Blog To HCD: Santa Cruz YIMBY Comments on Scotts Valley Housing Element (February 2024)

Letter sent to HCD on March 18, 2024 re: Scotts Valley

March 18, 2024

The Housing Element process is intended to make sure all California jurisdictions undertake a good-faith effort to plan for the housing needs of their communities over the following eight years. This feedback is on the February 2024 update to the December draft adopted by the City Council. We do not believe the changes on the revised December draft substantively address findings that HCD shared in a letter dated December 19, 2023 to Scotts Valley.

Affirmatively Furthering Fair Housing

HCD comment(s)from letter dated December 19, 2023: Given the fair housing conditions in the City and the location of RHNA sites, the element will need to include significant actions to promote housing mobility (e.g., housing choices and affordability) throughout the City to promote inclusive communities.

Scotts Valley has added additional text to Program H-3.2, AFFH. Scotts Valley needs to commit to land use reforms and with specific actions that affirmatively further fair housing, especially promoting housing mobility. Their approach to housing mobility beyond ADUs and SB9 is outreach and vague commitments. e.g.:

  • “explore land use strategies for providing ‘missing middle” housing” [page 2-24]
  • “conduct outreach to the development community to identify strategies to allow conversion of existing single-family residences into missing middle housing typologies (i.e., duplexes, triplexes, fourplexes, and multiplexes)” [page 2-24]
  • “[f]acilitate the development of 50 missing middle housing units”

Please note that Scotts Valley’s Annual Progress Report for 2023 includes ONLY single-family-detached and ADU homes. Scotts Valley should commit to analyze feasibility and develop incentives for missing middle homes, similar to the City of Santa Cruz, who is using a REAP grant for “Promoting Inclusive Residential Infill Development through Objective Standards for Properties with R-1 Single Family Residence Zoning (PL)” (see description here.)

Pipeline Projects

HCD comment(s) from letter dated December 19, 2023: Progress in Meeting the RHNA: The element was revised with a high-level statement indicating that there are no known barriers to development (pg. F-7) and updated each project status to state that the City continues to work with applicants on remaining steps. However, this does not demonstrate whether these units will be constructed and made available during the planning period.

Pipeline projects are incredibly important to the city meeting its housing goals, as existing projects make up roughly 20 percent of site inventory units and 34 percent of RHNA. Due to the significance of these projects, Scotts Valley should be doing everything in its power to ensure they move forward and actually get built during the 6th cycle. 

We repeat that some pipeline projects have been around for a while, including in the last RHNA cycle. The Town Center project has been in discussion since at least 2008, La Madrona’s EIR was started in 2020, and Valley Gardens’ in 2021.  We note the additions to Program H-1.3 which are to “identify strategies” rather than commitments to implement.  We want to see more realistic timelines for development of these projects in Appendix F (Pages F-7 thru F-9) and a stronger commitment to work with the developers to address barriers which may be delaying the process. 

In contrast, the city made great additions to Program H-1.10 regarding Surplus Land that relates to the Town Center project. 


HCD comment(s) from letter dated December 19, 2023: Land-Use Controls:...HCD’s prior review found that the element must analyze the City’s development standards including heights, lot sizes, setbacks, site coverage and maximum density requirements for potential constraints.…..While the element includes a program to revise development standards as part of the City’s rezone requirements, this program should not be limited to rezoned sites and should generally address parcels in the C-S and C- SC zones that permit multifamily and mixed-use housing.

We wholeheartedly agree with HCD’s recommendations for expanding revisions to development standards across the entire city, not only proposed rezoned sites. Financial feasibility must be part of any comprehensive study of development standards. We continue to recommend a higher base density than 40 du/acre for Mixed-Use parcels along transit corridors. Even with the other modifications, it may be that smaller projects just cannot meet and contribute to affordability requirements.