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

April 25, 2023

n 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. We support sustainable growth, including along transportation corridors and activity centers and a commitment to lower Vehicle Miles Traveled by housing people near services and jobs. The following are our comments on the City of Santa Cruz’s 6th cycle Housing Element draft in no particular order. 

The University

One of the largest sites for new housing in the next eight years will be UC Santa Cruz. The city acknowledges this in their site inventory and policy plan. Despite this, the city has been and continues to be a significant barrier to development at the university, as evidenced by past and ongoing litigation. (1) This is not acknowledged in the constraints portion of the city’s housing element. 

The city should make a good faith effort to analyze the barriers it presents to housing construction and planning with regards to UCSC and propose programs to mitigate these impacts. We suggest a commitment to providing municipal services to new housing at UCSC and a policy to not sue over housing production on campus.

We would also like the city to provide a reference for the affordability levels assumed for the UC Santa Cruz units. While there has been talk of these rents being set below market rates, providing a reference to a commitment is important as this is the single largest source of affordable units for the city in this cycle.


Pipeline Projects

The largest source of new units for the city during the 6th cycle will likely be from pipeline projects. For jurisdictions relying heavily on pipeline projects, HCD recommends (2) that “…the element should include programs with actions that commit to facilitating development and monitoring approvals of the projects, including the number of units and affordability (e.g., coordination with applicants to approve remaining entitlements, supporting funding applications, expediting approvals and monitoring of project progress, including rezoning or identification of additional sites, if necessary).”

In order to meet this recommendation by HCD, the city should create policies to monitor the progress of pipeline projects. This could include automatic entitlement extensions until midway through the 6th cycle, a commitment to work with the Coastal Commission on facilitating housing proposed in the coastal zone, and proactively reaching out to all pipeline projects to confirm that there is still development interest.


Policy 1 - Housing Production

We are thrilled that the city has met their 5th cycle goals, however, with no rezoning taking place to meet the 6th cycle production goals, policies to increase housing production will be of huge importance. 

Additionally, it is stated under Policy 1.2 that most new housing will be concentrated in the central core of the city, meaning along major commercial corridors and on major opportunity sites. While we laud recent progress that has been undertaken in the latter scope, we believe that the city should be looking towards additional opportunities as well as this scope could serve to not meet AFFH goals if new housing opportunities are restricted to downtown, commercial corridors, etc. In practice, this would serve to leave out neighborhoods such as Seabright, the majority of the West Side, Arana Gulch, etc. from seeing their fair share of development. 

Policy 2 - Affordable Housing

The ordinance options allowing 100 percent affordable residential development to be considered a “by-right” use would greatly speed along much needed affordable housing. As such, we urge expedited approval of this policy to 2024 or earlier (currently by the end of 2025). A commitment to developing or declaring city parking lots downtown surplus by a certain date with the goal of providing affordable housing would also be a valuable policy.

As part of objective 2.4c, we 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 support establishing a Tenant Opportunity to Purchase (4) program to help prevent displacement, empower tenants, and preserve affordable housing when the owner decides to sell.


Small Sites Program

The site inventory identifies a significant number of small parcels for development, many of which are projected to accommodate low income units. Per HCD’s Site Inventory Guidebook (5) “A parcel smaller than one half acre is considered inadequate to accommodate housing affordable to lower income households, unless the housing element demonstrates development of housing affordable to lower income households on these sites is realistic or feasible.” The city claims that many of these parcels have development opportunities due to common ownership with adjacent parcels; we would like to see the site inventory expanded to include these adjacent sites. 


Mid-cycle Review

To ensure the city makes appropriate progress towards its 6th cycle goals we would like to see a commitment to a mid-cycle review and adjustment (if needed). Tying this review to programs to increase housing production such as rezoning, ADU incentives, or removing development constraints would allow the city to quickly make up lost ground and minimize impacts of falling behind in the 6th cycle. This would also be a time to review pipeline projects which have not progressed.

Additional mid-cycle programs could include ministerial approval for all site inventory projects and SB10 upzoning of small sites to 10 units per parcel.

FAR and Density

A significant constraint to development of 2+ bedroom units is the units/ acre density requirement, something that does not apply to smaller units such as SROs. In order to increase the number of family sized (2+ bed) units built, this constraint should be removed or significantly modified. This could also be addressed by increasing the FAR for projects consisting of 50% or more 2+ bedroom units. This increase should allow the same net number of units as if they were proposed as SROs or a similar unlimited density unit. 

Policy 5 - Neighborhood Vitality

Policy 5 (Neighborhood Vitality) opens with the following context: “Quality of life is shaped, in part, by neighborhood conditions in Santa Cruz. As an older, established community, Santa Cruz requires a concerted effort to encourage the maintenance, rehabilitation, and improvement of housing and to promote sustainable, livable neighborhoods in the face of increasing density.” We wholly reject the framing that density and sustainable, livable neighborhoods are incompatible. The city should update this language.

Missing Middle

Creation of missing middle housing isn’t mentioned within the policy plan - the city should adapt zoning regulations that would incentivize this form of housing. Examples include reducing minimum lot size, lot width, and parking requirements (kudos to the latter already being included!). In Redwood City’s compliant 6th cycle housing element (6) amendments such as these are anticipated to result in an increase of at least 80 homes.


Upzoning Near Potential Light Rail Stations

The RTC has multiple scenarios for a passenger light rail route. In most scenarios stations would be located on the Westside, Bay/California, Downtown, and Seabright. (7) We encourage a program to look at additional density along the Coastal Rail Trail, with a focus on these station locations.


Tenant Protections

As a majority-renter city, it is important that we have strong tenant protections. There are a number of programs we would like to see implemented or expanded in the city including:

  • Elimination of or cap on rental application fees
  • Creation of a rental registry. This was recently passed by both Salinas(8) and Monterey (9)
  • Local preference for people employed in the county
  • COPA and TOPA programs (see Policy 2 - Affordable Housing)
  • Conduct a disparate impact analysis of non-high(est) resource areas (10) and apply a live-work preference if if it matches county demographics



We are pleased to see that elimination of parking minimums is included as a policy objective. In the city’s work to achieve this, we believe the elimination of such requirements within a mile walking area of five or more amenities (pharmacies, grocery stores, transit stops, etc) would be a good intermediate policy stepping stone.

We also encourage the city to work with METRO and AMBAG to advocate for the creation of and planning for more high quality transit stops within the city in the 2050 MTP/SCS (11) (scheduled for June 2026). Such transit stops allow for more sustainable and affordable housing to be built. 


Objective Standards

With the recent implementation of objective standards, the city should set forth a policy for staff to review and recommend if a project is consistent. If found consistent, the project should be placed on the consent agenda for all hearing bodies. Such projects should only be appealable to council if denied by the planning commission. This would greatly increase the incentive for developers to design projects compliant with the standards.

Affirmatively Furthering Fair Housing

As discussed in our Housing Production section, a majority of new housing is being planned along major corridors. This leaves out many exclusive and high opportunity neighborhoods from producing their fair share of housing. We encourage a policy to use SB10 or other means to expand housing opportunities in these neighborhoods and not limited to only Flexible Density Units (6.2d).

Permanent supportive housing is a key solution towards solving homelessness, the city should create a policy to ensure equitable distribution (and development potential) of such housing across all districts.