South Bay YIMBY

South Bay YIMBY is a grassroots group advocating for plentiful, inclusive, and affordable housing in the South Bay. We appreciate the opportunity to comment on San Jose’s Draft Housing Element, and thank staff for the considerable work they undertook in preparing this document.

Since 2014, San Jose has consistently ranked among the worst of California’s major cities in per capita housing growth. It ranked 8th out of the state’s ten largest cities in 2014, 8th in 2015, 7th in 2016, 7th in 2017, 9th in 2018, 9th in 2019, and last in 2020. The status quo is unacceptable, and San Jose must take “meaningful actions” to meet its housing needs during the 6th RHNA cycle. (Gov. Code § 65584(e).)

We believe the Draft Housing Element contains several commendable elements, with sites widely distributed and a promising set of policies. The city’s pipeline analysis, which discounts production based on the percent of entitled projects which have proceeded to be developed, is particularly praiseworthy, as is the proactive inclusion of zoning changes in the Sites Inventory. However, we believe the Draft Housing Element could and should be improved in several ways:

• The analysis of zoning as a constraint is minimal, while consideration of existing uses as a constraint is inconsistent, and the city does not consider what policy tools it may have to address high construction costs as a constraint.
• High-impact policies such as ministerial approval should be implemented sooner, rather than later, to make a difference in this planning period.
• Opportunities for affordable housing remain constrained to high traffic, high pollution arterials, with little to none located in the city’s highest resource census tracts and Racially Concentrated Areas of Affluence (RCAA).
• We commend the city’s anti-displacement and tenant protection policies, but more could be done to strengthen this aspect of the Housing Element.

The Draft Housing Element’s analysis of constraints is incomplete on zoning & construction costs

San Jose’s General Plan and zoning confine housing growth to only a narrow subset of the city’s land, yet the Draft Housing Element does not analyze whether this constrains housing growth within the city. The various zoning districts of the city are listed, but their standards such as setbacks are not assessed for whether they act as constraints. Nor is the relative proportion of different zoning districts considered. San Jose has a particularly high share of its land zoned exclusively for single family homes, covering 84-94% of the city’s residentially zoned land and a majority of all non-agricultural land within the urban growth boundary. Does this abundance of land with the most restrictive zoning designation constrain housing growth in San Jose? The document does not say.