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Exhibit G- Rosemead HCD Comment Matrix_v1CITY OF ROSEMEAD 2021-2029 Housing Element – Public Hearing Draft, December 2021 Response to State Department of Housing and Community Development (HCD) Comments 1 ADDITIONAL DATA / LOCAL KNOWLEDGE HCD Question/Concern by Topic City’s Response Location - Section Racial/Ethnic Areas of Concentration of Poverty (R/ECAP): The element notes there are no R/ECAPs in the City. However, the City does have an area of High Segregation and Poverty according to TCAC/HCD Opportunity maps and should include specific analysis. The analysis should address trends, past and current efforts, including investment and their effectiveness, local data and knowledge, other relevant factors (as noted below), particularly relative to equitable quality of life, resources, and strategies to address any inequities in quality of life. The analysis should also consider any overlapping fair housing issues with other components of the assessment of fair housing (e.g., access to opportunity and disproportionate housing needs, including displacement). City has identified one tract designated as an area of High Segregation and Poverty (Census Track No. 060374823.04) based on information provided by HCD. A majority of the parcels in this area are within in the Garvey Avenue Specific Plan (GASP). The City adopted the GASP in an effort to revitalize the area and create an attractive and convenient destination for local residents. • HE Appendix D - Fair Housing Disparities in Access to Opportunity: While the element addresses access to education, economic and environmental quality opportunities, it should also address access to opportunities for transportation. City has included analysis of transportation opportunities utilizing data from HCD’s AFFH Data Viewer and high-quality transit areas in the City. • HE Appendix D - Fair Housing Disproportionate Housing Needs: In addition to analyzing patterns of overpayment and overcrowding, the element should also address housing conditions. For example, while the element mentions City-wide statistics on lacking plumbing and kitchen facilities, it should also address patterns and trends within the City. The analysis could utilize data from the City’s code enforcement and neighborhood preservation programs and compare conditions from neighborhood to neighborhood. City has provided additional information regarding substandard housing conditions using local code enforcement data, and has provided a geographic assessment of where homeowner assistance/improvement programs have been provided throughout the City. Based on City mapping, there does not appear to be an overconcentration in any single neighborhood. • HE Appendix D - Fair Housing Sites Inventory: While the element included data on the location of RHNA sites relative to all fair housing components, the analysis should address how the sites improve fair housing conditions related to each component of the analysis (if sites exacerbate conditions, programs that can mitigate impact), whether the sites are isolated by income group and should be supported by local data and knowledge. City has provided additional information regarding impact of fair housing conditions described in the fair housing assessment on RHNA sites. • HE Appendix D - Fair Housing CITY OF ROSEMEAD 2021-2029 Housing Element – Public Hearing Draft, December 2021 Response to State Department of Housing and Community Development (HCD) Comments 2 Local Data and Knowledge: The element should consider other local data and knowledge to complete the affirmatively furthering fair housing (AFFH) analysis. Examples include input from neighborhoods such as the identified area of high segregation and poverty, knowledge from local planners and city administrators and city records and reports. City has provided additional data/information from local agencies to bolster the fair housing assessment throughout Appendix D. • HE Appendix D - Fair Housing Other Relevant Factors: The element must include other relevant factors that contribute to fair housing issues. For instance, the element can analyze historical land use, zoning and investment practices, presence of redlining, restrictive covenants, neighborhood investment or disinvestment, federal investment such as transportation infrastructure, demographic trends or any other information that supplements the reported data and assists in a complete analysis. City has provided additional information related to historical land use trends and demographic shifts specific to race as further analysis of factors that contribute to fair housing issues. • HE Appendix D - Fair Housing Contributing Factors: Upon a full analysis of the AFFH section, the element should re-evaluate contributing factors to fair housing issues. In addition, the element lists several contributing factors, but it should also prioritize those contributing factors. City has updated list of contributing factors in the AFFH section to reflect changes made throughout the Fair Housing appendix. Contributing factors have been prioritized, and those identified as ”High Priority” have been listed. • HE Appendix D - Fair Housing Goals, Actions, Metrics, and Milestones: The element must be revised to add or modify goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have specific commitment, metrics, and milestones as appropriate and must address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization and displacement protection. City has updated the list of goals, actions, metrics, and milestones in the AFFH