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HomeMy WebLinkAboutSB 9 and SB 10 Impacts to Huntington Beach - Submitted by Co (2) 2000 Main Street, fo��o�o p�ti<9 Huntington Beach, CA U =j 92648 City of Huntington Beach /61-PRcwED y-3 k/vs&,� &t7M(-WO) File #: 23-172 MEETING DATE: 2/21/2023 Subject: Submitted by Councilmember Burns - SB 9 and SB 10 Impacts to Huntington Beach Recommended Action: Direct the City Attorney to take any legal action necessary to challenge SB 9 and SB 10 and the laws that permit ADU's. Also, direct the City Manager to cease the processing of all applications/permits brought to the City by developers under SB 9, SB 10, or State law related ADU projects, until the courts have adjudicated the matter(s). Attachment(s): 1. Memo City of Huntington Beach Page 1 of 1 Printed on 2/16/2023 .,erSlj LegistarM r ' CITY OF HUNTINGTON BEACH CITY COUNCIL MEETING—COUNCIL MEMBER ITEMS REPORT TO: HONORABLE MAYOR AND CITY COUNCIL FROM: PAT BURNS, CITY COUNCIL MEMBER DATE: FEBRUARY 21, 2023 SUBJECT: SB 9 AND SB 10 IMPACTS TO HUNTINGTON BEACH The State's housing laws in recent years have become incredibly onerous and burdensome to cities, including fully developed cities like Huntington Beach. In 2021, the State passed SB 9 and SB 10 and State laws expand the ability for development of ADU's that circumvent local zoning controls, all of which produce a proliferation of development and multi-unit housing in already well-established single-family neighborhoods. The City has a duty to protect the quality and lifestyle of the neighborhoods that current owners have already bought into and for the future sustainability of Huntington Beach,the City has a duty to ensure the principles of Euclidean Zoning, like project/development compatibility, etc., are honored and respected. SB 9 and SB 10 and the State laws expanding ADU's are designed to undermine local City zoning authority (including in Charter Cities like Huntington Beach) by overriding local single family neighborhood zoning and incentivizing property owners to redevelop their single family residences into mutli-plex apartment-like developments (including for affordable housing). Radical redevelopment in already-established residential neighborhoods is not only a threat to quality and lifestyle, but to the value of the adjacent and neighboring properties. The City should not be put in a position by the State through SB 9 and SB 10 or those State laws expanding ADU's that would allow the diminution of an owner's property value without just compensation, and Huntington Beach should not have its Charter City zoning rights provided for by the California Constitution trampled by the State. RECOMMENDED ACTION Direct the City Attorney to take any legal action necessary to challenge SB 9 and SB 10 and the laws that permit ADU's. Also, direct the City Manager to cease the processing of all applications/permits brought to the City by developers under SB 9, SB 10, or State law related ADU projects, until the courts have adjudicated the matter(s). 692 io 1 CITY OF HUNTINGTON BEACH CITY COUNCIL MEETING—COUNCIL MEMBER ITEM MEMO TO: THE HONORABLE MAYOR AND CITY COUNCIL FROM: DAN KALMICK, CITY COUNCILMEMBER DATE: FEBRUARY 17, 2023 SUBJECT: COUNCILMEMBER BURN'S SB9/SB10 ITEM FOR 2/21/2023 AGENDA I appreciated Councilmember Burn's move to withdraw this item from last meeting's agenda. I am, however, surprised to see it back on the agenda with even wilder asks and requesting less information than last meeting's request. The addition of prohibiting Accessory Dwelling Units (ADUs - as Councilmember Burns fails to define) in this City is a surprisingly huge overreach by this Council. There is NO evidence presented that ADUs are a problem and removing the ability to add ADUs strips property owners of their property rights and could be considered a taking without just compensation, which Councilmember Burns seems to be trying to avoid. At the June 21, 2022, City Council Meeting,the City Council created Objective Standards to retain local control with regard to SB9. SB10 is an opt-in state law.The City has not opted into SB10 so how would we show harm from it in order to initiate litigation? I have attached the staff report from June of last year that includes a full run down of SB9 and SB10 and how the ordinance passed resolves most of the concerns in Councilmembers Burn's item. Furthermore, the City has not received a single SB9 application for a lot split.The attached Los Angeles Times article dated January 18th, 2023 and the cited study from UC Berkeley's Terner Center, show that SB9 has been ineffective at producing housing stock.There is no imminent threat from SB9 or SB10.ADUs have been part of the fabric of Huntington Beach since its inception. With nearly 20% of households in California now multigenerational and housing prices keeping more people out of the market, this item is literally NIMBYism: Not allowing ADUs in one's own backyard. Councilmember Burn's item states that he wants to uphold property rights of neighbors by limiting property rights on those looking to exercise them?This circular argument has no footing in reality. This item is a solution looking for a problem and a waste of city resources. I recommend that Councilmember Burns avail himself of the professional staff of the Community Development Department and not just the City Attorney's office when bringing items forward. This item will put our City and Staff into a peculiar position of violating state law based on local City policy. It is dangerous and misguided. SUPPLEMENTAL COMMUNICATION Meeting Date: a'a-\1aos Agenda Item No.; (��- I?02> 2000 Main Street, of ;. o Huntington 6Beach,CA City of Huntington Beach 48 Ne COUNTV Ca . File #: 22-437 MEETING DATE: 5/24/2022 PLANNING COMMISSION STAFF REPORT TO: Planning Commission FROM: Ursula Luna-Reynosa, Director of Community Development BY: Jennifer Villasenor, Deputy Director of Community Development SUBJECT: ZONING TEXT AMENDMENT NO. 22-002 (SB 9 DEVELOPMENT PROJECTS) REQUEST: To amend the Huntington Beach Zoning and Subdivision Ordinance (HBZSO) to establish permanent objective development and design standards for SB 9 development projects. On March 1, 2022, the City Council adopted an interim urgency ordinance establishing Chapter 237 of the HBZSO to establish development regulations and processing procedures for SB 9 development projects. The City Council extended the interim urgency ordinance on April 5, 2022. LOCATION: Citywide - Residential Low Density (RL) designated properties APPLICANT: City of Huntington Beach PROPERTY OWNER: N/A BUSINESS OWNER: N/A STATEMENT OF ISSUE: Zoning Text Amendment (ZTA) No. 22-002 is a City-initiated request to amend the Huntington Beach Zoning and Subdivision Ordinance (HBZSO) by adding Chapter 237 - Objective Standards for SB 9 Development Projects, which establishes development standards and review procedures for projects proposed pursuant to Senate Bill 9 (SB 9). SB 9 became effective on January 1, 2022, and requires cities to ministerially approve two unit developments and/or parcel maps to subdivide an existing lot in single-family residential zones. RECOMMENDATION: That the Planning Commission take the following actions: A) Find that Zoning Text Amendment No. 22-002 is exempt from the California Environmental Quality Act (CEQA) pursuant to Government Code Sections 65852.21(j) and 66411.7(n), which state City of Huntington Beach Page 1 of 7 Printed on 5/19/2022 powered by Legistarr" File#: 22-437 MEETING DATE: 5/24/2022 that the adoption of an ordinance by a city or county implementing the provisions of Government Code Sections 65852.21 and 66411.7 and regulating urban lot splits and two unit projects is not a project under CEQA. B) Recommend approval of Zoning Text Amendment No. 22-002 with findings (Attachment No. 1) by approving the draft City Council ordinance (Attachment No. 2) and forward to the City Council for consideration. ALTERNATIVE ACTION(S): Continue Zoning Text Amendment No. 22-002 and direct staff accordingly. PROJECT PROPOSAL: ZTA No. 22-002 proposes to amend the HBZSO by adding Chapter 237 - Objective Standards for SB 9 Development Projects, establishing development standards and review procedures for projects proposed pursuant to Senate Bill 9. Effective January 1, 2022, SB 9 adds Sections 65852.21 and 66411.7 to the Government Code. Section 65852.21 requires cities to consider a proposed housing development containing no more than two residential units within a single-family residential zone ministerially, without discretionary review or hearing, if the proposed housing development meets certain requirements. Section 66411.7 requires local agencies to ministerially approve a parcel map for an "urban lot split" meeting certain requirements. Both statutes permit the City to impose objective zoning, subdivision, and design standards on such projects as long as those standards would not have the effect of physically precluding the construction of up to two units on a lot or physically preclude either of the two units from being at least 800 square feet in floor area. Background: SB 9 was signed into law by Governor Newsom on September 16, 2021, and became effective on January 1, 2022. SB 9 was part of the California Senate's 2021 Housing Production Package, a group of housing laws aimed at increasing housing supply throughout the state. On March 1, 2022, the City Council adopted an interim urgency ordinance establishing Chapter 237 of the HBZSO, which provides development regulations and processing procedures for SB 9 development projects. The City Council extended the interim urgency ordinance on April 5, 2022. The proposed ZTA would establish permanent SB 9 regulations. To date, the City received several inquiries and one SB 9 submittal, but the submittal was subsequently withdrawn. ISSUES AND ANALYSIS: Summary of SB 9 To qualify for ministerial approval under SB 9, a two-unit development or urban lot split must satisfy specified criteria. These qualifying criteria include, but are not limited to the following: • The property must be located within a single-family residential zone. • The proposed development cannot be located within a historic district or on property included City of Huntington Beach Page 2 of 7 Printed on 5/19/2022 powered by LegistarT" File #: 22-437 MEETING DATE: 5/24/2022 on the State Historic Resources Inventory, or within a site designated or listed as