06 Addendum.Item #6 - Housing Element
PREPARED BY: Erin Walters, Associate Planner and
Jocelyn Shoopman, Associate Planner
Reviewed by: Town Manager, Assistant Town Manager, Town Attorney, and the Community
Development Director
110 E. Main Street Los Gatos, CA 95030 ● (408) 354-6872
www.losgatosca.gov
TOWN OF LOS GATOS
COUNCIL AGENDA REPORT
MEETING DATE: 2/6/2024 ITEM NO: 6 ADDENDUM
DATE: February 5, 2024
TO: Mayor and Town Council
FROM: Laurel Prevetti, Town Manager
SUBJECT: Review and Discuss the Proposed Revisions to the Draft Revised 2023-2031
Housing Element. Location: Town-Wide. General Plan Amendment Application
GP-22-003.
REMARKS:
In response to a Council Member’s questions, staff has provided the following responses in
italics to the summarized questions:
1. Provide a transcript of the January 18, 2024, Housing Element Advisory Board (HEAB)
Meeting. The meeting is nearly three hours long, the audio recording is not indexed, the
audio cannot fast forward or moved ahead, and many of the comments and at least one
motion was incomprehensible. This information is necessary because the HEAB made
changes to the document that had not been reviewed by the Town Council.
Staff does not have adequate time to prepare a verbatim transcript of the January 18, 2024
HEAB meeting for the February 6, 2024, Town Council meeting. A summary of HEAB’s
recommendations made at the January 18, 2024 meeting are included in Section C of the
February 6, 2024 Town Council staff report.
2. Provide a track change copy of the Housing Element without Housing Element Advisory
Board modifications.
A summary of HEAB’s recommendations made at the January 18, 2024, HEAB meeting are
included in Section C of the February 6, 2024 Town Council staff report. All changes
recommended by the HEAB were also included in Attachment 7 of the February 6, 2024 staff
report, with exception to HEAB recommendation #2 as outlined in the February 6, 2024 staff
report regarding language proposed in Implementation Project J. For further clarification,
staff has extracted the pages from the most recent version of the Draft Revised Housing
PAGE 2 OF 3 SUBJECT: DRAFT REVISED 2023-2031 HOUSING ELEMENT/GP-22-003 DATE: February 5, 2024
REMARKS (continued):
Element and removed the HEAB’s recommended edits (Attachment 13).
3. Provide a copy of all correspondence sent by Staff and consultants to HCD, as referenced in
the December 24, 2023, and January 18, 2024, meetings.
Attachment 14 of this Addendum includes a copy of all correspondence sent by staff and the
Housing Element consultant to HCD.
4. Provide written feedback to the Town Council on what has been covered and what the
content of the responses have been in the calls and include the response from HCD.
Attachment 8, of the February 6, 2024, Town Council staff report, includes a column titled
“HCD Feedback Summary” which details the verbal feedback provided by the HCD reviewer
via a Zoom meeting held on January 18, 2024, with staff and the Town’s Housing Element
consultant, as well as further communication from the Town’s HCD reviewer, received via
email on January 19, 2024.
5. Provide any communications between Council Members and HCD and any communications
between HEAB members and HCD. At the January 18, 2024, HEAB meeting there were
several representations made by Council Members and HEAB Board members regarding
what HCD has instructed the Town to do.
Staff is unaware of any direct communications between Council Members and HEAB
members with HCD. The informal preliminary review matrix provided by HCD on January 18,
2024, was provided in Attachment 9 of the January 18, 2024, HEAB Desk Item to the HEAB
and discussed as part of the January 18, 2024, HEAB meeting.
6. Provide any information obtained from the January 18, 2024, meeting between staff and
HCD that was provided to the HEAB.
When asked by HEAB members at the January 18, 2024 HEAB meeting, staff and the
Housing Element consultant summarized the verbal feedback provided by the HCD reviewer
at the Zoom meeting held on January 18, 2024, and within the informal preliminary review
matrix provided by the Town’s HCD receiver on January 18, 2024 (Attachment 8).
PAGE 3 OF 3 SUBJECT: DRAFT REVISED 2023-2031 HOUSING ELEMENT/GP-22-003 DATE: February 5, 2024
ATTACHMENTS:
Previously Received with the January 16, 2024 Staff Report:
1. Draft Revised Housing Element, Track Changes Copy
2. Draft Response Table
3. December 1, 2023 HCD’s Findings Comment Letter
4. Public Comments Received Between 11:01 a.m., Tuesday, December 19, 2023, and 11:00
a.m., Thursday, January 11, 2024
Previously Received with the January 16, 2024 Desk Item:
5. Comments from the Vice Mayor
6. Public Comments Received Between 11:01 a.m., Thursday, January 11, 2024, and 11:00
a.m., Tuesday, January 16, 2024
Previously Received with the February 6, 2024 Staff Report:
7. Draft Revised Housing Element, Track Changes – January 2024
8. Draft Response Table – January 2024
9. HCD Informal Preliminary Review Matrix with Staff’s Responses
10. Goldfarb & Lipman, LLP Feedback Table with Staff’s Responses
11. Track Changes and Clean Version of Program AY Housing Mobility
12. Public Comments Received Between 11:01 a.m., Tuesday, January 16, 2024, and 11:00 a.m.,
Thursday, February 1, 2024
Attachments received with this Addendum:
13. Pages from the Draft Revised Housing Element Without the Recommendations Made by the
Housing Element Advisory Board
14. Correspondence with HCD
Page 10-15 of Chapter 10 of the Draft Revised Housing Element
(January 2024 version) without recommendation #4 of the
January 18, 2024 Housing Element Advisory Board meeting
ATTACHMENT 13
10. Housing Element
JanuaryNovemberSeptember March 2023 2024 HCD Draft Revised Draft 2023-2031 Housing
Element
10-15
Justice, Diversity, Equity, and Inclusion
Like many other cities in the United States, Los Gatos has a history which includes racial injustice. The Town
also has a long-standing commitment to being equitable and inclusive. In the last couple years, with racial justice
issues at the forefront of local and national conversations, the Town has taken a more holistic approach to
Justice, Equity, Diversity, and Inclusion work. The Town of Los Gatos values justice, equity, diversity, and
inclusion (JEDI). The Town works proactively to ensure the rights and opportunities of everyone in Los Gatos and
opposes any attempts to undermine the safety, security, and rights of any members of the community. The Town
promotes equal treatment, equitable distribution of and access to resources, and engagement in issues affecting
the lives of residents, workers, and visitors. The Town does not tolerate discrimination, racial injustice, or police
brutality. The Town works toward realizing the values of diversity, equity, and inclusion by taking specific actions
to become a more inclusive community.
In May of 2017, the Town Council affirmed a commitment to Los Gatos as a diverse, supportive, equitable, and
inclusive community.
On June 5, 2020, the Town affirmed its commitment to stand in solidarity with the black community with a
Proclamation from the Mayor.
On June 17, 2020, the Mayor signed the Obama Foundation’s Mayor’s Pledge, committing to review Police
Department standards, report back to the community, and work on reforms.
On June 19, 2020, the Town launched a new webpage, “Becoming an Inclusive Community,” dedicated to
outlining the shared values of justice, diversity, equity, and inclusion. In naming the new webpage “Becoming an
Inclusive Community,” the Town acknowledged that there is work to do; and by clearly stating the commitment to
inclusivity and diversity, the Town strives to take the steps needed to reach that goal. The dedicated webpage
can be viewed at www.LosGatosCA.gov/Inclusivity and is kept updated on a regular basis with Town efforts and
current information.
On July 30, 2020, the General Plan Update Advisory Committee (GPAC) held a special meeting to review and
discuss the topics including racial, social, and environmental justice in the General Plan. As a result of this
meeting, the first Element of the 2040 General Plan is a new Racial, Social, and Environmental Justice Element.
In 2020, the Town hosted three community workshops via teleconference to foster dialogue on racial and social
justice and how Los Gatos can be more welcoming for all. The three conversations covered police reform, and
housing. The inclusivity webpage contains full video recordings, presentations, and other information associated
with these conversations.
On June 30, 2022, the Council adopted the 2040 General Plan with a brand-new chapter: the Racial, Social, and
Environmental Justice Element. This guiding Element works in conjunction with the Town’s commitment to create
a more inclusive Los Gatos and provide safe spaces for all to join in conversations to shape the Town’s future.
The Town’s work to further the goals and policies stated in this new Element include: hosting community
conversations; adopting Diversity, Equity, and Inclusion as an ongoing Council Strategic Priority since 2021;
implementing Police reforms; working with the California Senate and Assembly on the development of Senate Bill
1100, which updates public meeting laws to provide an important balance of maintaining freedom of speech,
protecting public safety, and providing protection for elected officials; and developing a formal JEDI plan with
goals, action items, and timelines.
Pop-up Community Outreach
Farmers’ Market Informational Booth
Town staff hosted a 2040 General Plan Update and Housing Element Update informational booth at the Los
Gatos Farmers’ Market on Sundays from 9:00 a.m. to 12:00 p.m. on the following dates:
June 27, 2021.
July 18, 2021.
August 8, 2021.
August 29, 2021.
Page 10-17 of Chapter 10 of the Draft Revised Housing Element
(January 2024 version) without recommendation #5 of the
January 18, 2024 Housing Element Advisory Board meeting
10. Housing Element
JanuaryNovemberSeptember March 2023 2024 HCD Draft Revised Draft 2023-2031 Housing
Element
10-17
To help guide the update to the General Plan, the Town Council appointed a GPAC. The GPAC was composed
of the Town’s General Plan Committee (GPC) and three additional residents. The GPC includes two Town
Council members, three Planning Commissioners, and four residents. The GPAC served to review and discuss
issues, opportunities, and the development the Draft 2040 General Plan. The GPAC held more than 35 public
meetings throughout the General Plan Update process, listening to community input and contributing to the
development of Land Use Alternatives, and the content of the General Plan document.
Public Participation to Affirmatively Furthering Fair Housing
The Los Gatos public participation program was also responsive to AFFH, which requires local jurisdictions to
conduct public outreach to equitably include all stakeholders in the housing element public participation program
(see Section 10.1.3 for more complete information on AFFH).
Tribal Consultation
This public participation effort also includes formal consultation, pursuant to Government Code §65352.3, with
representatives from nine Native American tribes that are present and active in Santa Clara County.
10.1.6 Public Comment
Public Comments
A full listing of public comments received during the public review of the 6th Cycle Housing Element are included
in Appendix I: Public Comments. Responses to public comments, where appropriate, are also provided.
10.2 Overview of Housing Needs and Constraints
This section summarizes the housing needs of Los Gatos as determined through the comprehensive housing
data assessment and analysis presented in Appendix B and serves as the basis for housing goals, policies, and
implementation programs. The housing summary gives an overview of population trends: characteristics of the
housing stock; housing affordability; and special needs households.
10.2.1 Introduction
The Bay Area continues to see growth in both population and jobs, which means more housing of various types
and sizes is needed to ensure that residents across all income levels, ages, and abilities have housing
opportunities. While the number of people drawn to the region over the past 30 years has steadily increased,
housing production has stalled, due to the high cost of land, contributing to the housing shortage that communities
are experiencing. In many communities, this has resulted in residents being priced out, increased traffic
congestion caused by longer commutes, and fewer people across income levels being able to purchase homes or
meet surging rents.
10.2.2 Los Gatos Overview
As California works to face its housing crisis, the State of California has adopted rules to ensure that the burden
of housing an economically diverse and growing population is shared proportionately among all California
communities. The Town is committed to meeting the housing challenge, while preserving the essential character
of the community. The Town faces some of the following conditions as summarized below:
Population growth trends in the Town are significantly lower than the County and regional rates.
The Town has more than double the County share of White population and a correspondingly smaller
percent of minority populations.
The Town has a higher share of high-income earners than the County and Bay Area.
The income gap between lower income residents and higher income residents in the Town is higher than
the average value for Bay Area jurisdictions.
Poverty rates are very low in the Town.
Pages 10-46 and 10-47 of Chapter 10 of the Draft Revised Housing
Element (January 2024 version) without recommendation #1 of the
January 18, 2024 Housing Element Advisory Board meeting
HCD Revised Draft Revised 2023-2031 Housing Element
10-46 HCD Revised Draft Revised 2023-2031 Housing Element March SeptemberNovemberJanuary
20232024
Programs
Performance Metric(s)
Delivery of Housing Element
IJ Helping Senior Housing s
PrograResourcesm
Provide financial assistance for health,
safety, emergency and accessibility home
repairs to low-income seniors and low-
income mobile homeowners through the
Below Market Price Program funds,
subject to availability of Program funds.
Provide regularly updated senior housing
resource materials at the Adult Recreation
Center, Library, and Farmers’ Market.
Implementation Policies
HE-1.6 Universal Design
HE-2.7 Senior Housing
HE-2.8 Equal Housing and Special Needs
HE-6.1 Fair Housing
HE-6.2 Financial Assistance
HE-6.3 Housing for Persons with Special Needs
HE-6.4 Affordable Housing Awareness
Responsible Department/Review Authority
Responsible Department/Review Authority
Community Development Department and the
Town Council
Timeframe
Ongoing and annual effort
Update materials annually
Funding Source
Town Affordable Housing Funds
Quantified Objective
Maintain the existing housing stock by funding
three home repairs to lower income seniors
annually
Performance Metric(s)
Measure the number of units assisted versus the
need
JK Small Multi-Unit Housing, “Missing
Middle”
The Housing Element supports the land
use goal of providing opportunities for
housing that can accommodate the
needs, preferences, and financial
capabilities of current and future residents
in terms of different housing types,
tenures, density, sizes, and costs.
Specifically, the Town aims to create
mixed residential neighborhoods through
new and innovative housing types that
meet the changing needs of Los Gatos
households and expand housing in a
variety of neighborhoodsall
neighborhoods. These housing types
include, but are not limited to, single
dwelling units, multifamily dwelling units,
accessory dwelling units, small and micro
units, use of pre-fabricated homes, and
clustered housing/cottage housing. The
Implementation Policies
HE-1.5 Variety of Housing Choices
HE-2.4 Rental Housing
HE-3.3 Efficient Development Processing
Responsible Department/Review Authority
Community Development Department
Timeframe
December 2024
Funding Source
None required
Quantified Objective
Increase the number of small multi-unit housinglow-
rise multi-family developments by five 50 units from
the previous yearover eight years with the goal of
achieving 100% of the units in low to medium
density designations and high median income
areas.
10. Housing Element
JanuaryNovemberSeptember March 2023 2024 HCD Draft Revised Draft 2023-2031 Housing
Element
10-47
Programs
Town will also promote small multi-unit
housing that increases density while
remaining consistent with the building
scale and character present in existing
neighborhoods. This includes multi-family
units or clustered residential buildings that
provide relatively smaller, less expensive
units within existing neighborhoods.
Update the Zoning Code to facilitate low
rise multi-family structuressmall multi-unit
housing in the low to mMedium
Residential Density designations.
TheGeneral Plan defines sSmall multi-unit
housing is defined as multiple units on a
single parcel (whether attached or
detached) that are compatible in scale
and form with detached single-family
homes. Common housing types include
duplexes; triplexes; fourplexes; courtyard
apartments; cottage courts; townhomes;
triplex stacked (vertical); and live-work
spaces.
Promote this program through publication,
to include the following information: Low
rise multi-family dwelling units ranging
from two to 10 units can help meet the
needs of families, seniors and students.
Permit processing times tend to be
shorter than larger multi-family buildings
due to the low-rise nature of the
structures.
