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 Santa Cruz County 6th cycle draft Housing Element of November 3, 2023. We appreciate the work of county planning staff on the many changes to the Housing Element over the past months. We have focused these comments on areas highlighted by HCD in the letter dated October 23, 2023.

Affirmatively Furthering Fair Housing

HCD: “Sites Inventory and AFFH: The analysis must explain whether sites are isolated by income group and discuss whether the distribution of sites improves or exacerbates conditions. If sites are isolated or exacerbate conditions, the element should identify further program actions that will be taken to promote inclusive and equitable quality of life throughout the community (e.g., new affordable housing opportunities in higher opportunity areas, housing mobility).”

• The County has added analysis related to Racially Concentrated Areas of Affluence (RCAA) but not substantially planned for more affordable housing in RCAA census tracts.
• The Housing Element HE still plans for 85% of affordable housing in high/highest access to opportunity regions as shown on TCAC/HCD Maps only ~ 5% of affordable housing is planned for racially-concentrated areas of affluence (RCAA).
• At least two census tracts (1208 and 1222.02) are both high/highest resource areas and RCAA, but have only above-moderate units planned. These two census tracts are primarily made up of low density, single family residential homes. Census tract 1222.02 in Aptos includes a grocery store and elementary school.
• Affordable units should be incentivized for these areas, including through missing middle housing.

Sustainability Update/Development standards as constraints

HCD: Land Use Controls “The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types. The analysis should analyze land use controls independently and cumulatively with other land use controls. The analysis should specifically address requirements related to floor area ratio (FAR) and lot coverage limits in the R-UM (Urban Medium) zone. The analysis should address any impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints.”