a city landmark or historic property pursuant to a city ordinance. • The development site cannot be prime farmland, wetlands, a site identified for conservation or habitat preservation, or a regulatory floodway and the development must meet specified standards if it is located in high or very high fire hazard severity zone, the flood zone, or within an earthquake fault zone. • The proposed development cannot require the demolition or alteration of housing occupied by a tenant within the last three years. • The proposed development cannot require the demolition or alteration of housing subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of moderate, low, or very-low income. • The proposed development cannot require the demolition or alteration of housing subject to any form of rent or price control. • An owner of the property cannot have removed residential units on the property from the rental market under the Ellis Act within the last 15 years. • If the site has been occupied by a tenant within the last three years, the proposed development cannot allow for the demolition of more than 25% of the existing exterior structural walls (unless allowed by local ordinance). In addition, in the case of an urban lot split: • The parcel map must subdivide an existing lot to create no more than two new lots of approximately equal lot area, provided that one lot shall not be smaller than 40% of the lot area of the original lot; • Unless the city otherwise allows, both newly created lots must be no smaller than 1,200 square feet; • The lot proposed to be subdivided must not have been established through a prior urban lot split; • The subject lot cannot be adjacent to any lot established through an urban lot split by the owner of the subject lot or by any person acting in concert with the owner of the subject lot; and • Except as otherwise provided in SB 9, the proposed subdivision must comply with all objective requirements of the Subdivision Map Act. In limited circumstances, a city may deny an application for an SB 9 two-unit development or urban lot split where the proposed project would have a specific, adverse impact upon health and safety or the physical environment and for which there is no feasible method to satisfactorily mitigate or avoid the specific, adverse impact. SB 9 also outlines what types of regulations a local jurisdiction can and cannot impose on an SB 9 project: 'Regulation (Permitted Not Permitted City of Huntington Beach Page 3 of 7 Printed on 5/19/2022 powered by LegistarTM File #: 22-437 MEETING DATE: 5/24/2022 Subdivision - Easements for provision of public - Dedication of right-of-way- Requirements services- Easements to ensure Construction of off-site improvements- subdivided lots have access to the Correction of nonconforming zoning public right-of-way conditions Objective - Objective zoning, subdivision, and - No setback can be required if unit is Standards design standards built within the footprint of existing structure- Otherwise maximum 4' setback from side and rear yards- Standards cannot physically prevent the development of an 800 s.f. unit on each lot Parking - Can require one space per unit - Cannot require parking if site is within '/2 mile of a high quality transit corridor or major transit stop or if there is a car share vehicle within a block of the project Rental - Can prohibit short term rental of - No additional owner occupancy Restrictions any units created through SB 9 - For requirements are allowed lot splits, applicants must submit an affidavit that they intend to occupy one of the unit as a principal residence for at least 3 years General Plan Conformance: ZTA No. 22-002 would add Chapter 237 to the HBZSO and establish development regulations and processing procedures for SB 9 development projects consistent with state law. SB 9 projects would be permitted within the Residential Low (RL) Density designated areas and allow duplexes and/or subdivisions (i.e. - lot splits) in single-family residential neighborhoods. The proposed regulations of ZTA No. 22-002 provide for duplexes and lot splits in accordance with state law, create ministerial review procedures, and establish objective development and design standards that conform to the goals and policies of the General Plan. ZTA No. 22-002 is consistent with the General Plan goals and policies identified below. Land Use Element Policy LU-1(D): Ensure that new development projects are of compatible proportion, scale, and character to complement adjoining uses. Policy LU-2(D): Maintain and protect residential neighborhoods by avoiding encroachment of incompatible land uses. Goal LU-4: A range of housing types is available to meet the diverse economic, physical, and social needs of future and existing residents, while neighborhood character and residences are well maintained and protected. Housing Element City of Huntington Beach Page 4 of 7 Printed on 5/19/2022 powered by LegistarT'" File#: 22-437 MEETING DATE: 5/24/2022 Policy 1.1: Preserve the character, scale and quality of established residential neighborhoods. Goal 2: Provide adequate housing sites through appropriate land use, zoning and specific plan designations to accommodate Huntington Beach's share of regional housing needs. Policy 4.3: Explore continued improvements to the entitlement process to streamline and coordinate the processing of permits, design review and environmental clearance. ZTA No. 22-002 would establish regulations to implement SB 9, a state law that allows for duplexes and lot splits in single-family residential zones. The proposed regulations provide a ministerial process for SB 9 projects in accordance with state law while ensuring objective standards are in place to protect the City's single-family residential neighborhoods from adverse impacts. The proposed ZTA introduces a new residential product type in the RL zoning districts. Consistent with state law, the proposed ZTA could result in development projects with a total of four units where there was previously one unit. As such, objective standards are proposed to ensure site design and architecture is context-sensitive and compatible with the existing single-family residential neighborhood. Because SB 9 units and lots, if a lot split occurs, would generally be smaller than a typical single-family property, SB 9 units may be more affordable to a larger segment of the community. In addition, the proposed ZTA includes an incentive that would allow greater square footage for property owners that voluntarily provide affordable units to low income households. The proposed processing procedures allow for ministerial approval if an applicant complies with the objective standards of the proposed ZTA. The proposed ministerial review procedures and objective standards provide a streamlined process with high level of certainty for property owners seeking to construct SB 9 projects in compliance with the objective standards. Zoning Compliance: The proposed amendments to the HBZSO have been developed pursuant to the regulations contained in SB 9 and reflect the minimum objective standards to protect the public health, safety and welfare and ensure SB 9 projects do not have a detrimental impact on single-family neighborhoods within the City. Below is a summary of the proposed SB 9 provisions. Applicability and General Requirements • Permitted in the Residential Low Density (RL) zoning district and specific plans with RL districts • SB 9 project shall comply with all other applicable requirements, including the HBZSO and Municipal Code • Applicant must affirm the SB 9 project meets the eligibility requirements of the state law • Application must include written approval from Homeowners' Association (HOA), if any • Applicant is required to record a covenant on the property with the following provisions: o Non-residential uses and short-term rentals shall be prohibited o Property owner intends to occupy one of the housing units as their principal residence for three years o A subsequent urban lot split on land previously subdivided via an urban lot split shall be prohibited o Parking for any existing units shall be maintained o Access to the public right-of-way shall be maintained in perpetuity City of Huntington Beach Page 5 of 7 Printed on 5/19/2022 powered by LegistarT" File#: 22-437 MEETING DATE: 5/24/2022 o Residential units on a single lot cannot be sold separately o For projects with a lot split, accessory dwelling units shall be prohibited Review procedures • Applications for SB 9 projects shall be approved ministerially • During the City's review, if the City identifies a potential issue with respect to adequate water, sewer, traffic flow, or public safety, the City may require the applicant to submit an Administrative Permit application • A SB 9 project may be denied if the project, based on a preponderance of the evidence, would have a specific, adverse impact with no feasible method to mitigate or avoid the impact • SB 9 projects requiring a coastal development permit (CDP) or tentative parcel map (TPM) shall be required to go through the normal approval process for those applications except no public hearing would be required Objective Standards • All development standards not specified in the ordinance shall apply the standards of the base zoning district • Maximum size: 800 square feet and one bedroom (lots less than 10,000 square feet); 1,600 square feet and two bedrooms (lots 10,000 square feet or greater) • Maximum height: 16 feet/one story • Side and rear setback: four feet (no encroachments would be permitted) • Parking: one enclosed or partially enclosed space (i.e. - carport) per new unit; no parking is required for new units within one-half mile of a high quality transit corridor or a major transit stop or if there is a car share vehicle within one block of the project • Design: all new units shall have the same architectural style, roof pitch, and color • All new units shall have solar panels • No rooftop decks shall be permitted • Additional Lot Split Standards: minimum lot width: 20 feet; access to public right-of-way must be maintained; flag lots are not permitted for corner lots, through lots, and lots with alley access. Environmental Status: ZTA No. 22-002 is exempt from the provisions of the California Environmental Quality Act (CEQA) pursuant to Government Code Sections 65852.21(j) and 66411.7(n), which state that the adoption of an ordinance by a city or county