Specifically, update the Zoning to allow
for all housing types considered for the
provision of Small Multi-Unit Housing
types as part of Low Density High
Density Residential designations.
Research existing regulatory impediments
to the creation of new housing types that
have the potential to fulfill unmet housing
needs (e.g., tiny homes, co-housing
developments) and if necessary, amend
applicable ordinances and development
standards to facilitate and to allow for
their development at the maximum
density.
Pursue establishment of a maximum
average unit size as a tool to moderate
unit sizes for developments over a certain
size but to allow flexibility for a range of
unit sizes.
Performance Metric(s)
Complete Zoning Code amendment by December
2024 and track the number of entitled Planning
applications received per year
Pages 10-52, 10-53, and 10-75 of Chapter 10 of the Draft Revised
Housing Element (January 2024 version) without recommendation #3
of the January 18, 2024 Housing Element Advisory Board meeting
HCD Revised Draft Revised 2023-2031 Housing Element
10-52 HCD Revised Draft Revised 2023-2031 Housing Element March SeptemberNovemberJanuary
20232024
Programs
In existing and new rental developments,
the Town could provide a rehabilitation
loan or another form of subsidy to a rental
property owner in exchange for securing
affordability covenants on a percentage of
units and the owner’s agreement to
restrict rents on these units to levels that
would be affordable to very low- and low-
income households.
Affordability covenants for three housing units with
BMP funding to increase the supply of affordable
housing per year
Performance Metric(s)
Number of affordability covenants
UQ Accessory Dwelling Units
Facilitate ADU/JADU production with the
following efforts:
Waive building fees when an ADU is
deed restricted for very low-and low-
income pursuant to Town Code
(Section 29.10.320(a).
Initiate a marketing program for
homeowners on the benefits of ADUs
and the availability of resources
(templates, cost calculators, technical
support) to support development.
Promote the use of Housing Choice
Vouchers (HCVs) and homesharing
(once established) to make the units
available to lower income
households.
Collaborate with countywide efforts to
develop pre-approved ADU plans
suitable for Los Gatos, including
designs that are ADA accessible.
Streamline the review and permitting
of ADU’s by publishing pre-approved
plans including plans that are ADA-
compliant, which shall be posted on
the Town’s website.
Promote California Housing Finance
Agency (CHFA) ADU grants of
$40,000 available to qualified
homeowners for pre-development
costs.
Proactively promote information made
available through the Santa Clara
County Planning Collaborative, a joint
initiative of all 16 jurisdictions in the
county on the Town’s website with
resources for interested property
owners.
Actively apply for grant programs, as
funds are made available to assist
Implementation Policies
HE-1.7 Infill Opportunities in Single-Family
Neighborhoods
HE-2.4 Rental Housing
HE-2.5 Pre-Approved Accessory Dwelling Units
HE-2.6 Promote Accessory Dwelling Unit
Construction
HE-2.7 Senior Housing
HE-3.1 Regulatory Incentives for Affordable
Housing
HE-3.3 Efficient Development Processing
HE-3.5 Development Impact and Permit Fees
Responsible Department/Review Authority
Community Development Department
Timeframe
Initiate marketing program and
coordinate efforts on pre-
approved ADU plans (2023)
and other resources and
services (December 2025).
Select at least three plans and
conduct media campaign to
promote (December 2024)
Monitor Annually monitor the
production and affordability of
ADUs
Amend the ADU Ordinance
(January 2024)
Monitor ADU/JADU production
against projection by July 2027
and develop strategies to
address any potential shortfall
in meeting RHNA by the end of
2027 annually and .adjust, if
necessary, within six months
Funding Source
Below Market Price Housing In-lieu Fees for
Waiving Building Fees and General Fund
Quantified Objective
10. Housing Element
JanuaryNovemberSeptember March 2023 2024 HCD Draft Revised Draft 2023-2031 Housing
Element
10-53
Programs
property owners in the construction of
ADU’s/JADU’s. Monitor funding
availability annually.
Develop and adopt objective
standards to allow more than one (at
minimum two) JADUs.
Annually monitor number of
ADU’s/JADU’s produced, affordability
levels. By July 2027, if the production of
ADU/JADU is falling short of the projected
trend, and make adjustmentsthe Town will
initiate developing strategies (additional
incentives, flexible development
standards, and/or identify additional sites
for housing development) to
accommodate a potential shortfall if
determined necessary (i.e. adopt
additional incentives or other
strategies).and assess whether additional
strategies and adjustments are necessary
to increase ADU production, including
searching for innovative funding sources
and revisiting the ADU marketing program
for property owners. shortfall by the end
of 2027.
Amend the ADU Ordinance to comply
with State law.
Work with a nonprofit organization to
administer a homesharing program that
will expand beyond roommate matching,
by assisting homeowners in renting out
ADUs and JADUs, further serving
residents in the region with outreach for
potential tenants.
Facilitate cConstruction of at
least 200 ADUs or JADUs with
a goal to facilitate construction
of up to 200 350 ADUs or
JADUs throughout the Planning
period with a goal of 5% of
these units being affordable to
lower-income households and
50% in single-family, high
median income neighborhoods
Publish pre-approved ADU
plans and templates, including
designs that address ADA and
senior housing needs
Post pre-approved plans on
Town website
Use the Town’s social media,
website, local press, and
community events to distribute
information
Adopt objective standards to
allow more than one JADU per
property by July 2025
Facilitate construction of at least
10 JADUs in low density
neighborhoods
Through a homesharing
programs, assist homeowners
in renting out available ADUs
and JADUs, especially in
high/higher resource areas
Performance Metric(s)
Number of Building Permits issued; number of
ADU/JADUs rented at a rental rate affordable for
very low-and low-income households
VR Density Bonus
Conduct a study to evaluate the existing
Density Bonus Ordinance and
recommend changes to increase the
number of units constructed. The study
will include an evaluation of the
implementation of the ordinance to date
and actual construction of affordable
housing units that utilized the Density
Bonus. Additional density and height
incentives beyond what the State requires
will be considered (i.e., fee reductions,
add free density of BMP units). The study
shall recommend improvements to the
Ordinance based on the outcome of the
evaluation.
Implementation Policies
HE-3.1 Regulatory Incentives for Affordable
Housing
HE-2.3 Mixed-Use Development
HE-2.8 Equal Housing and Special Needs
Responsible Department/Review Authority
Community Development Department
Timeframe
Amend the Density Bonus Ordinance
(December 2024)
Complete study by June 2026 and implement
recommended actions by December 2029
Funding Source
None required
10. Housing Element
JanuaryNovemberSeptember March 2023 2024 HCD Draft Revised Draft 2023-2031 Housing
Element
10-75
Programs
Measure the number of replacement housing units
entitled that are restricted to low-income
households
BLAV Senate Bill 9 Monitoring
Annually monitor the development of SB 9
applications every year beginning in 2023
to better understand their role in the Los
Gatos housing market if trends
indicate a potential shortfall in meeting
the estimated SB 9 development in the
Sites Inventory, and consider additional
efforts to incentivize SB 9 applications and
reassess and revise the overall sites
strategy for the RHNA within one year
through adjusting SB 9 capacity
assumptions with actual permitted units,
and/or identifying additional sites to expand
site capacity to the extent necessary to
accommodate the RHNA.
Annually monitor the number of SB 9
entitlements produced. By July 2027, if the
production of SB 9 entitlements is falling
short of the projected trend, the Town will
initiate and develop strategies (additional
incentives or provide greater flexibility to
the development standards) to
accommodate a potential shortfall by the
end of 2027.
Based on objective criteria that are
consistent with recent SB 9 applications in
the Town, about 3,000 parcels can
potentially accommodate SB 9 units.
Given the number of SB 9 applications
received during 2023 (four two-unit
development and seven urban lot splits), a
projection of 12 SB 9 units annually is
considered conservative.
Implementation
HE-1.1 Adequate Sites
Responsible Department/Review Authority
Community Development Department
Timeframe
Evaluate effectiveness of SB 9 approvals every
year beginning in 2023; and identify additional
incentives and/or site capacity, if needed by
20252027
Funding Source
General fund (staff time)
Quantified Objective
Prepare Annual Progress Report and issue 96 SB
9 entitlements units over the eight-year period
issue 12 SB 9 building permits per year
Performance Metric(s)
Number of issued SB 9 Building Permits.
BMAW Story Poles and Netting Policy
Update the Review Story Pole and
Netting Policy and explore create
alternative options for residential or
mixed-use projects with affordable
housing to reduce the associated costs of
installing story poles, by providing an
option to provide visuals, video rendering,
or other visual methods in place of story
poles for all multi-family and mixed-use
Implementation
Policy HE-3.1 Regulatory Incentives for Affordable
Housing
Responsible Department/Review Authority
Community Development Department
Timeframe
Implement by December March 20243, and
evaluate effectiveness of reduced requirements
every year beginning in 2025; and identify
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Intentionally
Left Blank
From: Veronica Tam
Sent: Thursday, February 1, 2024 10:49 AM
To: Jauregui, Jose @HCD <Jose.Jauregui@hcd.ca.gov>; Gabrielle Whelan <GWhelan@losgatosca.gov>;
McDougall, Paul@HCD <Paul.McDougall@hcd.ca.gov>
Cc: Joel Paulson <jpaulson@losgatosca.gov>; Jennifer Armer <JArmer@losgatosca.gov>; Jamie Power
; Erin Walters <EWalters@losgatosca.gov>; Jocelyn Shoopman
<jshoopman@losgatosca.gov>; Nazanin Salehi
Subject: RE: Los Gatos - Revised HE
[EXTERNAL SENDER]
Hi Paul and Jose –
Just a correction that we are not going for readoption yet. We would like to get the HE to a certifiable
status first.
Thanks,
Veronica
Veronica Tam, AICP
Principal
Veronica Tam and Associates, Inc.
From: Veronica Tam
Sent: Thursday, February 1, 2024 10:30 AM
To: 'Jauregui, Jose @HCD' <Jose.Jauregui@hcd.ca.gov>; Gabrielle Whelan <GWhelan@losgatosca.gov>;
McDougall, Paul@HCD <Paul.McDougall@hcd.ca.gov>
Cc: Joel Paulson <jpaulson@losgatosca.gov>; Jennifer Armer <JArmer@losgatosca.gov>; Jamie Power
; Erin Walters <EWalters@losgatosca.gov>; Jocelyn Shoopman
<jshoopman@losgatosca.gov>; Nazanin Salehi
Subject: Los Gatos - Revised HE
Hi Joe and Paul –
Attached (and below) are the revised pages for Los Gatos Housing Element based on our most recent
discussions. The Town is going to Planning Commission and Town Council for readoption. We are
hoping that you can take a look at these changes before we move to readopt.
Please note the GREEN highlights are new changes.
Revised Pages Only
https://www.dropbox.com/scl/fi/1s5nf8il7zmxk7nd4bhwt/Draft-Revised-Housing-Element-Revised-
Pages-Only.pdf?rlkey=aiiu0b9s09qfjaxry77ijdulj&dl=0
Full HE with Tracked Changes
ATTACHMENT 14
https://www.dropbox.com/scl/fi/m1a675bsloxifr09bxolk/Draft-Revised-Housing-Element-Track-
Changes.pdf?rlkey=okew0qyjququhbi94f7a81d2v&dl=0
Veronica Tam, AICP
Principal
Veronica Tam and Associates, Inc.
THIS PAGE HAS BEEN LEFT INTENTIALLY BLANK
From: Jauregui, Jose @HCD <Jose.Jauregui@hcd.ca.gov>
Sent: Wednesday, January 24, 2024 8:55 AM
To: Gabrielle Whelan <GWhelan@losgatosca.gov>
Cc: Veronica Tam ; Joel Paulson <jpaulson@losgatosca.gov>; Jennifer
Armer <JArmer@losgatosca.gov>; Jamie Power ; Erin Walters
<EWalters@losgatosca.gov>; Jocelyn Shoopman <jshoopman@losgatosca.gov>; Nazanin Salehi
; Barbara E. Kautz
Subject: Re: Los Gatos - adopted Housing Element Overlay Zoning ordinances and draft ordinance
amendment attached
[EXTERNAL SENDER]
Thank you for clarifying.
Warm regards,
Jose A. Jauregui he / him
Housing Policy Analyst
Housing Policy Development
Housing & Community Development
2020 W. El Camino Avenue, Suite 500 | Sacramento, CA 95833
Cell: (916) 820-1516
From: Gabrielle Whelan <GWhelan@losgatosca.gov>
Sent: Tuesday, January 23, 2024 4:59:46 PM
To: Jauregui, Jose @HCD <Jose.Jauregui@hcd.ca.gov>
Cc: Veronica Tam ; Joel Paulson <jpaulson@losgatosca.gov>; Jennifer
Armer <JArmer@losgatosca.gov>; Jamie Power ; Erin Walters
<EWalters@losgatosca.gov>; Jocelyn Shoopman <jshoopman@losgatosca.gov>; Nazanin Salehi
; Barbara E. Kautz
Subject: RE: Los Gatos - adopted Housing Element Overlay Zoning ordinances and draft ordinance
amendment attached
Hello, Mr. Jauregui. Thank you for your quick review. Here are our answers:
1.how does this apply to the sites in the inventory? Will there also be a zoning map change?
• The HEOZ has already been applied to all of the sites in the sites inventory. The overlay
zone and change to the zoning map went into effect in December 2023; the updated and
more explicit language will apply to all of those sites once the ordinance is approved by
Council.
2.Do all the sites in the inventory for the lower-income RHNA meet the 16 units per site minimum
number of units?
• Yes, all of the sites in the inventory comply with the 16-unit requirement. As a result of
previous revisions to remove low-income RHNA allocations from sites less than .5 acre, the
Town complies with the 16-unit requirement. Appendix D of the Housing Element explains
how several sites are made up of two smaller parcels, because the parcels are consolidated
under a single owner or otherwise are anticipated to develop together.
3.How do they meet the Clovis decision/minimum density issue for base zones that allow
residential development? Do the overlay minimum densities prevail? If so, where is that?
• Yes, the overlay minimum densities prevail. The revised language included in this ordinance
is explicit that projects with residential components must use the HEOZ densities, not the
base zoning. Section 29.80.510 (d) states, “Regardless of the underlying zoning designation,
no residential use may be developed that does not meet the applicable HEOZ development
standards.”
Please let me know if you have any follow-up questions. We are taking the draft amendment to the
Planning Commission for a recommendation tomorrow evening.
Thanks again.
(I’m adding Barb Kautz from Goldfarb and Lipman as a cc since Barb also helped us with the
ordinance revisions.)
Gabrielle Whelan ● Town Attorney
Town Attorney’s Office ● 110 E Main Street, Los Gatos, CA 95030
Desk: 408.354.6818 ● gwhelan@losgatosca.gov
www.losgatosca.gov [losgatosca.gov] ● https://www.facebook.com/losgatosca [facebook.com]
From: Jauregui, Jose @HCD <Jose.Jauregui@hcd.ca.gov>
Sent: Monday, January 22, 2024 11:00 AM
To: Gabrielle Whelan <GWhelan@losgatosca.gov>
Cc: Veronica Tam ; Joel Paulson <jpaulson@losgatosca.gov>; Jennifer
Armer <JArmer@losgatosca.gov>; Jamie Power ; Erin Walters
<EWalters@losgatosca.gov>; Jocelyn Shoopman <jshoopman@losgatosca.gov>; Nazanin Salehi
Subject: RE: Los Gatos - adopted Housing Element Overlay Zoning ordinances and draft ordinance
amendment attached
[EXTERNAL SENDER]
Good morning Gabrielle,
Just a few questions following a review of the draft ordinance provided.
