fact it is a water pollution control problem. There are other solutions that I don’t think have been considered. One, for instance, is composting toilets. You can buy at a very reasonable rate these composting toilets that are solar run, they can be put anywhere, there is absolutely no maintenance with them, and that might be another thought about cleaning up the sanitary conditions without actually having to provide housing because I think it is a tricky issue in Carlsbad. I am very much an advocate for protecting the environment. Ms. Anderson said she is an advocate for farm worker housing. They do a job for us. They pay taxes. Some time ago, I suggested maybe looking at a hybrid solution. Not housing them in one location, but looking for different locations in different areas of the community. One particular person I talked to got excited about not wanting to even consider it because they promised the citizens they wouldn’t put them in their backyard or put them in their neighborhood. Maybe the solution would be with the Farm Worker Committee maybe you need someone to look at it as a fresh idea. I work with families in thls community who are housed in apartments in the barrio area. There are three families to a unit. There has to be a better solution for all of the families, not just farm workers. We are all a family, we are all here in Carlsbad, and we are all either living or working here in Carlsbad. A lot of the families are living in the downtown area, and there are pockets, not just in the barrio, there are pockets throughout Carlsbad where you have poor people, and nobody really knows where they are because they don’t make any noise or waves. Our ministry administers to them every single day. I know where they are. They need help as well. We all could work together and take care of the people that are here, whether they are in the downtown, whether they are in the La Costa area, whether they are in our fields. We are all a family. We should all be willing to take care of all of the people in Carlsbad because we all benefit by everyone being here. Chairperson Scarpelli commented at one of the other workshops he mentioned that he appreciates all of the input with the different perspectives that people bring to the Commission and to the City in regard to how to deal with this family of ours in Carlsbad. The challenge seems almost insurmountable. Certainly, there have to be solutions out there. We have to try to work towards finding those solutions. I know Mike Wishcamper worked diligently for two HOUSING COMMISSION MINUTES MAY 12,2005 PAGE 12 of 12 years trying to get some housing with the cooperation of the City, recognizing the need for housing for the farm workers. Again, we ran into legal difficulties such as CC&R’s. We’ve got to start thinking outside of the box, because we are trapped in the box right now. Our zoning laws prevent us fiom doing what we have to do. A project came to this Commission for recommendation for approval in the last meeting and this Commission had a difficult time dealing with the cost numbers that were being given by the developer. In reality, the laws and the conditions the developer has to work under just add tremendously to the actual cost over a commercially built project. We talked about it being a non-profit project and yet the cost may be one and a half times as much as a for- profit project would have cost to build. We are funning into these types of difficulties. To the extent we can bring these issues to the legislatures that we are interfacing with to bring about the types of laws and regulations that we really need to solve these real issues that are facing us in housing. We all have to be diligent at that as citizens and for people we elect to govern us and the staff that work so hard to try to make things happen for us. It is a team effort, and it is a very difficult issue. I have been sitting on this Commission since it’s outset, and I am amazed at how much we have accomplished under such dire conditions that we have had to try to produce what has been produced in this city for affordable housing projects. Again, credit goes to a Council that has listened to his citizenry that this is something we feel needs to be addressed and needs to be dealt with and to a staff that works diligently day in and day out to try to implement what is available to make it happen. There are some tough odds when we look at what we have to deal with to make it all happen. These are real issues and real challenges that face us. Let’s keep working together on trying to work out the solutions. I have had to say this a number of times over the last couple of months to a number of people in different situations, but sometimes these insurmountable appearing challenges remind me of the definition of how do you eat an elephant? You do it by one bite at a time. I think that is what we are trying to do here. We do have to keep working at it. I want to thank everyone who appeared here this evening. I can assure you that this Commission and this staff take to heart the needs as it deals with affordable housing, and we are doing everydung in our power to address that issue with every opportunity that we have. Maybe with additional grant monies becoming available, we’ll be able to do it a little bit more, but be aware of the fact that we recognize the challenges there. The need is definitely there and we are doing the very best that we know how to meet those challenges. DIRECTOR’S REPORT The Director did not have a report this evening. ADJOURNMENT By proper motion, the meeting of May 12,2005 was adjourned at 7:20 p.m Respectfidly submitted, n Debbie Fountain Housing and Redevelopment Director PATRICIA CRESCENT1 Minutes Clerk MINUTES ARE ALSO TAPED AND KEPT ON FILE UNTIL THE WRITTEN MINUTES ARE APPROVED. The CdtyoPCarlrbad Hour-& Redevelopment Depsrtment AREPORT TO THE HOUSING aOmBSXON Staff: MikeOrixnxn seniox? Pla.nner Item No. X DATE: MAY 12,2005 SUBJECT: HOUSING ELEMENT PUBLIC WORKSHOP - The third of a series of workshops conducted by the City and undertaken to help continue work on updating the Housing Element of the City’s General Plan. This third and final workshop focuses on the goals, policies, and programs to meet the City’s housing needs during the 2005-20 10 housing cycle. I. RECOMMENDATION This is an informational item only, and no action is required. 