State Requires Revisions to Pasadena’s General Plan Draft Housing Element, Asks City to Address Public Comments

The California Department of Housing and Community Development (HCD) is seeking more revisions to the general plan draft housing element submitted by the city.

In a letter addressed to the Planning and Community Development Department dated Oct. 11, state Senior Program Manager Paul McDougall said revisions to the draft are needed so it would comply with the state’s Housing Element Law.

Last August, the City Council approved its draft housing element, without seriously considering local residents’ calls for the inclusion of several elements.

The approval was made pursuant to state’s order for cities to update their housing elements and adjust their zoning laws to allow the construction of at least 9,400 additional housing units over the next eight years, in response to Californika’s affordable housing crisis.

In the letter, McDougall stressed the importance of public participation in effective housing planning. He noted that while the element includes a summary of public comments, it did not describe how they were considered and incorporated into the element.

“By not providing an opportunity for the public to review and comment on a draft of the element in advance of submission, the City has not yet complied with statutory mandates to make a diligent effort to encourage the public participation in the development of the element and it reduces HCD’s ability to consider public comments in its review,” wrote McDougall.

The official said the availability of the document to the public and opportunity for the public to comment prior to submission to HCD is “essential” to the public process and HCD’s review.

According to McDougall, the public comments received by HDC were “meaningful” and “valuable.”

He noted that these comments ranged from a variety of topics including the protection and preservation of affordable housing, prioritization of affordable housing, the lack of rezoning for housing on religious institutions sites, the lack of sites for moderate-income households, and lack of analysis and zoning to address the needs of people experiencing homelessness, among others.

“The element includes no discussion of how these comments were considered or incorporated in the element. In future versions of the element, HCD strongly encourages the City to consider and address these comments, including revising the document as appropriate,” McDougall wrote.

Further in his letter, McDougall said the element “must evaluate the effectiveness of prior programs and appropriately adjust goals, objectives, policies, and programs.”

The housing element, he said, must also provide an evaluation of the effectiveness of goals and actions in meeting the housing needs of the special needs population including the elderly, persons with disabilities, and persons experiencing homelessness, among others.

While the element includes a general description and identifies the projected number of extremely low income households, the official said it must still analyze their existing housing needs.

“The element should analyze tenure, cost burden, overcrowding and other household characteristics then examine trends and the availability of resources to determine the magnitude of gaps in housing needs.”

McDougall said the housing element must include analysis of potential environmental constraints. It must also demonstrate the existing or planned water, sewer and dry utilities capacity to accommodate the regional housing need allocation in the planning period.

The city was given until Oct. 15, 2021 to adopt a housing element.

According to the letter, if the city fails to do this within 120 days after Oct. 15 “any rezoning to accommodate the regional housing needs allocation, including for lower-income households, shall be completed no later than one year from the statutory deadline.”