1.how does this apply to the sites in the inventory? Will there also be a zoning map change?
2.Do all the sites in the inventory for the lower-income RHNA meet the 16 units per site minimum
number of units?
3.How do they meet the Clovis decision/minimum density issue for base zones that allow
residential development? Do the overlay minimum densities prevail? If so, where is that?
Warm regards,
Jose A. Jauregui he / him
Housing Policy Analyst
Housing Policy Development
Housing & Community Development
2020 W. El Camino Avenue, Suite 500 | Sacramento, CA 95833
Cell: (916) 820-1516
[twitter.com] [facebook.com] [landlordtenant.dre.ca.gov]
From: Jauregui, Jose @HCD
Sent: Friday, January 19, 2024 9:51 AM
To: Gabrielle Whelan <GWhelan@losgatosca.gov>
Cc: Veronica Tam ; Joel Paulson <jpaulson@losgatosca.gov>; Jennifer
Armer <JArmer@losgatosca.gov>; Jamie Power ; Erin Walters
<EWalters@losgatosca.gov>; Jocelyn Shoopman <jshoopman@losgatosca.gov>; Nazanin Salehi
Subject: RE: Los Gatos - adopted Housing Element Overlay Zoning ordinances and draft ordinance
amendment attached
Received, thanks!
Jose A. Jauregui he / him
Housing Policy Analyst
Housing Policy Development
Housing & Community Development
2020 W. El Camino Avenue, Suite 500 | Sacramento, CA 95833
Cell: (916) 820-1516
[twitter.com] [facebook.com] [landlordtenant.dre.ca.gov]
From: Gabrielle Whelan <GWhelan@losgatosca.gov>
Sent: Friday, January 19, 2024 9:47 AM
To: Jauregui, Jose @HCD <Jose.Jauregui@hcd.ca.gov>
Cc: Veronica Tam ; Joel Paulson <jpaulson@losgatosca.gov>; Jennifer
Armer <JArmer@losgatosca.gov>; Jamie Power ; Erin Walters
<EWalters@losgatosca.gov>; Jocelyn Shoopman <jshoopman@losgatosca.gov>; Nazanin Salehi
Subject: RE: Los Gatos - adopted Housing Element Overlay Zoning ordinances and draft ordinance
amendment attached
Hello, Mr. Jauregui. Attached is a clean version of the proposed Housing Element Overlay Zone
ordinance. I inadvertently sent you a working draft yesterday. Thank you.
Gabrielle Whelan ● Town Attorney
Town Attorney’s Office ● 110 E Main Street, Los Gatos, CA 95030
Desk: 408.354.6818 ● gwhelan@losgatosca.gov
www.losgatosca.gov [losgatosca.gov] ● https://www.facebook.com/losgatosca [facebook.com]
From: Jauregui, Jose @HCD <Jose.Jauregui@hcd.ca.gov>
Sent: Friday, January 19, 2024 9:40 AM
To: Gabrielle Whelan <GWhelan@losgatosca.gov>
Cc: Veronica Tam ; Joel Paulson <jpaulson@losgatosca.gov>; Jennifer
Armer <JArmer@losgatosca.gov>; Jamie Power ; Erin Walters
<EWalters@losgatosca.gov>; Jocelyn Shoopman <jshoopman@losgatosca.gov>; Nazanin Salehi
Subject: RE: Los Gatos - adopted Housing Element Overlay Zoning ordinances and draft ordinance
amendment attached
[EXTERNAL SENDER]
Thank you Gabrielle!
Warm regards,
Jose A. Jauregui he / him
Housing Policy Analyst
Housing Policy Development
Housing & Community Development
2020 W. El Camino Avenue, Suite 500 | Sacramento, CA 95833
Cell: (916) 820-1516
[twitter.com] [facebook.com] [landlordtenant.dre.ca.gov]
From: Gabrielle Whelan <GWhelan@losgatosca.gov>
Sent: Thursday, January 18, 2024 12:34 PM
To: Jauregui, Jose @HCD <Jose.Jauregui@hcd.ca.gov>
Cc: Veronica Tam ; Joel Paulson <jpaulson@losgatosca.gov>; Jennifer
Armer <JArmer@losgatosca.gov>; Jamie Power ; Erin Walters
<EWalters@losgatosca.gov>; Jocelyn Shoopman <jshoopman@losgatosca.gov>; Nazanin Salehi
Subject: Los Gatos - adopted Housing Element Overlay Zoning ordinances and draft ordinance
amendment attached
Hello, Mr. Jauregui. Per our call this morning, attached for your review are:
1.The adopted Housing Element Overlay Zoning (“HEOZ”) ordinances (one establishing the
development standards for the Housing Element Overlay Zone and three others
applying the Housing Element Overlay Zone to specific parcels).
2.The staff report accompanying proposed amendments to the HEOZ ordinance, which
summarizes the changes.
3.The draft amendment to the HEOZ ordinance which established the development
standards for the Housing Element Overlay Zone, which will be presented to the
Planning Commission on 1/24 and to the Town Council on 2/6.
Thank you for your time this morning and your review of the Town’s proposed ordinance
amendments. If you have any questions about this material, recommended edits, or would like
to discuss, please let me know. I’ve included Nazanin Salehi of Goldfarb & Lipman, who is
assisting the Town with the proposed ordinance amendments.
Gabrielle Whelan ● Town Attorney
Town Attorney’s Office ● 110 E Main Street, Los Gatos, CA 95030
Desk: 408.354.6818 ● gwhelan@losgatosca.gov
www.losgatosca.gov [losgatosca.gov] ● https://www.facebook.com/losgatosca [facebook.com]
1 of 5
HEOZ Ordinance January 24, 2024
DRAFT ORDINANCE
AN ORDINANCE OF THE TOWN COUNCIL OF THE TOWN OF LOS GATOS
AMENDING CHAPTER 29, “ZONING REGULATIONS,” OF THE TOWN CODE
TO DEFINE “BY RIGHT APPROVALS” AND AMEND THE HOUSING
ELEMENT OVERLAY ZONE AS DIVISION 5 OF ARTICLE VIII, “OVERLAY
ZONES AND HISTORIC PRESERVATION.”
ZONING CODE AMENDMENT APPLICATION Z-24-001
PROPERTY LOCATION: TOWN WIDE
APPLICANT: TOWN OF LOS GATOS
WHEREAS, the Town of Los Gatos 2023-2031 Housing Element identifies amending the
Town Code to create the Housing Element Overlay Zone as a strategy to accommodate the
Town’s Regional Housing Needs Allocation (RHNA); and
WHEREAS, the Planning Commission at its meeting on August 23, 2023, reviewed the
proposed Town Code amendments, held a public hearing, and forwarded a recommendation of
approval to the Town Council; and
WHEREAS, on October 3, 2023, the Town Council accepted the report of the Planning
Commission’s recommendation of approval for the proposed Town Code amendment and held
a public hearing; and
WHEREAS, on November 7, 2023, the Town Council reviewed the proposed Town Code
amendments, held a public hearing, and introduced the ordinance to amend the Town Code to
modify the Affordable Housing Overlay Zone to be the Housing Element Overlay Zone; and
WHEREAS, the Town Council adopted Ordinance No. 2347 to enact the proposed Town
Code amendments on November 21, 2023; and
WHEREAS, on December 1, 2023, the Town received comments from the State Housing
and Community Development Department (HCD) regarding the adopted Housing Element
Overlay Zone ordinance; and
WHEREAS, staff has prepared a revised ordinance to address HCD’s comments; and
WHEREAS, the Planning Commission at its meeting on January 24, 2024, reviewed
proposed Town Code amendments, held a public hearing, and forwarded a recommendation of
_______to the Town Council; and
WHEREAS, this matter was regularly noticed in conformance with State and Town law
Draft Ordinance: Subject to
modification by Town Council based
on deliberations and direction.
2 of 5
HEOZ Ordinance January 24, 2024
and came before the Town Council on _____, 2024.
WHEREAS, on ______, 2024, the Town Council accepted the report of the Planning
Commission’s recommendation of ______ for the proposed Town Code amendments, held a
public hearing, and introduced an ordinance to add a definition of “by right approval” and
modify the HEOZ Ordinance; and
NOW, THEREFORE, BE IT ORDAINED by the Town Council of the Town of Los Gatos as
follows:
SECTION I. Section 29.10.020, “Definitions,” of Chapter 29, “Zoning Regulations,” of the Town
Code is amended to add the following between the definitions of “Business or commerce” and
“Carport” to read as follows:
By right approval shall have the meaning set forth in Government Code Section 65583.2 (i).
SECTION II. Division 5 of Article VIII, “Overlay Zones and Historic Preservation,” of Chapter 29,
“Zoning Regulations,” is amended to read as follows:
ARTICLE VIII. OVERLAY ZONES AND HISTORIC PRESERVATION
…
DIVISION 5. HOUSING ELEMENT OVERLAY ZONE
Sec. 29.80.505. Intent.
The Housing Element Overlay Zone (HEOZ) ordinance in this division is intended to
increase the supply and the mix of housing types, tenure, and affordability within the Town of
Los Gatos. Through appropriate densities, concessions, and fee deferrals or waivers, the HEOZ
encourages the development of housing affordable to all income levels on sites within the
Town that are deemed to be most appropriate for such uses. The Housing Element lists sites
within the Town of Los Gatos as key housing opportunities. The designation of these sites will
assist the Town in meeting its Regional Housing Needs Allocation (RHNA), as required by the
State.
Sec. 29.80.510. HEOZ and underlying zoning.
(a) “By right” residential developments on sites with underlying zoning of RM, CH, or NF-SP
(Table 1A below). Pursuant to Government Code Section 65583.2, subsections (h) and
(i), in the HEOZ, residential developments with at least 20 percent of the units proposed
for “low income” households and without a subdivision are subject to “by right
approval.” These developments are subject to the following:
3 of 5
HEOZ Ordinance January 24, 2024
1. The developments must be developed at the densities specified in Table 1A below
and in no event shall any residential development projects be developed below the
minimum density of 30 units per acre.
2. The developments shall be subject to non-discretionary design review based on
objective development standards in accordance with the procedures specified in
Article II, "Administration and Enforcement,” of Chapter 29, “Zoning Regulations,” of
the Town Code.
3. No California Environmental Quality Act review shall be required.
4. Subdivisions remain subject to all applicable state and local laws, including but not
limited to the Subdivision Map Act.
5. Residential units shall occupy at least 50 percent of the floor area in all mixed-use
projects.
6. For residential developments and mixed-use projects, the standards set forth in
Table 1A shall apply.
Table 1A HEOZ Development Standards for “By Right” Residential Development
General Plan
Land Use
Designation
Zoning Minimum Yards Maximum
Lot
Coverage
Maximum
Floor Area
Ratio (FAR)
Maximum
Height
Limit (ft)
Density
Units Per Acre
High Density
Residential
R-M As authorized by
Section 29.40.645
75% N/A 45 feet 30-40
Mixed-Use CH As authorized by
Section 29.60.435
N/A 3.0 45 feet 30-40
North Forty
Specific Plan
NF-SP As defined in
Specific Plan
As defined
in Specific
Plan
As defined
in Specific
Plan
As defined
in Specific
Plan
30-40
(b) For all other residential developments other than those described in subsection (a), the
standards set forth in Table 1B below shall apply.
Table 1B HEOZ Development Standards for Other Residential Development
General Plan
Land Use
Designation
Zoning Minimum Yards Maximum
Lot
Coverage
Maximum
Floor Area
Ratio (FAR)
Maximum
Height
Limit (ft)
Density
Units Per Acre
Low Density
Residential
R-1 As authorized by
Section 29.40.405
50% N/A 30 feet 0-5
Medium Density
Residential
R-1D, R-D,
and R-M
As authorized by
Section 29.40.405,
29.40.530, and
29.40.645
75% N/A 35 feet 14-22 or 5-12
in Very High
Fire Hazard
Severity Zones
Neighborhood
Commercial
C-1 As authorized by
Section 29.60.225
N/A 1.0 35 feet 10-20
4 of 5
HEOZ Ordinance January 24, 2024
Central Business
District
C-2 As authorized by
Section 29.60.335
N/A 2.0 45 feet 20-30
Office
Professional
O As authorized by
Section 29.60.100
N/A 1.0 35 feet 10-20
(c) The underlying zoning development standards will remain in effect for all other
development without a residential component.
(d) Regardless of the underlying zoning designation, no residential use may be developed
that does not meet the applicable HEOZ development standards.
(e) Where standards are not specified, the development standards provided in the
underlying zoning district shall apply.
SECTION III. CEQA.
The Town Council finds as follows:
A. No further Environmental Analysis is required as an Environmental Impact Report (EIR) was
prepared and certified for the 2040 General Plan Update on June 30, 2022, which included the
proposed Town Code amendments; and
B. The Town Code amendments are consistent with the General Plan and its elements; and
C. That all proceedings have been conducted in compliance with the provisions of Government
Code Section 65850 et seq.
SECTION IV. EFFECTIVE DATE.
This Ordinance was introduced at a regular meeting of the Town Council of the Town of
Los Gatos on the _______ day of_______, 2024, and adopted by the following vote as an
ordinance of the Town of Los Gatos at a regular meeting of the Town Council of the Town of Los
Gatos on the ____ day of ___________, 2024. This ordinance shall take effect 30 days after the
date it is adopted. The Town Clerk shall cause this ordinance or a summary thereof to be
published in accordance with Section 36933 of the California Government Code.
COUNCIL MEMBERS:
AYES:
NAYS:
ABSENT:
ABSTAIN:
5 of 5
HEOZ Ordinance January 24, 2024
SIGNED:
MAYOR OF THE TOWN OF LOS GATOS
LOS GATOS, CALIFORNIA
DATE: __________________
ATTEST:
TOWN CLERK OF THE TOWN OF LOS GATOS
LOS GATOS, CALIFORNIA
DATE: ________________
THIS PAGE HAS BEEN LEFT INTENTIALLY BLANK
From: Jauregui, Jose @HCD <Jose.Jauregui@hcd.ca.gov>
Sent: Friday, January 19, 2024 9:26 AM
To: Veronica Tam
Subject: Town of Los Gatos Informal Clarifications
Hi Veronica,
As discussed in our TA call, I have included in this email some clarifications on the following items
identified in the informal review matrix.
1.RCAA: The town must expand the analysis of what has contributed to being a RCAA including
zoning, land use, past investment or lack of investment, local opposition to housing types. For
example, you can include the North 40 lawsuit on a project that had higher density with
affordability. Additionally, include the TCAC scores within this analysis. Following the complete
analysis of the RCAA the town should re-evaluate contributing factors to see if there are other
contributing factors needed to be identified or need to be reprioritized.
2.Program D: Should be revised to remove unit cap or clarify that the unit cap will not be
implemented to allow maximum build out of each parcel or circumstances warranting allowable
densities.
3.Program AW: Program should be revised to include a list of visual methods the city will allow.
For example, video, visuals or other methods. In addition, its important to note that the
program should not be limited to going over 55 ft. This language should be removed/revised.
Warm regards,
Jose A. Jauregui he / him
Housing Policy Analyst
Housing Policy Development
Housing & Community Development
2020 W. El Camino Avenue, Suite 500 | Sacramento, CA 95833
Cell: (916) 820-1516
THIS PAGE HAS BEEN LEFT INTENTIALLY BLANK
Town of Los Gatos Informal Preliminary Review
Received 12/24/2023
Prior Review: 12/01/2023
Prior HCD Finding Page # Prelim
Revie
w
Notes
Affirmatively Furthering Fair Housing
Income and Racial Concentration Area of Affluence (RCAA):
The element now includes actions to promote an inclusive
community; however, the element must provide specific
analysis of income and RCAA at a regional level (town
compared to the broader region) to better formulate
appropriate policies and programs. The analysis should at
least address trends, conditions, coincidence with other fair
housing factors (e.g., race, highest resource, overpayment),
effectiveness or absence of past strategies (e.g., lack of
publicly assisted housing and lack of multifamily zoning), local
data and knowledge and other relevant factors.
