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 Housing Element of November 14, 2023 updated in February 2024. We appreciate the work of county planning staff on the many changes to the Housing Element over the past months.

Affirmatively Furthering Fair Housing

HCD letter of Jan 16, 2024: “Programs: As noted in the prior review, goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends….Specifically, the element should add actions to enhance housing mobility(housing choices and affordability) in higher resource, higher income and concentrated areas of affluence (regardless of the RHNA) and to revitalize communities through place-based strategies in lower resource, lower income and higher poverty areas.

We note the additional language supporting housing mobility:

• Program H-1J notes where SB10 rezoning is happening, but the parcel list hasn't changed, so several RCAAs with largely low-density single family homes (1208, 1212) still have no low-income housing planned. Note that the table HE-A-19 indicates that Census tract 1222.02 has 0 low income homes, but the narrative says 60 low income homes.
• Program H-1M includes the vague language of “consideration of actions…if necessary”. This should be a true commitment to action.
• Program H-3L is a terrific addition of place-based improvements in lower resource, lower income and higher poverty areas.

Development standards as constraints

HCD letter of Jan 16, 2024: Public Facility Sites: The element now generally discusses recent examples of public facility sites but should also discuss their suitability for development in the planning period, including status, anticipated schedule, and any known barriers to development in the planning period. Based on the outcomes of this analysis, Program 3I should be revised with a schedule of additional actions including completing entitlements, issuing permits and alternative actions (e.g., additional incentives, rezoning) by a specified date if sites do not progress as anticipated.