Santa Cruz YIMBY

To: Scotts Valley City Council

RE: Housing Element adoption on 12/20/2023 Agenda

The Housing Element process is intended to make sure all California jurisdictions undertake a good-faith effort to plan for the housing needs of their communities over the following eight years. We agree with HCD’s assessment that Scotts Valley’s October Housing Element does not substantially comply with state law and do not believe the changes on the revised December draft substantively address HCD’s findings.

The city should not adopt a noncompliant Housing Element and expect to be exempt from the consequences of said noncompliance. Attached is a flier which reviews some potential impacts of noncompliance.

Our feedback to the city on the December draft carries over from our November 21st letter to HCD and city staff (attached). We will reiterate some of the major points which remain unaddressed with additional context from HCD’s December 19th letter.

Affirmatively Furthering Fair Housing

HCD comment(s): [T]he element must include a significant suite of programs to promote housing mobility or housing choices and affordability throughout the City. These programs should not be limited to the RHNA and, instead, target significant and meaningful change… Given the fair housing conditions in the City and the location of RHNA sites, the element will need to include significant actions to promote housing mobility (e.g., housing choices and affordability) throughout the City to promote inclusive communities.

Without substantial changes, such as additional rezoning in R-1 single family neighborhoods, Scotts Valley perpetuates segregation and exclusivity.

Missing middle housing to add density in these R-1 neighborhoods must go beyond ADUs and SB9 - it should include rezoning and other incentives for duplexes, quadplexes, cottage courts and multiplexes. Gentle density can be done simply using SB10 and would allow Scotts Valley to equitably distribute new housing, especially in Census Tracts 1 and 2.

Pipeline Projects

HCD comment(s): For example, the element could address anticipated timelines for final maps submittal or detail the remaining steps and anticipated timelines for completion. The element could also discuss the City’s completion rate on pipeline projects from the last planning period, analyze any infrastructure schedules, outreach with project developers on potential timelines or other relevant information.

Pipeline projects are incredibly important to the city meeting its housing goals, existing projects make up roughly 20 percent of site inventory units and 34 percent of RHNA. Due to the significance of these projects, Scotts Valley should be doing everything in its power to ensure they move forward and actually get built during the 6th cycle.

We would like to see anticipated timelines for development of these projects and a commitment to work with the developers to navigate any barriers which can be addressed by the city which may be delaying the process.