State law requires cities to update their General Plan Housing Element every eight years. The City of Rocklin has prepared a Draft Housing Element for the 2021-2029 planning period, which includes an analysis required by State law related to: 1) existing demographics and housing characteristics; 2) market, government and environmental constraints; 3) land, financial and administrative resources available to meet housing demand; 4) accommodation of the City’s Regional Housing Need Allocation; 5) establishment and/or modification of goals and policies to address housing needs; and 6) a review of past accomplishments under the 2013 - 2021 Housing Element.
The City’s General Plan Safety Element and associated Action Plan is also being concurrently updated to address climate adaptation and resiliency strategies and identify new information relating to flood and fire hazards in compliance with State law and recent legislation. Update of the Safety Element is required to be completed in conjunction with the Housing Element Update.
Detailed descriptions of goal, policy and program additions, deletions and modifications associated with both the 2021-2029 Housing Element and 2021 Safety Element Update are included in the project summary contained in the General Plan EIR Addendum document.
The Planning Commission reviewed and conducted a public hearing for these items on August 3, 2021. During their deliberations, some members of the Commission expressed concern regarding the broadness of the language in proposed Safety Element Policy S-26, but no formal recommendation was made by the Commission regarding language revisions.
Upon further review, staff agrees that Policy S-26 as originally drafted should be revised to ensure appropriate protections and considerations for sensitive uses when adjacent to new facilities that are using, storing or producing hazardous materials. Therefore, staff recommends the following revisions to the policy and associated Action Plan Step and has incorporated the revised language into the General Plan EIR Addendum, Safety Element and Safety Element Action Plan documents that have been provided in the City Council meeting packet. Staff has also revised Safety Element Action Plan Step SA-6(n) for consistency with Safety Policy S-35.
Safety Element Policy S-26 Revised Language
S-26 Prohibit Ensure that any new facilities using, storing or producing hazardous materials, particularly those from being located directly adjacent to existing residential or school uses, comply with all applicable handling, safety and disposal regulations.
Safety Element Action Plan Step SE-6(m) Revised Language
SA-6(m) - Refer requests for comment related to new projects using, storing or producing hazardous materials to applicable responsible agencies to ensure proper handling, safety and disposal measures are incorporated. Restrict developers from receiving approval on projects engaging with significant volumes of hazardous materials that would be located next to housing or schools.
Safety Element Action Plan Step SE-6(n) Revised Language
SA-6(n) - Require developers of residential projects to provide a minimum of two ingress and egress points, or approved equivalent, in the project.
During the public comment portion of the hearing for these items, Beth Gonzales, representing Placer People of Faith Together (PPOFT), spoke to and read much of the correspondence she had submitted following publication of the Planning Commission’s agenda packet, which had also been provided to the Planning Commission in a Blue Memo prior to the start of the regular meeting. The full letter has also been provided as Attachment 5 to this City Council staff report.
Ms. Gonzales emphasized her desire for the City to budget funds for affordable housing development, consider implementing a zoning overlay that would allow churches to build or provide accommodations for either permanent or temporary affordable units on their property, allow and promote safe parking programs on church properties, and suggested that Mercy Housing be added as a qualified entity on page 7-38 of the 2021-2029 Housing Element Adoption Draft.
Some members of the Planning Commission expressed interest in having the City learn more about the program concepts suggested by PPOFT, and others noted that implementation of these types of items could be beneficial, but also complex in terms of how they relate to existing codes and regulations.
Staff noted that Placer County has just embarked on a regional initiative to develop an updated plan to address homelessness. The City is and will continue to be an active participant in that process. Staff recommended that the City wait to see what comes out of that broader effort before adding more City specific programs.
With regard to the request to add Mercy Housing to the list of qualified entities on page 7-38 of the Adoption Draft Housing Element, the context in the paragraph preceding the list discusses entities that specialize in the purchase of “At Risk” Housing developments. While Mercy Housing is a well-known and respected affordable housing developer and operator, staff is not aware that they specialize in that particular arena and therefore would not recommend that they be added to the document in that location. In addition, the list of qualified entities provided in the Housing Element was not intended to be exclusive, and the City is always willing to work with any future qualified entity that may approach the City regarding affordable housing.