11. PROJECT BACKGROUND The City of Carlsbad is in the process of updating the Housing Element of the General Plan, The General Plan is the City’s long range planning document that is organized into different elements addressing specific areas of concern such as Housing, Land Use, Circulation, Public Safety, and Open Space. The Housing Element addresses a variety of housing topics including the need, availability, and affordability of housing for specific periods, also known as housing cycles. The City Council adopted the current Housing Element in July 2000 for the housing cycle that will end on June 30,2005. State law requires that local jurisdictions update their Housing Element every new housing cycle, typically at five-year increments. The next housing cycle will begin on July 1, 2005 and continue until June 30, 2010. The contents, procedures, and approval requirements for Housing Element updates are contained in State Housing law. One of the procedures required is community engagement through public participation. As with previous housing cycles, the City is performing a series of public workshops addressing the housing needs and required contents of the Housing Element and soliciting public comment. Formal public participation will also be available during the future public hearings on the Housing Element at the Housing Commission, Planning Commission, and City Council. HOUSING ELEMENT PUBLIC WORKSHOP May 12,2005 Page 2 111. PROJECT DESCRIPTION The first Housing Element workshop was conducted on October 28, 2004 and covered State Housing law and Housing Element requirements, as well as technical housing and demographic data for Carlsbad. The second workshop was held on December 9, 2004 and dealt with the housing needs for Carlsbad, the resources available to address those housing needs, and the constraints to the provision of housing within the City. This third and final workshop generally covers the existing and new housing programs, new State law requirements, and Housing Element processing options. Each of these areas is discussed in more detail below. A. Existing Housing Programs Currently the Housing Element contains a number of programs intended to facilitate the provision of housing for all income groups and persons with special needs. As described in previous workshops, the income groups are categorized as very low, low, moderate, and above moderate-income and are based upon the countywide median income and family size. Persons with special needs include, but are not limited to, the elderly, farmworkers, large families, the homeless, and persons with disabilities. The programs that address these housing needs fall into general categories such as preservation and/or rehabilitation of existing housing, encouragement of new housing opportunities through funding and regulation, housing/jobs balance, and resource conversation. During the last Housing Element cycle, the City maintained virtually all of the existing programs in an attempt to maximize the options for developers and property owners to provide a variety of housing opportunities. Over the last five years, however, some of these programs have gone unused or have become obsolete. In addition, the State Department of Housing and Community Development (HCD) recommends that programs involving only hnding mechanisms not be included in Housing Elements. Therefore, the updated Housing Element would include only those programs that have been utilized and found effective in providing housing opportunities. In addition, the structure of the programs would be revised to more clearly associate the programs with their applicable housing goal. While this may appear to significantly reduce the number of programs, it would serve to more clearly focus the document and increase its readability. B. New State Housinp Law Requirements Since the adoption of the current Housing Element in July 2000, there have been several significant changes to State law and/or administrative interpretations by HCD. These changes impact the identification of adequate sites for the Regional Housing Needs Assessment (RHNA), provision of housing opportunities for farmworkers, allowance for emergency shelters and transitional housing, and accommodation for housing for disabled persons. Each of these changes is detailed below. HOUSING ELEMENT PUBLIC WORKSHOP May 12,2005 Pane 3 RHNA Adequate Sites Identification As discussed in the second Housing Element workshop, the RHNA consists of an allocation of housing units by income group that are anticipated to accommodate the City’s share of the region’s estimated growth over the next housing cycle. Recent revisions to State Housing law have modified the manner in which jurisdictions must show that the RHNA can be accommodated within the housing cycle. Previously, the RHNA was accommodated simply by showing enough vacant land to allow the development of the total number of anticipated housing units. The new method is much more complex and ties the particular income groups to minimum densities. The theory behind the statute is that higher density sites are much more likely to accommodate affordable housing. While Carlsbad’s experience with the development of affordable housing greatly differs from this theory, the City must nonetheless show the sites in accordance with State law. For relatively low-density jurisdictions such as Carlsbad, the