HomeMy WebLinkAboutReso 162-2023 ( 23-884)
400 GRAND AVENUE P.O. BOX 711 SOUTH SAN FRANCISCO, CA 94083
CITY COUNCIL 2023
FLOR NICOLAS, MAYOR
MARK NAGALES, VICE MAYOR
MARK ADDIEGO, MEMBER
JAMES COLEMAN, MEMBER
EDDIE FLORES, MEMBER
SHARON RANALS, CITY MANAGER
DEPARTMENT OF ECONOMIC
AND COMMUNITY DEVELOPMENT
Planning Department
E-MAIL: [email protected]
State Department of Housing and Community Development October 5, 2023
C/O Land Use and Planning Unit
2020 W. El Camino Ave, Suite 500
Sacramento, CA 95833
Re: City of South San Francisco 2023-2031 Housing Element Draft Submittal No. 4
Dear Mr. Paul McDougall,
Please find the City of South San Francisco’s Addendum to the Adopted Housing Element for
HCD determination that is complies with all state statutes. A word version summary of all
Addendum edits is attached, as well as a redlined Adopted Housing Element for review.
Please advise if this appropriately addresses HCD concerns listed in your guidance letters and if
we are now ready for Certification.
We look forward to the continued progress,
Tony Rozzi, AICP | he/him | Deputy Director
Economic and Community Development Department
City of South San Francisco
(650) 877-8535 | [email protected]
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SSF Draft Housing Element Submittal No. 4 to HCD – Track Changes Letter Only
400 GRAND AVENUE P.O. BOX 711 SOUTH SAN FRANCISCO, CA 94083
1. Include an analysis and documentation of household characteristics, including level of
payment compared to ability to pay, housing characteristics, including overcrowding, and
housing stock condition. (Gov. Code, § 65583, subd. (a)(2).)
Housing Stock Condition: The element mentions substandard housing based on ACS data
as it captures units in substandard condition as self-reported in Census surveys. As stated
in the previous review, the element must estimate the number of units in need of rehabilitation
and replacement. This estimate should include local information from a recent windshield
survey or sampling, estimates from the code enforcement agency, or information from
knowledgeable builders/developers, including non-profit housing developers or
organizations.
The survey has been completed and is copied below for review and comments.
Housing Stock Windshield Survey
City staff completed a windshield survey of the whole City. As a whole, most of the residential
neighborhoods in the City are in generally good condition and buildings are well-maintained.
Within each Planning Sub-Area / Neighborhood, there are a mix of newer and older
residential buildings; some of the older buildings are in more need of repair due to age of
building, weather conditions, material deterioration, etc. (see below images). Key
characteristics of each Planning Sub-Area / Neighborhood are highlighted below.
Figure 1: Planning Sub-Areas
Avalon-Brentwood
• Generally newer homes in good condition.
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400 GRAND AVENUE P.O. BOX 711 SOUTH SAN FRANCISCO, CA 94083
Downtown
• Mix of newer and older homes and multi-family residential buildings.
• Oldest part of the City with many historic structures, some of which are in need of restoration.
• More overcrowded part of the City, with higher percentage of rental properties that are not
well-maintained and in need of repair.
East of 101
• No existing residential.
El Camino Real
• Primarily commercial buildings with some newer mixed-use / multi-family developments in
good condition.
Lindenville
• No existing residential.
Orange Park
• Generally newer homes in good condition.
Paradise Valley/Terrabay
• Newer homes north of Hillside Blvd / Sister Cities Blvd that are in good condition.
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SSF Draft Housing Element Submittal No. 4 to HCD – Track Changes Letter Only
400 GRAND AVENUE P.O. BOX 711 SOUTH SAN FRANCISCO, CA 94083
• Older area south of Hillside Blvd / Sister Cities Blvd has more homes that are in need of
minor repair.
Sign Hill
• Generally newer homes in good condition.
Sunshine Gardens
• Generally newer homes in good condition.
Westborough
• Some older homes in need of repair, primarily due to deterioration from weather conditions.
Winston Serra
• Generally newer homes in good condition.
Summary
Overall, there are three neighborhoods where some portion of homes were noted for repair:
1. Downtown
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SSF Draft Housing Element Submittal No. 4 to HCD – Track Changes Letter Only
400 GRAND AVENUE P.O. BOX 711 SOUTH SAN FRANCISCO, CA 94083
2. Paradise Valley/Terrabay
3. Westborough
For the Downtown area, overcrowding, rental stock that has not been maintained, and
income levels are the primary determinants. Paradise Valley represents some of the older
homes adjacent to Downtown and suffers from similar characteristics and demographics.
Westborough’s location is defined by consistent weather and atmospheric influences on
building materials. The following Housing Programs have been modified to focus repair
investment in these neighborhoods:
Program PRSV-1.1 – Minor
home repair
Annually Citywide with focus on
identified lower
opportunity and
income areas
5 per year per District
(5 Districts)
Program PRSV-1.2 –
Prioritize funding for
housing rehabilitation
Annually
Program PRSV-1.3 –
Provide low interest loans
for housing rehabilitation
Annually
(HE Location Page 38):
2. An inventory of land suitable and available for residential development, including vacant sites
and sites having realistic and demonstrated potential for redevelopment during the planning
period to meet the locality’s housing need for a designated income level, and an analysis of
the relationship of zoning and public facilities and services to these sites. (Gov. Code, §
65583, subd. (a)(3).)
Identify actions that will be taken to make sites available during the planning period with
appropriate zoning and development standards and with services and facilities to
accommodate that portion of the city’s or county’s share of the regional housing need… (Gov.
Code, § 65583, subd. (c)(1).)
Realistic Capacity: The element must still account for the likelihood of residential
development in zones that allow for 100 percent nonresidential development. For example,
the element could discuss which zones allow 100 percent nonresidential development,
evaluate all (residential and nonresidential) recent trends in the zones, discuss how often
these developments include a residential component and account for that likelihood in the
calculation of residential capacity.
The Housing Element identifies three opportunity site corridors to meet RHNA Cycle 6
obligations:
1. Lindenville Opportunity Corridor
2. S. Airport Boulevard Opportunity Corridor
3. El Camino Real (North and South) Opportunity Corridor
Each one of these corridors will be evaluated individually for the potential conflict between
non-residential development and realistic residential development.
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SSF Draft Housing Element Submittal No. 4 to HCD – Track Changes Letter Only
400 GRAND AVENUE P.O. BOX 711 SOUTH SAN FRANCISCO, CA 94083
1. Lindenville Opportunity Corridor – red-lined edits beginning on P. 88
This sub-area is identified as Lindenville and covering 82 sites listed in Table 5-5 “Lindenville
Corridor Housing Opportunity Sites”. Mixed-use and 100% residential uses and 100% non-
residential uses are permitted throughout the selected opportunity sites, which are zoned
either T3C, T4C, T4M, or T5C.
Recent nonresidential trends in the City are almost entirely focused on Life Science Office
development – this use is well capitalized, has available financing from both traditional
markets and venture capital, and commands substantial rental rates once constructed. Life
Science Office can out compete any other land use on a price per square foot basis. In order
to manage the economic forces driving current Life Science Office development in the City,
Life Science Office uses are not permitted in these zoning districts where they would
otherwise displace potential housing development.
Additionally, any other non-residential use is proposed to be Floor Area Ratio (FAR)
restricted under the Lindenville Specific Plan zoning, as follows:
Nonresidential FAR: 2.0 max. if residential on-site, 0.5 if no residential on-site
For the Lindenville Corridor, previous allowable uses were confined to industrial uses only.
No significant redevelopment projects have been proposed during the entire RHNA Cycle 5
period from 2015-2023 and this sub-area of the City could be categorized as stable with
strong occupancy. The introduction of residential use to the area is likely to upend property
values to some extent, particularly for long-time property owners with a low cost basis.
Holistically, other development cycle forces aside from residential zoning also play an
important role – the regional job/housing ratio, available land for residential development
region wide, and a City’s streamlined review process all matter.