The Planning Commission voted 4-0 (one vacancy) to recommend City Council approval of the General Plan EIR Addendum, 2021-2029 Housing Element Update and 2021 Safety Element and Action Plan Updates as proposed.
Housing Element Update
Like many cities and counties throughout the state, the City of Rocklin is in the process of updating its 6th Cycle 2021-2029 Housing Element consistent with recent legislation and state law.
All documents, presentations, meetings and hearings related to the Housing and Safety Element Update discussed below have been open and available to the public. Prior packets and audio or video from the City’s Regional Housing Needs Allocation (RHNA) Committee, Planning Commission and City Council meetings can be found by entity and date on the City’s website at: https://www.rocklin.ca.us/agendas-minutes.
Correspondence received from other agencies or the public periodically throughout the course of the update process have been incorporated into various packets, as applicable depending upon their timing, and are not repeated in this report. Any correspondence received after publication of this packet and prior to the City Council meeting will be published and forwarded to the City Council.
Long before the formal start of the City’s current Housing Element Update, the City participated in a Regional Assessment of Impediments to Fair Housing (AI), which included extensive public outreach both with Rocklin stakeholders and those throughout the Sacramento region.
The City also formed a Regional Housing Needs Allocation (RHNA) Committee that conducted public meetings approximately every two weeks for a nine-month period between October 2018 and June 2019. The RHNA Committee, comprised of local housing and affordable housing developers, current and former City Council Members, Planning Commissioners and representatives from the Building Industry Association (BIA), examined a number of criteria and critical factors culminating in specific recommendations for sites to be included in the City’s Available Sites Inventory for the 6th Cycle Housing Element Update.
The City Council conducted a public hearing on July 28, 2020 and provided direction to staff regarding sites to be included in the RHNA Resolution of Intent (ROI) for inclusion in the Housing Element Update Available Sites Inventory and associated General Plan Amendments and Rezones. Actual General Plan Amendments and Rezones will be separately processed.
The City Council conducted a public workshop to solicit input on potential housing programs on September 22, 2020.
A Public Review Draft 2021-2029 Housing Element was prepared and widely distributed for public review on November 20, 2020.
The City Council and the Planning Commission conducted a special joint meeting and public hearing on December 8, 2020 to provide an additional opportunity for input prior to the City’s submittal of the document to the State Department of Housing Community Development (HCD) for their technical review.
The Draft 2021-2029 Housing Element document was submitted to HCD for their initial 60-day review on December 23, 2020.
Staff and the City’s Housing Element consultant team (PlaceWorks), worked with staff from HCD during that agency’s 60-day review period answering questions, providing additional text, maps, data and clarifications that HCD asked be incorporated into document.
Although staff's goal was that all items could be resolved by the close of HCD’s initial 60-day review period, a limited number of items remained outstanding and were included in the February 19, 2021 Findings Letter that the City received from HCD.
Staff provided an update to the City Council at the regular meeting on April 27, 2021 regarding the issues raised by HCD in their February 2021 letter and one additional item. Staff also provided a series of recommendations for how the items could be addressed. The items discussed with the City Council on April 27, 2021 included:
- Modifications to the Available Sites Inventory for the Lower Income Category to address a 5th Cycle Carryover.
- Revised Accessory Dwelling Unit (ADU) Assumptions.
- Incorporation of a more proactive approach to housing mobility and affirmatively furthering fair housing opportunities in high resource areas.
- Expanded evaluation of Housing Conditions and incorporation of a more proactive approach to address preservation/maintenance of existing affordable housing stock and avoid displacement.
- Suggested program language regarding review of regulations pertaining to large residential community care facilities.
Following receipt of the City Council’s direction at the April 27, 2021 meeting, staff and the consultant team completed a series of revisions to the document. The REVISED Public Review Draft 2021-2029 Housing Element was resubmitted to HCD on May 21, 2021 with a request for that agency’s expedited review. The City simultaneously released the REVISED Public Review Draft 2021-2029 Housing Element in track changes form for additional review by the public, stakeholders, Planning Commission Members and Members of the City Council.