A-69 ~/No Minimal analysis added; should
address trends, coincidence with
other factors (e.g., income, TCAC),
past strategies and effectiveness
such as result of North 40 in the
prior planning period, zoning, land
use and other factors. These
analyses should be incorporated
into contributing factors
Contributing Factors to Fair Housing Issues: Based on a
complete analysis, the element should re-assess and prioritize
contributing factors to fair housing issues. For example, the
Town is wholly a RCAA, highest resource and highest median
incomes in contrast to the rest of the region. As a result, fair
housing issues such as the lack of affordable housing and
segregation from the rest of the region should be a high
priority.
A-18 ~ Re-assess based on a complete
analysis
Goals and Actions: As noted above, the element must include
a complete analysis of affirmatively furthering fair housing
(AFFH). The element must be revised to add goals and
actions based on the outcomes of a complete analysis.
In addition, while the element includes some actions toward
AFFH and enhancing housing mobility (e.g., choices and
10-43-
10-50-
10-65
10-66
~/No See Programs J, L, O, Q, T, AV
Program J should clarify that
capacity will be increased (not just
zoning text), development
standards will be adjusted to
facilitate maximum densities and
affordability), actions should be added, numeric targets should
be increased, and geographic targeting should be fine-tuned
to better promote inclusive neighborhoods throughout the
Town. This is particularly important since over 80 percent of
the lower-income regional housing need allocation (RHNA) is
isolated in two census tracts. As noted in HCD’s prior review
and the assessment of fair housing, the Town is wholly a
racially concentrated area of affluence, highest resource and
highest median incomes in contrast to the rest of the region.
These conditions and circumstances warrant significant and
robust actions (not limited to the RHNA) to promote housing
mobility and increasing housing choices and affordability
throughout the Town, including lower-density neighborhoods.
Actions should be added and revised with aggressive numeric
targets and geographic targets throughout the Town, including
lower-density neighborhoods. Examples include creating more
housing choices and affordability in single-family
neighborhoods beyond complying with law (e.g., SB 9, ADUs)
such as missing middle housing types, targeting affordable
housing funding, homesharing, more than one unit of
converted space within a single-family structure, increased
multifamily capacity, enhanced efforts on religious institutional
sites and other alternative land use and financing strategies.
increase the objective (~150 units)
or add strategies (religious
institutional, JADU plus, SB 10)
Consider adding JADU plus to
ADU HCV homesharing program
and increasing objective
Program AV should go beyond
complying with SB 9 (marketing,
modification to development
standards)
For all housing mobility actions
(Programs J, L, O, Q, T, AV),
geographic targeting should be
revised to clarify town-wide
including highest median income
areas and numeric targets should
be reflected with geographic
targeting (e.g., 100 units townwide
and 50% in highest median income
areas)
Sites Inventory, Analysis and Adequate Sites
Small Sites: The element identifies several sites with parcels
less than a half-acre (p. D-13) that have common ownership
and, in some cases, expressed interest to redevelop the site.
For small sites with expressed interest in redevelopment, the
element should clarify that the expressed interest is also in
consolidating the sites. For the remaining sites (Sites D-2 and
D-5), the element should explain the circumstances leading to
the potential for consolidation such as necessity to consolidate
due to access, feasibility, shape, or site planning flexibility.
Based on the outcomes of this analysis, the element should
add or modify Program K (Lot Consolidation) to further
promote lot consolidation, if appropriate.
D-2 Yes
Electronic Sites Inventory: For your information, while the
Town has submitted an electronic sites inventory as part of
N/A FYI
this submittal, pursuant to Government Code section 65583.3,
the Town must submit an electronic sites inventory with its
adopted housing element. Please see HCD’s housing element
webpage at https://www.hcd.ca.gov/planning-andcommunity-
development/housing-elements for a copy of the form and
instructions. The Town can reach out to HCD at
sitesinventory@hcd.ca.gov for technical assistance
Adequate Sites Programs: As noted in the prior review, if
necessary to make appropriate zoning available to
accommodate the lower-income RHNA, programs must be
revised to meet all requirements pursuant to Government
Code section 65583.2, subdivisions (c), (h) and (i). The
element includes Programs D (Program By Right Zoning Text
Amendment to Accommodate RHNA), AR (General Plan
Amendment) and AS (Adequate Sites for Housing) to address
these requirements. With respect to sites identified in prior
planning periods, the element meets statutory requirements,
but these actions must be completed by January 31, 2024.
With respect to a shortfall of adequate sites to accommodate
the lower-income RHNA, the element includes Programs AR
and AS. However, the Programs commit to the appropriate
zoning given the rezoning occurs after the statutory deadline
of January 31, 2023. HCD understands the Town completed
the rezoning after the statutory deadline and, therefore, the
rezoning must meet all by right requirements pursuant to
Government Code section 65583.2, subdivisions (h) and (i).
Based on a cursory review, the rezoning does not appear to
meet these requirements. As a result, these programs must
clearly commit to meet all by-right requirements by January
31, 2024.
In addition, please be aware, the recent California appellate
decision in Martinez v. City of Clovis found that while overlays
can be used in a rezone, when the base zone allows
residential development, both the base zone and the overlay
zone must comply with the minimum density requirements of
Government Code section 65583.2, subdivision (h). The Town
may need to adjust its rezoning strategy if the underlying
zoning for sites that will be rezoned allows minimum densities
Not
Found
No/? Revisions?
less than 20 dwelling units per acre. Martinez v. City of Clovis
(2023) 90 Cal.App.5th 193, 307 Cal.Rptr.3d 64.
Governmental Constraints
Land Use Controls: HCD’s prior review found that the Town
must list and evaluate development standards in the North
Forty Specific Plan and High Density Residential and
Commercial designation. In response, the Town has now
listed development standards by each zoning district but
should also analyze those development standards for impacts
on housing supply and cost and most importantly, the ability to
encourage maximum densities without exceptions. For
example, lot coverages, heights, and setbacks in the
Multifamily Residential (RM) zone; and lot coverage heights
and guest parking requirements in the North Forty Specific
Plan could be constraints. Based on the outcomes of a
complete analysis, the element should add or modify
programs to include specific commitment to review and revise
these development standards as necessary.
C-1
C-5
10-62
? RM parking program? Guest
parking reduced?
Guest parking and lot coverage in
the North Forty Specific Plan
analyzed?
Local Processing and Permit Procedures: The element now
discusses decision-making bodies and lists approval findings
for the Architecture and Site Application. However, the
element should also analyze these processes to better inform
programs to address identified constraint. For example, the
element mentions the decision-making body depends on the
scope of the application. The element should explain the
scope, resulting decision-making body and impacts on
approval timing and certainty. In addition, the element lists
approval findings and concludes some findings may be
constraints then modifies Program AQ (Zoning Code
Amendments) to amend approval findings (considerations).
But the element should discuss which approval findings may
be constraints to better inform implementation of Program AQ.
10-62 No/? See Program AQ
Program should remove or modify
Findings 4 and 6 of the
architectural and site process
Scope trigger for approval body
analyzed? Addressed?
Programs: As noted above, the element requires a
complete analysis of potential governmental constraints.
Depending upon the results of that analysis, the Town may
need to revise or add programs and address and remove or
mitigate any identified constraints. In addition, programs
should be revised, as follows:
TBD Depends on complete analysis
Program D (Additional Capacity for the North Forty Specific
Plan): The Program should also commit to establish or modify
development standards to facilitate achieving maximum
densities, regardless of the level of affordability and should
specify to either remove the unit cap or increase the unit cap
to allow maximum build out of each parcel, including State
Density Bonus Law or other circumstances that might warrant
increasing allowable densities.
10-41 ~/No/? No action included to modify
development standards?
No action to remove cap.
Commitments should also not
implement the cap to allow
maximum build out of each parcel
or other circumstances warranting
increasing allowable densities
Program V (Housing opportunities for Persons living with
Disabilities): Given the importance of promoting housing
access for persons with disabilities, the Program could be
modified with a date earlier in the planning period (e.g., by
December 2024).
? No/? Revisions?
Program AA (Reduce Parking Standards): The Program
currently commits to “Initiate a study to determine specific
updates…” While initiating a study and making a
determination are important steps by themselves, these
actions do not result in outcomes. The Program should clearly
commit to amending the municipal code. For example, the
Program could commit to: “Initiate a study and outreach,
including with developers, and amend the Municipal Code,
as follows:…”
10-53 Yes
Program AQ (Zoning Code Amendments): The Program
commits to apply the Housing Element Overlay Zone (HEOZ)
to identified sites and modify development standards. HCD
understands this action has been completed. Based on a
cursory review of the Town’s Ordinance 2347, some
development standards such as heights may be a constraint
on achieving maximum densities. As a result, this Program
should commit to monitor and evaluate these development
standards, including outreach with the development
community, and making adjustments, as appropriate, by a
specified date.
10-61 ~/No Include a timeline when
amendments will be completed, if
necessary (e.g., 6 months)
Program AW (Story Poles and Netting Policy): While the
Program now commits to revise Story Poles and Netting
Policy Requirements; these requirements are constraints and
impact housing costs; supply (number of units) and approval
certainty and should be removed or replaced with cost
effective measures to promote certainty for the developers
10-65- No Program AW
Video rendering should be
expanded to other visual methods
and the community. Further, the element should evaluate the
effectiveness of any future requirements or measures, and
making adjustments, as necessary, by a specified date (e.g.,
by 2028).
Scope of alternative should be
expanded to all multifamily and
mixed use
Housing Programs: ADU
Program Q Accessory Dwelling Units (ADU): While the
Program now commits to amend the ADU Ordinance, it must
also commit to establish incentives such as modifying
development standards (e.g., heights), pursuing funding;
waiving fees beyond ADU law; proactive marketing and
establishing points of contact to ease permitting processes. In
addition, the Program commits to monitor production and
affordability of ADUs annually but should also commit to
making adjustments by a specified date (e.g., within six
months) if production and affordability are not meeting
assumptions. Further, the Program should clearly commit to
options beyond incentives such as rezoning if production and
affordability far differs from assumptions.
10-48-Yes
Public Participation:
Public participation in the development, adoption and
implementation of the housing element is essential to effective
housing planning. Throughout the housing element process,
the Town should continue to engage the community, including
organizations that represent lower-income and special needs
households, by making information regularly available and
considering and incorporating comments where appropriate.
Please be aware, any revisions to the element must be posted
on the local government’s website and to email a link to all
individuals and organizations that have previously requested
notices relating to the local government’s housing element at
least seven days before submitting to HCD. HCD particularly
encourages the Town to continue engaging commenters on
this review. These comments contained valuable insights that
can result in a more effective housing elements, especially
related to programs and specific commitment. HCD’s future
reviews will continue to consider the extent to which the
revised element documents how the Town solicited,
considered, and addressed public comments in the element.
? Revisions?
The Town’s consideration of public comments must not be
limited by HCD’s findings in this review letter.
Other (HCD use only)
Public comments TBD Must address new public
comments
Document availability FYI
Rezone timing FYI Cant be found in full compliance
until all rezones are complete
50% nonvacant resolution FYI
Electronic sites inventory FYI
Overlay No Program AQ HE Overlay zone
Modification Authority N/A Informal submittal
THIS PAGE HAS BEEN LEFT INTENTIALLY BLANK
From: Veronica Tam
Sent: Wednesday, January 17, 2024 8:39 AM
To: Jauregui, Jose @HCD <Jose.Jauregui@hcd.ca.gov>
Cc: McDougall, Paul@HCD <Paul.McDougall@hcd.ca.gov>; Erin Walters <EWalters@losgatosca.gov>;
Jennifer Armer <JArmer@losgatosca.gov>
Subject: Re: Los Gatos
Okay. Will do!!
Sent from my iPhone
On Jan 17, 2024, at 8:30 AM, Jauregui, Jose @HCD <Jose.Jauregui@hcd.ca.gov> wrote:
That also works with my schedule. Veronica can you please send over a teams invite please?
Warm regards,
<Image.png>
Jose A. Jauregui he / him
Housing Policy Analyst
Housing Policy Development
Housing & Community Development
2020 W. El Camino Avenue, Suite 500 | Sacramento, CA 95833
Cell: (916) 820-1516
<Image.png>
<Image.png>
[twitter.com]
<Image.png>
[facebook.com]
<Image.png>
[landlordtenant.dre.ca.gov]
From: Veronica Tam
Sent: Wednesday, January 17, 2024 8:23:38 AM
To: McDougall, Paul@HCD <Paul.McDougall@hcd.ca.gov>
Cc: Jauregui, Jose @HCD <Jose.Jauregui@hcd.ca.gov>; Erin Walters <EWalters@losgatosca.gov>;
Jennifer Armer <JArmer@losgatosca.gov>
Subject: Re: Los Gatos
That works for me.
Sent from my iPhone
On Jan 17, 2024, at 8:20 AM, McDougall, Paul@HCD <Paul.McDougall@hcd.ca.gov> wrote:
1030a tomorrow works; we could maybe squeeze something in today but it’s a bit crammed
From: Veronica Tam
Sent: Tuesday, January 16, 2024 9:42 AM
To: McDougall, Paul@HCD <Paul.McDougall@hcd.ca.gov>; Jauregui, Jose @HCD
<Jose.Jauregui@hcd.ca.gov>
Cc: Erin Walters <EWalters@losgatosca.gov>; Jennifer Armer <JArmer@losgatosca.gov>
Subject: Los Gatos
Any chance with a quick meeting before the Town’s meeting on Thursday night?
Veronica Tam, AICP
Principal
Veronica Tam and Associates, Inc.
THIS PAGE HAS BEEN LEFT INTENTIALLY BLANK
From: Veronica Tam
Sent: Sunday, December 24, 2023 6:24 PM
To: Jauregui, Jose @HCD <Jose.Jauregui@hcd.ca.gov>; Joel Paulson <jpaulson@losgatosca.gov>
Cc: Jennifer Armer <JArmer@losgatosca.gov>; McDougall, Paul@HCD <Paul.McDougall@hcd.ca.gov>;
Jocelyn Shoopman <jshoopman@losgatosca.gov>
Subject: RE: Los Gatos Housing Element
[EXTERNAL SENDER]
Hi Jose –
Attached please find the revised pages with revisions to address comments from the December 1 letter,
based on our meeting recently. We are hoping that you and Paul can take a look at these changes to
keep us moving forward. Specifically, revisions have been made to:
- Add regional data for RCAA analysis and revise the priority for mobility issues
- Address the small sites/lot consolidation potential
- Include additional discussions on development standards – height, parking, and open space
requirements
- Include additional actions to address development standards, program actions to promote
mobility (SB 9, additional ADU actions, small multi-family housing in low density neighborhoods,
homesharing)
All new changes are highlighted in blue. Please let me know if you have any questions.
Thanks,
Veronica Tam, AICP
Principal
Veronica Tam and Associates, Inc.
HCD Revised Draft 2023-2031 Housing Element
A-18 Appendix A November 2023
▪ The Town will participate in housing outreach outside of the Town boundaries to the greatest
extent possible. Outreach activities are further detailed in Section 10.6, Implementation
Programs of this Housing Element.