Recent residential trends in South San Francisco suggest the construction of jobs
continue to outpace housing units, there was limited land for residential development close
to transit until the General Plan Update was adopted, and entitlement review processes are
limted and quick (as explored in Chapter 4, page 50+). These factors combine to make
stable, low occupancy industrial uses in the Lindenville Corridor viable residential opportunity
sites. The pipeline project at 7 S. Linden Avenue is a great example – redevelopment of a
single story industrial campus with over 550 rental units. Other potential pipeline applications
(owner has expressed interest, hired architect, or otherwise entered into property sale
negotiations with a residential developer) include:
• 70 Unit Townhome Development on Railroad Avenue under the T4C Zoning
• 40 Unit Townhome Development at 170 S. Spruce Ave under the T3C Zoning
• 150 Unit Development on S. Spruce Ave under the T4C Zoning
• 150 Unit Development at 1487 Huntington Ave under the T5C Zoning
By limiting FAR development for 100% nonresidential development, the City is preserving
the Lindenville Corridor for either A) adaptive reuse of existing buidlings for maker space and
other light industrial users, or B) residential redevelopment that is permitted with high FAR
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400 GRAND AVENUE P.O. BOX 711 SOUTH SAN FRANCISCO, CA 94083
and density allowances. Our calculations for realistic capacity, however, are always based
on minimum FAR to ensure a conservative optimism for redevelopment on opportunity sites.
2. South Airport Boulevard Opportunity Corridor
This sub-area is identified as South Airport Boulevard and covering 41 sites listed in Table
5-6 “South Airport Boulevard Corridor Housing Opportunity Sites”. Mixed-use and 100%
residential uses and 100% non-residential uses are permitted throughout the selected
opportunity sites, which are zoned either T5C or T6UC.
Recent nonresidential trends in the City are almost entirely focused on Life Science Office
development – this use is well capitalized, has available financing from both traditional
markets and venture capital, and commands substantial rental rates once constructed. Life
Science Office can out compete any other land use on a price per square foot basis. In order
to manage the economic forces driving current Life Science Office development in the City,
Life Science Office uses are not permitted in these zoning districts where they would
otherwise displace potential housing development.
For the South Airport Boulevard Corridor, previous allowable uses were confined to
hospitality, amenity, commercial, and industrial uses only. No significant redevelopment
projects have been proposed during the entire RHNA Cycle 5 period from 2015-2023 and
this sub-area of the City could be categorized as stable with strong occupancy up until
COVID-19 when the hospitatly sector (Hotels, Convention Centers, for instance) was
decimated. The introduction of residential use to the area is likely to upend property values
to some extent, particularly for long-time property owners with a low cost basis. Holistically,
other development cycle forces aside from residential zoning also play an important role –
the regional job/housing ratio, available land for residential development region wide, and a
City’s streamlined review process all matter.
Recent residential trends in South San Francisco suggest the construction of jobs
continue to outpace housing units, there was limited land for residential development close
to transit until the General Plan Update was adopted, and entitlement review processes are
limted and quick (as explored in Chapter 4, page 50+). These factors combine to make
stable, low occupancy industrial uses or low performing hospitality uses in the South Airport
Boulevard Corridor viable residential opportunity sites. The opportunity site at 245 S. Airport
Boulevard is a great example – redevelopment of low cost, poorly reviewed hotel that has
been on the market for sale could result in up to 480 units without State Density Bonus or
maximum densities considered. Other potential pipeline applications (owner has expressed
interest, hired architect, or otherwise entered into property sale negotiations with a residential
developer) include:
• 154 Unit Development on 100 Utah Avenue under the T5C Zoning
Our calculations for realistic capacity, however, are always based on minimum FAR to
ensure a conservative optimism for redevelopment on opportunity sites.
3. El Camino Real (North and South) Opportunity Corridor
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400 GRAND AVENUE P.O. BOX 711 SOUTH SAN FRANCISCO, CA 94083
This sub-area is identified as El Camino Real (North and South) and covering 29 sites listed
in Table 5-7 and 5-8 “El Camino Real – North and South Corridor Housing Opportunity Sites”.
Mixed-use and 100% residential uses and 100% non-residential uses are permitted
throughout the selected opportunity sites, which are zoned T4C, T5C or RH-180.
Recent nonresidential trends in the City are almost entirely focused on Life Science Office
development – this use is well capitalized, has available financing from both traditional
markets and venture capital, and commands substantial rental rates once constructed. Life
Science Office can out compete any other land use on a price per square foot basis. In order
to manage the economic forces driving current Life Science Office development in the City,
Life Science Office uses are not permitted in these zoning districts where they would
otherwise displace potential housing development.
For the El Camino Real Corridor, previous allowable uses were included hospitality, amenity,
commercial, mixed-use and residential uses. Substantial redevelopment activity has
occurred on the residential and public investment side – the City’s new Park and Recreation
Facility and Police Headquarters have been focused at the intersection of El Camino Real
and Chestnut Avenue. These public investments will anchor nearby residential projects just
completed or in the pipeline, as discussed in the next section.
Recent residential trends in South San Francisco suggest the market rate apartmetn
development on the western side of US-101 has been very strong for the last eight years.
The City has entitled or constructed over 2,000 units. Recently completed or pipeline/entitled
projects along the El Camino Real Opportunity Corridor include:
• 800 units at 1051 Mission Road entitled under and currently completing construction
documents.
• 172 units at 988 El Camino Real entitled and fully constructed.
• 184 units at 180 El Camino Real entitled and currently completing construction
documents.
• 338 units at 410 Noor Avenue entitled and under construction.
• 262 units at 1477 Huntington Avenue entitled.
These numbers are based on actual entitled projects, all of which used maximum density
and State Density Bonus Law with their applications. Our calculations for realistic capacity,
however, are always based on minimum FAR to ensure a conservative optimism for
redevelopment on opportunity sites.
(HE Location Page 896):
In addition, the element did not address comments related to the timing of specific plans
completion and clarify whether appropriate zoning is in place prior to implementing the
specific plans.
For the three corridors identified above, all identified zoning used to calculate opportunity site
capacity has been adopted and effective since November, 2022.
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400 GRAND AVENUE P.O. BOX 711 SOUTH SAN FRANCISCO, CA 94083
Additionally, the Lindenville Specific Plan is currently underway and funded primarily through
an MTC/ABAG Priority Development Area grant. Funding must be used and the project must
be completed by the December, 2023. The City is currently on track to complete the project
in the Fall of 2023. The Lindenville Specific Plan may modify zoning to improve the capacity
for residential development, but there are no proposed edits that would reduce capacity
on any opportunity sites identified. Instead, the Lindenville Specific Plan will clarify
specific zoning expectations and maintain or improve densities throughout the study area.
Original General Plan assumptions of base density remain in the draft Housing Element to
be conservative about residential unit yield. Adopted zoning is already in place to permit
housing in Lindenville as part of the Housing Element opportunity site analysis.
At this time, there is no schedule for the creation of a South Airport Corridor Specific Plan
– the City is currently completing applications to submit to MTC/ABAG for expandion of a
Priority Development Area to include this corridor for future study. In the interim, the City has
adopted appropriate density and development standards to permit residential and mixed use
development throughout the South Airport Corridor. A future specific plan, similar to the
Lindenville Specific Plan, will simply refine design and development expectations but will
maintain identified General Plan and zoning densities for purposes of opportunity sites RHNA
assumptions.
(HE Location Page 89):
Nonvacant Sites Analysis: The element did not address this finding. While the element
includes general statements related to the lifecycle of the types of uses that are on the
existing sites, it does not provide support to demonstrate the potential for residential
development on the sites identified in the inventory. See prior review.
See analysis above as response. Edited below per HCD comments:
1. Expand discussion of existing uses, trends to demonstrate potential for
redevelopment
Nearly every opportunity site identified in the adopted Housing Element is non-vacant. This
is the nature of fully built out cities in San Mateo County like South San Francisco. The
existing operation/structures on many of the nonvacant sites is nearing the end of its useful
life, however. The City has attempted to thoughtfully identify opportunity sites with the three
study corridors (Lindenville, South Airport, and El Camino Real) that have underperforming
commercial centers and low density industrial development – none of the identified sites have
existing residential uses, although the City still proposes a new program for no net-loss as a
proactive measure throughout South San Francisco.
The City’s confidence level for these selected opportunity sites redevelopment is high –
nearly every residential project that has been constructed since 2013 has been on
underperforming or underdevelopment commercial properties within the Downtown area or
its environs. While these sites are not as simple as green field development, the City’s
experience and that of associated developers has grown tremendously over the last ten
years. Akin to Redwood City’s downtown success, South San Francisco has mimicked the
adoptiong of objective form based codes, streamlined review under SB 330, and poured
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400 GRAND AVENUE P.O. BOX 711 SOUTH SAN FRANCISCO, CA 94083
millions of Housing Trust Fund dollars into affordable housing projects for pre-development,
land acquisition, and operation.
Review of the City’s eight year performance under RHNA Cycle 5 through the Housing
Element’s Annual Progress Report shows that 81% of the RHNA units were produced.
Without the COVID-19 pandemic and subsequent freeze on residential construction, well
over 100% of total RHNA units (1,864) would have been issued construction permits. While
the City has fallen short in producing the lower income RHNA units, this Housing Element
has new programs in place to improve production – advocate and HCD recommendations
have been incorporated throughout the Housing Element programs for RHNA Cycle 6.