implementing the provisions of Government Code Sections 65852.21 and 66411.7 and regulating urban lot splits and two unit projects is not a project under CEQA. Coastal Status: ZTA No. 22-002 will require certification of a Local Coastal Program Amendment by the California Coastal Commission. City of Huntington Beach Page 6 of 7 Printed on 5/19/2022 powered by LegistarTM File #: 22-437 MEETING DATE: 5/24/2022 Other Departments Concerns and Requirements: ZTA No. 22-002 was developed with assistance from the City Attorney's Office. Public Notification: Legal notice was published in the Huntington Beach Wave on May 12, 2022 and notices were sent to individuals and organizations requesting notification (Planning Division's Notification Matrix). As of May 17, 2022, no communications regarding the request have been received. Application Processing Dates: DATE OF COMPLETE APPLICATION: MANDATORY PROCESSING DATE(S): Not Applicable Not Applicable SUMMARY: Staff is recommending approval of ZTA No. 22-002 for the following reasons: • The proposed provisions are consistent with state law • It is consistent with the goals and policies of the General Plan. • The proposed ZTA provides clear standards and a ministerial approval process for single- family residential property owners that want to improve their properties while maintaining sensitivity to the existing single-family residential neighborhoods. ATTACHMENTS: Draft City Council Ordinance City of Huntington Beach Page 7 of 7 Printed on 5/19/2022 powered by LegistarT"' 6/21/2022 \ 1INGT/74*. I ••• 44 ZTA No . 22 -002 • SB 9 Development Projects • , City Council Meeting • 41. : ` June 21 , 2022 t<% s 17, 1909 • o•......... P\\ ONTY c l Request • ZTA No. 22-002 • Amend HBZSO by adding Chapter 237—Objective Standards for SB 9 Development Projects • Establishes development standards and review procedures for projects proposed pursuant to Senate Bill 9 (SB 9) • Planning Commission Action • Public hearing on May 24, 2022 • Recommended approval to the City Council W' �,',• "r, tRr k it t a e u uurlaun .' Airlimigss COMMUNICATION Data:_141202,1_ Agerd 1 m t_ 99--will_ 6/21/2022 SB 9 qualifying criteria • Property must he located in a single- • Proposed development cannot demolish family residential zone (RL) or alter: • Property cannot be a historic site or in a • Deed restricted affordable housing historic district • Housing subject to rent control • Property must be within an urbanized • Housing removed from the rental area as designated by the U.S. Census market pursuant to the Ellis Act • Property cannot be located on: within the last 15 years • Housing occupied by a tenant in the • Farmland last 3 years (must maintain at least • Wetlands 75%of the existing exterior walls) • Hazardous waste site • Conservation or habitat preservation area • Regulatory floodway rl".49/• • on , • Urban lot sp lit criteria • Two new lots of approx. equal size 40% I 60% • Min. lot size: 1,200 I square feet I t I I !"'- - • No prior or 40% I 60% 1 subsequent urban lot / I I split I II • Same owner(or 60% 1 I person acting "in , 1 40%° concert" with owner) I i f ' cannot split adjacent Pubk Straat Public Street Public Slieet lots 2 6/21/2022 SB 9 regulations • SB 9 law allows cities to adopt certain regulations for SB 9 developments: • Easements for provision of public services and access to right-of-way • Objective zoning, subdivision, and design standards • Parking requirement of one space per unit • Prohibition of short term rentals • Affidavit that the owner intends to occupy one of the units for at least 3 years • Denial of SB 9 project must be based on specific, adverse health and safety impact with no feasible mitigation Interim Urgency Ordinance • March 1, 2022: City Council adopted urgency ordinance to establish interim standards • April 5, 2022: City Council extended the urgency ordinance • Proposed ordinance generally maintains same provisions w/ following changes: • Increased maximum square footage for larger lots • Clarifies ADUs are prohibited in SB 9 projects proposing a lot split • Provision of affordable units is voluntary Increased square footage incentive • Design standards revised to be objective 3 6/21/2022 Objective standards • Max size: 800 s.f./one bedroom or • Design: architecture, roof pitch, 1,600 s.f./two bedrooms depending color same as existing dwelling on lot size • Solar panels required • Required parking: One space • STRs not allowed (garage or carport) • Development must occur with • Max height: 16 feet (if detached concurrent lot split from existing dwelling) • All other standards of base zoning district and parcel map • Side and rear setback: 4 feet requirements apply Must allow exceptions if standard would preclude two 800 s.f, units on a lot Review procedures • Ministerial "by right" process • Lot split: • Subdivision application & process required • No public hearing required • Coastal Zone: • Coastal development permit application & process required • Notification requirements of HBZSO Chapter 245 apply • No public hearing required 4 6/21/2022 Local ordinance objective standards • Existing Regulations - up to 3 units • I Single Family Residence+ 1 ADu+ ? JADL avu A ;INGIE "AIAIEY REutUENCE -- z 590E Local ordinance objective standards SB 9 without ordin,Ince &objective stand, i d, Up to 8 units 5; j ._ .i � n non. �•� A414 I UOU BIDE 5B 9 with quciin,un$.K a0e oblectivest,lnd,uil., 4.—LOT*PUT ti Up to 4 units Fez Vo+ • 8 SIDE 5 6/21/2022 Recommendation • Approve ZTA No. 22-002 and forward to the City Council for adoption based on: • Complies with state law • Consistency with General Plan goals and policies • Provides clear standards, streamlined review and certainty in the approval process while avoiding impacts to existing neighborhoods •c_ Questions ? f` • �.v 6 California's HOME Act Turns One:Data and Insights from the First Yea... https://ternercenter.berkeley.edu/research-and-policy/sb-9-turns-one-app.. California's HOME Act Turns One: Data and Insights from the First Year of Senate Bill 9 - Terner Center The California HOME Act—otherwise known as Senate Bill (SB) 9—took effect on January 1st, 2022 and makes it possible for homeowners to split their home's lot and build up to four homes on a single-family parcel. Upon the law's passage, some hailed it as a major victory for zoning reform that would open up new avenues for small-scale homebuilding in previously exclusionary places. Others feared that the law might lead to speculation and unchecked growth at the expense of community character and vulnerable residents. One year in, we find that the impact of SB 9 has been limited so far. Some of the state's largest cities reported that they have received just a handful of applications for either lot splits or new units,while other cities reported none. In this commentary,we take a first look at SB 9's preliminary outcomes by assessing new housing development enabled by the law in a handful of jurisdictions statewide, exploring how many applications were submitted, and talking to local planners about why the numbers are so low. What is SB 9? SB 9 allows homeowners to create up to four homes on an existing parcel, in effect, eliminating single-family-only zoning. Crucially,the law allows the owner to"split" their lot, which makes it easier to sell or finance additional homes on a single parcel.A 2021 analysis by the Terner Center estimated that over 700,000 new homes would be newly feasible to build if SB 9 passed and taking into account on- the-ground market dynamics. However,we noted that it would be unlikely that anywhere near this number of homes would actually be built. Homeowners face multiple barriers to using SB 9 to split their lot and create new homes, including high construction costs and/or lack of expertise with homebuilding.We also found that local governments have created restrictions that limit the potential of SB 9. Our June 2022 analysis of a sample of ordinances from around the state found that some local regulations—such as low maximum unit size,height limitations, and other design rules—may render the construction of SB 9 homes infeasible. Is SB 9 being used? To answer this question,we collected data from thirteen jurisdictions across the state on applications received and approved for both lot splits and new homes as allowed under SB 9. Cities were selected based on our 2021 analysis showing where SB 9 projects would most likely be financially feasible, as well as cities that have had high accessory dwelling unit (ADU) production relative to their population. Relatively high ADU performance is a relevant metric for this analysis given that the size, scale, and location are likely to be similar—often owner-occupied single- family parcels—for ADU and SB 9 projects. We also interviewed eight planning professionals from four of these jurisdictions to better understand how SB 9 uptake has played out in those communities. 