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Home My WebLink AboutSS6 - Updated Draft of the General Plan Housing Element Update (PA2017-141) - CorrespondenceSHOPOFF REALTY INVESTMENTS iransfofming Opportunity into Value July 12, 2021 Mr. James Campbell Deputy Community Development Director City of Newport Beach 100 Civic Center Drive Newport Beach, CA 92660 RE: General Plan Housing Element Update PA 2017-141 City Council Study Session - July 13, 2021 Item SS6 Dear Mr. Campbell: Received After Agenda Printed July 13, 2021 Item No. SS6 As it relates to the State's request for additional residential units in the City of Newport Beach, Shopoff Realty Investments would like to have the city include an additional 350 dwelling units as part of your allocation. These units are proposed to be in what is known as Phase II of Uptown- Parcels: 445-133-07 & 445-133-08. These units would be additive to those 1,244 residential units already approved in the General Plan for the Uptown. At this time, it is anticipated that a portion of the 350 units would be allocated as apartment units and a portion would be allocated as condominiums. Uptown can accommodate these units in that the Planned Community allows for additional density given the approved height(s). If you have any questions regarding this matter, please notify us as soon as possible as we realize this is a time sensitive matter. Sincerely, Brian G. Rupp Executive Vice President - Real Estate Shopoff Realty Investments, LP July 13, 2021 City of Newport Beach City Council 100 Civic Center Drive Newport Beach, CA 92660 RE: Comments to Initial Draft Housing Element and Amendments City of Newport Beach City Council: www.kennedycomniission.org 17701 Cowan Ave., Suite 200 Irvine, CA 92614 949 250 0909 Thank you for the opportunity to review and comment on the City of Newport's 2021-2029 initial draft Housing Element and subsequent changes. We are in the process of reviewing the draft amendments and are submitting this initial letter to provide public comments. The Kennedy Commission (the Commission) is a broad-based coalition of residents and community organizations that advocates for the production of homes affordable for families earning less than $27,000 annually in Orange County. Formed in 2001, the Commission has been successful in partnering and working with Orange County jurisdictions to create effective housing and land -use policies that has led to the new construction of homes affordable to lower income working families. We continue to request that the City focus on strategies and programs to ensure that affordable housing be prioritize in the 6th Cycle Housing Element. This is important since during the current 5th cycle planning period the City had a total Regional Housing Needs Assessment (RHNA) of five, one at very low-income, one at low-income, one at moderate and two at above moderate. To date, the City has approved two housing units at moderate and 1,744 at above moderate'. At very -low income the City has approved 92 units and five at low-income. Although the City had exceeded 5th Cycle targets for each income category, there is an unbalanced production of moderate and above moderate units. The number of moderate and above moderate units approved in the last seven years was 17 times more than those at low and very low income. The need for a strong inclusionary policy is necessary to address the disproportionate production of housing. Housing Policies to Increase Affordable Housing As the 5th Cycle Housing Element Annual Progress Report indicates, most opportunity sites have been developed in unbalanced way and mostly with above market rate housing. As the City reviews the proposed scenario to redistribute housing among the focus areas, we recommend the adoption of an Inclusionary Housing Ordinance to ensure the identified opportunity sites are truly feasible and effectively provide affordable housing in a balanced manner. We recommend that the ordinance be targeted to address a 15%-20% requirement of affordable housing production at extremely low, very low- and low-income categories. These are the categories that market rate development is not addressing in Newport Beach. The City will also have to consider No Net Loss when it identifies opportunity sites. It is crucial that affordable housing moves along with market -rate housing given the limited sites that are available. Considering the state's, No Net Loss requirements, if the sites 1 Newport Beach 2020 Housing Element Annual Progress Report, Table B Page 2 of 2 Kennedy Commission Comments — 7/13/21 Newport Beach Initial HE Draft and Amendments identified for affordable housing are developed for market -rate housing, the City will have to rezone new sites for the appropriate density.2 The sites identified for lower income categories are predominately identified based on default densities for lower income. The identified areas are all unique in opportunities and challenges. The City needs to identify affordable housing policies and programs that will facilitate and incorporate affordable housing at the extremely low, very low- and low-income categories on these sites. In addition, each focus area needs to be evaluated for realistic development capacity and opportunities. Affirmatively Furthering Fair Housing The City of Newport Beach has not provided an adequate analysis or recommendations on how the City will address contributing factors to Fair housing issues in the City. The following is required: • The preparation, adoption, and implementation of a housing element requires a diligent effort to include all economic segments of the community. • Assessment of Fair Housing in Newport Beach: Summary of Issues and Analysis of Patterns, Trends, and Disproportionate Housing Needs. • A summary of fair housing issues in the Newport Beach and an assessment of the jurisdiction's fair housing enforcement and outreach capacity. • An analysis and summary of fair housing issues utilizing available federal, state, and local data and knowledge. The analysis must include a variety of factors, such as trends and patterns within the locality and in comparison, to the broader region. • the analysis must address: Integration and segregation; Racially or ethnically concentrated areas of poverty; Disparities in access to opportunity, including for persons with disabilities. • Disproportionate housing needs (this may include things like overpayment, overcrowding, housing conditions disproportionately affecting protected classes), including displacement risk. • Identified sites serve the purpose of replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity. • Identification and Prioritization of Fair Housing Contributing Factors • Programs with a schedule of actions with timelines and specific commitment to have a "beneficial impact" within the planning period to achieve the goals and objectives of addressing contributing factors to Fair housing issues. We ask that the City prioritize the housing needs of large families of low, very low and extremely low-income, who encounter difficulties in finding decent, affordable housing during the development of its new Housing Element. As the City moves forward with the making changes to the draft Housing Element update, the Commission urges the city to support the development of affordable homes. The Commission has provided the following recommendations for the city to incorporate: 1. Adopt an Inclusionary Housing Ordinance with a 15-20% requirement of affordable housing production at extremely low, very -low and low-income categories. 2 Government Code § 65863 Kennedy Commission Comments 7/13/21 Newport Beach Initial HE Draft and Amendments Page 3 of 3 2. Prioritize affordable housing funding and programs to increase affordable housing options for families of low, exceptionally low and extremely low-income. 3. Identify city owned sites and prioritize these sites for the development of affordable housing in Newport Beach. 4. Ensure that development focus sites being identified and discussed in the initial drafts are realistic and available during the planning period. 5. Ensure opportunity sites are not simply up zoned or rezoned without including affordable housing policies that will capture the financial and land use incentives being given to property owners and market rate developers. Affordable Housing program is needed. 6. Affirmatively Furthering Fair Housing — The City of Newport Beach should provide an adequate analysis of how the city will Affirmatively Furthering Fair Housing. The Commission looks forward to partnering with the City of Newport Beach to create opportunities to increase affordable homes for lower income households in the city. If you have any questions, please free to contact me at (949) 250-0909 or cesarckkennedycommission.org. Sincerely, Cesar Covarrubias Executive Director