Those are the broad trends of development in South San Francisco. More specifically,
identified pipeline projects provide clues to the City’s redevelopment potential. Table 5-2
indicates the current pipeline projects and existing uses, which are all quite similar to each
other in existing operation and the RHNA Cycle 6 identified opportunity sites:
Site Address APN Existing Use Acres
201 Baden Ave
199 Airport Blvd
012-335-120
012-335-110 Commercial 0.49
180 El Camino Real 014-183-110 Commercial
1477 Huntington Ave 014-184-999 Commercial 1.98
40 Airport Blvd 015-126-010 Commercial 1.63
421 Cypress Ave
209-213 Lux Ave
012-314-070
012-314-080
012-314-090
Commercial
Parking Lot 0.58
455-463 Grand Ave 012-305-060
012-305-070
Commercial
Parking Lot 0.32
7 S Linden Ave 014-074-010 Industrial 4.22
1051 Mission Rd 093-312-050
093-312-060 Vacant 5.9
124 Airport Blvd
100 Produce Ave
015-113-180
015-113-380 Commercial 4.12
423 Commercial Ave 012-323-200 Residential 0.14
These pipeline projects have been entitled for redevelopment on commercial property, some
of which are income positive commercial or industrial uses such a restaurant, office park,
and industrial warehouse facility. This variety of existing uses suggests that similar sites in
the Lindenville, South Airport and El Camino Real corridors with hotels, commercial retail, or
warehouse uses will also have redevelopment potential.
Almost uniformly, the pipeline projects have existing structures that are single or two story
buildings, at least fifty years old, with on-site parking that monopolizes the site. The
opportunity sites selected throughout the three corridors for RHNA Cycle 6 share these
characteristics as these sites historically have been redeveloped successfully in South San
Francisco since 2013. Additionally, the opportunity sites are varied in size. While there are
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400 GRAND AVENUE P.O. BOX 711 SOUTH SAN FRANCISCO, CA 94083
some sites smaller than 0.5 acres, there are two pipeline projects of that size and proceeding
with new residential units. The project at 201 Baden Avenue would be up to 82 units and
entirely affordable.
Finally, the opportunity sites selected are informed by expressed interest in redevelopment
– many property owners reached out to City staff during the General Plan Update process to
upzone and redevelop their properties with mixed use housing. Underperforming hotels (245
S. Airport Blvd) and commercial storage buildings (101 Utah Avenue) along South Airport
Bouleveard, industrial food production facilities in Lindenville (151-171 S. Spruce Ave), and
shuttered restaurants along El Camino Real (840 El Camino Real) have submitted
preliminary applications or initiated conversations with the Planning Division to redevelop into
housing.
(P.951 in redlined HE)
Replacement Housing Requirements: The element includes “comment noted” in response
to HCD’s previous replacement housing requirements finding. However, Cell 112 of the
electronic sites inventory has current residential use on 0.71 acres (APN #101-620-070) with
nine lower-income and 48 moderate-income units. The element must include a program or
remove the site. The replacement housing program must have the same requirements as set
forth in Government Code section 65915, subdivision (c)(3).
Resolved. An incorrect address was used to refer to a mixed use zoned property that is
currently develped with a commercial fast casual restaurant. This address is 471 El Camino
Real, not 455 El Camino Real as previously indicated. The site has been updated (Cell 112)
in the revised HCD Sites Inventory Template to show the existing use as Commercial and
will be resubmitted with the revised Housing Element.
Additionally, the City of South San Francisco already introduced a Program to require no net
loss meeting the expectations of replacement housing requirements, shown below and
edited per HCD letter dated 06/18/23:
Program PRSV-6.1 – Update Zoning Code to require no net loss. The City shall
update the Zoning Ordinance to require that there is no net loss in the number of
residential units during reconstruction or renovation. Replacement provisions will have
the same requirements as set forth in Government Code section 65915, subdivision
(c)(3).
Responsibility: Department of Economic and Community Development – Planning
Division
Time Frame: No later than December 31, 2023
Funding Source: N/A, staff time
(HE Location Page 93212)
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400 GRAND AVENUE P.O. BOX 711 SOUTH SAN FRANCISCO, CA 94083
Supportive Housing: The element includes further information towards addressing this
finding. In addition, the element includes links to updated land use tables and definitions in
the updated General Plan and companion zoning. However, the element needs to describe
and analyze the City’s supportive housing standards and codes and demonstrate
consistency with section 65583(c)(3) or revise programs.
Specific code reference listed below:
(3) Address and, where appropriate and legally possible, remove governmental and
nongovernmental constraints to the maintenance, improvement, and development of
housing, including housing for all income levels and housing for persons with disabilities. The
program shall remove constraints to, and provide reasonable accommodations for housing
designed for, intended for occupancy by, or with supportive services for, persons with
disabilities. Transitional housing and supportive housing shall be considered a residential
use of property and shall be subject only to those restrictions that apply to other residential
dwellings of the same type in the same zone. Supportive housing, as defined in Section
65650, shall be a use by right in all zones where multifamily and mixed uses are permitted,
as provided in Article 11 (commencing with Section 65650). Cal. Gov. Code § 65583
To address this, the City previously included a Program to refine zoning to be consistent with
State Law and how Supportive Housing is regulated. Please see program below for details
on action and deliverable date with updated per HCD letter dated 06/18/23:
Program SNP-8.2 – Zoning for Supportive Housing and Permanent Supportive
Housing. Amend zoning and permit procedures to permit supportive housing (as
defined by Government Code section 65582) as a residential use in all zones allowing
residential uses and only subject to those restrictions that apply to other residential
uses of the same type in the same zone. In adddition, permanent supportive housing
is a type of supportive housing that meets specific statutory requirements pursuant to
Government Code section 65651, The City will also amend zoning to permit
permanent supportive housing without discretionary action (including removing
conditional use permits and statutory CEQA exemptions) in all zones allowing
multifamily if meeting specific requirements pursuant to Government Code section
65651.
Responsibility: Department of Economic and Community Development – Planning
Division
Time Frame: No later than December 31, 2023.
Funding Source: Staff time
(HE Location Page 124222)
Low Barrier Navigation Centers: The element includes further information on Low Barrier
Navigation Centers. However, a Low Barrier Navigation Center, in the City’s Municipal Code
is narrowly defined as a Domestic Violence Shelter and limits facilities to serving just a
maximum of ten clients. In addition, the element includes a link to updated land use tables
and definitions as part of the updated General Plan and companion zoning. However, the
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400 GRAND AVENUE P.O. BOX 711 SOUTH SAN FRANCISCO, CA 94083
element must demonstrate compliance with Government Code section 65660 and include
programs as appropriate.
Currently, the adopted Zoning Ordinance defines Low Barrier Navigation Center narrowly as
a Domestic Violence Shelter. This type of use is limited to ten clients, which does not appear
to be in conflict with Government Code Section 65660, which does not specify unlimited size
for a Low Barrier Navigation Center. State code requires this use is by-right in zones where
multifamily and mixed uses are permitted, including nonresidential zones permitting
multifamily uses pursuant to Government Code Section 65660.
The zoning classification should be updated, however, to match the Low Barrier Navigation
Center definition and language and thus a new program has been introduced to ensure
compliance, shown below and edited per HCD letter dated 6/18/23:
Program CST-3.3 – Revise Zoning Definition for Domestic Violence Shelter to
match the requirements of a Low Barrier Navigation Center under CA Government
Code Section 65660 and 65662, including by-right zoning (without discretionary
action) provisions, as applicable, in mixed use and non-residential zones permitting
multifamily uses and meeting specific requirements pursuant to Government Code
section 65652.
Responsibility: Department of Economic and Community Development – Planning
Division
Time Frame: No later than December 31, 2023
Funding Source: Staff time
(HE Location Page 208125):
Single Room Occupancy (SRO) Units: The element states that SRO units are no longer
permitted in South San Francisco and existing SRO units are managed under the City’s legal
non-conforming ordinance. In addition, the element states that group residential uses are
permitted and meet the general goal of previous SRO developments but does not describe
how. The element must describe how (development standards and permit procedures) SROs
are allowed or add a program as appropriate.
This description is being restated as the definitions in the adopted Zoning Ordinance have
been updated to resolve this concern – staff previously misrepresented this response. Single
Room Occupancy uses now fall under the City’s Group Residential Uses, defined below:
Group Residential. Shared living quarters without separate kitchen or bathroom
facilities for each room or unit, offered for rent for permanent or semi-transient
residents on a weekly or longer basis. This classification includes rooming and
boarding houses, dormitories and other types of organizational housing, private
residential clubs, and residential hotels intended for long-term occupancy (30 days or
more) but excludes Hotels and Motels (see Hotel and Motel), and Residential Care
Facilities (see Residential Care Facilities).