section to reflect changes made throughout the Fair Housing appendix. • HE Appendix D - Fair Housing Extremely Low-Income (ELI) Households: While the element identifies the projected number of ELI households, it must still analyze their existing housing needs. This is particularly important given the unique and disproportionate needs of ELI households. For example, the element could analyze tenure, cost burden, overcrowding and other household characteristics then examine trends and the availability of resources to determine the City has provided expanded analysis of extremely low-income (ELI) households by providing addition information related to race, tenure (occupancy), cost burden/severe cost burden, and overcrowding, and has provided programs to address conditions. • HE Background Information, Section E • HE Housing Plan • HE Appendix D – Fair Housing CITY OF ROSEMEAD 2021-2029 Housing Element – Public Hearing Draft, December 2021 Response to State Department of Housing and Community Development (HCD) Comments 3 magnitude of gaps in housing needs. For additional information, see the Building Blocks at http://www.hcd.ca.gov/community- development/building-blocks/housing-needs/extremely-low- income-housing-needs.shtml. Housing Conditions: The element quantifies the age of the housing stock and some enforcement activities. However, it must estimate the number of units in need of rehabilitation and replacement. For example, the analysis could include estimates from a recent windshield survey or sampling, estimates from the code enforcement agency, or information from knowledgeable builders/developers, including nonprofit housing developers or organizations. For additional information, see the Building Blocks at http://www.hcd.ca.gov/community-development/building- blocks/housing-needs/housing-stock-characteristics.shtml. City has provided additional data from the Code Enforcement Division in the assessment housing conditions of existing residential properties/structures throughout the City. • HE Background Information Overcrowding: The element quantifies the number of overcrowded households, but it should also quantify overcrowded households by tenure (renter and owner) and include analysis such as evaluating trends, comparing rates of overcrowding to other areas, and assessing the magnitude of the need. City has provided additional Census information related to overcrowding households by tenure (occupancy), a comparison between city and regional (SCAG) conditions, and programs to address overcrowding. • HE Background Information SITES INVENTORY ANALYSIS HCD Question/Concern by Topic City’s Response Page Number Progress in Meeting the RHNA: The City’s RHNA may be reduced by the number of new units built since July 1, 2021. The element must credit these units to the various income groups based on actual or anticipated sales price or rent level of the units or other mechanisms ensuring affordability (e.g., deed-restrictions). Most of the projects are credited toward the above moderate-income category and do not require analysis. However, the element should demonstrate the affordability of the approved project at 3001 Walnut Grove Avenue as described above. City has provided additional information related to the affordability restrictions of the residential development located at 3001 Walnut Grove Avenue. The developer is required to enter into an affordable housing agreement with the City. The developer will deed restrict seven units for low-income households for a minimum of 55 years. • HE Housing Resources, Section B Parcel Listing: The element lists parcels by various factors such as size, zoning, general plan designation and existing use. However, the description of existing use is generic and must include sufficient detail to facilitate an analysis of the potential for addition development on nonvacant sites. For example, many sites describe existing uses as commercial. Instead, the inventory could City has updated the Sites Inventory Table to include additional parcel information such as detailed land use, year built, and square footage. • HE Appendix C – Sites Inventory CITY OF ROSEMEAD 2021-2029 Housing Element – Public Hearing Draft, December 2021 Response to State Department of Housing and Community Development (HCD) Comments 4 describe the use as commercial, structure older than 50 years in poor condition, vacancies present, and an existing floor area 0.1. Alternatively, the inventory could utilize various data layers with similar information. For more information, see the HCD’s Housing Element Sites Inventory Guidebook at https://www.hcd.ca.gov/community-development/housing- element/housing-element-memos.shtml. Suitability of Nonvacant Sites: The element briefly mentions nonvacant sites mainly consist of underdeveloped properties with low-value or marginal uses, but it must include analysis to demonstrate the potential for redevelopment of nonvacant sites. The analysis should consider the extent to which existing uses may constitute an impediment to additional residential development, the City’s past experience with converting existing uses to higher density residential development, the current market demand for the existing use, an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development, development trends, market conditions, and regulatory or other incentives or standards to encourage additional residential development on these sites. In addition, because the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households, it must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period. (Gov. Code, § 65583.2, subd. (g)(2).) Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA. City acknowledges that the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households. To address HCD’s concern the City has provided additional information and findings including age and condition of structures, development trends of non-residential uses, potential retention of non-residential use on mixed-use sites, details on incentives and available financial resources to demonstrate that existing uses on non- vacant sites will not significantly impede additional housing development during the planning period. • HE Housing Resources, Section C Realistic Capacity: The element mentions expected densities in mixed-use designations based on aggregated intensity across all land and the average density of some recent developments. However, the element should also address the likelihood of 100 percent nonresidential uses and account for this likelihood in the calculation of residential capacity. This is particularly important Of the mixed-use areas within the City, only the Garvey Area Specific Plan-Incentivized Mixed-Use (GSP-MU) area would allow 100% non-residential development. However, the likelihood that properties within this area are developed exclusively non-residential is considered very low as building permit data shows that the three largest sites within this area • HE Housing Resources, Section A CITY OF ROSEMEAD 2021-2029 Housing Element – Public Hearing Draft, December 2021 Response to State Department of Housing and Community Development (HCD) Comments 5 since the mixed-use overlay appears to allow 100 percent nonresidential uses, including uses allowed under base zoning. The analysis should address development trends, performance standards or other relevant factors such as enhanced policies and programs. For example, the element should analyze all development activity in these nonresidential zones, how often residential development occurs and adjust residential capacity calculations, policies, and programs accordingly. have been approved for mixed use development featuring at total of 528 residential units. These development projects are currently in plan check with permit issuance pending. Small Sites: The element identifies several sites at less than a half- acre in Table A, Appendix C. These sites are not eligible absent a demonstration that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower-income housing units as projected for the site or unless other evidence is provided. If the inventory indicates some sites can be consolidated it should also provide analysis demonstrating the potential for consolidation. For example, the analysis could describe the City’s role or track record in facilitating small-lot consolidation, policies or incentives offered or proposed to encourage and facilitate lot consolidation, conditions rendering parcels suitable and ready for lot consolidation, or information from the owners of each aggregated site. City has verified there are no parcels less than a half-acre in size which were assumed to accommodate lower-income households that are not part of a larger consolidated site. City has also included additional information related to historical trends which demonstrate a successful track record in facilitating small lot consolidation, specifically within the Garvey Avenue Special Plan area. • HE Housing Resources, Section C Environmental Constraints: While the element generally describes a few environmental conditions within the City (pp. 33-34), it must relate those conditions to identified sites and describe any other known environmental or other constraints that could impact housing development on identified sites in the planning period. City has provided additional information related to environmental impacts of seismic hazards (liquefaction zones) and noise generated from typical vehicular traffic on identified RHNA sites. • HE Constraints on Housing Production, Section A Infrastructure: The element mentions water and sewer providers, but it should also clarify whether sufficient total water and sewer capacity (existing and planned) to accommodate the regional housing need is available and add or modify programs if appropriate. City has providing addition data and information which indicates the City’s water, wastewater, and sewer capacity will remain adequate to accommodate the projected RHNA allocation. Additionally, the City has included a program to develop water and sewer master plans by the end of 2025 to ensure of adequate infrastructure capacity is available throughout the planning period (Program 7). • HE Constraints on Housing Production, Section A • HE Housing Plan, Program 7 Electronic Sites Inventory: For your information, pursuant to Government Code section 65583.3, the City must submit an electronic sites inventory with its adopted housing element. The City will submit an electric version of the Sites Inventory Table to HCD after City Council adoption of the Housing Element for State certification, per HCD procedures. • HE Appendix C – Sites Inventory CITY OF ROSEMEAD 2021-2029 Housing Element – Public Hearing Draft, December 2021 Response to State Department of Housing and Community Development (HCD) Comments 6 City must utilize standards, forms, and definitions adopted by HCD. Please see HCD’s housing element webpage at https://www.hcd.ca.gov/community-development/housing- element/index.shtml#element for a copy of the form and instructions. The City can reach out to HCD at sitesinventory@hcd.ca.gov for technical assistance. ZONING AMENDMENTS HCD Question/Concern