Second HCD Comment Letter

On July 5, 2024, the County of San Mateo received a second comment letter from the California Department of Housing and Community Development (HCD) regarding the County’s revised adopted Housing Element submitted to HCD for review in March 2024. The County is in communication with HCD regarding the substance of the comment letter, and is working diligently to amend the Housing Element in response to the comments received, to ensure full compliance with state law. Once revisions are complete, the updated Housing Element will be posted for public review, and notification of availability will be provided to all interested parties.  

Questions and comments regarding HCD’s most recent comment letter may be directed to:
William Gibson
455 County Center, Redwood City, CA 94063

March 2024 Revised Housing Element

San Mateo County has released a revised updated draft 2022-2031 Housing Element, in response to comments received from the California Department of Housing and Community Development (HCD).

The Housing Element of the San Mateo County General Plan is intended to:

  • Identify and inventory housing needs, constraints to housing production, and housing resources.
  • Assess the status and effectiveness of housing policies.
  • Incorporate County housing policies and programs.
  • Demonstrate the County’s ability to meet its share of regional housing needs as established by its Regional Housing Needs Allocation (RHNA), by identifying sufficient sites that are likely to be developed or redeveloped with housing of appropriate types and densities in the next 8 years of the Housing Element cycle (2022-2031).

The Housing Element is required by state law, and is required to be updated on a schedule established by state law, with contents and using methods also established by law. On updating, the County is required to submit the Housing Element to the California Department of Housing and Community Development (HCD) for HCD’s review of its compliance with state law.

San Mateo County submitted its draft Housing Element to the California Department of Community Development on January 20, 2023. HCD responded on April 20, 2023, with a letter providing an inventory of requested modifications to the Housing Element to ensure compliance with state law. The County has now completed its revisions in response to HCD’s comments.

The updated draft Housing Element is available to view. Significant changes, additions, edits, and information directly responsive to HCD’s comments are shown in red text throughout the Housing Element. Minor editing for clarity, correction of errors, or other changes that do not alter the substance of the Housing Element are not indicated in the text.

An inventory of changes made in response to HCD’s comments is available to view. Each of HCD’s comments is listed, and the responsive changes are summarized and identified by page number in the Housing Element.

Public Hearings

The County Planning Commission considered the updated Housing Element on April 10, 2024, and voted to recommend that the Board of Supervisors adopt the updated Housing Element and associated Negative Declaration. The Board of Supervisors will consider the adoption of the Housing Element at its regularly scheduled hearing on April 23, 2024, at 9:00 AM. Any comments on the amended Housing Element may be made, up until the time of the Board of Supervisors hearing, to:

William Gibson
455 County Center, Redwood City, CA 94063

Amendments in Response to HCD

Many of the modifications requested by HCD are relatively minor, including additional data and more comprehensive explanation and clarification of analysis, current and proposed programs and policies, County regulations, and other straightforward changes to ensure the Housing Element contains sufficient information and analysis to clearly demonstrate compliance with state law.

Other modifications required substantial new analysis, addition or expansion of policies and programs, and other changes leading to substantial amendments to the substance of the Housing Element.

Most significantly, the amended Housing Element includes a comprehensive revision of the Housing Element Sites Inventory and Rezoning Program. The Housing Element Sites Inventory, representing sites that are likely to be developed or redeveloped with housing in the next 8 years without any changes to current zoning or other regulations, has been entirely reassessed, with extensive new research on recent development trends and types to support the development assumptions and projections for all types of sites included in the Inventory. The Rezoning Program, including sites that are likely to develop or redevelop in the next 8 years if rezoned for multifamily residential development, has also been expanded, with new sites at greater densities across more County areas, also supported by extensive new analysis of recent development trends and development feasibility. The Sites Inventory and Rezoning Program now demonstrate that the County has sufficient sites to meet its required RHNA, with a substantial buffer across every income level. The Sites Inventory and Rezoning Program are summarized in Section 4 of the Housing Element, and detailed data and explanation of the analysis, findings, and projections are included in Appendix E.

The amended Housing Element also includes extensive new analysis of fair housing issues and expansion and strengthening of the policies and programs intended to address fair housing needs. These changes are included in Appendices G through G-5, and new and modified fair housing programs are also included throughout the Housing Plan, Section 3 of the Housing Element.

Other changes include:

  • Programs committing to:
    • A new Rural South Coast Housing Study and Strategy
    • A comprehensively updated Farm Labor Housing Study and Strategy
    • An initial study of a Community Plan for Pescadero
    • A site-by-site assessment of the feasibility of developing farm labor housing in the County’s Coastal Zone
    • Encouraging the use of local labor and provide publicly-available labor resources
    • Creation of an ADU resource center to facilitate and incentivize the creation of accessory dwelling units
    • Various other expanded programs committing to the development of housing and housing assistance to various special needs populations, including farm laborers, the homeless, low-income seniors, large families, and female-headed households.
  • As noted above, various new, expanded, or clarified data and explanatory materials to provide additional information as requested by HCD, related to housing needs, housing constraints, the County’s current regulations and programs, and the effectiveness of the prior Housing Element.
  • More specific and aggressive goals, timelines, milestones, and outcomes for policies and programs throughout the Housing Plan.

Throughout the update process, the County has consulted with County partners, including community stakeholders, housing advocates, organized labor, and others, to ensure that the amendments are not only directly responsive to comments received from HCD, but also further the County’s policy goals, and meet identified housing needs.

The County has also been in communication with HCD, to ensure that the proposed changes are responsive to HCD’s comments, and are in compliance with state law.