1 of 5 2/2/2023, 11:12 AN California's HOME Act Turns One:Data and Insights from the First Yea... https://ternercenter.berkeley.edu/research-and-policy/sb-9-turns-one-app.. We found that SB 9 activity is limited or non-existent in these thirteen cities (Table 1). Los Angeles had the most overall activity,with 211 applications for new units under SB 9 in 2022. The state's other large cities all reported very few applications for lot splits or new units. For example, the city of San Diego reported receiving just seven applications for new SB 9 units in 2022. To put these numbers into context, the city of San Diego permitted over 5,OOo new homes in all of 2021 and Los Angeles permitted just under 2O,000 new homes in 2021. Table 1. SB 9 Applications Received and Approved through November, 2022 Jurisdiction How many How How many How many applications many lot applications applications for lot splits splits for SB 9 for SB 9 has your city have been units has units has received? approved your city your city in your received? approved? city? Anaheim 2 0 1 0 Bakersfield 0 0 0 0 Berkeley 1 0 5 0 Burbank 1 0 7 2 Danville 20 13 0 0 Long Beach 1 0 1 0 Los Angeles 28 0 211 38 Sacramento 9 6 9 8 San Diego 3 0 7 0 San Francisco 4 2 25 4 San Jose 10 5 1 0 Santa Maria o 0 0 0 Saratoga 21 2 15 1 Among our sample, the smaller cities of Saratoga and Danville stand out for having a relatively higher number of SB 9 applications. Saratoga reported 15 applications for SB 9 units and 21 applications for lot splits in 2022. By comparison,the city permitted 71 total units of housing in 2021. Likewise, the city of Danville reported receiving 20 applications for lot splits,though no applications had been received for new units. What's going on? First,why Saratoga and Danville?The overperformance of these two cities relative to others in our analysis may be partly explained by the fact that these cities have larger single-family lot sizes. Planners from each jurisdiction we interviewed have 2 of 5 2/2/2023, 11:12 AN California's HOME Act Turns One:Data and Insights from the First Yea... https://ternercenter.berkeley.edu/research-and-policy/sb-9-turns-one-app.. seen that SB 9 seems to work best on larger lot sizes which allow for more room to build one to two new homes and noted the larger lot sizes in Saratoga and Danville. In addition, most homes are located in the center of their parcel, making the addition of another house geometrically difficult on a smaller lot size. Saratoga and Danville also have significantly higher home sale prices, making it more likely that splitting a lot will be financially beneficial to the homeowner. Second,why not cities that have seen relatively high levels of ADU development? San Diego has seen almost no SB 9 activity, despite high levels of ADU construction,with 871 ADUs permitted in 2021. Similarly, Santa Maria,which permitted 401 ADUs in 2021, reported receiving no applications for SB 9 units or lot splits.This contrast is worth pointing out given that ADUs are similar in size and location to new SB 9 units. Planners in cities with high ADU development that we interviewed hypothesized that more prescriptive state ADUs laws are likely pushing homeowners interested in creating new units towards ADUs. Recent changes in ADU laws—including laws that limit impact fees, remove owner-occupancy requirements, and allow for larger units—have made it easier to build Currently, however, SB 9 does not have this same flexibility. In fact, we found in a previous analysis that some cities are imposing additional requirements on SB 9 projects, including guidelines that are prohibited by state law for ADUs.As such, it may be more attractive for a homeowner to pursue an ADU rather than an SB 9 project. In addition,local ADU incentive programs are likely having an effect. Planning staff in San Diego and San Jose noted that their local ADU policies may preclude interest in SB 9. For example, San Diego allows larger ADU sizes and bonus ADU units (which allow owners to build multiple units on a single lot) in exchange for restrictions to make the units available to people with moderate incomes. San Diego and San Jose also adopted fairly permissive SB 9 implementing ordinances, as noted in our previous analysis. However, their ordinances,while more accommodating of SB 9 development than other cities, still do not match the incentives offered to homeowners considering ADUs, such as limiting impact fees or offering pre-approved design plans. Why does this matter? SB 9 has the potential to help solve the state's housing shortage, particularly by creating more units in single-family neighborhoods and providing entry-level homeownership opportunities,but only if the law's promise is realized through implementation. It is still too early to say that SB 9 is not working. Limited uptake of the new law may be impacted by the capacity and staff constraints that many planning departments are experiencing, alongside rising interest rates,high inflation, and ongoing supply chain/construction disruptions. However, it is also not too early to think of ways to strengthen SB 9 and remove ongoing barriers for homeowners interested in building more units on their property. Low numbers of applications for SB 9 projects so far do not necessarily imply low interest overall. Planners told us that while applications for SB 9 have been low, inquiries to their departments about SB 9 are high. That these inquiries have largely not yet translated into a correspondingly high number of applications may simply reflect the time and resources needed to pursue an SB 9 project as well as the aforementioned benefits of pursuing an ADU instead. However, the discrepancy could also suggest that more can be done at the local and state levels to improve overall utilization. 3 of 5 2/2/2023, 11:12 AN California's HOME Act Turns One:Data and Insights from the First Yea... https://ternercenter.berkeley.edu/research-and-policy/sb-9-turns-one-app.. Below are three specific areas that policymakers should examine to improve uptake of one of California's recent signature housing laws: Create more prescriptive state standards for SB 9 homes. SB 9 uptake could be improved by creating more prescriptive land use and zoning standards to enable greater SB 9 feasibility. This approach is one reason that ADUs have become a California success story, going from an insignificant share of the state's housing growth to nearly a fifth of all new units permitted statewide in just six years. This growth took time and persistence,with several rounds of legislation leading to the current ADU boom. SB 9 could benefit from similar legislative efforts. These efforts could include establishing more flexible standards for new home design—such as larger maximum home sizes and heights—and limiting extra costs—such as impact fees, particularly for single-family home to duplex conversions. In addition, planners we interviewed noted that SB 9's owner-occupancy requirement is likely limiting uptake. Policymakers may consider revisiting this requirement to encourage higher usage,while maintaining proper guardrails to protect against speculation by institutional investors and displacement in vulnerable communities. California's Department of Housing and Community Development should also consider pathways for jurisdictions to better leverage SB 9 for meeting future Regional Housing Needs Assessment (RHNA) goals. One such change could be allowing cities to include more aggressive growth rate assumptions in their planning if that city is taking proactive approaches to implementing SB 9. This shift would create an incentive for local governments to bolster educational outreach to residents and pursue more comprehensive implementation, as many have done with ADUs. Adopt more flexible local SB 9 ordinances. Cities have a role to play in the success of SB 9 as well. Even without new state legislation, local policymakers can consider adopting policies to improve SB 9 uptake, such as limiting fees and creating clear guidance and procedure for homeowners. Local policymakers can also consider additional strategies to increase housing supply in low-density neighborhoods outside of the state's SB 9 framework, including by increasing housing options above and beyond duplexes and creating design standards that facilitate several types of small-scale infill development. Some cities, such as Berkeley and Sacramento,have begun exploring this approach.A comprehensive local approach to missing middle housing can greatly complement the goals of SB 9. Address homeownership barriers. SB 9 has the potential to create more small- scale homeownership opportunities that are affordable to moderate-income buyers,but significant obstacles that are specific to homeownership development under SB 9 remain. Specifically, legislators should reassess requirements under certain policies such as the Subdivision Map Act and construction defect liability laws which increase costs and deter the construction of homeownership projects, as identified in our previous research on missing middle housing. These policies accrue costs that might otherwise be absorbable in the context of larger-scale homebuilding,but can make new small-scale for-sale homes financially infeasible to build. Legislators should consider creating exemptions or special categories for small-scale homeownership projects such as those allowed under SB 9. What's next? The passage of SB 9 in 2021 was hailed by many as a significant housing milestone that could create meaningful amounts of new homes in high-resourced 4 of 5 2/2/2023, 11:12 AN California's HOME Act Turns One:Data and Insights from the First Yea... https://ternercenter.berkeley.edu/research-and-policy/sb-9-turns-one-app.. neighborhoods while partly addressing the nefarious origins of single-family only zoning. However, ensuring major policy shifts achieve their intended goals often requires a sustained effort beyond one legislative cycle. Relatively low usage of SB 9 thus far indicates that the law could benefit from changes to its current form. For SB 9 to fulfill its promise,we should continue to monitor its impacts and legislators should consider revisiting the program as we enter the second year of implementation.As California enters a period of increased economic uncertainty— as shown by the governor's recent budget proposal and pending spending cuts—it is crucial to set up SB 9 for success now to ensure homeowners can make use of the law when economic conditions improve. Acknowledgments Many thanks to the San Francisco Foundation for their support of this work. Thank you to the planning professionals at the cities of Danville,San Diego, San Jose, and Santa Maria for sharing their insights as part of this analysis. We would also like to acknowledge Celeste Goyer,Jared Basler,Ned Resnikoff,Nolan Gray, and Ryan Joy for their review. Thank you to our Terner Center colleagues Ben Metcalf, Carolina Reid, and Ryan Finnigan as well as Terner Fellow Bill Fulton. This research does not represent the institutional views of UC Berkeley or of the Terner Center's funders.Funders do not determine research findings or recommendations in Terner Center's research and policy reports. 