by Topic City’s Response Page Number Emergency Shelters: The City currently does not have a zone available to permit emergency shelters without discretionary action, a requirement in statute for over a decade. HCD cannot find the element in compliance until the appropriate zoning is adopted with sufficient capacity to accommodate the need for emergency shelters. In addition, the element should analyze capacity in the proposed M-1 zone relative to any conditions inappropriate for human habitability. The analysis should also address the proposed development standards, including parking requirements, for compliance with statutory requirements and add or modify programs as appropriate. City is currently processing an amendment to the Zoning Ordinance which will allow emergency shelters by-right to address current housing needs. The Zoning Ordinance amendment is anticipated to be adopted in January 2022. • HE Constraints on Housing Production, Section B • HE Housing Plan, Program 9 Manufactured Housing: Government Code section 65852.3 generally requires manufactured homes on foundations to be allowed on lots zoned for single-family residential uses and only subject to the same standards as single-family residential uses. The element describes that manufactured housing is only allowed in the R-2 zone and may be allowed in the R-1 zone subject to essentially a conditional use permit. This appears inconsistent with state law. The element should either demonstrate compliance with statutory requirements or add or modify programs as appropriate. City has included a program to amend the Zoning Code to allow manufactured housing in the R-1 Zone by-right, in compliance with State law. (Program 9, formerly Program 8) • HE Constraints on Housing Production, Section B • HE Housing Plan, Program 9 Transitional and Supportive Housing: Transitional and supportive housing must be permitted as a residential use in all zones allowing residential uses and only subject to those restrictions that apply to other residential dwellings of the same type in the same zone. (Gov. Code, § 65583, subd. (a)(5).) The element states transitional and supportive housing are allowed by right in the R-1, R-2, R-3 and GSP-R/C zones but does not clearly demonstrate City has included a program to amend the Zoning Ordinance to address changes to State law including AB 101 (Low Barrier Navigation Center) and AB 139 (Emergency and Transitional Housing). Program also will amend the Zoning Ordinance to allow supportive housing by right in the RC-MUDO and FCMUO zones. In addition, remove minimum parking requirements for units occupied by supportive housing residents if the develop- • HE Constraints on Housing Production, Section B • HE Housing Plan, Program 9 CITY OF ROSEMEAD 2021-2029 Housing Element – Public Hearing Draft, December 2021 Response to State Department of Housing and Community Development (HCD) Comments 7 whether these uses are permitted in all zones allowing residential uses such as mixed-use zones. The element must demonstrate compliance with statutory requirements or add or revise programs. ment is located within one-half mile of a public transit stop per AB 2162 (Supportive Housing). (Program 9) Zoning Code and Fees Transparency: The element must clarify its compliance with new transparency requirements for posting all zoning and development standards on the jurisdiction’s website or add or modify programs as appropriate. City’s website already maintains development codes and full fee schedule for online viewing, in compliance with State law. Hyperlinks to associated webpages have also been provided. • HE Constraints on Housing Production, Section B SB 35 Streamlined Ministerial Approval Process: The element must clarify whether there are written procedures for the SB 35 (Chapter 366, Statutes of 2017) Streamlined Ministerial Approval Process or add a program to address these requirements. City has provided a program to adopt SB 35 (Streamlining Provisions) to allow streamlined ministerial approval for qualified residential developments with at least 10% affordability, in compliance with State law, by end of 2024. (Program 9) • HE Housing Plan, Program 9 Large Households: The element notes large households are defined as consisting of five or more persons and refers to data in Table 10. However, Table 10 refers to large households as four or more persons and the element should include the correct data. In addition, the element should quantify large households by tenure (renter and owner) and include analysis such as evaluating trends, comparing percentages to other areas, and assessing the magnitude of the need. City has updated data tables as appropriate. Additional information regarding large household trends and comparisons of conditions between the city and county. • HE Background Information, Section F Farmworkers: The element indicates a small amount of the workforce in Rosemead are farmworkers. However, farmworkers from the broader area and those employed seasonally may have housing needs, including within the City’s boundaries. As a result, the element should at least acknowledge the housing needs of permanent and seasonal farmworkers at a county-level (e.g., using USDA county-level farmworker data) and include programs as appropriate. City has provided additional information regarding farmworker population within the surrounding SCAG region and included a program to address promotion/facilitation of farmworker housing (Program 9, formerly Program 8) • HE Background Information, Section F • HE Housing Plan, Program 9 HOUSING PLAN (POLICIES/PROGRAMS) HCD Question/Concern by Topic City’s Response Location within Housing Element Program 6 (Adequate Sites): The Program commits to rezone sites that meet various requirements, including permitting at least 16 units on a site. Then the Program appears to identify a site(s) that City has not selected a rezone site that does not permit at least 16 units for lower income housing. Of the ten sites listed in Program 6, three are projected to accommodate lower income • HE Housing Plan, Program 6 CITY OF ROSEMEAD 2021-2029 Housing Element – Public Hearing Draft, December 2021 Response to State Department of Housing and Community Development (HCD) Comments 8 does not permit 16 units. This site(s) may not be utilized toward the shortfall of sites to accommodate the RHNA for lower-income households. housing: 9238 Lower Azusa Rd (19 lower income units), 9200 Lower Azusa Rd (37 lower income units), and 9201 Lower Azusa Rd (16 lower income units). Program 6 data table has been updated to reflect this finding. Sites Identified in Prior Planning Periods: The element must include a program for vacant sites identified in two of more consecutive planning periods’ housing elements or nonvacant sites identified in a prior housing element, that are currently identified to accommodate housing for lower-income households. The program must be implemented within the first three years of the planning period and commit to zoning that will meet the density requirements for housing for lower-income households and allow by-right approval for housing developments that include 20 percent or more of its units affordable to lower-income households. (Gov. Code, § 65583.2, subd. (c).) City has added Program 11 By-Right Approval of Projects with 20 Percent Affordable Units on “Reuse” Housing Element Sites to be implemented within three years from the 2021-2029 Housing Element statutory deadline, in compliance with State law. • HE Housing Plan, Program 11 Lot Consolidation: The element includes Programs 4 and 7 to promote consolidation of smaller sites. However, based on information in Appendix A, these programs do not appear to have been effective in the prior planning period. These Programs should be revised as appropriate based on a complete analysis under Finding A4 and a complete evaluation of program effectiveness in the prior planning period. City has provided additional information describing Rosemead’s successful trend of lot consolidation, as well as the effectiveness of existing city polices incentivizing land assemblage (e.g, Community Benefits Program), specifically within the mixed-use zones and specific plan areas. • HE Housing Resources, Section C Program 8 (Special Housing Needs and Zoning): As noted in Finding A4, the element cannot be found in compliance until zoning is amended to permit emergency shelters without discretionary action. This program should be revised with specific and clear commitment and timing as appropriate. City is currently processing an amendment to the Zoning Ordinance which will allow emergency shelters by-right to address current housing needs. The Zoning Ordinance amendment is anticipated to be adopted in January 2022. Program 9 has been updated to reflect this. • HE Housing Plan, Program 9 The element must include programs to assist in the development of very low-, low-, and moderate-income households, including ELI and all special needs households (e.g., elderly, homeless, farmworkers, persons with disabilities, female-headed households). Program actions could include proactive outreach (e.g., annually) and assistance to non-profit service providers and developers, prioritizing some funding for housing developments affordable to lower-income, ELI and special needs households and offering financial incentives or regulatory concessions to Meaningful actions to assist all income and special needs groups, including ELI, are included in several programs within the Housing Plan including provisions for owner- and renter- occupied grant and loan funding for low- and moderate-income households (Program 1), down payment assistance to lower income families (Program 2), creation of additional housing options (Program 3), land development financial assistance for construction of low- and moderate-income households (Program 4), policy changes to facilitate development of special • HE Housing Plan, Programs 1, 2,3, 4, 9, 11, 12, 13, and 14 CITY OF ROSEMEAD 2021-2029 Housing Element – Public Hearing Draft, December 2021 Response to State Department of Housing and Community Development (HCD) Comments 9 encourage a variety of housing types. While the element includes Program 9 (Development of Housing for ELI), it must still include actions for lower-income and all special needs households. Finally, Program 9 should be revised with discrete timing and outreach with developers (e.g., annually) and Program 11 (Mobile Home Park Assistance) should be revised with specific commitment and timing to apply or assist applications for funding (e.g., bi-annually). needs housing, especially for those experiencing homelessness (Program 9, formerly Program 8), allowing by-right approval of projects with 20% affordable units on certain sites identified in the element inventory (Program 11), rental assistance payment to low-income families and seniors (Program 12, formerly 10), and fair housing policies to address disparities in housing opportunities for all income groups (Program 14, formerly 12). Program 13 (formerly 11) Mobile Home Park Assistant Program (MPAP) has been updated to include specific action and timing commitments.