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Group Residential uses, are conditonally permitted in the RM-22, RH-37.5 and RH-50, RH-
180, DRM, DRH, DRC Zoning Districts with a Minor Use Permit. Group Residential uses are
permitted by-right in the T3N Zoning District, and conditionally permitted in the T4M, T5C
and T6UC Zoning Districts with a Conditional Use Permit.
The Minor Use Permit and Conditional Use Permit process are described in detail starting
on P.65.
(HE Location Page 126132)
Programs: The element does not include a complete site analysis; therefore, the adequacy
of sites and zoning were not established. Based on the results of a complete sites inventory
and analysis, the City may need to add or revise programs to address a shortfall of sites or
zoning available to encourage a variety of housing types.
A revised site analysis has been submitted for consideration and new programs
listed/reflected in the updated redlines.
AFFH analysis conducted with review of each relevant program and numerical goals to
further fair housing have now been included in the evaluaiton matrix. Affected programs will
be updated to include metrics and neighborhood focus areas, as appropriate, to ensure
AFFH implementation.
Site analysis is now complete with programs continued, modified, or newly introduced per
HCD guidance.
Accessory Dwelling Units (ADU): The element now assumes an average of 38 ADUs per
year and assumes 304 ADUs over the eight-year regional housing needs allocation (RHNA)
Cycle 6 period. In addition, ADU assumptions have been updated based on a four-year cycle
(2019-2022) with available data and revisions after errors were found. The element should
include a commitment to reconcile trends with reported units within the Cities submitted
annual progress report. Further, as stated in the previous review, programs should commit
to additional incentives and strategies, frequent monitoring (every other year) and specific
commitment to adopt alternative measures such as rezoning or amending the element within
a specific time (e.g., six months) if number and affordability assumptions are not met.
Modified Program CRT-6.1 below and City will continue to rely on CRT-10.1 and CRT-10.2
to actively promote meaningful ADU construction and participation through a pilot
construction management project and per HCD letter dated 6/18/23:
Program CRT-6.1 – Continue to support the development of secondary dwelling units
consistent with State Law and educate the community about these standards. City will
continue to allow permissive design standards for ADUs with no parking required in
most instances, reduced setbacks, larger units and ADUs allowed on both single- and
multi-family zoned parcels. Actively promote participation in the City’s two-year pilot
program Hello ADU for comprehensive project management support for ADU
construction. City shall track compliance with ADU construction through the Annual
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Progress Report to reconcile trends with actual ADU permits issued and commit to
new ADU promotion programs if ADU construction falls more than 30% off-trend.
Responsibility: Department of Economic and Community Development – Planning
Division; Planning Commission
Time Frame: Annual reporting to HCD through the Annual Progress Report; if ADU
production and affordability falls 30% below recent trend line assumptions, City shall
adopt alternate measures (e.g., incentives, funding, development standard
modification, rezoning) to maintain adequate sites to accommodate the regional
housing need allocation by income group and promote ADU construction within six
months.
Funding Source: Staff time to promote program; City funding for promotion programs,
additional construction management.
(HE Location Page 94199)
3. An analysis of potential and actual governmental constraints upon the maintenance,
improvement, or development of housing for all income levels, including the types of housing
identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in
the analysis pursuant to paragraph (7), including land use controls, building codes and their
enforcement, site improvements, fees and other exactions required of developers, and local
processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).)
Address and, where appropriate and legally possible, remove governmental and
nongovernmental constraints to the maintenance, improvement, and development of
housing, including housing for all income levels and housing for persons with disabilities
(Gov. Code, § 65583, subd. (c)(3).)
Land Use Controls: The element included additional information on land use controls.
However, the analysis must specifically describe and analyze maximum lot coverage in the
RH-50 zone, height limits in the RM-22, DRM, and T3 zones, maximum floor area ratios in
the ETC zone without utilizing a community benefit, the FAA height constraint in the T6 zone,
and whether there are minimum unit sizes.
Additional analysis below to address these identified gaps and per HCD letter dated 6/18/23:
• RH-50 Maximum Lot Coverage
o RH-50 lot coverage is 65%, as shown in the adopted zoning standards Table
20.070.003: Development Standards – Residential Zoning Districts, available
here:
https://library.qcode.us/lib/south_san_francisco_ca/pub/municipal_code/item/t
itle_20-division_ii-chapter_20_070-20_070_003
o When combined with other development standards, lot coverages of 65 percent
facilitate achieving maximum densities. For example, after accounting for
setbacks, parking, minimum open space and landscaping, even on a minimum
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lot size of 5,000 square foot, the development standards would accommodate
approximately six units or 50 units per acre.
• RM-22, DRM, T3C Height Limits
o RM-22 has a height limit of 35 ft/3 stories. When combined with other
development standards, a height limit of 35 ft/3 stories facilitate achieving
maximum densities. For example, after accounting for setbacks, parking,
minimum open space and landscaping, even on a minimum lot size of 5,000
square foot, the development standards would accommodate approximately
three units or 22 units per acre.
o DRM has a height limit of 35 ft/3 stories. When combined with other
development standards, a height limit of 35 ft/3 stories facilitate achieving
maximum densities. For example, after accounting for setbacks, parking,
minimum open space and landscaping, even on a minimum lot size of 5,000
square foot, the development standards would accommodate approximately
three units or 22 units per acre.
o T3C has a height limit of 50 feet and a maximum density of 60 du/ac. This
zoning district with several opportunity sites is near single family, low density
residential and the adotped height limit of 50 feet has been done to scale
development appropriately. Staff has received a preliminary application for
townhomes at 170/180 S. Spruce Avenue since adoption of the General Plan
showing feasibility. The project actually proposes the minimum density of 20
du/ac at the two addresses and a height of approximately 35 feet – the project
would be for-sale and provide 15% of the base density units at low and
moderate income levels per adotped City Ordinance.
o When combined with other development standards, a maximum FAR still
permits maximum densities. For example, after accounting for setbacks,
parking (zero minimum parking required), minimum open space and
landscaping, even on a minimum lot size of 10,000 square foot, the
development standards would accommodate approximately 46 units or 200
units per acre.
• ETC Maximum Floor Area Ratio without Community Benefits
o Maximum FAR is not indicated in adopted zoning that excludes Community
Benefits. Community Benefits are only required for non-residential projects,
however. For residential projects, density and height are the primary zoning
controls. Permitted denisty is 200 du/ac and there is no height limit, other than
Federal Aviation Administration (FAA) height constraints that begin at
approxmately 200 feet, allowing for some of the largest residential project
opportunities in South San Francisco.
o When combined with other development standards, a maximum FAR still
permits maximum densities. For example, after accounting for setbacks,
parking (zero minimum parking required), minimum open space and
landscaping, even on a minimum lot size of 10,000 square foot, the
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development standards would accommodate approximately 46 units or 200
units per acre.
• T6UC FAA Height Constraint
o This zoning district is governed by the Federal Aviation Administration (FAA)
height limits, which typically do not have limitations until 150 feet or higher.
T6UC allows Flex High Rise building types, which are permitted to go up to 12
stories (averaging around 120 feet) and therefore no constraints on potential
residential construction for these opportunity sites is anticipated.
o When combined with other development standards, a maximum height limit of
150 ft per FAA, for instance, still permits maximum densities. For example, after
accounting for setbacks, parking (zero minimum parking required), minimum
open space and landscaping, the development standards would accommodate
approximately 46 units or 200 units per acre.
• Minimum unit sizes in any of these zones?
o No minimum sizes for residential units are required in any of the transect form
based zoning districts. Only building form and function are managed by zoning,
thereby creating maximum flexibility for density and development of opportunity
sites.
(HE Location Page 6465)
Fees and Exactions: The element includes additional information on fees and exactions.
However, the element must list and analyze planning fees including, but not limited to,
conditional use permits (CUP), zone changes, general plan amendments, variances, site
plans, specific plans, affordable housing in lieu fee, lot line adjustment, and other
environmental fees. Based on the outcomes of the analysis, the element should include
programs to address identified constraints.