very low- and low-income vacant sites must be designated at a minimum of 20 dwelling units per acre. While there is no codified minimum density for moderate-income sites, HCD staff has indicated that vacant sites in the range of 12 to 15 dwelling units per acre would suffice. In addition to requiring more specificity with regard to density, State Housing law now requires that these sites be specifically identified by parcel number rather than generally referenced as before. A minimum of 50 percent of the vacant land identified to accommodate the RHNA must be designated for exclusively residential uses (i.e. not a mixed use). Farmworker Housing State Health and Safety Code states that “no conditional use permit, zoning variance, or other zoning clearance shall be required of employee housing that serves 12 or fewer employees that is not required of any other agricultural activity in the same zone.” Therefore, State law preempts a local jurisdiction from restricting these uses, Emergency Shelters and Transitional Housing While there are no specific statutes that require a City to address housing for the homeless in their zoning ordinances, HCD has recently begun to apply the requirements to provide housing opportunities for persons of special needs to mean that local jurisdictions expressly provide for emergency shelters, transitional housing, or their equivalents in the local ordinances. Housing for Disabled Persons State law now clearly states that jurisdictions must make reasonable accommodations in their zoning and land use regulations to afford disabled persons an equal opportunity for housing. Reasonable accommodations would consist of the allowance for modifications or exceptions to zoning or other standards that might otherwise preclude the provision of housing for disabled persons (such as a modification to setback requirements to accommodate an access ramp). HOUSING ELEMENT PUBLIC WORKSHOP May 12,2005 Page 4 Income Group Very low C. Proposed New HousinP Prowarns Total Housing Units 1,793 In addition to the revisions to the existing Housing Element programs, several new programs are being proposed for the updated Housing Element. These programs are detailed below. RHNA Adequate Sites Identification Given the new State law requirements mandating increased specificity in site density and location, staff has analyzed all of the existing vacant land within the City and identified areas that can accommodate the housing units specified in the RHNA. The housing unit amounts in the City’s RHNA are derived by the San Diego Association of Governments (SANDAG) and were finalized on February 25, 2005. The intent of the RHNA is to ensure that there is not an over-concentration of housing affordable to lower income households within any portion of the region. The RHNA for Carlsbad for the five-year housing cycle is contained in Table 1 below. I Low 1,014 bierate I 1,486 I I Other I 2,022 I 1 TOTAL I 6,3 15 I It is important to note that the housing units in the RHNA do not equate to the number of units that must be built within the five-year housing cycle. Rather it is the City’s share of the anticipated growth. There are many factors, such as property owner and builder development schedules and market demand, which are out of the City’s control. Therefore the City must simply show that it can accommodate the growth through adequate sites and the reduction of constraints to housing provision, should that growth occur. Taking into consideration all of the existing, vacant residentially designated properties in the City that would qualify at the necessary density ranges, there is currently not enough land to accommodate the lower and moderate income units in the RHNA (lower income includes both very low- and low income housing). Using the State law information above, the corresponding density range for lower income is Residential High (RH) and for moderate income is Residential Medium High (RMH). There are, however, several areas within the City currently at various stages of planning that will include RH and RMH lands, namely the Robertson Ranch Master Plan, Ponto Redevelopment area, and La Costa Village Town Square. In addition to vacant residential lands, State law allows credit for several other areas to be counted in the RHNA accommodation. Non-residential (Le. mixed use) areas that are designated to allow high-density housing can account for up to 50 percent of the RHNA accommodation. A HOUSING ELEMENT PUBLIC WORKSHOP May 12,2005 Pane 5 jurisdiction may also take into account underutilized higher density residential sites, those being sites that are developed, but have not reached their total potential for housing. Second dwelling units (SDUs) may also be counted as lower income units to the extent in number as the number of SDUs built during the previous housing cycle. The currently anticipated accommodation of the RHNA by income group is shown in Attachment 1. As staff is still deriving capacities for some areas, the numbers in the table are approximate and would be finalized prior to Housing Element preparation. In addition to the areas and projects noted above, the City has allotted up to 1,000 dwelling units in the Village Redevelopment area and, therefore, can count those units towards the RHNA accommodation. The City is also in discussions with property owners/developers about future projects that would include higher density residential uses. Since these projects are not yet in process, the Housing Element would need to include programs to address the provision of housing within these areas. The updated Housing Element would also include programs to address the development of underutilized sites and future mixed use sites in existing non-residential zones (such as Smart Growth Opportunity areas). Farmworker Housing In April 2004, the City amended the Zoning Ordinance to allow temporary agricultural