Fair Housing Issue
Los Gatos’ households are segregated by income, and income segregation is higher in the Town
than in other Bay Area jurisdictions. Further, most of the Town is considered an RCAA, with non-
Hispanic White and higher income household majority populations. While the Town has median
incomes comparable to neighboring jurisdictions, the proportion of non-Hispanic White residents
in Los Gatos is higher than the countywide trend. The Town may lack sufficient housing
opportunities suitable for lower income households and outreach about such opportunities for
protected groups including communities of color.
Priority Level: High
Contributing factors:
▪ Lack of affordable housing overall is due to the high percentage of above moderate rate single-family
housing stock in Town.
▪ The Town will address this issue by allocating a percentage of the Town Affordable Housing
(Below Market Price) Fund to subsidize housing for extremely low-income households as
identified in Implementation Program N.
▪ Segregation of the limited affordable housing in Town is predominately located in the central portion of
Town due to a limited area of where multi-family dwelling units are permitted.
▪ The Town will use “Affirmative Marketing” strategies, as described in Implementation Program
ATI, to work with affordable and market rate housing developers to ensure that affordable
housing is affirmatively marketed to households with disproportionate housing needs, including
Hispanic and Black households who work in and live outside of Los Gatos (e.g., materials in
Spanish and English, distributed through employers). The Town will also amend its Zoning
Ordinance in order to increase the development of affordable housing.
▪ Opportunities, including employment, environmental, economic, and housing may not be accessible to all
residents, especially those in vulnerable populations.
▪ In addition to Program AT described above, Los Gatos will implement programs to facilitate the
development of affordable housing, including special needs housing, to increase housing
opportunities in the Town (Programs D, E, L, N, O, W). The Town will also serve vulnerable
populations through Senior Housing Resources (Program I), Housing Opportunities for the
Homeless (Program U), Assistance for Persons with Developmental Challenges (Program V),
and Supportive Services for the Homeless (Program Y). The Town also aims to increase
transportation opportunities for new households through Program AF, Transit Oriented
Development.
Fair Housing Issue
Appendix A. AFFH Report
November 2023 Appendix A A-69
RCAAs. An RCAA is a census tract (1) with a percentage of its total White population that is 1.25 times
higher than the average percentage of the COG region’s White population; and (2) has a median income
that is 2 times higher than the COG Area Median Income (AMI). Generally, these are understood to be
neighborhoods in which there are both high concentrations of non-Hispanic White households and high
household income rates. As shown in Figure A-19, when comparing Los Gatos to the surrounding county and
region, it is safe to speculate that the Town has more RCAAs than other communities, the county, and the region.
The majority of the Town is located within an RCAA with the exception of census tract 5067.03 located in the
northern portion of the Town, north of Interstate Highway 85 and west of California State Route 17.
Figures A-41 and A-42 show RCAAs in Los Gatos and the region. Los Gatos a racially concentrated area of
affluence (RCAA). Saratoga only has few census tracts identified as RCAAs similar to Southern San Jose and
parts of Campbell. Cupertino, Santa Clara, and Sunnyvale have no areas with a high enough concentration of
racial affluence to be identified as an RCAA. These trends are similar to the region overall which shows several
census tracts as an RCAA.
As discussed above, Los Gatos has a median income comparable to many neighboring cities. The median
household income in the Town is lower than Cupertino, Monte Sereno, and Saratoga. Despite having a lower
median household income, Los Gatos has a higher concentration of RCAA tracts compared to Cupertino and
Saratoga. This is likely due to the racial/ethnic minority populations in these cities. Also discussed above,
Saratoga and Cupertino have non-White populations of 61 percent and 77.5 percent, respectively, compared to
only 29.9 percent in Los Gatos. While the proportion of White residents has decreased in the Town and County
over the last decade, Los Gatos still has a significantly higher population of White residents (72 percent)
compared to the County (32 percent) and the Bay Area (39 percent). As discussed above, 65 percent of Los
Gatos households earn more than 100 percent of the AMI, compared to 55 percent for the county and 52 percent
for the Bay Area
As shown in Figure A-22 above, most Los Gatos and Campbell tracts have non-Hispanic White majority
populations while Saratoga, Cupertino, and Sunnyvale have Asian majority populations. Despite being comprised
of tracts with median incomes similar to these jurisdictions (Figure A-38), Los Gatos has more RCAAs. As
mentioned above, this is likely due to the larger White populations in Los Gatos. However, concentrations of
RCAAs in Los Gatos are similar to other jurisdictions west of the 101 Freeway, stretching from the west side of
Gilroy to Pacifica. Jurisdictions along the 85 and 280 Highways, from Los Gatos to Burlingame (San Mateo
County) are also comprised of mostly TCAC highest resource tract (Figure A-45).
All tracts in Los Gatos, except tract 5067.03 in the northeast corner of the Town, also encompassing part of the
City of Campbell, are considered RCAAs. Tract 5067.03 is a high resource area. The remaining RCAA tracts in
Los Gatos are described in detail in Table A-4. All RCAAs are also highest resource areas with majority non-
Hispanic White populations. All the RCAAs in the City also have median household incomes exceeding
$150,000.
According to the HCD AFFH Data Viewer 2.0, there are three subsidized housing projects in Los Gatos. One has
49 affordable units and is located in tract 5068.01, which is considered an RCAA. The other affordable projects,
Villa Vasona (105 affordable units for seniors/persons with disabilities) and Open Doors (64 affordable units), are
in tract 5067.03, the only tract in Los Gatos that is not considered an RCAA. This tract, and the areas along State
Route 17, have higher concentrations of areas zoned for multi-family housing. Nearly all of the areas in the
central and eastern areas of the Town are zoned for single-family residential uses. The Town’s Zoning Map is
presented in Figure A-43.
RCAAs are prevalent in Los Gatos due to the small racial/ethnic minority population and to limited affordable
housing projects and multi-family zoned areas. However, programs outlined in this Housing Element promote fair
housing through increased housing opportunities in these high resource RCAAs. Specifically, as described in
Section 10.5, Goals, Policies, and Implementation Programs, the Town will facilitate the buildout of the North
Forty Specific Plan and increase allowed density (Program D), subsidize housing for extremely low income
households (Program N), and provide incentives for affordable housing development (Program O). The Town will
also implement affirmative marketing strategies for affordable housing opportunities in the Town.
HCD Draft Revised 2023-2031 Housing Element
C-5 Appendix C January 2024
and surrounding properties is multiple residential. The R-M zone is the major multiple residential zoning district in
the Town and is designed to allow various density ranges. The applicable General Plan land use category for the
R-M zone is High Density Residential.
•Minimum lot area: 8,000 square feet.
•Minimum lot width: 60 feet.
•Maximum lot coverage: The maximum lot coverage is 40 percent for a residential project.
•Maximum building height: The maximum building height is 30 feet for a residential project, except when the
building has below grade parking the maximum is 35 feet.
•Setback requirements for a mixed-use project:
Front 25 feet
Rear 20 feet
Side, single-family and two-family
dwellings
8 feet
Side, multiple-family dwellings.
Provided that if the wall facing the
side yard contains:
10 feet
a.Bedroom windows 12 feet
b.Living room windows 20 feet
Side abutting street 20 feet
•Parking requirements for a multi-family residential development: One and one-half times the number of living
units in such dwellings, as well as one visitor parking space for each residential unit, unless the Planning
Commission makes a finding that more or less visitor parking is necessary due to the size or type of housing
unit(s).
•Location of buildings and courts:
o 24 feet between buildings, provided that there is 40 feet between any wall of a building;
o 20 feet between opposing walls for a court, provided that the opposing walls contain:
▪Living room windows, the minimum distance is 40 feet.
▪Bedroom windows, the minimum distance is 24 feet.
•Recreational open space for multiple-family dwellings:
o For multi-family residential development: 200 square feet per unit.
o For condominiums: 200 square feet per unit for a ground floor unit. 120 square feet per unit for a dwelling
unit above the ground floor.
One of the greater constraints on development in the R-M zone is the parking requirements for multi-family
residential development. The Housing Element includes a program to initiate amendments to the Town Code to
reduce parking requirements for projects near transit, to remove guest parking requirements, and allow parking to
be unbundled from residential units.
Cumulative Impacts of Development Standards
The Town generally requires two parking spaces per single-family unit (attached or detached) but 2.5 parking
spaces (inclusive of guest parking) per multi-family unit. One of the greater constraints on development in the R-
M zone is the parking requirements for multi-family residential development. The Housing Element includes a
Appendix C. Governmental and Non-Governmental Constraints
January 2024 Appendix C C-1
program to initiate amendments to the Town Code to reduce parking requirements for projects near transit, to
remove guest parking requirements, and allow parking to be unbundled from residential units.
As for height, the Town permits 30 to 35 feet for housing up to 20 units per acre. This height limit is more than
adequate to accommodate the allowable density. Within the new Housing Element Overlay Zone, the Very High
Density Residential, Mixed Use Commercial, and North Forty Specific Plan have increased height to 45 feet
accommodate the 30 to 40 dwelling units per acre. Furthermore, the Town Code does not limit height by the
number of stories. This approach allows the developers the flexibility to accommodate the allowable density and
creative design (such as split-levels). The Town Code’s definition of height excludes towers, spires, elevator and
mechanical penthouses, cupolas, wireless telecommunication antennas, similar structures and necessary
mechanical appurtenances that are not used for human activity or storage. Therefore, the height limit of 45 feet
does not impede development of four-story buildings or the achievement of 40 units per acre.
Currently, open space requirements are different for multi-family housing from condominium units. This Housing
Element includes a program action to align the open space for these housing types as part of the objective
design standards.
Overall, developments in the Town rarely reach the high end of the density range, primarily due to market
reasons. For multi-family housing, lower density townhome developments with larger units typically command
higher prices and profits. To facilitate a range of housing unit sizes and prices, this Housing Element includes a
program action to establish a maximum average unit size for multi-family development over a certain size. This
performance standard will moderate unit sizes but still allow developers the flexibility to include some large units.
Housing Types Permitted
The Town regulates the type, permitting requirements, and standards for development, which implements the
General Plan and its land use designations, through the Town’s Zoning Ordinance, Chapter 29 of the Municipal
Code. This code section identifies residential zoning districts and allowable housing types as summarized in
Table C-2 below.
Table C-2 Housing Types Allowed by Zoning District
Zoning District
Residential Permitted Uses Residential Uses Allowed with a
Conditional Use Permit
Resource
Conservation
Zone
(RC)
• Single-family dwelling, provided that there is
not more than one (1) principal residential
structure on a lot
• Accessory dwelling units
• Junior accessory dwelling units
• Residential care facility, small family home
• Residential care facility-large family home
• Residential care facility-group home
• Caretaker residence
Hillside
Residential (HR)
• Single-family dwelling, provided that there is
not more than one (1) principal residential
structure on a lot
• Accessory dwelling units
• Junior accessory dwelling units
• Residential care facility, small family home
• Residential care facility-large family home
• Residential care facility-group home
• Caretaker residence
Single-Family
Residential
Zone
(R-1)
• Single-family dwelling, provided that there is
not more than one (1) principal residential
structure on a lot
• Accessory dwelling units
• Junior accessory dwelling units
• Residential care facility, small family home
• Residential care facility-large family home
• Residential care facility-group home
10. Housing Element
January 2024 HCD Draft Revised 2023-2031 Housing Element 10-41
Programs
Performance Metric(s)
Number of units and affordability level applied for;
number of units and affordability level entitled;
number of units and affordability level permitted;
number of units and affordability level completed
D Additional Housing Capacity for the
North Forty Specific Plan
Amend the North Forty Specific Plan to
allow for a density from 30 dwelling units
per acre to 40 dwelling units per acre and
increase the total number of dwelling units
allowed in the Specific Plan.
Sites identified in the North Forty Specific
Plan Area are reuse sites and must permit
owner-occupied and rental multi-family
uses by-right for developments in which
20 percent or more of the units are
affordable to lower-income households.
See Implementation Program AR and AS.
Amend the North Forty Specific Plan to
include a policy specifying that additional
units as a result of the State density
bonus law, SB 330, and other applicable
state laws will not count toward the unit
cap and the unit cap will not impede the
achievement of the RHNA.
Implementation Policies
HE-1.1 Adequate Sites
HE-3.3 Efficient Development Processing
Responsible Department/Review Authority
Community Development Department
Timeframe
January 2024
Funding Source
None required
Quantified Objective
Facilitate the construction of 45 new homes for
lower-income households.
Performance Metric(s)
Number of affordable homeownership units entitled
and the number of units entitled for lower-income
Households
E Affordable Development on Town
Owned Property
Pursue opportunities to work with an
affordable housing developer to construct
affordable housing on Town owned
property.
Implementation Policies
HE-1.1 Adequate Sites
HE-2.9 Public/Private Partnerships
Responsible Department/Review Authority
Town Manager
Timeframe
Ongoing effort
Funding Source
None required
Quantified Objective
The Town owns two properties that could be
suitable for affordable housing up to 20 units.
Performance Metric(s)
The number of Planning applications submitted for
new affordable housing
F Update Permit Software System
Implementation Policies
HE-3.3 Efficient Development Processing
10. Housing Element
January 2024 HCD Draft Revised 2023-2031 Housing Element 10-43
Programs
The number of Planning applications submitted for
new multi-family development utilizing the new floor
area ratio standard
H Coordination with Water and Sewer
Providers
Deliver the adopted Housing Element to
the San Jose Water Company and the
West Valley Sanitation District so that
they can prioritize current and future
resources or services for housing
development that helps meet Los Gatos’
RHNA for lower income households.
Implementation Policies
HE-1.3 Infrastructure
Responsible Department/Review Authority
Community Development Department
Timeframe
Upon adoption of the Housing Element
Funding Source
None required
Quantified Objective
Deliver Housing Element
Performance Metric(s)
Delivery of Housing Element
I Senior Housing Resources
Provide financial assistance for health,
safety, emergency and accessibility home
repairs to low-income seniors and low-
income mobile homeowners through the
Below Market Price Program funds,
subject to availability of Program funds.
Provide regularly updated senior housing
resource materials at the Adult Recreation
Center, Library, and Farmers’ Market.
Implementation Policies
HE-1.6 Universal Design
HE-2.7 Senior Housing
HE-2.8 Equal Housing and Special Needs
HE-6.1 Fair Housing
HE-6.2 Financial Assistance
HE-6.3 Housing for Persons with Special Needs
HE-6.4 Affordable Housing Awareness
Responsible Department/Review Authority
Responsible Department/Review Authority
Community Development Department and the
Town Council
Timeframe
Ongoing and annual effort
Update materials annually
Funding Source
Town Affordable Housing Funds
Quantified Objective
Maintain the existing housing stock by funding
three home repairs to lower income seniors
annually
Performance Metric(s)
Measure the number of units assisted versus the
need
J Small Multi-Unit Housing, “Missing
Middle” Implementation Policies
HE-1.5 Variety of Housing Choices
HE-2.4 Rental Housing
HE-3.3 Efficient Development Processing
HCD Draft Revised 2023-2031 Housing Element
10-44 HCD Draft Revised 2023-2031 Housing Element January 2024
Programs
The Housing Element supports the land
use goal of providing opportunities for
housing that can accommodate the
needs, preferences, and financial
capabilities of current and future residents
in terms of different housing types,
tenures, density, sizes, and costs.