Environmental Review

The County prepared an Initial Study and Negative Declaration for the Housing Element, as the California Environmental Quality Act requires. The Initial Study and Negative Declaration determined that, as a programmatic document that does not directly impact the environment absent subsequent implementation actions, adopting the Housing Element has no potential environmental impacts. Subsequent implementation of some programs in the Housing Element will require additional environmental review, which will take place as those programs are implemented. The Initial Study and Negative Declaration were circulated for public comment between May 3, 2023, and June 9, 2023. The current amendments to the Housing Element do not alter the scope or determination of the Initial Study and Negative Declaration, and no additional environmental assessment is required. The Initial Study and Negative Declaration will be considered by the Board of Supervisors concurrent with consideration of the adoption of the Housing Element. The current amendments to the Housing Element do not alter the scope or determination of the Initial Study and Negative Declaration, and no additional environmental assessment is required.

Previous Updates

HCD Comment Letter on the County’s Draft 2023-2031 Housing Element Submittal Now Available

The County has received the Department of Housing and Community Development’s review and comment letter for the draft updated Housing Element. The County is evaluating HCD’s comments and will determine appropriate amendments to the Housing Element to address the comments.

2023-2031 Housing Element Initial Study and Negative Declaration

The County has prepared an Initial Study, evaluating the potential environmental impacts of adoption of the draft 2023-2031 Housing Element, and a Notice of Intent to adopt a Negative Declaration, determining that adoption has no potential environmental impacts. The comment period for the Initial Study and Negative Declaration is May 3 through June 9, 2023. Comments must be submitted to Will Gibson by 5:00 PM on June 9, 2023.

Related Documents:

San Mateo County HCD Submittal Draft 2023-2031 Housing Element Now Available

San Mateo County has submitted its draft 2023-2031 Housing Element to the California Department of Housing and Community Development (HCD) for review.  HCD has 90 days in which to provide formal comments on the draft. After the HCD review, the Housing Element will be considered for adoption by the County Board of Supervisors. Please contact William Gibson with any questions or comments on the submitted draft, updated schedule and process, or other related matters.

Related Documents:

aerial view of neighborhood Housing-Element1.jpg Housing-Element2.jpg Housing-Element4.jpg

San Mateo County is updating the County’s Housing Element. The Housing Element is a required component of the County’s General Plan and must be updated every eight years. The updated Housing Element will include assessments of the County’s housing needs over the next eight years, policies and programs to address that need, and identification of available locations for housing development. View the County’s current Housing Element.

The County is currently drafting the updated 2022-2031 Housing Element and preparing it for public release. When the Housing Element draft is complete, it will be available here and will be posted for a minimum of 30 days for public review. There will be hearings on the draft Housing Element at the North Fair Oaks Community Council, Midcoast Community Council, and County Planning Commission, with dates to be scheduled.

Let's Talk Housing

Let's Talk Housing is a collaborative effort on the part of all San Mateo County jurisdictions to gather community input and feedback on housing needs and goals, to inform each jurisdiction's Housing Element Update. Learn more about this shared effort by visiting the County's Let's Talk Housing website 

Housing Element Update Outreach
 

Meetings, Workshops and Outreach

What We're Hearing

What is the Housing Element?

The Housing Element is a component of the County’s General Plan, which establishes the goals and policies for the future development of the unincorporated County. The Housing Element is a required component of the General Plan, mandated by State Law, and the Housing Element must be periodically updated, on a schedule established by State law.

The Housing Element is the primary document that assesses the County’s housing needs and establishes policies and programs to address those needs, for the next eight years, from 2023 to 2031.

The Housing Element must also demonstrate that the unincorporated County has sufficient developable or redevelopable sites to meet the County’s Regional Housing Needs Allocation, the amount of housing that the State of California and the regional Association of Bay Area Governments determines is needed over the next eight years. 

The County’s Housing Element only covers unincorporated portions of the County; each City within the County also has its own Housing Element, which must be updated on the same schedule. 

Once the Housing Element is updated, it must be reviewed by the County Planning Commission, adopted by the Board of Supervisors, and submitted to the California Department of Housing and Community Development for review and approval. 

More information on the requirements for the Housing Element, the update process, and other elements of State law are available on the HCD website.

What is the Regional Housing Needs Allocation (RHNA)?

The California Department of Housing and Community Development (HCD) determines the amount of housing needed for the Bay Area as a whole, over the eight years covered by the Housing Element. The Association of Bay Area Governments then allocates this total housing need among all the jurisdictions in the Bay Area, including each city and county. Each jurisdiction’s amount is its Regional Housing Need Allocation or RHNA. The total RHNA for each jurisdiction is also divided by income level, showing the amount of housing needed for various income categories. 

The RHNA process is described in more detail on HCD’s website, and the allocations for Bay Area jurisdictions are available on ABAG’s website, as well as a description of the process for creating the allocations, and other information on the RHNA process.

A key component of the County’s Housing Element will be an inventory of sites available for the development of housing at appropriate income levels, demonstrating that there is sufficiently available land to meet the County’s RHNA.

What is the Process for Updating the Housing Element?

The Housing Element update is in its early stages. The process will include information gathering and data collection on current housing conditions and housing needs, challenges, and barriers; analysis of available sites for housing development; public outreach, input, and engagement, including various public workshops and forums; creation and assessment of housing policies and programs; draft documents; Planning Commission review, Board of Supervisors approval, and ultimately submittal to the California Department of Housing and Community Development for review and approval. A proposed schedule and information on these steps will be posted here as the update proceeds.

Opportunities for Input

The Housing Update will be based on community input, and there will be a variety of opportunities to participate in public forums and hearings, and to provide direct input by other means. Input opportunities will be posted to this page as the update proceeds. To receive email updates, please sign up using the form on this page.