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.

The following are our comments on the City of Scotts Valley’s submitted Housing Element of July 5, 2023.

Justification and Analysis of 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.” (1)

Scotts Valley is expecting that all sites identified for rezoning (2) will develop roughly 50% of their units for very-low, low, or moderate income families, while providing little to no evidence (historic or otherwise) that this level of affordability will be realistically produced. 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.

Most of the parcels in the Site Inventory under Rezones-Mixed Use are non-vacant, as is the largest one in the Town Center Specific Plan. The City has not described the realistic development potential of each site, including, as HCD recommends, “...the extent that the nonvacant site’s existing use impedes additional residential development, the jurisdiction's past experience converting existing uses to higher density residential development, market trends and conditions, and regulatory or other incentives or standards that encourage additional housing development on the nonvacant sites.” (3)

This is compounded by the fact that these sites (Rezones-Mixed Use and the Town Center Specific Plan parcel) account for more than 50% of the lower income RHNA, so ” …the existing use is presumed to impede additional residential development, unless the housing element describes findings based on substantial evidence that the use will likely be discontinued during the planning period.” (4) The city has not provided such findings aside from noting surface soil contamination in the process of remediation at the town center site.

If the city misses its target of 50% affordability on even just a few parcels (especially its larger sites), it faces the daunting task of identifying other sites to make up the difference under No Net Loss 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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(1) Santa Cruz Civil Grand Jury - Housing Our Workers, page 18, Finding 9
(2) Housing Element, F24-26(3) , Page 24(4) , Page 27(5) , Page 22