farmworker housing in all zones except residential through approval of a Conditional Use Permit (CUP). In addition, the Residential Agricultural (R-A) allows agricultural labor housing by CUP. There are currently no definitions for the terms referenced above in the Zoning Ordinance. While the local ordinance may require CUPS for these facilities, State law preempts local regulations for smaller facilities of 12 or fewer agricultural employees and, therefore, they are allowed uses. This is not dissimilar to the situation that exists in residentially zoned areas with regard to health facilities, such as care facilities for the developmentally disabled, with six or fewer people. The City’s Zoning Ordinance does not expressly state that these are permitted uses. In order to hrther clarifL the differences between the City’s regulations and the State’s local ordinance preemption, the Housing Element would need a program that addresses the differences between the facilities referenced in the Zoning Ordinance and those smaller facilities referenced in State law. Emergency Shelters and Transitional Housing In the current, state-certified Housing Element, the City showed that it could accommodate housing for the homeless by describing the steps taken to assist with the location of, and conditionally permit, La Posada Guadalupe de Carlsbad and generally identifying areas that might be compatible for those uses. The successful operation of La Posada within the industrial area for over ten years, plus the City’s ongoing financial commitment in the operations, has demonstrated that Carlsbad can provide for emergency shelters and transitional housing. The updated Housing Element may augment the existing programs to further clarify this willingness to work with homeless providers in the location and permitting of such facilities. HOUSING ELEMENT PUBLIC WORKSHOP May 12,2005 Page 6 Housing for Disabled Persons Other jurisdictions within the State have been successful in demonstrating reasonable accommodation for housing for disabled persons by adopting an ordinance allowing modifications or exceptions to zoning regulations for qualified persons. These ordinances have allowed for minor structural modifications andor regulatory exceptions for such accommodations. Therefore the updated Housing Element would include a program to develop such an ordinance based upon those ordinances previously deemed consistent with the California Fair Employment and Housing Act. D. Housinp Element Processing ODtions For most jurisdictions in the State, the Housing Element must be reviewed and certified by HCD. Once a city has prepared a draft element, it is submitted to HCD for review. Provided that HCD returns positive comments, the city then makes the necessary revisions to the element and takes it through the local approval process. Once approved locally, the city submits the final element to HCD for official certification that the element is in substantial compliance with State Housing law. If HCD requires major revisions to the draft element, then the City and HCD proceed with iterations of review and comment, as necessary, to satisfy HCD’s concerns. In 1995, SANDAG sponsored legislation to allow San Diego region jurisdictions to conduct a pilot program for self-certification of their Housing Elements. Under this program, each SANDAG member jurisdiction has the option of reviewing its own Housing Elements and certifying that the element is in substantial compliance with State law. In order to self-certify, the decision-maker of the jurisdiction (i.e. the City Council) must make the following findings: 1. The Housing Element substantially complies with the requirements of State law, both with respect to content and preparation; and 2. The Housing Element and programs address the dispersion of affordable housing throughout the jurisdiction; and 3. The jurisdiction has met their self-certification housing performance objectives. The housing performance objectives mentioned in item number 3 are derived using a different process than the RHNA and contain an additional income group: extremely low income (less than 30 percent of the area median income). Also, whereas the RHNA must be addressed by new construction, the self-certification performance objectives can satisfied through a broader range of housing opportunities such as acquisition of existing housing, rent/purchase subsidies, rehabilitation and others. It is assumed that providing housing for the extremely low-income group requires heavier subsidies and/or City participation than for higher income groups. Therefore the performance objectives for the other income categories are reduced accordingly. HOUSING ELEMENT PUBLIC WORKSHOP May 12,2005 Page 7 The City has made efforts to provide for extremely low-income housing over the last housing cycle and, due to those efforts, has met or exceeded all of the self-certification performance objectives. In recognition of those efforts, and to reduce the materials and labor expenses associated with HCD certification, the City may chose to self-certify its Housing Element this housing cycle. E. Next Steps Following the receipt of public comments from the third workshop, and potential incorporation into the element, the draft Housing Element will be completed, along with the corresponding environmental review documents. The element and environmental review will then be made available for a publicly noticed 30-day review period. Any comments received during that review period will be reviewed and, as appropriate, incorporated into the draft element. The Housing Element will then be presented for approval at public hearings before the Housing Commission, Planning Commission, and City Council. W 0 0 z h z 0 --- c 8 T * 'C u) C 3 U .- 2 E 2 Q) s a 0 s cui 0 a - w Q) E 3 'si e I II li II a e i- z n c 0 e w E 0 0 2 w II k w a 0 E a n t- LL 2