5 of 5 2/2/2023, 11:12 AT California duplex law not yet working as expected-Los Angeles Times https://www.latimes.com/california/story/2023-01-18/new-california-du.. California duplex law not yet working as expected - Los Angeles Times Hannah Wiley Once seen as the death knell for single-family-home neighborhoods in California, a new law meant to create more duplexes has instead done little to encourage construction in some of the largest cities in the state, according to a new report published Wednesday. Senate Bill 9 was introduced two years ago as a way to help solve California's severe housing crunch by allowing homeowners to convert their homes into duplexes on a single-family lot or divide the parcel in half to build another duplex for a total of four units. The law went into effect at the start of 2022. The bill received bipartisan support and ignited fierce debate between its backers, who said SB 9 was a much-needed tool to add housing options for middle-income Californians, and critics,who blasted it as a radical one-size-fits-all policy that undermined local government control. Neither argument has so far proved to be true. Across 13 cities in the state, SB 9 projects are "limited or nonexistent,"according to a new study by the UC Berkeley Terner Center for Housing Innovation. The report focused on cities considered high-opportunity areas for duplexes because they've reported significant increases in the construction of accessory dwelling units — also known as granny flats, casitas or ADUs —in recent years and have available single-family properties for possible divided lots.ADUs are small, free-standing homes most often built in the backyards of existing single-family homes. The cities are Anaheim, Bakersfield, Berkeley, Burbank, Danville, Long Beach, Los Angeles, Sacramento, San Diego, San Francisco, San Jose, Santa Maria and Saratoga. By the end of November,the cities had collectively received 282 applications for SB 9 projects, and had approved only 53. Los Angeles accounted for the bulk of applications with 211 submitted and 38 approved, according to the report. San Francisco received 25 applications and had approved four,while San Diego received seven and had approved none. Three cities received one application, and in Bakersfield, Danville and Santa Maria, zero were submitted. Applications for dividing lots seem to be even less popular than for building duplexes. Just io0 applications were submitted, the report noted, and 28 had been approved. 1 of 3 2/2/2023, 11:11 AN California duplex law not yet working as expected-Los Angeles Times https://www.latimes.com/california/story/2023-01-18/new-california-du.. David Garcia, Terner Center's policy director, said SB 9 is only in its first year of implementation and should be given more time before it's judged as ineffective. But he added that lawmakers should consider whether the law needs tweaking. "It doesn't seem like Senate Bill 9 in its first year has resulted in very meaningful amounts of new housing," Garcia said. "Pretty much everywhere you look, Senate Bill 9 activity is very marginal. It is nonexistent in some places." Homeowners right now have an easier time building an ADU than a duplex, thanks to local and state laws that have eased barriers to construction in recent years, Garcia said. It took multiple rounds of legislation to see productive ADU development, and the same will probably be true for SB 9 projects,he said. Recognizing that more was needed to speed up housing construction in California, the Legislature began overhauling state ADU laws in 2016, and cities followed suit with their own local ordinances to clear red tape in the building process,which has inspired a widespread ADU movement. Between the start of 2017 and January 2023, the city of Los Angeles reported receiving 35,098 applications for ADUs. It has issued permits for 25,88r and 13,640 have been granted certificates of occupancy. Heidi Vonblum, San Diego's planning director, said the law is new and barriers to development are still being worked out.At the same time, the city has an ADU program that"has been very attractive to property owners,"Vonblum said,while updated zoning rules and community plans have eliminated"the need to rely on other programs." It's a similar situation in Sacramento,where homeowners are allowed to build up to two ADUs on their properties, said Kevin Colin,the city's zoning administrator. Colin's team handles one to two ADU applications"each working day,"he said, because there's such high interest in the projects. To replicate that success, the Terner Center report suggested cutting fees associated with new duplex development, or adding more uniform standards for SB 9 projects to ensure local governments can't attach subjective criteria that discourage applications, such as architectural design requirements or stringent landscaping rules. It also proposed revising a mandate that homeowners who split their lots must live in one of the units for at least three years, a key concession lawmakers made to reduce opposition from organizations worried about gentrification. Senate President Pro Tern Toni Atkins (D-San Diego), author of the legislation, said SB 9 was"never intended to be an overnight fix to our housing shortage." "We always said not every homeowner would be able, or want, to utilize the tools provided by the bill on Day One,"Atkins said in a statement. "Subdividing a lot, or even just adding an ADU, is a big investment.This bill was never intended to be a sledgehammer approach —it was meant to increase the housing supply over time, and as awareness of the law increases and more homeowners have the ability to embrace the tools, I'm confident that we will see results." Garcia and other housing experts said slow progress could also be attributed to the effects of the COVID-19 pandemic,when prices for building materials shot up and homeowners and buyers faced significant market uncertainty. That was followed by 2 of 3 2/2/2023, 11:11 AN California duplex law not yet working as expected-Los Angeles Times https://www.latimes.com/california/story/2023-01-18/new-california-du.. high inflation and interest rates. But other factors could be contributing to sluggish SB 9 interest. Matthew Lewis, spokesperson for California YIMBY, a housing advocacy organization that supported SB 9, said both ADUs and duplexes have their financial and logistical pros and cons. ADUs are an ideal way to generate some "passive income"from a renter, Lewis said, and make great homes for aging parents or young adult children. Duplexes are good for that too,but the additional units can be sold separately for even greater economic opportunity. On the other hand,ADUs are typically a property extension of the main home, so it can be difficult or even impossible to separately sell the extra unit. Duplexes require significantly more financing, and the addition of a separate sewer line and water service. "The reality is people will follow the path of least resistance to building the house they want," Lewis said, adding that it could be worth going back to the drawing board to ensure local governments are doing what they can to ease burdens to duplex development. Although the Terner Center report offers legislators a limited snapshot of how SB 9 has worked so far, the state is also expected to have more robust data available this summer. Any attempt to modify SB 9 this year,however, is sure to reignite opposition from many of the dozens of cities and neighborhood associations that tried to block its passage in 2021. Since then, some cities have gone to great lengths to avoid implementing the law, including the Silicon Valley suburb of Woodside,which declared itself a mountain lion sanctuary and invited a stern warning for compliance by the state attorney general's office. 3 of 3 2/2/2023, 11:11 Ali Moore, Tania From: Kalmick, Dan Sent: Friday, February 17, 2023 12:46 PM To: supplementalcomm@surfcity-hb.org Subject: Please Include this supplemental communication for Item#26 Attachments: 621 Sup Corn - PP (1).pdf;Att3 - PC staff report.pdf; SB9 -California's HOME Act Turns One Data and Insights from the First Year of Senate Bill 9 -Terner Center.pdf; SB9 - California duplex law not yet working as expected - Los Angeles Times.pdf; KALMICK 2023-02-07 - MEMO REGARDING BURNS ITEM SB9_SB10.pdf Please include the attachments herein as supplemental communication for the City Council on Item#26—SB9/10 Please make the Memo the lead item. Thank you, Dan Kalmick City Councilmember City of Huntington Beach dan.kalmick@surfcitv-hb.org (657) 360-4796 'ftriv 2000 Main Street Huntington Beach, CA 92648 1 Switzer, Donna From: Fikes, Cathy Sent: Tuesday, February 21, 2023 1:23 PM To: Agenda Alerts Subject: FW: Proposal to Cease Processing Permit Applications under SB 9, et al. Attachments: Huntington Beach-2-21-23-AG clean final.pdf From: David Pai<David.Pai@doj.ca.gov> Sent:Tuesday, February 21, 2023 12:18 PM To:Strickland,Tony<Tony.Strickland@surfcity-hb.org>; CITY COUNCIL<city.council@surfcity-hb.org> Cc:Gates, Michael<Michael.Gates@surfcity-hb.org> Subject: Proposal to Cease Processing Permit Applications under SB 9, et al. Mayor Strickland and Honorable Councilmembers: Please see attached. DAVID PAI I Supervising Deputy Attorney General Land Use and Conservation Section, Public Rights Division �'" f,pafaa� ° rw, Department of Justice, Office of the Attorney General fity 1515 Clay Street, 20th Floor I Oakland, California 94612 Telephone (510) 879-0816 I David.Pai@doj.ca.gov File drop: https://fx.doi.ca.gov/filedrop/"dKliQ4 CONFIDENTIALITY NOTICE:This communication with its contents may contain confidential and/or legally privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of the communication. CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of the communication. Meeting Date.