Submittal of the May 21, 2021 REVISED Public Review Draft 2021-2029 Housing Element initiated a second 60-day review period for HCD, with comments due back to the City no later than July 20, 2021. In their July 20, 2021 response letter (see full HCD letter in Attachment 1 to this Staff Report), HCD requested the following additional items be addressed:
ADU’s
Unfortunately, HCD was not moved by all the data and narratives provided in the REVISED May 21, 2021 Public Review Draft Housing Element describing the potential for ADU development in Rocklin. Further, they did not concur that (based on past trends) 192 ADU’s are achievable within the 8-year Planning Period and do not support inclusion of that assumption in the City’s RHNA Available Sites Analysis.
HCD is insisting that ADU projections for Rocklin and other agencies be based on recent past trends alone and have indicated in their letter that only 32 units can be assumed in the City’s RHNA Available Sites Summary Table as coming from ADU’s. Through subsequent communication with HCD, agency representatives verbally agreed that the number of ADU’s assumed toward RHNA could be increased to 40 units. This does not prevent the City from striving to achieve a much higher number through the use of marketing, pre-approved plans, etc. In addition, any ADU units that are constructed within the Planning Period can count toward the City’s RHNA accomplishments at whatever level of affordability can be documented. The Housing Element document presented for consideration has revised narratives and tables to reflect HCD’s direction on this topic.
Enhanced Housing Mobility Strategies
HCD has indicated that the proposed programs to enhance housing mobility and affordability in high opportunity areas (i.e., promote the use of Housing Choice Vouchers and development of ADU’s in high opportunity areas) do not go far enough to address these issues. The City requested more specific direction from HCD staff on this topic in an attempt to ensure that additional revisions would be considered adequate by HCD. As a result of those discussions, a number of text clarifications and program revisions have been incorporated into the Housing Element document presented for consideration. Please see the screen shots in Attachment 2 to this staff report showing all new text incorporated into the July 2021 Housing Element Adoption Draft in response to HCD’s July 20, 2021 comment letter. The latest edits to the document are shown in yellow highlight.
Housing Condition Survey
Due to limited staffing and the number of programs already required to be implemented within one year of Housing Element adoption and/or within one year of the Planning Period (from May 15, 2021), the City had proposed to complete a Housing Condition Survey and formulate an implementation plan to reduce the potential for displacement of individuals within existing affordable units in 2023. HCD has indicated that this effort needs to be initiated sooner. The Housing Element document presented for consideration includes revised language indicating that implementation will occur by August 2022.
Conversion of Available Sites Inventory Into HCD Template
HCD has developed a very specific Excel Table for Available Sites Data that it is now requiring all agencies to use. This table was not available for use when the City’s original 2021-2029 Public Review DRAFT Housing Element was prepared and released. The new format is extremely difficult to work with in terms of initial input and editing. In order to minimize the number of times input and editing would be required, the City’s consultant will complete this item following City adoption of the Housing Element Update.
Housing Element Adoption Schedule
In order for the City to remain on an eight-year cycle for future Housing Element Updates (instead of every four years), the City Council must take action to adopt the Housing Element on or before September 10, 2021. The last regular City Council Meeting prior to that deadline is August 24, 2021.
Safety Element Update
The required update of the Safety Element has also been triggered by recent legislation. The revised Safety Element has been prepared to follow the most recent State guidance and recommendations on community safety and vulnerability. It is also consistent to the extent possible with recent and ongoing related plans across Placer County, including the new Placer County Sustainability Plan and the ongoing update to the county-wide Local Hazard Mitigation Plan (LHMP) which is still in process. The City adopted the 2016 county-wide LHMP by reference into the current Safety Element and anticipates that a similar process will need to completed in the future following adoption of this Safety Element Update once the latest county-wide LHMP has been completed.
The Safety Element and associated Action Plan has been reviewed by City Departments and distributed to appropriate state agencies.
Findings and Conclusions
Staff and the City's consultant team believe that the July 2021 2021-2029 Housing Element Adoption Draft being presented can be found by HCD to comply with all statutory requirements outlined in Article 10.6 of the Government Code and qualify for Final Certification by that agency.
The 2021 Safety Element and associated Action Plan updates have also been prepared to comply with state law including recent legislation.
An Addendum to the 2012 Rocklin General Plan EIR is the appropriate level of environmental review for the project.
The proposed 2021-2029 Housing and 2021 Safety Element documents are consistent with the other elements of the General Plan.