Blog Santa Cruz YIMBY comments on the City of Santa Cruz August 2023 Draft Housing Element

Aug. 29, 2023

Santa Cruz YIMBY has the following comments on the City of Santa Cruz’s 6th cycle Housing Element draft dated August 21, 2023 (1). We appreciate the changes that have been made since the July 2023 draft, many of which were responsive to our input. We are focusing this letter on some remaining issues in the amended Housing Element (2).

In response to the ever-increasing cost of living, Santa Cruz YIMBY advocates for abundant housing at all levels of affordability to meet the needs of a growing population in Santa Cruz County. The Housing Element is an opportunity for the City of Santa Cruz to address the housing crisis on its own terms. 

(1) City of Santa Cruz Housing Element - August 21, 2023
(2) HCD letter to City of Santa Cruz dated August 8, 2023

Policy 1 - Housing Production

  • Objective 1.1d enforces unit replacement requirements and should include monitoring unit loss due to consolidation, e.g. the conversion of multi-unit homes into single-family. This could include penalties, such as ADU requirements or other fees.
  • Objective 1.2a adopts an EIR for the Downtown Expansion Plan. The City should consider more units in the Downtown Expansion Plan to account/prepare for future RHNA cycles.
  • Objective 1.3g is a good addition - we hope that this allows the City to increase the number of units in the Downtown Expansion Plan for future cycles.
  • Objective 1.5a includes a review of ADU development and we are pleased to see the added timeline commitment of 18 months. There is still an opportunity for a menu of actions that would facilitate development if it lags such as:
    • Allowing multiple ADUs
    • Developing a concession program
    • Other financial or technical incentives
  • Objective 1.5e could be tightened to “Amend ADU owner occupancy regulations by May 2024”
  • Objective 1.6a related to the Planned Development Permit process could be incorporated into a local density bonus program.

Policy 2 - Affordable Housing 

  • In Objective 2.1a, we suggest this be moved earlier than 2026.
  • Objective 2.2c explores additional funding for affordable housing, but only focuses on the potential ballot measure. This could be expanded to a menu of options - e.g. parcel tax tied to upzoning land, impact fees for single-family projects.
  • We appreciate the target number of VLI units in Objective 2.2f. Consider a menu of options for “facilitate”, e.g. ministerial approval, subsidies such as land or funding. 
  • We like the newly added Objective 2.2i! There could be an added objective that is not specific to faith-based organizations to encourage ALL developers to consider Santa Cruz, i.e “why Santa Cruz is a good place to build affordable housing”.
  • As part of Policy 2.4, we still support establishing a Community Opportunity to Purchase (3) program to give qualified non-profit organizations the right of first offer or refusal to purchase certain properties offered for sale in the City. We also still support establishing a Tenant Opportunity to Purchase program to help prevent displacement, empower tenants, and preserve affordable housing when the owner decides to sell.
  • We appreciate the change to Objective 2.5a. This is another opportunity to add a menu of options for assistance for at-risk units, or those with expiring covenants.

(3)  Community Opportunity to Purchase Act (COPA) | San Francisco
(4) EBCLC's Tenant Opportunity to Purchase Act (TOPA) - East Bay Community Law Center

Policy 3 - Special Needs and Homelessness

  • We appreciate the tightening of language in Objective 3.1b. This is an opportunity for a menu of options for how the city will “Assist in the development...”, e.g. financial assistance? Land?
  • We recommend a program that identifies city land and adopts ministerial approval for permanent supportive, transitional housing or homeless shelters or homes accessible to persons with disabilities.
  • Objective 3.1c is a good program! Fair Housing Act/reasonable accommodations update should be earlier than January 2025
  • Objectives 3.2a, 3.3g, 3.3h and 3.3i lack milestones with dates.
  • Few objectives in Policy 3 related to Homelessness focus on developing housing. It is unfortunate to have Objective 3.3j about unsanctioned camps included.
  • Objective 3.3l low-barrier navigation centers update to state requirements should be earlier than June 2025
  • We are happy to see the ministerial approval added to Objective 3.4d and recommend a lower threshold than 50 units.

The University

  • Objective 3.5a does not include how the city will facilitate development of units on campus. 
  • Objective 3.5b (legislation) is vaguely worded to “Support state legislation…” which repeats from the 5th cycle. Note that as recently as 2022, the City formally expressed opposition to proposed legislation intended to facilitate more housing at UCSC (5). 
  • The City could develop a Student Housing Overlay that builds on their Flexible Density Units (FDUs) and encourages housing for students in the city.

(5)  Minutes from City Council meeting, 4-26-2022
(6) City of Santa Cruz, UCSC in talks to possibly end lawsuits over enrollment and housing plans

Policy 5 - Neighborhood Vitality

  • Objective 5.1a, 5.4c, 5.5a lack milestones with dates.
  • Objective 5.2a What options is the City considering?

Policy 6 - AFFH

  • Policy 6.1 focuses on Housing Vouchers with a high reliance on the Housing Authority. The City should consider a city-sponsored voucher program using funding such as CDBG and HOME grants.
  • Objective 6.1a could include a menu of options for the landlord incentives.
  • Objective 6.2d The time frame for zoning amendments to expand housing opportunities in single family zones should be sooner than 2029. This initiative for single-family and high resource areas should be synchronized with the Objective 6.2e date of 2026.
  • Objective 6.2f should also include updating the Local Coastal Plan (LCP).
  • Objective 6.3a the initial milestone of listing properties should be earlier than June 2027.
  • Objective 6.4b should be tightened to the action phrase “Amend the City’s Relocation Ordinance by September 2025”

Policy 7 - Resource Conservation and Environmental Stewardship

  • Objective 7.1a, 7.1b, 7.1c, 7.2b, 7.3a, 7.3b, 7.4b lack milestones with dates. 
  • The City should add the University to their commitment to provide infrastructure in Objective 7.1c. The City has been and continues to be a significant barrier to development at UCSC, as evidenced by past and ongoing litigation.  
  • Objective 7.3b promotes bikeable/walkable neighborhoods, but with few specifics. This could reference current ongoing efforts such as updating the City’s Active Transportation Plan.

Transit Oriented Development and Alternative Modes of Transportation

We still encourage a program to look at increased density along the Coastal Rail Trail, with a focus on station locations to ensure rail service is feasible.