___24_12/22.3 Agenda Item No.; ry(p (3 — d707 J i 4`t.l 01 fh ROB BONTA State of California ,<. •' Attorney General DEPARTMENT OF JUSTICE 1515 CLAY STREET,20TH FLOOR P.O.BOX 70550 OAKLAND,CA 94612-0550 Public: (510)879-1300 Telephone: (510)879-0816 Facsimile: (510)622-2270 E-Mail: David.Pai@doj.ca.gov February 21, 2023 VIA EMAIL (confirmed by U.S. Regular Mail) (tony.strickland@surfcity-hb.org; City.Council@surfcity-hb.org) Mayor Strickland and City Councilmembers City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 RE: Proposal to Cease Processing Permit Applications Under SB 9,SB 10, or ADU-related State Laws Dear Mayor Strickland and Honorable Councilmembers: We write regarding the unlawful action related to SB 9, agendized as Item Number 26 on the February 21, 2023 regular meeting agenda of the Huntington Beach City Council (File No. 23-1702). That item directs the City Manager to "cease the processing of all applications/permits brought to the City by developers under SB 9, SB 10, or `State law related' ADU projects, until the courts have adjudicated the matter(s)."The item also directs the City Attorney to "take any legal action necessary to challenge SB 9 and SB 10 and the laws that permit ADU's." If adopted, the directive to cease processing such applications would be in direct violation of SB 9, the Housing Crisis Act, and may give rise to claims under the Housing Accountability Act. We urge the Council to decisively reject this unlawful proposal. A. Prohibiting the Processing of All SB 9 Project Applications Violates State Law Directing the City Manager to cease processing all applications under SB 9 would violate not only SB 9 itself, but also the Housing Crisis Act. Depending on the specifics of an SB 9 permit application, it would also violate the Housing Accountability Act. Under SB 9, local agencies must provide a ministerial approval process for any proposed housing development consisting of two residential units within a single-family residential zone (i.e., duplexes), and for any proposed subdivision of an existing parcel within a single-family residential zone into no more than two parcels. (Gov. Code, §§ 65852.21, subd. (a), 66411.7, subd. (a).)As the Department of Housing and Community Development(HCD)'s SB 9 Fact Sheet explains, ministerial review is where the "public official merely ensures that the proposed development meets all the applicable objective standards for the proposed action but uses no February 21, 2023 Page 2 special discretion or judgment in reaching a decision."' The statute provides that an SB 9 project may be denied only if the legislative body finds a project poses significant, quantifiable, direct, and unavoidable impacts—based on objective, identified written findings—to public health or safety on a case-by-case,project-specific basis. (Gov. Code §§ 65852.21, subd. (d); 66441.7, subd. (d); 65589.5, subd. (d)(2).)Nothing in SB 9 permits a City to reject any and all SB 9 projects "to protect the quality and lifestyle" of"well-established single-family neighborhoods." (Burns Memorandum, February 21, 2023). Further, we understand that in 2022, the City Council adopted a zoning amendment establishing objective development and design standards for SB 9 projects. (See City of Huntington Beach's Zoning Text Amendment 22-002.) Thus, it is unclear how the City Council can direct its City Manager to cease the processing of any SB 9 applications on the grounds that any SB 9 project would be inconsistent with the City's current zoning. Moreover, to date,there does not appear to be any SB 9 permit applications to the City,which makes this misguided and unlawful proposal even more puzzling. The Housing Crisis Act of 2019 prohibits the City from imposing any moratorium, or similar restriction or limitation, on housing development with exceptions limited only to specific and imminent threats of health and safety. (Gov. Code § 66300, subd. (b)(1)(B)(i).) Any development policy, standard, or condition enacted on or after January 1, 2020, that does not comply with the Housing Crisis Act shall be deemed void. (See Gov Code § 663300, subd. (b)(2).) The proposed action item directs the City Manager to stop processing any and all SB 9 applications until a court adjudicates whatever action the City Attorney may take to challenge SB 9. Such a directive violates the Housing Crisis Act. Finally, we note that SB 9 permit applications may be protected under the Housing Accountability Act. (Gov. Code § 65589.5, subd. (h)(2) [defining housing development projects].) If an SB 9 permit application conforms to the City's own objective development and design standards, the City may only deny such a project based on findings of certain specified health and safety threats. Specifically, the HAA requires the City to find that the project poses a health and safety threat and that those dangers are "significant, quantifiable, direct, and unavoidable," and that such findings are based on"objective, identified,written ... standards ... as they existed on the date the application was deemed complete." (Gov. Code § 65589.5, subd. (d)(2).). Disagreements over whether SB 9 is inconsistent with a city's zoning does not, standing alone, constitute a specific, adverse impact on public health or safety under the HAA. (Gov. Code § 65589.5, subd. (d)(2)(A).) Further, a categorical ban of SB 9 applications on the basis that the City Attorney is being instructed to challenge SB 9 in court is not a valid basis to cease the processing of those permit applications. In addition to the state's enforcement powers, housing organizations and aggrieved applicants have actionable legal rights and remedies under the HAA. We note that the HAA also See https://www.hcd.ca.gov/docs/planning-and-community- development/sb9factsheet.pdf February 21, 2023 Page 3 empowers the court to, upon a finding that a city acted in bad faith, award attorneys' fees and costs to the prevailing plaintiff or petitioner. (Gov. Code § 65589.5, subd. (k)(1)(a).)As the City is aware,having recently unsuccessfully defended itself against HAA claims brought by various nongovernmental organizations, courts have not been shy in awarding these fees and costs against the City. B. Prohibiting the Processing of ADU Projects Also Violates State Law State ADU law requires ministerial approval of, and sets the minimum requirements for, ADU development, while permitting local governments to establish their own ADU programs. (See Gov. Code § 65852.2, subd. (a)(1), (e)(1), and (g).)Although the agenda item does not attempt to define what the phrase "state law related ADU projects"is meant to refer to,there is no question that a categorical ban of any type of ADU application—"state law related"or otherwise—violates state law because ADUs are required to be ministerially approved. (Gov. Code § 65852.2, subd. (a)(3), (b)(1), (e)(1).)Indeed, HCD will issue a Notice of Potential Violation with regard to this particular aspect of the agenda item. C. The Directive's Reference to SB 10 is Nonsensical Given that SB 10 is a Voluntary Mechanism Which the City Has Chosen Not to Invoke Finally, we note that SB 10 permits—but does not require—cities and counties to enact ordinances to allow up to 10 dwelling units on any parcel, at a height specified in the ordinance, if the parcel is located within a transit-rich area or urban inf ill site. (Gov. Code § 65913.5.) It is, therefore, a voluntary, opt-in upzoning law. Given that the City of Huntington Beach has not chosen to invoke SB 10, we can discern no reason to direct the City Attorney to challenge SB 10 or the City Manager to stop processing SB 10 project applications. Agenda Item No. 26 is not only misguided, it is unlawful. As we stated in our letter to City Attorney Gates just one week ago, our office stands ready to enforce state housing laws if necessary. Sincerely, DAVID PAI Supervising Deputy Attorney General For ROB BONTA Attorney General cc: City Attorney Michael E. Gates(Michael.Gates@surfcity-hb.org) DP: dp Switzer, Donna From: Fikes, Cathy Sent: Tuesday, February 21, 2023 12:54 PM To: Agenda Alerts Subject: FW: Notice of Potential Violation Attachments: HuntingtonBeachNOPV-ADU-022123.pdf From: Heaton, Brian@HCD<Brian.Heaton@hcd.ca.gov> Sent:Tuesday, February 21, 2023 12:16 PM To: CITY COUNCIL<city.council@surfcity-hb.org> Cc:Zelinka, Al<AI.Zelinka@surfcity-hb.org>; David Pai <David.Pai@doj.ca.gov>; Gates, Michael <Michael.Gates@surfcity-hb.org>; Strickland, Tony<Tony.Strickland@surfcity-hb.org>; Zisser, David@HCD <David.Zisser@hcd.ca.gov> Subject: Notice of Potential Violation Huntington Beach City Council, Attached please find a Notice of Potential Violation regarding the City's intent to cease processing Accessory Dwelling Unit (ADU) permits. Regards, oaa/01. Brian Heaton,AICP 44. Senior Housing Accountability Manager, Housing Accountability Unit Housing and Community Development or .'Z, 2020 W. El Camino Avenue, Suite 500 I Sacramento, CA 95833 ec;44rscrR Phone: 916.776.7504 10. f HOUSING Is KEY iidaN Agenda(tom No, CP - 1 STATE OF CALIFORNIA-BUSINESS,CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM,Governor DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT �Q �,Un{rya DIVISION OF HOUSING POLICY DEVELOPMENT arm ate, 2020 W.El Camino Avenue,Suite 500 Sacramento,CA 95833 (916)263-2911 /FAX(916)263-7453 www.hcd.ca.gov •Cittrapl', . February 21, 2022 Mayor and City Council City of Huntington Beach Via: City.Council(asurfcity-hb.orq 2000 Main Street Huntington Beach, CA 92648 Dear Mayor Tony Strickland; Mayor Pro Tern Gracey Van Der Mark; and City Councilmembers Rhona Bolton, Pat Burns, Dan Kalmick, Casey McKeon, and Natalie Moser: RE: City's Intent to Cease Processing Accessory Dwelling Unit (ADU) Permits — Notice of Potential Violation The California Department of Housing and Community Development (HCD) is aware that today, the City Council of the City of Huntington Beach (City) will consider a proposal to "direct the City Manager to cease the processing of all applications/permits brought to the City by developers under SB 9, SB 10, or State law related to ADU projects, until the courts have adjudicated the matter(s)."1 The purpose of this letter is to notify the City that refusing to process ADU permits would be unlawful and in violation of state law, including but not limited to State ADU Law (Gov. Code, §§ 65852.150, 65852.2, 65852.22) and the Housing Crisis Act (HCA) of 2019 (Gov. Code, § 66300), and raises concerns under Affirmatively Furthering Fair Housing (AFFH) requirements (Gov. Code, § 8899.50) and State Housing Element Law (Gov. Code, § 65583 et seq.).2 1 Agenda for City Council/Public Financing Authority Regular, and Special Meeting of the Housing Authority, February 21, 2023, Item 26, File # 23-172, available at https://huntingtonbeach.legistar.com/LegislationDetail.aspx?ID=6028468&GUID=EBF79AC4-60E3- 4BC4-BC9F-34115765B077. 