Per HCD request, the following fee schedule and related fees for a sample residential project
are listed below to help illustrate the overall fees and exactions and their measure as a
contraint. Additional information has been provided per HCD letter dated 6/18/23:
Current Fee Schedule:
https://www.ssf.net/home/showpublisheddocument/28173/638035828937770000
Planning fees are based on a cost recovery model and generally represent a minor proportion
of total development costs per units. Sample Residential Project – 100 Unit Multi-family
Development (85’ tall, 7 stories)
Planning Fee Amount
Residential -Multi Family Design Review $2,314
Categorical Exemption CEQA Clearance
Environmental Consistency Analysis CEQA Clearance
$185 OR
$5,543
San Mateo County Environmental Documentary Handling Fee $50
City Attorney Reimbursement Deposit $2,000
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Legal Notices $554
Inclusionary Housing Requirement – 15% of total units at base density
or $308,000 per unit in lieu fee
TBD
TOTAL Anticipated Fees $5,103 - $10,461 depending on CEQA
Clearance Costs
• Total Fees as Percentage of Development/Construction Costs – Approximately
4% through review of all 20 Cities and County of San Mateo
• No General Plan Amendment, Zoning Text Amendment, Zoning Map Amendment,
Specific/Master Plan, or Variance fees typically apply.
No identified opportunity sites require special zoning or General Plan amendments – these
are only required in unique circumstances and would not apply to any identified opprotunity
sites. Therefore, no substantial fees aside from Design Review, Environmental Compliance
Review, and City Attorney Review are required. As illustrated in the example above, the total
anticipated fees represent 4 percent of development costs, placing South San Francisco as
the fifth among its peers in San Mateo County for proportional fees.
(HE Location Page 6768 - 71)
Local Processing and Permit Procedures: The element includes information on
processing and permit procedures. However, the element should further describe and
analyze findings for the Design Review Board for multifamily units. The element should
identify and analyze approval findings for impacts on approval certainty, the presence of
processes or guidelines to promote certainty and add or modify programs as appropriate.
The Design Review Board shall review all multifamily units for compliance with adopted
objective design standards (adopted and effective since November, 2022). During the multi-
family residential review process, the Design Review Board is allocated a SINGLE meeting
to provide design comments before forwarding to the Planning Commission for project
consideration and approval as long as the project meets all Design and Zoning standards.
The process is already described in detail in the submitted Housing Element but some
clarifications related to required findings is included below with a new program added.
The following required findings are included below:
20.480.007 Required Findings
A. The Chief Planner, Planning Commission, or City Council may only approve a design
review application if it finds that the application is consistent with the purposes of this chapter
and with the following:
1. The applicable standards and requirements of this Ordinance;
2. The General Plan and any applicable specific plans the City Council has adopted;
3. Any applicable design guidelines adopted by the City Council;
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4. Any approved tentative map, Use Permit, variance, or other planning or zoning approval
that the project required; and
5. The applicable design review criteria in Section 20.480.006 (“Design Review Criteria”)
above.
Staff is proposing a new program to edit Finding No. 5 reference to Section 20.480.006 to
ensure consistent review of objective design standards only.
Program CST-4.2 – Update Design Review Criteria to reflect objective design
standards. With the recent updated Zoning Ordinance with objective standards for
single-family and multi-family residential development, additional reference updates
are necessary to ensure residential projects are reviewed under objective design
standards only. Section 20.480.006 shall be updated to refer to adopted objective
design standards only.
Responsibility: Department of Economic and Community Development – Planning
Division
Time Frame: No later than December 31, 2023
Funding Source: Staff time
(HE Location Page 7376 and 209)
Reasonable Accommodation Ordinance: The element was revised to state that reasonable
accommodations would be provided “when so doing would be consistent with the purposes
of the Zoning Ordinance and it is not possible or practical to approve a variance” (page 70).
However, the purpose of the reasonable accommodation is to provide a separate exception
process to zoning and land use. As a result, the element must include a program to address
this constraint.
Per HCD guidance, City of South San Francisco will update the Zoning Ordinance via
Program EQ-8.3, illustrated below:
New Updated for HCD Review
Program EQ-8.3 – Ensure accessibility requirements. When residential buildings
are inspected for occupancy, check for posters that explain the right to request
reasonable accommodations for persons with disabilities. Make this information
available and clearly transparent on the City's website and fund landlord training and
outreach on reasonable accommodations. Additionally, Chapter 20.510 provides the
Waiver and Modifications process to establish an alternate means of granting relief
from the requirements of the Zoning Ordinance when so doing would be consistent
with the purposes of the Zoning Ordinance and it is not possible or practical to
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approve a variance. This procedure is intended, but is not limited to facilitating
compliance with the Federal Fair Housing Act, the Americans with Disabilities Act,
and the California Fair Employment and Housing Act by providing reasonable
accommodation to persons with disabilities seeking fair access to housing through
modification of the application of the City’s zoning regulations. If reasonable
accommodation is not be provided appropriately and the City receives this feedback,
modify Chapter 20.510 as needed with HCD input, if necessary.Update Chapter
20.510 with the HCD model ordinance provided at t.ly/dYdaJ to ensure compliance
with Reasonable Accommodation requirements.
Responsibility: Department of Economic and Community Development – Building
Division; Planning Division
Time Frame: Ongoing and establish procedure by December 31, 2025.
Funding Source: City funds, staff time
(HE Location Page 187165)
Programs: The element requires a complete analysis of potential governmental constraints.
Depending upon the results of that analysis, the City may need to revise or add programs
and address and remove or mitigate any identified constraints.
Additional programs added in response to further analysis, as detailed above.
AB-2339 Compliance per HCD Review Letter 3, dated 9/29/23
City of South San Francisco must comply with AB-2339 and introduce a new program
showing that emergency housing shelters are by-right in a zone that currently permits
residential zoning. A modified program has been introduced:
Program CST-5.2 – Compliance with AB-2339 to allow by-right Emergency
Shelters. In addition to the Mixed Industrial zone, the City will add a zoning district
where residential uses are permitted to permit emergency shelters by-right (without
discretionary action) (e.g.,T5 Corridor Zoning District (T5L) or similar). Zoning and
permit procedures will be amended to meet all requirements pursuant to AB 2339,
including amending the definition of emergency shelters, establishing or revising
development standards if necessary and ensuring sufficient and suitable capacity
to meet the need for emergency shelters, including proximity to services.
Responsibility: Department of Economic and Community Development –
Planning Division
Time Frame: Within 1 year of adoption
Funding Source: Staff time
(HE Location Page 199)
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Program CST-4.1 (Implement Adopted Objective Design Standards): The program must
include actions and timing to implement the objective standards.
The current program language is included below and edited per HCD reviewer request:
Program CST-4.1 – Implement adopted objective design standards. Implement
the updated Zoning Ordinance with objective standards for single-family and multi-
family residential development as projects are submitted. Implementation shall include
review of each project under Section 20.480.006.
Responsibility: Department of Economic and Community Development – Planning
Division
Time Frame: Completed as part of General Plan Update and companion zoning.
Objective Design Standards shall be implemented on a rolling basis as projects are
submitted. Each residential project will be subject to no more than five public
meetings and design feedback will be provided initially at the Design Review Board
meeting, held once per month.
Funding Source: Staff time
(HE Location Page 194196)
4. Include a program which sets forth a schedule of actions during the planning period, each
with a timeline for implementation, which may recognize that certain programs are ongoing,
such that there will be beneficial impacts of the programs within the planning period, that the
local government is undertaking or intends to undertake to implement the policies and
achieve the goals and objectives of the Housing Element... (Gov. Code, § 65583, subd. (c).)
Timing: As state in the previous review, to have a beneficial impact in the planning period
and achieve the goals and objectives of the housing element, programs must have specific
commitment to housing outcomes and discrete timing (e.g., at least annually or by January
2024). While some programs have been revised, many programs still do not include specific
timeframes that are associated with each action that are committed to in the program. For
example, many programs have a range (e.g., 2023-2025), ongoing, or have timeframes of
annual or bi-annual. The element must review all programs to ensure actions have a specific
timeframe for implementation within the planning period.
1. Some programs are implemented daily, such as the following Program PRSV-2.1 below.
Implementing an arbitrary AND specific timeframe makes no sense – some programs
should only report on an annual basis while being implemented on a daily basis. Program
PRSV-2.1 has been modified to attempt to find common ground with HCD repeat requests
for discrete, somewhat arbitrary implementation dates. Similar edits are made throughout
for programs that “have a range (e.g., 2023-2025), ongoing, or have timeframes of annual
or bi-annual.”
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Program PRSV-2.1 – Enforce housing, building and safety codes. The City shall
continue to aggressively enforce uniform housing, building, and safety codes as well
as eliminate incompatible uses or blighting influences from residential
neighborhoods through targeted code enforcement and other available regulatory
measures.
Responsibility: City Attorney; Fire Department; Department of Economic and
Community Development – Building Division
Time Frame: Ongoing implementation with reporting annually through the Annual
Progress Report.
