Santa Cruz YIMBY

Santa Cruz YIMBY advocates for abundant housing at all levels of affordability to meet the needs of a growing population in Santa Cruz County. We support sustainable growth, including along transportation corridors and activity centers and a commitment to lower Vehicle Miles Traveled by housing people near services and jobs.

We submit the following comments on the City of Scotts Valley’s 6th cycle Housing Element draft of May 19, 2023(1).

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(1) Scotts Valley Housing Element - Public Review Draft 5.19.2023

Probability of Meeting Low Income Targets

“The City of Scotts Valley has facilitated the building of market rate housing in recent years, but has made little effort to develop housing for low income workers.”(2) According to the site inventory (3) Scotts Valley is expecting that all sites identified for rezoning will set aside roughly 50% of their units for very-low, low, or moderate income families, while providing little evidence that this level of affordability will be realistically produced. Meanwhile, the city’s four pipeline projects consist of only 18% affordable units. We would like the city to explain why it expects to achieve this 50% target, and how it will enable the development of additional housing if this target is not being met. For comparison, the City of Santa Cruz (4) is projecting a 20% affordability rate for most parcels in its site inventory.

If the city misses its target of 50% affordability, it faces the daunting task of identifying other sites to make up the difference under No Net Loss law. With nearly half of its very-low and low income units planned for through the Town Center Specific Plan, this single project not producing as many units as expected would subject the city to this law. Additionally, there is only a 9% buffer for moderate income units, HCD recommends a buffer of between 15 and 30 percent (5).

In order for Scotts Valley to meet the needs of its most vulnerable residents, it is essential that plans for affordable housing not only sound good, but are workable and realistic.

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(2) Santa Cruz Civil Grand Jury - Housing Our Workers, page 18, Finding 9
(3) Housing Element, F-23
(4) The only jurisdiction in Santa Cruz County to meet its 5th cycle goals
(5) Housing Element Sites Inventory Guidebook, page 22

Pipeline Projects

A significant source of new units for the city during the 6th cycle will be from pipeline projects. For jurisdictions relying heavily on pipeline projects, HCD recommends (6) that “…the element should include programs with actions that commit to facilitating development and monitoring approvals of the projects, including the number of units and affordability (e.g., coordination with applicants to approve remaining entitlements, supporting funding applications, expediting approvals and monitoring of project progress, including rezoning or identification of additional sites, if necessary).”