2 In addition, although it is outside the scope of this letter, HCD notes that cessation of processing applications for proposed SB 9 projects would be in violation of SB 9 itself (Gov. Code, §§ 65852.21, 66411.7) and may constitute a violation of other laws, including but not limited to the HCA (Gov. Code, § 66300), Housing Accountability Act (Gov. Code, § 65589.5), and Permit Streamlining Act (Gov. Code, §§ 65905.5, 65913.10, 65940 et seq.). HCD has notified the California Office of the Attorney General of these potential violations. For more information about SB 9, please refer to HCD's SB 9 Fact Sheet, available at https://www.hcd.ca.gov/docs/planning-and-community- development/sb9factsheet.pdf. Mayor Tony Strickland; Mayor Pro Tern Gracey Van Der Mark; and City Councilmembers Rhona Bolton, Pat Burns, Dan Kalmick, Casey McKeon, and Natalie Moser Page 2 State ADU Law The City Council's action would be an unlawful attempt to preempt the application of State ADU Law. Specifically, State ADU Law requires local governments to process ADU applications ministerially. For example, Government Code section 65852.2, subdivisions (a)(3)(A) and (b)(1), require permitting agencies to approve or deny ADU applications ministerially and without discretionary review within 60 days of a complete application's submittal. Under both provisions, "If the local agency has not acted upon the completed application within 60 days, the application shall be deemed approved." In addition, Government Code section 65852.2, subdivision (e)(1), states "a local agency shall ministerially approve an application for a building permit within a residential or mixed-use zone to create" ADUs that meet specific requirements. Moreover, the City, upon denying an ADU or junior ADU (JADU) application, must provide "in writing a full set of comments to the applicant with a list of items that are defective or deficient and a description of how the application can be remedied by the applicant" (Gov. Code, § 65852.2, subd. (b)(2)). Notably, Government Code section 65852.2, subdivision (a)(7), states, "No other local ordinance, policy, or regulation shall be the basis for the delay or denial of a building permit or a use permit under this subdivision."3 The City Council's direction to cease application and permit processing, therefore, cannot preclude the City from acting to approve or deny a permit to create an ADU. Housing Crisis Act of 2019 The proposed action would also constitute a violation of various provisions of the HCA. For example, the HCA prohibits a local government from "enact[ing] a development policy, standard, or condition" that would have the effect of"[c]hanging the general plan land use designation, specific plan land use designation, or zoning of a parcel or parcels of property to a less intensive use or reducing the intensity of land use within an existing general plan land use designation, specific plan land use designation, or zoning district in effect at the time of the proposed change, below what was allowed under the land use designation or zoning ordinances ... in effect on January 1, 2018." (Gov. Code, § 66300, subd. (b)(1)(A).) The statute defines "reducing the intensity of land use" to include "any other action that would individually or cumulatively reduce the site's residential development capacity." (Ibid.) 3 For more information about State ADU Law, please refer to HCD's Accessory Dwelling Unit Handbook (Updated July 2022), available at https://www.hcd.ca.gov/sites/default/files/2022- 07/ADUHandbookUpdate.pdf. Mayor Tony Strickland; Mayor Pro Tern Gracey Van Der Mark; and City Councilmembers Rhona Bolton, Pat Burns, Dan Kalmick, Casey McKeon, and Natalie Moser Page 3 Clearly, refusing to process ADU permits would have the effect of reducing the residential development capacity of sites across the city, in violation of the HCA. The HCA also prohibits a local government from "[i]mposing a moratorium or similar restriction or limitation on housing development ... within all or a portion of the jurisdiction ... other than to specifically protect against an imminent threat to the health and safety of persons residing in, or within the immediate vicinity of, the area subject to the moratorium ...." (Gov. Code, § 66300, subd. (b)(1)(B)(i).) Moreover, the local government shall not enforce such "a moratorium or other similar restriction on or limitation of housing development until it has submitted the ordinance to, and received approval from, [HCD]." (Gov. Code, § 66300, subd. (b)(1)(B)(ii).) If HCD denies approval, "that ordinance shall be deemed void." (Ibid.) A resolution directing the cessation of ADU permits would function like an ordinance doing the same and would therefore be in violation of the HCA. HCD will not approve such a significant limitation on housing development, and the ordinance will be deemed void. Affirmatively Furthering Fair Housing The City Council's decision to deny ADU permits would be at odds with the City's AFFH obligations. ADUs can provide more affordable housing opportunities for low- and moderate-income households and provide access to higher-resource communities, helping to "overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics." (Gov. Code, § 8899.50, subd. (a)(1).) Indeed, the City's own draft housing element notes that the provision of ADUs is a strategy for addressing the needs of senior residents, single-parent households, and extremely low-income households, and 98 percent of the 563 projected ADUs in the draft housing element are allocated for very low-, low-, and moderate-income households.4 Housing Element Compliance Finally, while the City's housing element is currently out of compliance with State Housing Element Law, on September 30, 2022, HCD found that the draft housing element met statutory requirement at the time of review. HCD remains eager to see the City achieve compliance. However, the City Council's direction to cease processing 4 Huntington Beach Housing Element Update (Draft July 2022), p. B-51, available at https://www.hcd.ca.gov/housing-elements/docs/huntington-beach-6th-draft080122.pdf. Mayor Tony Strickland; Mayor Pro Tern Gracey Van Der Mark; and City Councilmembers Rhona Bolton, Pat Burns, Dan Kalmick, Casey McKeon, and Natalie Moser Page 4 ADU applications would represent a new— and significant—governmental constraint to the production of housing that would need to be addressed in the housing element, and impact the adequacy of the sites inventory, jeopardizing the City's pursuit of housing element compliance. Indeed, the City's current draft housing element projects the development of 563 new ADUs in the planning period to meet its regional housing needs allocations and includes several policies and programs related specifically to ADUs, including Policy 2.76 and Programs 2D and 2E.7 Conclusion HCD would like to remind the City that HCD has enforcement authority of State ADU Law, the HCA, AFFH, and State Housing Element Law, among other state housing laws. Accordingly, HCD may review local government actions and inactions to determine consistency with these laws. If HCD finds that a city's actions do not comply with state law, HCD may notify the California Office of the Attorney General that the local government is in violation of state law (Gov. Code, § 65585, subd. (j)). HCD will continue to monitor the City's actions regarding the proposed resolution, and if the City approves a resolution that violates state housing law, HCD will respond in order to remedy those violations. In addition, please be advised that the California Office of the Attorney General is also aware of this matter. If you have any questions or would like to discuss the content of this letter, please contact Brian Heaton at Brian.Heaton(a�hcd.ca.gov. Sincerely, David Zisser Assistant Deputy Director Land Use and Local Government Relations cc: Al Zelinka, City Manager Michael E. Gates, City Attorney David Pai, Supervising Deputy Attorney General s Id., pp. 4-15, B-48, B-49, B-51. 6 Id., p. 4-4. Id., p. 4-15. Moore, Tania From: Fikes, Cathy Sent: Monday, February 20, 2023 8:57 PM To: Agenda Alerts Subject: FW: Orange Coast League of Women Voters &agenda 26 From: diane nied <sstemc6@gmail.com> Sent:Saturday, February 18, 2023 6:42 PM To:CITY COUNCIL<city.council@surfcity-hb.org> Subject: Orange Coast League of Women Voters&agenda 26 Please find enclosed a letter from the League of Women Voters of Orange Coast, with many members as residents of Huntington Beach. This letter addresses concerns regarding Agenda Item 26 at the next Council meeting. Thank You Diane Nied LWVOC Housing/homelessness Action Team la 2023.2.18 HB Ietr.3 SUPPLEMENTAL COMMUNICATION Meeting Date: 42//c9AP3 Agenda item No.; t o9(D(c 3 -/4 LEAGUE OF WOMEN VOTERS February 18, 2023 To: Huntington Beach Mayor Strickland and City Council Members From: League of Women Voters of Orange Coast RE: February 21, 2023 City Council Meeting Agenda Item 26 The League of Women Voters position on housing and meeting basic human needs, states: "League supports measures to provide State programs to increase the supply of safe, decent, and adequate housing for all Californians. And supports action at all levels of government for the provision of affordable housing for all Californians." The League specifically supported SB 9. The statement from the California State League of Women Voters, on the bill's website, is as follows: https://focus.senate.ca.gov/sb9#support "We urgently need SB 9 to increase affordable housing supply in high-opportunity neighborhoods. Too many Californians — especially first-time homebuyers, low- and middle-income workers, and people of color — are locked out of the housing market because of exclusionary zoning that favors high-income households. SB 9 will empower local communities to build more middle-income housing and make the dream of homeownership a reality for more Californians." Aliso Viejo, Capistrano Beach, Costa Mesa, Dana Point, Lake Forest, Huntington Beach, Irvine, Laguna Beach, Laguna Hills, Laguna Niguel, Laguna Woods, Mission Viejo, Newport Beach, Rancho Santa Margarita, San Clemente, San Juan Capistrano, Seal Beach Our Orange Coast members, many living in Huntington Beach, support actions to provide affordable housing, to reduce or eliminate the number of sheltered or unsheltered residents, and provide needed rental housing. Benefits from Senate Bill 9: • The California Housing Opportunity and More Efficiency(HOME) Act streamlines the process for a homeowner to create a duplex or subdivide an existing lot. • This legislation will provide access to more rental and ownership options for working families who would otherwise be priced out of neighborhoods. • The provisions of the Home Act would allow homeowners to choose to build a duplex on a single family lot, or if the lot is of sufficient size, to subdivide the lot into two lots and build a duplex on each lot. • Accessory Dwelling Units allow multigenerational families to thrive together. Therefore, the League of Women Voters of Orange Coast opposes the proposed action by the Huntington Beach City Council to direct the city attorney to take any legal action necessary to challenge SB 9 and SB 10. SB 10 has already been declined by the city, as allowed by the act itself. Respectfully Submitted, Executive Committee League of