Funding Source: City funds
2. Date ranges were also provided to give a best estimate for earliest and latest
implementation. Based on the HCD comment, South San Francisco will select the latest
date in the range for implementation, but of course, this ultimately weakens the program
at the expense of HCD comments for a discrete deliverable date in lieu of a date range.
Edits are made throughout for programs that “have a range (e.g., 2023-2025), ongoing,
or have timeframes of annual or bi-annual.”
(HE Location Page 196 212 for PRSV-2.1 and throughout Program for Updates)
Monitoring and evaluation programs: The element contains programs that commit to
evaluations or monitoring of activities. Many of the activities are done on a bi-annual basis.
However, the programs lack specificity on what will be evaluated, if the activity will then be
modified accordingly, and when those modifications will occur. Programs that need to be
revised include Program EQ 5.1, CRT 2.2, and CRT 3.1.
Edits completed to provide metrics or select an expert consultant to advise City on
appropriate measurements. Modified per HCD letter dated 6/18/23 and 7/14/23.
Program EQ-5.1 – Conduct a robust evaluation of the inclusionary housing
program. Evaluate the effectiveness of delivering units for residents with the
greatest housing needs (e.g., single parent families, child-friendly housing,
accessible/visitable units for persons with disabilities) and make modifications as
appropriate.
Responsibility: Department of Economic and Community Development – Economic
Development and Housing Division
Time Frame: Bi-annually
Funding Source: City funds, staff time
P. 179 183 in redlined HE
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Program CRT-2.2 – Regularly review Inclusionary Housing Ordinance. The City
shall review the success of the Inclusionary Housing Ordinance, not more frequently
than bi-annually, to determine if the objectives of the ordinance are being met.
Consideration shall be made to revising provisions of the ordinance to ensure that a
range of housing opportunities for all identifiable economic segments of the
population, including households of low and moderate incomes, and those persons
with developmental disabilities, are provided.
Responsibility: Department of Economic and Community Development – Economic
Development and Housing Division and Planning Division
Time Frame: Evaluate bi-annually as part of Annual Progress Report and make
revisions, as appropriate, within one year
Funding Source: Staff time
P. 184 194 in redlined HE
Program CRT-3.1 – Review Commercial and Housing Linkage Fee. The City
shall continue to implement the Commercial and Housing Linkage Fee, reviewing
not more frequently than bi-annually, to determine if the fee is appropriate and
keeping pace with affordable housing production needs.
Responsibility: Department of Economic and Community Development – Economic
Development and Housing Division; City Council
Time Frame: Evaluate annually as part of Annual Progress Report and make
revisions, as appropriate, within one year
Funding Source: City funds
P. 184 195 in redlined HE
Educational Materials programs: The element was revised to include commitments to
provide educational and proactive outreach for a number of housing activities. However, the
element does not state if those materials have already been developed or timing for
development, and when they will be made available on the website or other locations.
Programs to be revised include EQ 1.1, EQ 3.1, EQ 4.1, EQ 6.1, EQ 7.2, CRT 10.1, CRT
10.2, and CRT 11.1.
Edits completed to provide clarity on whether documents were complete and how they are
available and distributed.
Program EQ-1.1 – Enforce equal housing opportunity laws. The City shall
require that all recipients of locally administered housing assistance funds and other
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400 GRAND AVENUE P.O. BOX 711 SOUTH SAN FRANCISCO, CA 94083
means of support from the City acknowledge their understanding of fair housing law
and affirm their commitment to the law. The City shall proactively provide materials
to help with the understanding of and compliance with fair housing law by including
these on the Housing Division website, distributing at all hosted housing events, and
an annual communication via distribution mailing list, water bill, or similar to property
owners.
Responsibility: Department of Economic and Community Development – Housing
Division
Time Frame: Ongoing – Annual reporting as part of CDBG Funding and Annual
Progress Report. Legal notice posted regularly online here for more information:
https://www.ssf.net/departments/economic-community-development/housing.
Funding Source: Staff time
P. 175 178 in redlined HE
Program EQ-3.1 – Provide renter education and assistance. Continue to
connect low-income residents to city, county, state, and non-profit resources that
provide technical, legal, and financial assistance for renters facing eviction in
multiple languages. The City shall proactively provide educational materials by
including these on the Housing Division website, distributing at all hosted housing
events, and an annual communication via distribution mailing list, water bill, or
similar, to tenants.
Responsibility: Department of Economic and Community Development –Housing
Division
Time Frame: Offered daily from City staff and North County’s Core Services
Provider YMCA. Supportive documents regularly posted online here for more
information: https://www.ssf.net/departments/economic-community-
development/housing.
Funding Source: CDBG or HOME administrative funds, as available, staff time
P. 177 180 in redlined HE
Program EQ-.4.1 – Provide resident housing rights education. Provide
education, outreach, and referral services for residents regarding their rights as
tenants and buyers. The City utilizes CDBG funds to support Project Sentinel, a local
fair housing nonprofit, to provide counseling, dispute resolution, and other services
to residents. Project Sentinel assists both renters and homeowners with issues
related to discrimination, landlord issues, housing privacy, reverse mortgages,
eviction, foreclosure, and numerous other housing issues. The City shall proactively
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provide educational materials by including these on the Housing Division website,
distributing at all hosted housing events, and an annual communication via
distribution mailing list, water bill, or similar, to tenants.
Responsibility: Department of Economic and Community Development – Housing
Division
Time Frame: Daily ad hoc support and Annual Training. Legal notice posted
regularly online here for more information:
https://www.ssf.net/departments/economic-community-development/housing.
Funding Source: City funds, staff time, CDBG
P. 178 182 in redlined HE
Program EQ-6.1 – Increase affordable units. Increase the number of affordable
rental and homeownership units in moderate and higher resource areas of South
San Francisco through targeted redevelopment and gentle infill. Prioritize the
development of the existing Municipal Services Building at 33 Arroyo Drive and any
other jurisdiction owned assets for 100% affordable housing development
partnership or jurisdiction-led project. The City shall proactively provide promotional
materials on development opportunities by including these on the Housing Division
website, distributing at all hosted housing events, and an annual communication via
distribution mailing list to potential development partners.
Responsibility: Department of Economic and Community Development – Planning
Division. Developer information provided at the following websites and updated
regularly: https://www.ssf.net/departments/economic-community-
development/housing/resources-for-developers and https://construction.ssf.net/.
Time Frame: Evaluate annually as part of Annual Progress Report
Funding Source: Staff time
P. 180 184 in redlined HE
Program EQ-7.2 – Fund home repair for low-income property owners and
tenants. Continue to fund minor home repairs and implement a preference for
projects in low opportunity census tracts identified in the AFFH analysis. Expand the
program to assist renters. The City shall proactively provide educational materials
by including these on the Housing Division website, distributing at all hosted housing
events, and an annual communication via distribution mailing list, water bill, or
similar, to property owners and tenants.
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Responsibility: Department of Economic and Community Development – Housing
Division. Home repair information posted and updated online here:
https://www.ssf.net/departments/economic-community-development/housing.
Time Frame: Annually during CDBG Funding Public Hearings
Funding Source: CDBG funds, as available
P. 181-2186 in redlined HE
Program CRT-10.1 – Maintain and update preapproved accessory dwelling
unit (ADU) plans. Preapprove additional ADU plans from ADU vendors to expedite
ADU permit processing if State law changes and current plan designs need
adjustment. The City shall proactively provide educational materials by referring to
these posted documents on the Planning Division website, distributing at all hosted
housing events, and an annual communication via distribution mailing list, water bill,
or similar, to property owners.
Responsibility: Department of Economic and Community Development – Planning
Division
Time Frame: Ongoing – current plans meeting all local and state codes are
approved and available to residents here:
https://www.ssf.net/departments/economic-community-development/planning-
division/accessory-dwelling-units-junior-accessory-dwelling-units. Will be reported
annually through the Annual Progress Report.
Funding Source: Staff time, consultant time for plan updates through the
Commercial Linkage Fee
P. 192 204 in redlined HE
Program CRT-10.2 – Continue ADU construction management program with
Hello Housing or similar, to promote privately funded ADU
construction. Continue operation of construction management program for ADU
design, permitting and construction through Genentech grant of One Million dollars.
The City shall proactively provide educational materials by including these on the
Housing Division website, distributing at all hosted housing events, and an annual
communication via distribution mailing list, water bill, or similar, to property owners.
Responsibility: Department of Economic and Community Development – Planning
Division
Time Frame: Ongoing while funding permits. Program details are posted and
regularly updated here: https://www.ssf.net/departments/economic-community-
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development/planning-division/accessory-dwelling-units-junior-accessory-dwelling-
units and https://www.helloadu.org/.
