Santa Cruz YIMBY

Santa Cruz YIMBY has the following comments on the City of Santa Cruz’s 6th cycle Housing Element draft dated August 21, 2023 (1). We appreciate the changes that have been made since the July 2023 draft, many of which were responsive to our input. We are focusing this letter on some remaining issues in the amended Housing Element (2).

In response to the ever-increasing cost of living, Santa Cruz YIMBY advocates for abundant housing at all levels of affordability to meet the needs of a growing population in Santa Cruz County. The Housing Element is an opportunity for the City of Santa Cruz to address the housing crisis on its own terms.

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(1) City of Santa Cruz Housing Element - August 21, 2023
(2) HCD letter to City of Santa Cruz dated August 8, 2023

Policy 1 - Housing Production

• Objective 1.1d enforces unit replacement requirements and should include monitoring unit loss due to consolidation, e.g. the conversion of multi-unit homes into single-family. This could include penalties, such as ADU requirements or other fees.
• Objective 1.2a adopts an EIR for the Downtown Expansion Plan. The City should consider more units in the Downtown Expansion Plan to account/prepare for future RHNA cycles.
• Objective 1.3g is a good addition - we hope that this allows the City to increase the number of units in the Downtown Expansion Plan for future cycles.
• Objective 1.5a includes a review of ADU development and we are pleased to see the added timeline commitment of 18 months. There is still an opportunity for a menu of actions that would facilitate development if it lags such as:
• • Allowing multiple ADUs
  • Developing a concession program
  • Other financial or technical incentives
• Objective 1.5e could be tightened to “Amend ADU owner occupancy regulations by May 2024”
• Objective 1.6a related to the Planned Development Permit process could be incorporated into a local density bonus program.

Policy 2 - Affordable Housing

• In Objective 2.1a, we suggest this be moved earlier than 2026.
• Objective 2.2c explores additional funding for affordable housing, but only focuses on the potential ballot measure. This could be expanded to a menu of options - e.g. parcel tax tied to upzoning land, impact fees for single-family projects.