Women Voters Orange Coast Aliso Viejo, Capistrano Beach, Costa Mesa, Dana Point, Lake Forest, Huntington Beach, Irvine, Laguna Beach, Laguna Hills, Laguna Niguel, Laguna Woods, Mission Viejo, Newport Beach, Rancho Santa Margarita, San Clemente, San Juan Capistrano, Seal Beach Moore, Tania From: Fikes, Cathy Sent: Monday, February 20, 2023 8:57 PM To: Agenda Alerts Subject: FW: Feb 21 City Council Agenda Item 26 From: Linda Moon<Isapiro048@gmail.com> Sent:Saturday, February 18, 2023 4:34 PM SUPPLEMENTAL To:CITY COUNCIL<city.council@surfcity-hb.org> COMMUNICATION Subject: Feb 21 City Council Agenda Item 26 Meeting Date: fr//c9o93 Dear Mayor Strickland and City Council Members Agenda Item No.; moo (22- /3a) I am a 48 year resident of Huntington Beach and I maintained a law practice here for 40 years before my retirement. I am writing in opposition to Item 26, Councilmember Burns' request to authorize the City Attorney to bring legal action to challenge the provisions of SB 9 and 10 and ADU requirements. Senate Bill 9—the California Housing Opportunity and More Efficiency(HOME)Act streamlines the process for a homeowner to create a duplex or subdivide an existing lot. Any new housing created as a result of this bill must meet a specific list of qualifications that protects historic districts, preserves environmental quality and the look of communities, and prevents tenants from being displaced. This legislation will provide access to more rental and ownership options for working families who would otherwise be priced out of neighborhoods. You have noted yourself that Huntington Beach is 95% built out. There is little room or resources to build affordable housing. Yet there continues to be a need for housing our workforce and the grown children we raised here. The legislation creates the ability for the city to increase housing in existing neighborhoods, without changing their character. The provisions of the Home Act would allow homeowners to choose to build a duplex on a single family lot, or if the lot is of sufficient size, to subdivide the lot into two lots and build a duplex on each lot. Building two modest units on a 6,000 foot lot or even a 3000 foot lot is less impactful than allowing a 4000 foot mansion on a 2500 square foot lot as occurs often in Huntington Beach. This legislation will allow more families to reside in low-density neighborhoods, which are currently financially prohibitive for them. Senate Bill 10 authorizes a local government to voluntarily adopt an ordinance to zone any parcel for up to 10 units of residential density per parcel, at a height specified in the ordinance, if the parcel is located in a transit-rich area or an urban infill site, as those terms are defined. The City has no obligation to utilize the provisions of SB 10. There is, therefore, no reason to challenge its provisions. Accessory Dwelling Units (authorized by prior separate legislation) provide needed housing for family members, students, the elderly, in-home healthcare providers, the disabled, and others, at below market prices within existing neighborhoods. Duplexes, Quadplexes and ADU's will not solve Huntington Beach's housing crisis but they will create benign tools to reduce the need for affordable housing. Like previous litigation challenging housing mandates, lawsuits to challenge these statutes would be futile and costly. 1 Sincerely, Linda Sapiro Moon (714) 381-8425 5861 Liege Dr. Huntington Beach, CA 92649 2 Moore, Tania From: Fikes, Cathy Sent: Monday, February 20, 2023 9:26 PM To: Agenda Alerts Subject: FW: City Council Meeting From:vanessaweb@aol.com <vanessaweb@aol.com> Sent: Monday, February 20, 2023 3:06 PM To:CITY COUNCIL<city.council@surfcity-hb.org> Subject:City Council Meeting Dear Members of City Council, We are unable to attend the meeting, but we want our voices to be heard and counted. Item 23. We support the flying of the Pride flag as a symbol of the diversity and support for all. We feel it encourages visitors and businesses. Item 26. We do not agree with Huntington Beach fighting compliance with the state mandate for Regional Housing Needs Allocation. We need people from all income levels to work in HB. We can't expect them to commute for hours to work for minimum wage. Everyday on social media, people are pleading, asking for referrals for homes or apartments. Many of them have lived here all their lives. Please do not waste your time and our money by fighting this. Item 27. It is appropriate for the council to say the Pledge of Allegiance. It is not necessary to have an invocation which can be exclusionary. Thank you. Sincerely, Vanessa and Jeff Webster 19421 Hansen Ln. Sent from the all new AOL app for iOS SUPPLEMENTAL COMMUNICATION Meeting Date: *49(20- Agenda Item No.; ago 163 '/?e2) i Moore, Tania From: christopher.j.varga@gmail.com Sent: Tuesday, February 21, 2023 12:22 PM To: CITY COUNCIL; supplementalcomm@surfcity-hb.org Subject: City Council Meeting 2-21-23 Huntington Beach City Council Meeting 2/21/23 My comments on the following Agenda Items: Agenda Item 23 (23-165): Flags on Government Property I oppose this ordinance as it will have and is having a negative impact on local businesses and puts Huntington Beach in a negative light. Huntington Beach is a tourist destination and by flying flags that make people feel welcome should be displayed. We as a city should promote inclusion and not exclusion. Support Local Businesses that depend on all people from outside the city to come and spend their free time and money. This ordnance does not make Huntington Beach appear to be a place that all are welcome. Does this City Council listen to the public Comments? With the vast majority opposing this ordnance why doesn't this council listen? Are public comments not valued or are they something to ignore? Agenda Item 26(23-172): ADU Permits I oppose this attempt to stop processing ADU permits. This is once again the CC attempt to not comply with the State of California on housing solution. This will cost the tax payers of Huntington Beach fighting a no win battle the state of California. Please stop this costly battle with the State. General Comments: I thought the Huntington Beach City Council was a non-partisan public office. Will the so called conservative council members ever break ranks? Or is it an "all for one and one for all" type mentality? I'm hoping that as some point, one of the recently elected council member will break away for a vote or two. Maybe the city council should be partisan so we have a better idea who we are voting for in the future. I just what to point out the 4 recently elected city council members roughly were vote in by approximately 20,000 votes each. That about 10%of the city population. Please keep the other 90%of the city population in mind when you make decisions that affect all of us. Sincerely, Chris Varga 40+year resident of Huntington Beach S UM:7 Meeting Date: . .1 3 Agenda Item Nt.° � a3 O 7a Switzer, Donna From: Fikes, Cathy Sent: Tuesday, February 21, 2023 12:51 PM To: Agenda Alerts Sk 7,4`, ^"�w37; L r Subject: FW: February 21 2023 meeting C-Ci: 4. a � ` dON Meeting Date: e.// -1 /23 From:Annilise Flanagan-Frankl<anniliseff@gmail.com> Agenda Item No.; (023 -17-2) Sent:Tuesday, February 21, 2023 11:17 AM To:CITY COUNCIL<city.council@surfcity-hb.org> Subject: February 21 2023 meeting I am unable to attend the meeting in person and wish to make a public comment on the following agenda items. #23. I OPPOSE this item. HB needs to demonstrate it is an inclusive comment. #24. This needs more information #25. This needs more information. #26. I OPPOSE this item. State law applies to ALL communities. #27. I OPPOSE this item. To be an inclusive community the separation of church and state should not intersect. This opens the door to unnecessary litigation. Annilise Flanagan-Frankl Annilise M. Flanagan-Frankl, M.A. CounselingPsychologist Nationally Certified School Psychologist Remember - the past is over, the future is a mystery,and today is a gift. That is why it is called the PRESENT. Make today count. Call: 847-226-3119 i Switzer, Donna From: Fikes, Cathy Sent: Tuesday, February 21, 2023 1:23 PM To: Agenda Alerts Subject: FW: City Council Meeting 2-21-23 From: christopher.j.varga@gmail.com<christopher.j.varga@gmail.com> Sent:Tuesday, February 21, 2023 12:22 PM To: CITY COUNCIL<city.council@surfcity-hb.org>; supplementalcomm@surfcity-hb.org Subject:City Council Meeting 2-21-23 Huntington Beach City Council Meeting 2/21/23 My comments on the following Agenda Items: Agenda Item 23 (23-165): Flags on Government Property I oppose this ordinance as it will have and is having a negative impact on local businesses and puts Huntington Beach in a negative light. Huntington Beach is a tourist destination and by flying flags that make people feel welcome should be displayed. We as a city should promote inclusion and not exclusion. Support Local Businesses that depend on all people from outside the city to come and spend their free time and money. This ordnance does not make Huntington Beach appear to be a place that all are welcome. Does this City Council listen to the public Comments? With the vast majority opposing this ordnance why doesn't this council listen? Are public comments not valued or are they something to ignore? Agenda Item 26(23-172): ADU Permits I oppose this attempt to stop processing ADU permits. This is once again the CC attempt to not comply with the State of California on housing solution. This will cost the tax payers of Huntington Beach fighting a no win battle the state of California. Please stop this costly battle with the State. General Comments: I thought the Huntington Beach City Council was a non-partisan public office. Will the so called conservative council members ever break ranks? Or is it an "all for one and one for all" type mentality? I'm hoping that as some point, one of the recently elected council member will break away for a vote or two. Maybe the city council should be partisan so we have a better idea who we are voting for in the future. I just what to point out the 4 recently elected city council members roughly were vote in by approximately 20,000 votes each. That about 10%of the city population. Please keep the other 90%of the city population in mind when you make decisions that affect all of us. Sincerely, Chris Varga 40+year resident of Huntington Beach Sir Meeting Date: -- Agenda Item No.;, 26 ( 23- 1 7-2) i