Funding Source: Staff time, consultant time for program administration using
Genentech grant funding
P. 192 205 in redlined HE
Program CRT-11.1 – Connect residents to mortgage assistance
resources. Provide mortgage assistance to help low-income homeowners at risk of
foreclosure with financial or counseling support. Provide residents with resources
and connections to HEART of San Mateo County, a countywide homeowner
assistance program, and other non-profit homeowner assistance programs. The
City shall proactively provide educational materials by including these on the
Housing Division website, distributing at all hosted housing events, and an annual
communication via distribution mailing list, water bill, or similar, to property owners.
Responsibility: Department of Economic and Community Development –Housing
Division
Time Frame: Ongoing with resources regularly updated and posted here:
https://www.ssf.net/departments/economic-community-development/housing/fair-
housing-legal-services.
Funding Source: Staff time, City funding to Core Social Service Agencies
P. 193 206 in redlined HE
Program CRT-4.1 (Site Acquisition for Affordable Housing): The program was revised to
include program planning annually. In addition, the element should describe what potential
incentives will be offered and include proactive outreach to developers.
Updated with potential incentives and proactive outreach to read as follows:
Program CRT-4.1 – Site acquisition for affordable housing. The City shall work
with for-profit and nonprofit housing developers to acquire sites that are either vacant
or developed with underutilized, blighted, and/or nonconforming uses for the
development of affordable housing. Annually, the City will meet with developers to
discuss and identify development opportunities, and potential funding sources,
potential impact fee waiver or funding contributions by the City, and attend residential
and commercial broker conferences to identify opportunities.
Responsibility: Department of Economic and Community Development – Housing
Division and Planning Division; Planning Commission; City Council
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Time Frame: Annual Reports to City Council via Public Hearing, Closed Session, or
Memorandum update on potential site acquisition with annual program planning
Funding Source: Various
P. 185 196 in redlined HE
Program EQ 6.1 (Increase Affordable Units): The program should specify when it will make
33 Arroyo Drive and other jurisdiction owned assets available for disposition within the
planning period and in accordance to the Surplus Lands Act. In addition, as 33 Arroyo drive
was identified in the previous housing element cycle, the program should commit to make
the site available by-right when at least 20 percent of the units are affordable to lower-income
households. (Gov. Code, § 65583.2, subd. (c).)
Program has been modifed as follows to commit to investigation of locally owned jurisdiction
sites no later than December 31, 2030, however, the City is not able to pre commit to
disposing this site given there are competing community uses that could be located on locally
owned jurisdiction sites. This is particularly true for 33 Arroyo Drive.
Program EQ-6.1 – Increase affordable units. Increase the number of affordable
rental and homeownership units in moderate and higher resource areas of South
San Francisco through targeted redevelopment and gentle infill. Prioritize the
development of jurisdiction owned assets for 100% affordable housing development
partnership or jurisdiction-led project and following the Surplus Lands Act. The City
shall proactively provide promotional materials on development opportunities by
referring to these posted documents on the Housing Division website, distributing at
all hosted housing events, and an annual communication via distribution mailing list
to potential development partners.
Responsibility: Department of Economic and Community Development – Planning
Division
Time Frame: No later than December 31, 2030, and evaluate annually as part of
Annual Progress Report
Funding Source: Staff time
P. 180 184 in redlined HE
Program CRT 9.1 (Create Affordable Housing Overlay Zone): The element now includes
a commitment to “explore provisions for an affordable housing overlay zone that requires
less that 100% of units at affordable income levels” However, it is unclear if the consideration
will be done as part of the overlay zone implementation consistent with AB 2011 and SB 6
or if another overlay zone is being considered. If another overlay zone is being considered,
the element must include specific timeframes for implementation.
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Program has been updated to reflect the bifurcated process – The City will codify AB 2011
and SB 6 for simplicity no later than December 31, 2023 and will explore and implement a
potential City-led overlay no later than December 31, 2026. See updated program below:
Program CRT-9.1 – Create affordable housing overlay zone. Implement an
affordable housing overlay zone consistent with AB 2011 and SB 6 that permits
100% affordable housing developments in as many appropriate zoning districts as
possible. Additionally, and separately, explore provisions for a City-led affordable
housing overlay zone that requires less than 100% of units at affordable income
levels to ensure feasible opportunities.
Responsibility: Department of Economic and Community Development – Planning
Division
Time Frame: Updated zoning ordinance to reflect AB 2011 and SB 6 no later than
December 31, 2023, and updated zoning ordinance consideration of a City-led
affordable housing overlay zone that requires less than 100% of units at affordable
income levels no later than December 31, 2026.
Funding Source: Staff time to ensure zoning consistency with this General Plan
goal.
P. 190 202 in redlined HE
5. Promote and affirmatively further fair housing opportunities and promote housing
throughout the community or communities for all persons regardless of race, religion, sex,
marital status, ancestry, national origin, color, familial status, or disability, and other
characteristics... (Gov. Code, § 65583, subd. (c)(5).)
As stated in the prior review, Goals and actions must specifically respond to the analysis and
to the identified and prioritized contributing factors to fair housing issues and must be
significant and meaningful enough to overcome identified patterns and trends. Actions must
have specific commitment, milestones, geographic targeting, and metrics or numeric
objectives. The element was not revised to include milestones, metrics or numerical
objectives, and geographic targeting. In addition, it is unclear which program actions relate
to the prioritized contributing factors listed on page 152. Finally, most of the program
commitments around AFFH are educational or commit to outreach. Many of the programs
that significantly respond to fair housing issues only commit to “evaluate” and “consider”
actions rather than provide a specific commitment. For example, as acknowledge in the
AFFH analysis, the City faces a significant displacement risk. However, Program EQ 3.2
commits to conduct a public hearing to understand options for anti-displacement and
Program EQ- 3.4 only commits to “evaluate” and if directed develop a just cause for eviction
notice. The programs must provide a specific commitment to adopt appropriate anti-
displacement strategies from the list of potential strategies that will be evaluated. This does
not limit the City in adoption of other strategies in addition to those listed. Finally, the program
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400 GRAND AVENUE P.O. BOX 711 SOUTH SAN FRANCISCO, CA 94083
should provide specific timeframes for milestones when implementing this program including
community workshops, feasibility analysis, and finally adoption of implementing policies.
Programs EQ-3.2 and 5.1 have been updated with suggested HCD language per letter dated
6/18/23:
Program EQ-3.2 – Conduct a public hearing to consider an anti-displacement
plan. Explore Conduct a public hearing to understand options for an anti-
displacement plan to halt displacement in the city, particularly in Downtown, Sign
Hill, El Camino, and Sunshine Gardens, and establish policies and objectives, as
appropriate, which may include a rent stabilization policy, just cause-eviction and
harassment protections, tenant and landlord mediation programs, right of first
refusal, rental assistance, tenant legal counseling, and a rent board to implement the
program. As policies are developed and /adopted, develop objectives by which to
measure the success of each program area based on best practices and
professional guidance.
Responsibility: Department of Economic and Community Development – Economic
Development and Housing Division
Time Frame: 2023-2025
Funding Source: City funds, staff time
P. 177 180 in redlined HE
Program CST-5.1 – Permanent Supportive Housing. Group home housing is
currently permitted in multiple residential only zoning districts with approval of a
minor use permit to support the availability of housing choices for persons with
special needs. Under HCD best practice guidance, however, requiring these housing
types to obtain a special use or CUP could potentially subject housing for special
needs populations to higher discretionary exceptions processes and standards
where an applicant must, for example, demonstrate compatibility with the
neighborhood, unlike other residential uses. Update Zoning Ordinance to allow by-
right in all residential zoning districts allowing residential uses similar to other
residential uses of the same type in the same zone.
Responsibility: Department of Economic and Community Development – Planning
Division
Time Frame: 2023
Funding Source: Staff time
P. 196 210 in redlined HE
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Additionally, with guidance from HCD, staff has prepared the following matrix to evaluate all
appropriate programs under the rubric of Affirmatively Furthering Fair Housing (AFFH) below,
citing necessary edits to adopted Programs, including deliverables, timeline, and
targeted numerical objectives.
Affirmatively Furthering Fair Housing Primary Action Matrix – Program Updates will apply
Programs
Timing
Geographic
Targeting
Targeted
Numerical
Objective
Housing Mobility and New Opportunity in Higher Opportunity Areas
Program EQ-5.2 – Participate in a regional
down payment assistance program to support
Missing Middle housing demand.
Quarterly Neighborhoods
west of Highway
101
250 Households
Program EQ-6.1 – Increase affordable units Annually Moderate and
higher resource
and income area
neighborhoods
Dispersed RHNA
allocation Citywide
so that each of Five
Districts has a
percentage of new
housing relative to
existing households
with a goal of 200
units per District.