Specifically, the Town aims to create
mixed residential neighborhoods through
new and innovative housing types that
meet the changing needs of Los Gatos
households and expand housing choices
in all neighborhoods. These housing
types include, but are not limited to, single
dwelling units, multifamily dwelling units,
accessory dwelling units, small and micro
units, use of pre-fabricated homes, and
clustered housing/cottage housing. The
Town will also promote small multi-unit
housing that increases density while
remaining consistent with the building
scale and character present in existing
neighborhoods. This includes multi-family
units or clustered residential buildings that
provide relatively smaller, less expensive
units within existing neighborhoods.
Update the Zoning Code to facilitate small
multi-unit housing in the low to medium
designations.
Small multi-unit housing is defined as
multiple units on a single parcel (whether
attached or detached) that are compatible
in scale and form with detached single-
family homes. Common housing types
include duplexes; triplexes; fourplexes;
courtyard apartments; cottage courts;
townhomes; triplex stacked (vertical); and
live-work spaces.
Promote this program through publication,
to include the following information: Low
rise multi-family dwelling units ranging
from two to 10 units can help meet the
needs of families, seniors and students.
Permit processing times tend to be
shorter than larger multi-family buildings
due to the low-rise nature of the
structures.
Research existing regulatory impediments
to the creation of new housing types that
have the potential to fulfill unmet housing
needs (e.g., tiny homes, co-housing
developments) and if necessary, amend
Responsible Department/Review Authority
Community Development Department
Timeframe
December 2024
Funding Source
None required
Quantified Objective
Increase the number of small multi-unit housing
developments by 50 units over eight years.
Performance Metric(s)
Complete Zoning Code amendment by December
2024 and track the number of entitled Planning
applications received per year
10. Housing Element
January 2024 HCD Draft Revised 2023-2031 Housing Element 10-45
Programs
applicable ordinances to allow for their
development.
Pursue establishment of a maximum
average unit size as a tool to moderate
unit sizes for developments over a certain
size but to allow flexibility for a range of
unit sizes.
K Lot Consolidation
The Town will conduct outreach to
property owners in these areas to identify
meaningful incentives to facilitate lot
consolidation, lot assemblage and
redevelopment in mixed use and
commercial areas. Based on this
feedback, within two years of Housing
Element adoption, the Town will consider
the development of a Lot Consolidation
Ordinance to include specific incentives
such as: flexible development standards
such as reduced setbacks, increased lot
coverage, increased heights, reduced
parking, reduced fees, and streamlined
permit processing through administrative
staff review. Upon adoption of the
Ordinance, the Town will work with
property owners that are receptive to lot
consolidation/lot assemblage to assist
them in facilitating the parcel merge
process in a streamlined and timely
manner.
Implementation Policies
HE-3.4 Lot Consolidation
Responsible Department/Review Authority
Community Development Department
Timeframe
June 2025
Funding Source
None required
Quantified Objective
Facilitate nine lot consolidations.
Performance Metric(s)
Complete Zoning Code amendment
L Below Market Price Program
Conduct a study to evaluate the existing
BMP Program and recommend changes
to the program to increase the number of
Implementation Policies
HE-2.7 Senior Housing
HE-3.1 Regulatory Incentives for Affordable
Housing
HE-4.1 Property and Housing Conditions
HCD Draft Revised 2023-2031 Housing Element
10-48 HCD Draft Revised 2023-2031 Housing Element January 2024
Programs
affordable housing or “buy-down” existing
affordability covenants to have deeper
affordable units in existing rental
properties. This program is analogous to
purchasing covenants in new
developments in conjunction with the
BMP program, but for existing
apartments.
In existing and new rental developments,
the Town could provide a rehabilitation
loan or another form of subsidy to a rental
property owner in exchange for securing
affordability covenants on a percentage of
units and the owner’s agreement to
restrict rents on these units to levels that
would be affordable to very low- and low-
income households.
Timeframe
January 2026
Funding Source
Below Market Price Housing In-lieu Fees
Quantified Objective
Affordability covenants for three housing units with
BMP funding to increase the supply of affordable
housing per year
Performance Metric(s)
Number of affordability covenants
Q Accessory Dwelling Units
Facilitate ADU/JADU production with the
following efforts:
• Waive building fees when an
ADU is deed restricted for very
low- and low-income households
pursuant to Town Code (Section
29.10.320(a).
Initiate a marketing program for
homeowners on the benefits of
ADUs and the availability of
resources (templates, cost
calculators, technical support) to
support development. Promote
the use of Housing Choice
Vouchers (HCVs) and
homesharing (once established)
to make the units available to
lower income households.
• Collaborate with countywide
efforts to develop pre-approved
ADU plans suitable for Los Gatos,
including designs that are ADA
accessible.
• Streamline the review and
permitting of ADU’s by publishing
pre-approved plans including
plans that are ADA-compliant,
which shall be posted on the
Town’s website.
• Promote California Housing
Finance Agency (CHFA) ADU
grants of $40,000 available to
Implementation Policies
HE-1.7 Infill Opportunities in Single-Family
Neighborhoods
HE-2.4 Rental Housing
HE-2.5 Pre-Approved Accessory Dwelling Units
HE-2.6 Promote Accessory Dwelling Unit
Construction
HE-2.7 Senior Housing
HE-3.1 Regulatory Incentives for Affordable
Housing
HE-3.3 Efficient Development Processing
HE-3.5 Development Impact and Permit Fees
Responsible Department/Review Authority
Community Development Department
Timeframe
▪ Initiate marketing program and coordinate
efforts on pre-approved ADU plans (2023)
and other resources and services
(December 2025)
▪ Select at least three plans and conduct
media campaign to promote (December
2024)
▪ Annually monitor the production and
affordability of ADUs
▪ Amend the ADU Ordinance (January 2024)
▪ Monitor ADU/JADU production against
projection by July 2027 and develop
strategies to address any potential shortfall
in meeting RHNA by the end of 2027
Funding Source
Below Market Price Housing In-lieu Fees for
Waiving Building Fees and General Fund
10. Housing Element
January 2024 HCD Draft Revised 2023-2031 Housing Element 10-49
Programs
qualified homeowners for pre-
development costs.
Annually monitor number of
ADU’s/JADU’s produced, affordability
levels. By July 2027, if the production of
ADU/JADU is falling short of the projected
trend, develop strategies (additional
incentives, flexible development
standards, and/or identify additional sites
for housing development) to
accommodate a potential shortfall by the
end of 2027.
Amend the ADU Ordinance to comply
with State law.
Quantified Objective
▪ Facilitate construction of at least 200 ADUs
or JADUs with a goal to facilitate
construction of up to 350 ADUs or JADUs
throughout the Planning period
▪ Publish pre-approved ADU plans and
templates, including designs that address
ADA and senior housing needs
▪ Post pre-approved plans on Town website
▪ Use the Town’s social media, website, local
press, and community events to distribute
information
Performance Metric(s)
Number of Building Permits issued; number of
ADU/JADUs rented at a rental rate affordable for
very low-and low-income households
R Density Bonus
Conduct a study to evaluate the existing
Density Bonus Ordinance and
recommend changes to increase the
number of units constructed. The study
will include an evaluation of the
implementation of the ordinance to date
and actual construction of affordable
housing units that utilized the Density
Bonus. Additional density and height
incentives beyond what the State requires
will be considered (i.e., fee reductions,
add free density of BMP units). The study
shall recommend improvements to the
Ordinance based on the outcome of the
evaluation.
Amend the Density Bonus Ordinance to
comply with State law.
Implementation Policies
HE-3.1 Regulatory Incentives for Affordable
Housing
HE-2.3 Mixed-Use Development
HE-2.8 Equal Housing and Special Needs
Responsible Department/Review Authority
Community Development Department
Timeframe
▪ Amend the Density Bonus Ordinance
(December 2024)
▪ Complete study by June 2026 and implement
recommended actions by December 2029
Funding Source
None required
Quantified Objective
Increase affordable housing units generated by an
amended Density Bonus Ordinance
Performance Metric(s)
Measure the number of affordable units that
received entitlements
S Congregational Land Overlay Zone
Expand site opportunities by allowing
affordable housing on religious sites.
Study new Congregational Land Overlay
to build upon what is available through AB
1851 and AB 2244 and help
congregations by connecting them with
affordable housing development partners.
Implementation Policies
HE-3.1 Regulatory Incentives for Affordable
Housing
HE-2.7 Senior Housing
HE-2.8 Equal Housing and Special Needs
HE-2.9 Public/Private Partnerships
HE-2.11 Smart Growth
Responsible Department/Review Authority
Community Development Department
HCD Draft Revised 2023-2031 Housing Element
10-50 HCD Draft Revised 2023-2031 Housing Element January 2024
Programs
Timeframe
Complete by December 2025
Funding Source
None required
Quantified Objective
Increase affordable housing on one religious sites
by 25 units.
Performance Metric(s)
Complete study and measure the number of
congregational units that receive entitlements
T Nonprofit Affordable Housing
Providers
Support the efforts of nonprofit affordable
housing organizations that provide
housing services in Los Gatos.
Encourage the participation of these
providers in developing housing and
meeting the affordable housing needs of
Los Gatos households particularly
extremely low-income households. Staff
will meet with nonprofit groups on at least
on an annual basis to discuss constraints
to development and develop strategies
and actions for affordable housing
development, including incentives for the
development of affordable housing as
provided under the Affordable Housing
Overlay Zone.)
Research and pursue a homesharing
program, including research and
coordination with non-profit and other
organizations to assist with matching
tenants with existing homeowners.
Implementation Policies
HE-2.3 Mixed-Use Development
HE-2.7 Senior Housing
HE-2.8 Equal Housing and Special Needs
HE-2.9 Public/Private Partnerships
Responsible Department/Review Authority
Community Development Department
Timeframe
Ongoing and annual effort to support nonprofit
affordable housing organizations
Pursue a homesharing program by December 2025
and market program annually with the goal of 5
matches a year
Funding Source
None required
Quantified Objective
Meet with nonprofit affordable housing providers to
identify constraints and barriers
Performance Metric(s)
Develop incentives for affordable housing and
measure number of units using incentives
U Increased Range of Housing
Opportunities for the Homeless
Continue to support the County of Santa
Clara’s Continuum of Care plan, as well
as the “Housing 1000” campaign by
“Destination: Home” to provide housing
opportunities for homeless households,
including emergency shelter, transitional
housing, and permanent affordable
housing opportunities.
Implementation Policies
HE-2.8 Equal Housing and Special Needs
HE-2.9 Public/Private Partnerships
Responsible Department/Review Authority
Community Development Department
Timeframe
Ongoing and annual effort
Funding Source
County CDBG
10. Housing Element
January 2024 HCD Draft Revised 2023-2031 Housing Element 10-53
Programs
Y Supportive Services for the Homeless
Continue to support community and
nonprofit organizations that provide
supportive services for homeless persons
in Los Gatos in part by continuing to fund
the Town's annual grant and
disseminating opportunities for other
agency funding to West Valley
Community Services (WVCS), in order to
support its Comprehensive Emergency
Assistance Program (CEAP).
Continue to work with and fund local
nonprofits, and to collaborate with local
homeless service providers to provide
information on homeless needs in the
Town.
Implementation
HE-2.3 Mixed-Use Development
HE-2.8 Equal Housing and Special Needs
Responsible Department/Review Authority
Town Manager
Timeframe
Ongoing and annual effort
Funding Source
Town of Los Gatos
Quantified Objective
Continue the Town’s support to provide funds to
WVCS for homeless persons services
Performance Metric(s)
The number of Town residents assisted through
WVCS
Z Stabilize Rents
Study and implement recommendations
with regard to the Town’s Rental Dispute
Mediation and Arbitration Ordinance 2128
to help further stabilize rents for long-term
residents.
Implementation
HE-2.3 Mixed-Use Development
HE-2.4 Rental Housing
HE-6.6 Rental Dispute Mediation and Arbitration
Ordinance
Responsible Department/Review Authority
Community Development Department
Timeframe
Complete study by January 2025 and implement
Municipal Code changes by June 2025
Funding Source
Below Market Price Housing In-lieu Fees
Quantified Objective
Implement improvement opportunities for the
Rental Dispute Mediation and Arbitration Ordinance
Performance Metric(s)
Measure the number of disputes resolved versus
unresolved
AA Reduce Parking Standards
Initiate a study and outreach, including
developers and make specific updates
that would result amendments to the
Municipal Code, as follows :
▪ Align parking requirements with
the preparation of Objective
Design Standards.
Implementation
HE-2.7 Senior Housing
HE-2.8 Equal Housing and Special Needs
HE-3.1 Regulatory Incentives for Affordable
Housing
Responsible Department/Review Authority
Community Development Department
Timeframe
10. Housing Element
January 2024 HCD Draft Revised 2023-2031 Housing Element 10-61
Programs
Safety Code Section 17000, et
seq.).
▪ Allow for group homes of seven
and more by right in residential
districts, and to conform with
HCD’s Group Home Technical
Advisory (Dec 2022)
▪ Modify the language of Municipal
Code Section 29.10.530(a) to
remove finding number 5 of the
mandatory criteria for granting a
reasonable accommodation
request.
In addition, the Town will prioritize special
needs housing by allowing for reduced
processing times and streamlined
procedures for applicable zoning/land use
applications. Include preferential handling
of special needs populations in
management plans and regulatory
agreements of funded projects.
AQ Zoning Code Amendments
Amend the Zoning Code to comply with
State law and ensure adequate sites are
available to accommodate the identified
sites in the Sites Inventory. These Code
revisions include:
▪ Amend the Zoning Code to include
a Housing Element Overlay Zone
(HEOZ) to apply to the sites
included in the Site Inventory to
modify the development standards
(i.e., density, lot coverage, FAR,
height) on those sites. The Town
will commit to monitoring and
evaluating the HEOZ development
standards, including outreach with
the development community, and
making adjustments as necessary.
▪ Clarify the text of the non-
residential zones regarding
housing.
▪ Rezone the Caltrans Right-of-Way
– Site E3 from R:1:8 to R-M.
▪ Amend the Accessory Dwelling
Unit Ordinance.
▪ Amend the Density Bonus
Ordinance.
▪ Amend the Architecture and Site
considerations for a multi-family
and mixed-use project to make
Implementation
HE-1.1 Adequate Sites
HE-1.2 Multi-family Housing Densities
HE-2.11 Smart Growth
Responsible Department/Review Authority
Community Development Department
Timeframe
Complete rezonings by January 31, 2024, and
monitoring and evaluation of the HEOZ
developments standards by December 2026.
Funding Source
General Plan Update Fund
Quantified Objective
Amend the Zoning Code consistent with the
Housing Element timing
Performance Metric(s)
Number of affordable homeownership units entitled
and numbers of units entitled for moderate, low,
and very-low households and adopt the Zoning
Code amendments
HCD Draft Revised 2023-2031 Housing Element
10-62 HCD Draft Revised 2023-2031 Housing Element January 2024
Programs
them objective and provide
certainty in outcomes.
▪Amend the Conditional Use Permit
findings for a multi-family and
mixed-use project to make them
objective and provide certainty in
outcomes. Specifically, address
Finding (1) relating to use
desirable to the public
convenience and Finding (2)
relating to the integrity and
character of the zone. These
findings be considered subjective
and open to interpretation.
▪Amend the Zoning Code to clarify
that the Town will comply with
Section 65852.3 of the
Government Code to allow the
installation of manufactured
homes.
▪Amend the Zoning Code to align
the private open space and the
community recreation space
requirements for a multi-family and
condominium project with the
Objective Design Standards.
▪Amend the Zoning Code to align
parking requirements for a multi-
family and condominium project
with the preparation of the
Objective Design Standards.
