Comments Regarding San Mateo's Updated Draft 2023-2031 Housing Element

August 9, 2023

City of San Mateo
330 West 20th Avenue
San Mateo, CA 94403

email to: Housing@cityofsanmateo.org, citycouncil@cityofsanmateo.org,
planningCommission@cityofsanmateo.org

Subject: San Mateo 2023-2031 Housing Element – comments on July 26, 2023 update

Dear Mayor Lee and Members of the San Mateo City Council, Planning Commission, and City Staff,

The Sierra Club Loma Prieta Chapter's Sustainable Land Use Committee (SLU) advocates on land use issues in San Mateo and Santa Clara Counties. Thank you for providing the opportunity for SLU to provide input on the July 26, 2023 Updated Draft San Mateo 2023-2031 Housing Element (HE).

The overall updated draft Housing Element (HE) is an improvement, but more focused and stronger policies and programs are needed to have a reasonable expectation of meeting the RHNA number of 7,015 new housing units, particularly for affordable units. Our key comments are listed below.

City staff need to communicate very closely with the California Department of Housing and Community Development (HCD) to assure a high likely hood that this HE version will be approved.
 

This is the third review of a proposed HE to HCD and time is running out to get the HE certified. Not having the HE certified in a timely manner has major negative consequences for San Mateo. This includes losing control of development (e.g., Builders Remedy), losing access to government funding, and undermining all the other important aspects of the proposed 2040 General Plan including the planned vote in November 2024 to consider changes to Measure Y.

City staff should be in very close communication with HCD staff to assure that this HE version is very likely to be certified.

The City must take strong new actions to assure that the RHNA goals are met


Obtaining a HCD certified HE is just an interim step toward the real goal of having the RHNA goals met, particularly for affordable housing units. The HE Housing Plan (p. H-70 to H-97) needs to demonstrate a significant change to current policies and programs in order to realistically be able to reach the goal. The lack of affordable housing on the Peninsula is a significant contributor to environmental degradation as workers must commute long distances by car, emitting greenhouse gases (GHG) as well as other pollutants. It also leads to sprawl, as more development is done in areas that were open space or agricultural land.

There are specific areas that will need to be retained or expanded to make sure the final HE contains the key actions needed to make significant progress on addressing the enormous lack of affordable housing in the Bay Area. Listed below are the most important goals, policies, and programs in the HE that need to be retained and strengthened in the final HE.

The “buffer” for meeting the goals for affordable units (low and very low) is only 9% as shown on page H-7. This is a lower number than in the earlier versions of the HE. This makes it less likely that enough affordable units will be built. The buffer number for affordable units should be higher.
 
The HE should prioritize policies and programs that reduce costs and streamline the processes for affordable units. The following policies and programs should be strengthened to accomplish this need:
 
H1.7 -Update Zoning Codes to Support Housing Production,
 
H 1.8 - Adopt Objective Design Standards,
 
H 1.9 – Establish Minimum Densities for Mixed-Use Projects, and
 
H 1.12 - Encourage Development of Missing Middle Housing within half mile of the transit corridor.
 
Funding that can be used to support affordable housing is a fundamental need and more must be done to obtain funding. This could include establishing or increasing Vacancy Tax, Commercial Linkage Fees, and Transfer Tax. It is particularly important that funding focus on repairing the legacy of discrimination in housing. The following policies and programs should be strengthened to accomplish this goal:
 
a. H 1.2 - Utilize Public Funding for New Affordable Housing,
 
b. H 1.3 - Increase Affordable Housing Production,
 
c. H 1.17 - Permitting and Development Fee Schedule Review,
 
d. H 3.3 – Evaluate Housing Revenue Sources,
 
e. H 5.1.1 - Adjust the City's Below Market Rate (inclusionary) program to provide larger density bonuses, and/or increased city support in exchange for affordable units in high resource areas.
 
f. H 5.1.2 - Support the design of a regional forgivable loan program for homeowners to construct an ADU that is held affordable for extremely low-income households. However, the units should be dedicated for at least 30 years, with affirmative marketing to households with disproportionately high housing needs including persons with disabilities, single parents, and minority households, and
 
g. H 5.1.3 - Explore the potential to implement a loan program for ADU construction If a City-funded ADU loan program is determined to be infeasible. The City will support the design of a regional forgivable loan program for homeowners to construct an ADU that is held affordable for extremely low-income households for 15 years.
 
The updating of H1.20 “Adopt San Mateo General Plan 2040” is built into the HE.
 

H1.20 would lead to a ballot measure in November 2024 to update Measure Y. If approved by the voters, significantly higher density and heights would be possible in key areas, such as near transit. This change, if approved, will make meeting the RHNA numbers more possible. It will also potentially make providing more open space to “green” the City more feasible (parks, open space, trees, wider and safer bike and pedestrian paths, restoring creeks and riparian areas, etc.). However, it is important that the City have a strong communication plan to inform the voters of the reasons for this vote and the consequences of approval or denial. The plan to meet RHNA needs to be clear in case the measure fails.

We ask that you consider this information as you finalize the Housing Element for submission to the State HCD. SLU is prepared to help the City in advancing the HE as it is finalized and when it goes into effect.


Respectfully submitted,

Gita Dev
Co-Chair Sustainable Land Use Committee, Sierra Club Loma Prieta Chapter