Program EQ-6.3 – Affordable housing fund
policy
No later
than 2025
Citywide (includes
S. Airport Corridor)
Allocation of up to
$55,000 per unit in
funding support for
up to 1,000 units
over RHNA Cycle
Program CRT-2.1 – Implement Inclusionary
Housing Ordinance
Annually Citywide with focus
on identified higher
opportunity and
income areas
15% of all new
units minimum
Program CRT-4.1 – Site acquisition for
affordable housing
Annually Citywide with focus
on identified higher
opportunity and
income areas
Parcel acquisition
in each City district
(5 Districts)
Program CRT-4.6 – City led acquisition and/or
development of new mixed-income affordable
housing
Annually Citywide with focus
on identified higher
opportunity and
income areas
300 units with 20
percent target in
higher income
areas
Program CRT-6.1 – Continue to support the
development of secondary dwelling units and
educate the community about this program
Annually Citywide with focus
on identified higher
opportunity and
income areas
38 units per year
with 50 percent in
relatively higher
income
neighborhoods
Program CRT-10.1 – Maintain and update
preapproved accessory dwelling unit (ADU)
plans
Annually
Program CRT-10.2 – Continue ADU
construction management program with Hello
Housing or similar to promote privately funded
ADU construction
2023-2025
Program CRT-6.2 – Continue to implement SB
9 units and subdivision allowances
Annually Citywide with focus
on identified higher
5 units per year
with 50 percent in
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400 GRAND AVENUE P.O. BOX 711 SOUTH SAN FRANCISCO, CA 94083
opportunity and
income areas
relatively higher
income
neighborhoods
Program CRT-7.2 – Allow housing on sites
with institutional uses
2023-2025 Citywide with focus
on identified higher
opportunity and
income areas
100 units during
RHNA Cycle 6
Program CRT-9.1 – Create affordable housing
overlay zone
2026 Citywide with focus
on identified higher
opportunity and
income commercial
corridor areas
200 units during
RHNA Cycle 6
Program SNP-4.1 – Accessibility Modification
Programs
Annually Citywide with focus
on identified higher
opportunity and
income areas
10 per year, as
funding permits
Program SNP-6.1 – Support a variety of
housing unit designs, including larger housing
units that can accommodate large families
Annually Citywide 25% of all units as
large family units
during RHNA Cycle
6
Program SNP-9.1 – Continue to promote
Home Sharing
Annually Citywide with focus
on identified higher
opportunity and
income areas
10 per year, with
cooperation from
County partners
Place-Based Strategies toward Community Revitalization
Program EQ-6.2 – Incentivize accessibility
development
Annually Citywide with focus
on identified higher
opportunity and
income areas
>5% of all units in
an entitled project
development
Program EQ-7.1 – Prioritize Capital
Improvement Program for vulnerable
populations
Annually Downtown, Orange
Park, Lindenville,
E101 and other
areas with higher
concentrations of
lower-income
households or
vulnerable
populations
Lower income
census tracts or
flood prone tracts
should receive
largest proportion
of CIP investment
over period of
RHNA Cycle 6
Program EQ-7.2 – Fund home repair for low-
income
Annually Lower opportunity
census tracts
10 households per
year as funding and
County
collaborations allow
Program CRT-4.2 – Support and pursue
funding applications for affordable housing
Annually City-wide Apply to annual
San Mateo County
NOFA and Federal
NOFA as partner
with projects
Program PRSV-1.1 – Minor home repair Annually Citywide with focus
on identified lower
opportunity and
income areas
5 per year per
District (5 Districts) Program PRSV-1.2 – Prioritize funding for
housing rehabilitation
Annually
Program PRSV-1.3 – Provide low interest
loans for housing rehabilitation
Annually
Program PRSV-2.1 – Enforce housing,
building and safety codes
Annually Citywide
enforcement
N/A
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400 GRAND AVENUE P.O. BOX 711 SOUTH SAN FRANCISCO, CA 94083
Program PRSV-3.1 – Direct CIP funding for
infrastructure equitably
Annually Downtown, Orange
Park, Lindenville,
E101 and other
areas with higher
concentrations of
lower-income
households or
vulnerable
populations
Lower income
census tracts or
flood prone tracts
should receive
largest proportion
of CIP investment
over period of
RHNA Cycle 6
Program QOL-3.1 – Implement the Active
South City Pedestrian and Bicycle Plan
Annually Citywide with focus
on poorly
connected
neighborhoods
(Westborough,
Avalon, Buri Buri)
Equitable allocation
of bicycle and
pedestrian
infrastructure miles
over period of
RHNA Cycle 6
Program QOL-4.1 – Implement the Active
South City Pedestrian and Bicycle Plan
Annually Citywide with focus
on poorly
connected
neighborhoods
(Westborough,
Avalon, Buri Buri)
Equitable allocation
of bicycle and
pedestrian
infrastructure miles
over period of
RHNA Cycle 6
Program QOL-5.1 – Implement the Zoning
Ordinance to require amenity, active, outdoor
and flex working spaces in new development
Annually Citywide with focus
on E101, S. Airport
Corridor,
Lindenville Corridor
and El Camino
Real Corridor
Five percent
increase in
Citywide open
space over period
of RHNA Cycle 6
Program QOL-6.1 – Implement the Zoning
Ordinance to require neighborhood Amenity
uses in new development
Annually Citywide with focus
on E101, S. Airport
Corridor,
Lindenville Corridor
and El Camino
Real Corridor
Five percent
increase in
Citywide open
space over period
of RHNA Cycle 6
Program SNP-1.3 – Facilitate multi-
generational housing
Annually Citywide with focus
on identified higher
opportunity and
income areas
ADU Construction
Metrics – 38 per
year, Citywide
Displacement Risk
Program EQ-1.1 – Enforce equal housing
opportunity laws
Annual or bi-
annual
City-wide with
emphasis in areas
of higher
displacement risk
Assist 100
households per
year for RHNA
Cycle 6
Program EQ-2.1 – Legal counsel and
advocacy assistance
Program EQ-3.1 – Provide renter education
and assistance
Program EQ-.4.1 – Provide resident housing
rights education
Program EQ-4.2 – Provide landlord housing
rights education
Program EQ-8.2 – Provide fair housing
training
Program EQ-3.2 – Conduct a public hearing to
consider an anti-displacement plan
2025 Citywide TBD after
evaluation
Program EQ-3.4. Evaluate and, if directed
under EQ-3.2, develop a local just cause for
eviction ordinance to go above California’s
2025 Citywide TBD after
evaluation
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400 GRAND AVENUE P.O. BOX 711 SOUTH SAN FRANCISCO, CA 94083
Tenant Protection Act (TPA), the state’s just
cause for eviction law adopted in 2019
Program EQ-3.3 – Create a rental task force 2025 Citywide with focus
on areas facing
highest percentage
of displacement
(Old Town, Orange
Park, Lindenville)
TBD after
evaluation
Program EQ-8.1 – Create Preservation Plan 2023-2025 Citywide 100 units preserved
over RHNA Cycle 6
period
Program EQ-8.5 – Continue the Rental
Assistance Pilot Program
2023 Citywide with focus
on areas facing
highest percentage
of displacement
(Old Town, Orange
Park, Lindenville)
25 households
assisted annually
over RHNA Cycle 6
period, if program
continued
Program CRT-4.1 – Site acquisition for
affordable housing
Annual Citywide with focus
on identified higher
opportunity areas
Parcel acquisition
in each City district
(5 Districts)
Program CRT-9.2 – Preserve naturally-
occurring affordable housing
2024 Citywide with focus
on areas facing
highest percentage
of displacement
(Old Town, Orange
Park, Lindenville)
Preserve 100 Units
over RHNA Cycle 6
period
Program CRT-9.4 – Explore adoption of a
Community Opportunity to Purchase Act
Policy
2024 Citywide with focus
on areas facing
highest percentage
of displacement
(Old Town, Orange
Park, Lindenville)
Provide 100 Units
over RHNA Cycle 6
period
Program PRSV-5.1 – Monitor at-risk units Annually Citywide with focus
on areas facing
highest percentage
of displacement
(Old Town, Orange
Park, Lindenville)
Preserve 50 Units
over RHNA Cycle 6
period
Program PRSV-5.2 – Assist tenants at risk of
displacement
Annually Citywide with focus
on areas facing
highest percentage
of displacement
(Old Town, Orange
Park, Lindenville)
Preserve 50 Units
over RHNA Cycle 6
period
P. 184 188 in redlined HE – inserted table and updated programs, as appropriate