AR General Plan Amendment
Amend the General Plan to modify the
designation of 16492 Los Gatos
Boulevard and Parcel 532-07-086 from
Low Density Residential to Neighborhood
Commercial, modify the designation of the
Cal Trans Right-of-Way from Low Density
Residential to Medium Density
Residential, and establish new maximum
densities for the High Residential,
Medium Density Residential, Low Density
Residential, Mixed-Use, Neighborhood
Commercial, and Central Business
District land use designations to provide
for the development of housing for the
sites in the Site Inventory. See Program
AQ.
As individual elements of the General
Plan are amended, the Town will review
Implementation
HE-1.1 Adequate Sites
HE-1.2 Multi-family Housing Densities
HE-2.11 Smart Growth
Responsible Department/Review Authority
Community Development Department
Timeframe
Complete General Plan amendments by January
31, 2024
Funding Source
General Plan Update Fund
Quantified Objective
Adopt General Plan amendments consistent with
the Housing Element timing.
Performance Metric(s)
Adopt General Plan amendments.
10. Housing Element
January 2024 HCD Draft Revised 2023-2031 Housing Element 10-65
Programs
AU Replacement Unit Program
Adopt a policy requiring replacement
housing units subject to the requirements
of Government Code section 65915 (c)(3)
when new development occurs on a
housing inventory site which currently has
or within the past five years had
residential uses (existing, vacated or
demolished), and was legally restricted to
low-income households, or subject to
price control, or occupied by low-income
households.
Implementation
HE-1.1 Adequate Sites
Responsible Department/Review Authority
Community Development Department
Timeframe
Adopt a policy by January 2024 and apply the
policy as applications on sites within the Sites
Inventory are received and processed
Funding Source
General fund (staff time)
Quantified Objective
New policy adopted
Performance Metric(s)
Measure the number of replacement housing units
entitled that are restricted to low-income
households
AV Senate Bill 9 Monitoring
Annually monitor the development of SB 9
applications every year beginning in 2023
to better understand their role in the Los
Gatos housing market if trends and
consider additional efforts to incentivize
SB 9 applications.
Implementation
HE-1.1 Adequate Sites
Responsible Department/Review Authority
Community Development Department
Timeframe
Evaluate effectiveness of SB 9 approvals every
year beginning in 2023; and identify additional
incentives and/or site capacity, if needed by 2025
Funding Source
General fund (staff time)
Quantified Objective
Prepare Annual Progress Report and issue 96 SB
9 entitlements over the eight-year period
Performance Metric(s)
Number of issued SB 9 Building Permits.
AW Story Poles and Netting Policy
Update the Story Pole and Netting Policy
and create options for residential or
mixed-use projects with affordable
housing to reduce the associated costs of
installing story poles, by providing an
option to provide video rendering in place
of story poles for all multi-family and
mixed-use projects, and all projects over
Implementation
Policy HE-3.1 Regulatory Incentives for Affordable
Housing
Responsible Department/Review Authority
Community Development Department
Timeframe
Implement by March 2024, and evaluate
effectiveness of reduced requirements every year
HCD Draft Revised 2023-2031 Housing Element
10-66 HCD Draft Revised 2023-2031 Housing Element January 2024
The following action matrix includes the Town’s goals and actions to affirmatively further fair housing.
Program Specific Commitment Timeline Geographic
Targeting
Eight-Year
Metric
Fair Housing Outreach and Enforcement
Program A.
Developer Forum
Meet with housing developers to
discuss constraints and housing
opportunities.
Annually Townwide
Meet with housing
developers
annually.
Program O.
Affordable
Housing
Development
Outreach to attract and support
affordable housing developers in
the Town and identify housing
opportunities.
Annually Townwide
Facilitate the
construction of 460
new homes for
moderate to lower-
income
households.
Program W.
Rental Dispute
Resolution
Program
Administer the Rental Dispute
Resolution Program. Annually Townwide
Provide counseling
to all members of
the public who
contact the Town.
Programs
55 feet in height to reduce constrains/cost
and increase approval certainty.
beginning in 2025; and identify additional incentives
and/or site capacity, if needed, within six months of
need identification.
Funding Source
General fund (staff time)
Quantified Objective
Reduce cost of development by modifying the story
pole requirements for affordable housing projects.
Performance Metric(s)
Measure impact of modifying the story pole policy
on the number of affordable housing units entitled
AX Local Labor Program List
Establish and post a list of local labor
unions and apprenticeship programs on
the website to encourage the developers
and contractors to hire local labor.
Implementation
Policy HE-1.4 Housing Design
Responsible Department/Review Authority
Community Development Department
Timeframe
Establish a list by December 31, 2024, to post
online.
Funding Source
General fund (staff time)
Quantified Objective
Annually update the list or upon request from a
local union.
Performance Metric(s)
N/A
10. Housing Element
January 2024 HCD Draft Revised 2023-2031 Housing Element 10-67
Program Specific Commitment Timeline Geographic
Targeting
Eight-Year
Metric
Program AE. Fair
Housing Law
Education
Increase dissemination of fair
housing information.
By end of August
2023. Townwide
Add 50 new
subscribers to the
Notify me
subscriber list.
Program AM.
Santa Clara
County Fair
Housing
Consortium
Continue to support the efforts
of the Santa Clara County Fair
Housing Consortium.
Annually Townwide
Counsel 10
tenants annually
on tenant/landlord
concerns to
prevent
displacement.
Program I. Senior
Housing
Resources
Provide regularly updated senior
housing resource materials at
the Adult Recreation Center,
Library, and Farmers’ Market.
Annually Townwide
Assist three senior
households
annually though
senior housing
resources.
Program X.
Assistance for
Persons with
Developmental
Challenges
Continue to work with the
California Department of
Developmental Services
Regional Center to inform
families about housing and
services available for persons
with developmental challenges.
Annually Townwide Assist three
families annually.
Program AN.
Community
Education Using a
Variety of
Communication
Methods
Provide information about
available housing resources
through a variety of
communication methods.
Quarterly Townwide
Assist three low-
income families
annually.
Program AO.
Educate Single-
Family Property
Owners Regarding
In-Fill Housing
Options
Provide education on SB 9 and
ADU’s.
Consider adding fair housing
information to SB 9 and ADU
applications/materials; new
landlords.
Quarterly Townwide
Increase the
number of ADU
building permit
applications from
2022 baseline of
25. Increase the
number of SB 9
applications from
2022 baseline of 9.
Program AN.
Community
Education on
Housing Needs
Provide education on the
problems and needs of
affordable housing as a means
of changing negative attitudes.
Annually Townwide
Celebrate
Affordable Housing
Month annually in
May by posting on
social media
accounts with
education on
affordable housing.
Program AT.
Affirmative
Marketing
Disseminate information on
available development including
providing notice of new housing
opportunities in the flyer for local
school districts in the Town.
Annually Townwide
Affirmatively
market all
affordable housing
Opportunities.
New Housing Opportunities in High Resource Areas
Program D.
Additional Housing
Capacity for North
Forty Specific Plan
Increase allowed density in
North Forty Specific Plan and
facilitate buildout of the Plan.
Amend the SP to include a
policy specifying that additional
units as a result of the State
density bonus law, SB 330, and
other applicable state laws will
not count toward the unit cap
and the unit cap will not impede
the achievement of the RHNA.
By January 2024
North Forty Specific
Plan area (highest
resource area)
Facilitate the
construction of 45
new homes for
lower-income
households.
Program N. Funds
for Development
Use Town Affordable Housing
(Below Market Price) Fund to Annually Townwide Subsidize five
developments
HCD Draft Revised 2023-2031 Housing Element
10-68 HCD Draft Revised 2023-2031 Housing Element January 2024
Program Specific Commitment Timeline Geographic
Targeting
Eight-Year
Metric
for Extremely Low
Income (ELI)
Households
subsidize housing for extremely
low-income households.
which include
extremely low-
income
households.
Program O.
Affordable
Housing
Development
Provide incentives for affordable
housing development and Annually Townwide (all high
resource areas)
Facilitate the
construction of 460
new homes for
moderate to lower-
income
households (100
for moderate, 190
for low, and 170 for
very-low).
Program Q. ADUs
Initiate marketing plan, coordinate
pre-approved ADU plans, and
monitor production and
affordability of ADUs.
Monitor affordability of ADUs
through communication with
applicants (form with intent to
rent).
Monitor ADU
projection by July
2027 and develop
strategies to
address potential
shortfall by the end
of 2027
Townwide (all high
resource areas)
Facilitate
construction of at
least 200 ADUs with
a goal to facilitate
construction of up to
350 ADUs or
JADUs, with a goal
of 5% of these units
being affordable to
low income
households.
Program AB.
Allow for 100
Percent Affordable
Residential
Development in
Mixed-Use
General Plan
Designations
Amend the General Plan and
the Municipal Code to allow for
100 percent affordable
residential development without
the requirement of commercial
uses.
By June 2024 Townwide
Facilitate the
construction of
affordable units in
mixed use GP
designations.
Housing Mobility
Program J. Small
Multi-Unit “Missing
Middle” Housing
Update zoning code and
promote small multi-unit housing
program, with goal of providing
housing for families, seniors,
and students. Facilitate small
multi-unit housing in the low to
medium density designations.
By January 2024 Townwide
Facilitate the
development of 50
units of small multi-
unit housing over
eight years.
Program L. Below
Market Price
Program
Conduct a study to evaluate the
existing BMP Program and
recommend changes to the
program to increase the number
of units constructed.
By June 2025 Townwide
Increase number
of BMP units
annually by five
units (from 257
baseline).
Program V.
Housing
Opportunities for
Persons Living
with Disabilities
Review and update regulations
and encourage implementation
of Universal Design.
Amend Zoning Code to increase
housing for persons with
disabilities.
2023-2031
By December
2025.
Townwide
Increase housing
for persons with
disabilities by 90
units.
Program AP.
Special Needs
Housing
Establish streamlined
procedures for special needs
housing.
Amend the Zoning Code to
remove barriers to building
special needs housing
By January 2028
By January 2024
Townwide
Adopt Zoning Cod
amendments to
facilitate the
construction of
units for special
needs populations.
Program X.
Assistance for
Persons with
Developmental
Challenges
Work with local and/or regional
partners to provide rental
assistance for persons with
developmental challenges.
Annually Townwide
Provide rental
assistance for
persons with
disabilities.
10. Housing Element
January 2024 HCD Draft Revised 2023-2031 Housing Element 10-69
Program Specific Commitment Timeline Geographic
Targeting
Eight-Year
Metric
Program Q: ADUs
Promote the use of Housing
Choice Vouchers (HCVs) and
homesharing (once established)
to make the units available to
lower income households.
By December
2025 Townwide
Initiate a marketing
plan and
coordinate efforts
for HCVs and
homesharing
programs.
Program T:
Nonprofit
Affordable
Housing Providers
Pursue a homesharing program
and market program annually.
By December
2025 Townwide Facilitate 5
matches per year.
Program AV:
SB 9 Monitoring Monitor SB 9 applications
Monitor annually
and consider
additional efforts if
needed by 2025
Townwide
Facilitate
development of 96
SB 9 entitements
Place-based Strategies for Neighborhood Improvement
Program AI.
Countywide Home
Repair Programs
Support home repair programs
including Habitat for Humanity
East Bay/Silicon Valley,
Rebuilding Together, Housing
Trust of Santa Clara County,
and contribute funding from the
Town’s Below Market Price
monies to support these
programs.
2023-2031
Townwide with
emphasis on
central and western
tracts where
substandard
housing conditions
and aging units are
more prevalent.
Complete three
minor home
repairs or
accessibility
improvements for
lower income
households
annually.
Program AJ.
Residential
Rehabilitation
Program
Create a new program to assist
lower income homeowners,
including senior and disabled
households, with funding for
home repairs and
improvements.
By December
2026 Townwide
Provide
rehabilitation to
five low-income
homeowner units
annually.
AFFH: CIP
Projects
Complete projects related to
public facilities and
transportation infrastructure
outlined in the Capital
Improvement Program, including
the Los Gatos Adult Recreation
Center Restroom Remodel for
ADA Compliance and Shannon
Road Pedestrian and Bikeway
Improvements.
By 2030
Townwide with
emphasis on north
and western areas
of the Town.
Complete at least
three CIP projects
during the planning
period.
Tenant Protection and Anti-Displacement
Program Z.
Stabilize Rents
Study and implement
recommendations with regard to
the Town’s Rental Dispute
Mediation and Arbitration
Ordinance 2128 to help further
stabilize rents for long-term
residents.
By June 2025 Townwide
Implement
improvement
opportunities for
the Rental Dispute
Mediation and
Arbitration
Ordinance
Program AG.
Preserve “At-Risk”
Affordable
Housing Units
Monitor affordable, multi-family
housing units in the Town to
ensure that they retain their
affordability status.
Annually Townwide
Preserve
affordability of all
affordable units.
Program AU.
Replacement Unit
Program
Adopt a policy and apply the
policy as applications on sites
within the Sites Inventory are
received and processed
By January 2024 Townwide
Require
replacement
housing for 100%
of displaced low-
income
households.
HCD Draft Revised 2023-2031 Housing Element
D-2 Appendix D January2024
Site Capacity
On sites with Property Owner Interest and/or conceptual development plans submitted, 1,331 units are projected:
480 very low income; 283 low income; 264 moderate income; and 304 above moderate income units. Additional
vacant and underutilized sites add another 624 potential units: 154 very low income; 74 low income; 76 moderate
income; and 320 above moderate income.
Small Parcels
While the Sites Inventory in this Housing Element includes a few small “parcels”, no small “sites” less than 0.5
acre are used to accommodate lower income RHNA units. A site is typically comprised of a few parcels. In this
Sites Inventory, only parcels that are already consolidated or under common ownership, totaling more than 0.5
acre, are used to meet the lower income RHNA. The majority of property owners who have expressed interest in
redevelopment have either communicated their interest through submittal of a Property Owner Interest Form
and/or a SB 330 preliminary and/or formal application, in which a future development would comprise of merging
multiple parcels into a single parcel. Sites that include small parcels are:
• B-1: 3 parcels (7.04 acres; 1.49 acres; and 0.28 acre) under common ownership (Los Gatos Lodge), with
expressed interest from property owner to redevelop the site, including the merging of three parcels into a
single parcel. Access to the site is provided through a single entrance fronting along Los Gatos-Saratoga
Road which serves all three parcels and that all parcels are under common ownership;
• C-2: 3 parcels (0.34 acres; 1.20 acres; and 1.34 acres) under common ownership with expressed interest
from property owner to redevelop the site, including the merging of three parcels into a single parcel.
Analysis of the parcels has shown that there is potential for shared access given the parcels location with
frontage along Los Gatos Boulevard, partial frontage along Garden Lane, and that all parcels are under
common ownership;
• D-1: 7 parcels (2.90 acres; 0.78 acres; 0.44 acres; 0.44 acres; 3.74 acres; 6.07 acres; and 1.02 acres),
with expressed interest from property owner to redevelop the site, including the merging of seven parcels
into a single parcel. Analysis of the parcels has shown that there is potential for shared access given the
parcels location with frontage along Los Gatos Boulevard, the previous development pattern of the North
Forty Phase I, and that all parcels are under common ownership;
• D-2: 2 parcels (1.17 acres and 0.11 acre) under common ownership, including the merging of two parcels
into a single parcel. Analysis of the parcels has shown that there is potential for shared access given the
parcels location along Burton Road, the smaller parcel (0.11 acre) is located at a dead-end road and
would be dependent on a lot merger to provide for sufficient development area, and that all parcels are
under common ownership;
• D-5: 2 parcels (0.56 acre and 0.26 acre) under common ownership. Analysis of the parcels has shown
that there is potential for shared access given the parcels location along Burton Road, partial frontage
along Los Gatos Boulevard, and that all parcels are under common ownership;
No other small parcels are used to meet the Town’s lower income RHNA.
The Town’s efforts to facilitate lot consolidation will be completed through Implementation Program K and will
include the following actions:
• Opportunity sites outreach: The Town will conduct outreach to property owners in these areas to identify
meaningful incentives to facilitate lot consolidation, lot assemblage and redevelopment in mixed-use and
commercial areas.
• Development Incentives: The Town will consider the development of a Lot Consolidation Ordinance to include
specific incentives such as: flexible development standards such as reduced setbacks, increased lot
coverage, increased heights, reduced parking, and reduced fees.
• Technical assistance: The Town will work with property owners that are receptive to lot consolidation/lot
assemblage to assist them in facilitating the parcel merge process in a streamlined and timely manner.
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From: Jauregui, Jose @HCD <Jose.Jauregui@hcd.ca.gov>
Sent: Saturday, December 2, 2023 6:57 AM
To: Joel Paulson <jpaulson@losgatosca.gov>
Cc: Jennifer Armer <JArmer@losgatosca.gov>; Veronica Tam
McDougall, Paul@HCD <Paul.McDougall@hcd.ca.gov>; Jocelyn Shoopman
<jshoopman@losgatosca.gov>
Subject: Los Gatos Housing Element
Hello Joel,
Please see the attached HCD finding letter for the Town of Los Gatos HE review. Let me know if you have
any questions or concerns.
Warm regards,
Jose A. Jauregui he / him
Housing Policy Analyst
Housing Policy Development
Housing & Community Development
2020 W. El Camino Avenue, Suite 500 | Sacramento, CA 95833
Cell: (916) 820-1516
STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT DIVISION OF HOUSING POLICY DEVELOPMENT 2020 W. El Camino Avenue, Suite 500 Sacramento, CA 95833 (916) 263-2911 / FAX (916) 263-7453www.hcd.ca.gov
December 1, 2023
Joel Paulson, Director Community Development Department Town of Los Gatos
110 E Main Street
Los Gatos, CA 95030
Dear Joel Paulson:
RE: Town of Los Gatos’ 6th Cycle (2023-2031) Revised Draft Housing Element
Thank you for submitting the Town of Los Gatos’ (Town) revised draft housing element received for review on October 2,2023, along with revisions received on November 28,2023. These revisions were made available to the public for at least seven days prior to submitting
to HCD pursuant to AB 215 (Chapter 342, Statutes of 2021). Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. Our review was facilitated by a conversation on November 7, 2023 with yourself, Jennifer Armer, Planning Manager,
Jocelyn Shoopman and Erin Walter, associate planners, and Veronica Tram, the Town’s
consultant. In addition, HCD considered comments from Los Gatos Community Alliance, Rutan and Tucker, Phil Koen, Eric S. Phillips, and Anne Paulson pursuant to Government Code section 65585, subdivision (c).
The revised draft element, including revisions, addresses many statutory requirements;
however, revisions will be necessary to substantially comply with State Housing Element Law (Gov. Code, § 65580 et seq) as follows:
1.Affirmatively further[ing] fair housing in accordance with Chapter 15(commencing with Section 8899.50) of Division 1 of Title 2…shall include an
assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd.
(c)(10)(A).)
Promote and affirmatively further fair housing opportunities and promote housingthroughout the community or communities for all persons regardless of race,
religion, sex, marital status, ancestry, national origin, color, familial status, or
disability, and other characteristics... (Gov. Code, § 65583, subd. (c)(5).)
Income and Racial Concentration Area of Affluence (RCAA): The element now
includes actions to promote an inclusive community; however, the element must
Joel Paulson, Director Page 2
provide specific analysis of income and RCAA at a regional level (town compared
to the broader region) to better formulate appropriate policies and programs. The
analysis should at least address trends, conditions, coincidence with other fair housing factors (e.g., race, highest resource, overpayment), effectiveness or absence of past strategies (e.g., lack of publicly assisted housing and lack of multifamily zoning), local data and knowledge and other relevant factors.
Contributing Factors to Fair Housing Issues: Based on a complete analysis, the element should re-assess and prioritize contributing factors to fair housing issues. For example, the Town is wholly a RCAA, highest resource and highest median incomes in contrast to the rest of the region. As a result, fair housing issues such as the lack of affordable housing and segregation from the rest of
the region should be a high priority. Goals and Actions: As noted above, the element must include a complete analysis of affirmatively furthering fair housing (AFFH). The element must be
revised to add goals and actions based on the outcomes of a complete analysis.
In addition, while the element includes some actions toward AFFH and enhancing housing mobility (e.g., choices and affordability), actions should be added, numeric targets should be increased, and geographic targeting should be
fine-tuned to better promote inclusive neighborhoods throughout the Town. This
is particularly important since over 80 percent of the lower-income regional housing need allocation (RHNA) is isolated in two census tracts. As noted in HCD’s prior review and the assessment of fair housing, the Town is wholly a racially concentrated area of affluence, highest resource and highest median
incomes in contrast to the rest of the region.
These conditions and circumstances warrant significant and robust actions (not limited to the RHNA) to promote housing mobility and increasing housing choices and affordability throughout the Town, including lower-density neighborhoods.
Actions should be added and revised with aggressive numeric targets and geographic targets throughout the Town, including lower-density neighborhoods. Examples include creating more housing choices and affordability in single-family neighborhoods beyond complying with law (e.g., SB 9, ADUs) such as missing middle housing types, targeting affordable housing funding, homesharing, more
than one unit of converted space within a single-family structure, increased multifamily capacity, enhanced efforts on religious institutional sites and other alternative land use and financing strategies. 2. An inventory of land suitable and available for residential development, including
vacant sites and sites having realistic and demonstrated potential for
redevelopment during the planning period to meet the locality’s housing need for
Joel Paulson, Director Page 3
a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
Identify actions that will be taken to make sites available during the planning
period with appropriate zoning and development standards and with services and
facilities to accommodate that portion of the city’s or county’s share of the
regional housing need for each income level that could not be accommodated on
sites identified in the inventory… (Gov. Code, § 65583, subd. (c)(1).)
Small Sites: The element identifies several sites with parcels less than a half-acre (p. D-13) that have common ownership and, in some cases, expressed
interest to redevelop the site. For small sites with expressed interest in
redevelopment, the element should clarify that the expressed interest is also in consolidating the sites. For the remaining sites (Sites D-2 and D-5), the element should explain the circumstances leading to the potential for consolidation such as necessity to consolidate due to access, feasibility, shape, or site planning
flexibility. Based on the outcomes of this analysis, the element should add or
modify Program K (Lot Consolidation) to further promote lot consolidation, if appropriate.
Electronic Sites Inventory: For your information, while the Town has submitted an
electronic sites inventory as part of this submittal, pursuant to Government Code
section 65583.3, the Town must submit an electronic sites inventory with its adopted housing element. Please see HCD’s housing element webpage at https://www.hcd.ca.gov/planning-andcommunity-development/housing-elements for a copy of the form and instructions. The Town can reach out to HCD at
sitesinventory@hcd.ca.gov for technical assistance.
Adequate Sites Programs: As noted in the prior review, if necessary to make
appropriate zoning available to accommodate the lower-income RHNA, programs must be revised to meet all requirements pursuant to Government Code section 65583.2, subdivisions (c), (h) and (i). The element includes Programs D (Program By Right Zoning Text Amendment to Accommodate RHNA), AR
(General Plan Amendment) and AS (Adequate Sites for Housing) to address
these requirements. With respect to sites identified in prior planning periods, the element meets statutory requirements, but these actions must be completed by January 31, 2024. With respect to a shortfall of adequate sites to accommodate the lower-income RHNA, the element includes Programs AR and AS. However,
the Programs commit to the appropriate zoning given the rezoning occurs after
the statutory deadline of January 31, 2023. HCD understands the Town completed the rezoning after the statutory deadline and, therefore, the rezoning must meet all by right requirements pursuant to Government Code section 65583.2, subdivisions (h) and (i). Based on a cursory review, the rezoning does
not appear to meet these requirements. As a result, these programs must clearly
commit to meet all by-right requirements by January 31, 2024.
Joel Paulson, Director Page 4
In addition, please be aware, the recent California appellate decision in Martinez
v. City of Clovis found that while overlays can be used in a rezone, when thebase zone allows residential development, both the base zone and the overlayzone must comply with the minimum density requirements of Government Codesection 65583.2, subdivision (h). The Town may need to adjust its rezoning
strategy if the underlying zoning for sites that will be rezoned allows minimum
densities less than 20 dwelling units per acre. Martinez v. City of Clovis (2023) 90Cal.App.5th 193, 307 Cal.Rptr.3d 64.
3.An analysis of potential and actual governmental constraints upon the
maintenance, improvement, or development of housing for all income levels,
including the types of housing identified in paragraph (1) of subdivision (c), and
for persons with disabilities as identified in the analysis pursuant to paragraph
(7), including land use controls, building codes and their enforcement, site
improvements, fees and other exactions required of developers, and local
processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).)
Address and, where appropriate and legally possible, remove governmental and
nongovernmental constraints to the maintenance, improvement, and
development of housing, including housing for all income levels and housing for
persons with disabilities…(Gov. Code, § 65583, subd. (c)(3).)
Land Use Controls: HCD’s prior review found that the Town must list andevaluate development standards in the North Forty Specific Plan and HighDensity Residential and Commercial designation. In response, the Town has nowlisted development standards by each zoning district but should also analyze
those development standards for impacts on housing supply and cost and mostimportantly, the ability to encourage maximum densities without exceptions. Forexample, lot coverages, heights, and setbacks in the Multifamily Residential (RM)zone; and lot coverage heights and guest parking requirements in the North Forty
Specific Plan could be constraints. Based on the outcomes of a complete
analysis, the element should add or modify programs to include specificcommitment to review and revise these development standards as necessary.
Local Processing and Permit Procedures: The element now discusses decision-
making bodies and lists approval findings for the Architecture and SiteApplication. However, the element should also analyze these processes to betterinform programs to address identified constraint. For example, the elementmentions the decision-making body depends on the scope of the application. Theelement should explain the scope, resulting decision-making body and impacts
on approval timing and certainty. In addition, the element lists approval findingsand concludes some findings may be constraints then modifies Program AQ(Zoning Code Amendments) to amend approval findings (considerations). But the
Joel Paulson, Director Page 5
element should discuss which approval findings may be constraints to better
inform implementation of Program AQ.
Programs: As noted above, the element requires a complete analysis of potential governmental constraints. Depending upon the results of that analysis, the Town may need to revise or add programs and address and remove or mitigate any identified constraints. In addition, programs should be revised, as follows:
• Program D (Additional Capacity for the North Forty Specific Plan): The Program should also commit to establish or modify development
standards to facilitate achieving maximum densities, regardless of the
level of affordability and should specify to either remove the unit cap or increase the unit cap to allow maximum build out of each parcel, including State Density Bonus Law or other circumstances that might warrant increasing allowable densities.
• Program V (Housing opportunities for Persons living with Disabilities): Given the importance of promoting housing access for persons with disabilities, the Program could be modified with a date earlier in the planning period (e.g., by December 2024).
• Program AA (Reduce Parking Standards): The Program currently commits to “Initiate a study to determine specific updates…” While initiating a study and making a determination are important steps by themselves, these actions do not result in outcomes. The Program should clearly commit to amending the municipal code. For example, the Program could commit to:
“Initiate a study and outreach, including with developers, and amend the Municipal Code, as follows:…”
• Program AQ (Zoning Code Amendments): The Program commits to apply
the Housing Element Overlay Zone (HEOZ) to identified sites and modify
development standards. HCD understands this action has been completed. Based on a cursory review of the Town’s Ordinance 2347, some development standards such as heights may be a constraint on achieving maximum densities. As a result, this Program should commit to
monitor and evaluate these development standards, including outreach
with the development community, and making adjustments, as appropriate, by a specified date.
• Program AW (Story Poles and Netting Policy): While the Program now
commits to revise Story Poles and Netting Policy Requirements; these
requirements are constraints and impact housing costs; supply (number of units) and approval certainty and should be removed or replaced with cost effective measures to promote certainty for the developers and the community. Further, the element should evaluate the effectiveness of any
future requirements or measures, and making adjustments, as necessary,
by a specified date (e.g., by 2028).
Joel Paulson, Director Page 6
4.Develop a plan that incentivizes and promotes the creation of accessory dwelling
units that can be offered at affordable rent... (Gov. Code, § 65583, subd. (c)(7).)
Program Q Accessory Dwelling Units (ADU): While the Program now commits toamend the ADU Ordinance, it must also commit to establish incentives such asmodifying development standards (e.g., heights), pursuing funding; waiving feesbeyond ADU law; proactive marketing and establishing points of contact to ease
permitting processes. In addition, the Program commits to monitor productionand affordability of ADUs annually but should also commit to making adjustmentsby a specified date (e.g., within six months) if production and affordability are notmeeting assumptions. Further, the Program should clearly commit to optionsbeyond incentives such as rezoning if production and affordability far differs from
assumptions.
5.Local governments shall make a diligent effort to achieve public participation of
all economic segments of the community in the development of the HousingElement, and the element shall describe this effort. (Gov. Code, § 65583,
subd. (c)(9).)
Public participation in the development, adoption and implementation of thehousing element is essential to effective housing planning. Throughout thehousing element process, the Town should continue to engage the community,
including organizations that represent lower-income and special needshouseholds, by making information regularly available and considering andincorporating comments where appropriate. Please be aware, any revisions tothe element must be posted on the local government’s website and to email alink to all individuals and organizations that have previously requested notices
relating to the local government’s housing element at least seven days beforesubmitting to HCD. HCD particularly encourages the Town to continue engagingcommenters on this review. These comments contained valuable insights thatcan result in a more effective housing elements, especially related to programs
and specific commitment. HCD’s future reviews will continue to consider the
extent to which the revised element documents how the Town solicited,considered, and addressed public comments in the element. The Town’sconsideration of public comments must not be limited by HCD’s findings in thisreview letter.
The element will meet the statutory requirements of State Housing Element Law once it has been revised and adopted to comply with the above requirements pursuant to Government Code section 65585.
For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), as the Town failed to adopt a compliant housing element within 120 days of the
Joel Paulson, Director Page 7
statutory deadline (January 31, 2023); programs to rezone and make prior identified
sites available or address a shortfall of capacity to accommodate the RHNA (e.g.,
Program D: Program By Right Zoning Text Amendment to Accommodate RHNA, Program AR: General Plan Amendment, Program AS: Sites Previously Identified) must be completed no later than one year from the statutory deadline. Otherwise, the local government’s housing element will no longer comply with State Housing Element Law,
and HCD may revoke its finding of substantial compliance pursuant to Government
Code section 65585, subdivision (i).
Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant, the Strategic Growth Council and HCD’s
Affordable Housing and Sustainable Communities program, and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the Town will meet housing element requirements for these and other funding sources.
For your information, some general plan element updates are triggered by housing element adoption. HCD reminds the Town to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor’s Office of Planning and Research at:
https://www.opr.ca.gov/planning/general-plan/guidelines.html.
HCD appreciates the commitment and cooperation the housing element update team provided during the update and review. HCD is committed to assisting the Town in
addressing all statutory requirements of State Housing Element Law. If you have any
questions or need additional technical assistance, please contact Jose Armando Jauregui, of our staff, at jose.jauregui@hcd.ca.gov.
Sincerely,
Paul McDougall Senior Program Manager