Questions Received and Staff Responses After Publishing the NC/PC Agenda Report

1. Does the City have alternative sites available to make up difference if the NC amendments are not approved?

- No, the City does not have any alternative sites that could replace the 19 affordable units that would be provided as a result of the NC amendments, which means that such a decision would result in a net loss of affordable units in violation of State Housing law.

2. Could you include the acreage for each of the lots noted in a table in the staff report – the 16 parcels in NC zone and 4 parcels in PC zone?

- A column showing acreage has been added to the table in the staff report below. Note that Attachment I to the staff report includes a map that shows the location of each parcel.

APN Owner Address Acreage NC Zone 1 299-071-02-00 NCTD N/A 4.44 2 299-100-50-00 City of Del Mar N/A 0.02 3 299-100-49-00 Marten, RT 2236 Jimmy Durante Blvd. 0.42 4 299-100-30-00 Matthews, Erin 2148 Jimmy Durante Blvd. 0.38 5 299-100-28-00 Read Family LLC 2126 Jimmy Durante Blvd. 0.51 6 299-100-29-00 Stonebreaker Trust 2132 Jimmy Durante Blvd. 0.51 7 299-100-27-00 Knorr, Donna Trust 2120 Jimmy Durante Blvd. 0.90 8 299-071-06-00 Bungalows LLC 2010 Jimmy Durante Blvd. 2.12 9 299-071-07-00 Westech Realty 2002 Jimmy Durante Blvd. 1.42 10 299-100-48-00 Watermark LP N/A 1.55 11 299-100-47-00 Watermark LP N/A 1.13 12 299-100-32-00 City of Del Mar N/A 0.04 13 299-100-33-00 NCTD N/A 0.68 14 299-100-34-00 2201 Del Mar LLC 2201 San Dieguito Drive 1.13 15 299-100-35-00 Scarab Group 2195 San Dieguito Drive 0.26 16 299-100-36-00 S.C. Edison N/A 0.23 PC

Zone 1 300-200-24-00 Newberry, Douglas 832 Camino del Mar 0.18 D.M. Building 0.56 2 300-222-31-00 853 Camino del Mar Group LLC 3 300-222-32-00 Ocean 8 View LLC 322 8th Street 0.26 4 300-222-33-00 Wuotan LLC 807 Camino del Mar 0.30

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3. Of the 16 NC parcels in the table above, could you provide a breakdown by acreage of “realistic” development potential for housing?

- The City will need to demonstrate to State HCD that the adequate sites it has identified to accommodate its required 5th Cycle very low/low units have realistic potential of future development. - Of the 16 parcels, staff has identified four parcels that would achieve the City’s requirement and have realistic potential of future housing in the next eight years. These parcels include 2002 Jimmy Durante Blvd, 2126 Jimmy Durante Blvd, 2148 Jimmy Durante Blvd, and 2236 Jimmy Durante Blvd. The two “Watermark” sites have not been included. - Acreage breakdown follows:

15.73 ac = 16 parcels totals - 5.41 ac = 4 parcels not developable due to constraints (2 NCTD lots at 4.44ac + 0.68 ac and 2 City of Del Mar lots at 0.02 ac + 0.04 ac) - 2.68 ac = 2 parcels identified as “Watermark” site - 2.12 ac = 1 parcel with recently renovated buildings at 2010 JDB not considered feasible to adding housing in the next 8 years - 2.8 ac = 4 parcels not considered feasible to adding housing in the next 8 years (2132 JDB at 0.51 ac, 2120 JDB at 0.90 ac, 2201 San Dieguito Dr at 1.13 ac, 2195 San Dieguito Dr at 0.26 ac) = 2.72 ac = 4 parcels considered to have realistic potential of future housing (2002 JDB at 1.42 ac, 2126 JDB at 0.51 ac, 2148 JDB at 0.38 ac, and 2236 JDB at 0.42 ac)

NC Parcels Acreage & Potential

Feasible (4 parcels), 2.72 ac or 17% Constrained (4 parcels), 5.41 ac or 34%

Not Feasible (4 parcels), 2.8 ac or 18%

Not Feasible (1 parcel), "Watermark", 2.12 ac or 14% 2.68 ac or 17%

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4. How many actual units are anticipated in the NC/PC zone if these amendments pass? Is it hundreds of units?

- Here is a table of the units anticipated to occur over the next 8 year cycle within the NC and PC zones as a result of the proposed allowance for housing. You can see that we are expected to get exactly what we need in terms of the 22 required affordable units for the 5th Cycle. Also, the combined total maximum for both zones is still less than the number of units within the existing Del Mar Woods multi-dwelling unit complex in the RM- South zone. There are only two projects that would be facilitated by the amendments that are expected to exceed 10 units. The rest will likely be 4-8 units total.

5. Would the amendments result in ‘20 units per lot’ because the density of the zone would be changed to allow 20 dwelling units per acre?

- No, the density standard is a ratio of the number of dwelling units compared to the size of a lot. One acre is equivalent to 43,560 square feet. The density of 20 du/ac is the minimum density that the State will recognize as a zoning action to create adequate sites.

- In the NC zone, there are only two property owners with lots that could support a project with new housing that would result in more than 10 units/lot.

- In the rest of the NC zone and Pc zone future housing development would be much smaller clusters of 4-8 units per lot, which would include a requirement for one of those units on each lot to be set-aside for rental to a household that meets the income criteria for low income, very low income, or extremely low income.

6. Would the amendments increase the allowable development intensity of the zone in conflict with the Del Mar Community Plan?

- No, the existing development standards of the NC and PC zones are not changing. Compliance with the existing height, floor area ratio, lot coverage, and setbacks will

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continue to be required. By comparison, the allowed occupancy of a commercial use is much higher than the occupancy of a dwelling unit the same size.

- Also, all future applications for housing development must comply with all applicable plan policies, development standards, and permit procedures.

7. Do we know how much FAR/lot coverage "headroom" there is in the NC and/or PC, i.e. how much new housing can be added without demo or remodel?

- 46 dwelling units total, including 11 affordable units on privately owned vacant parcels:

o Watermark parcels 2.3 acres (30 market rate/10 affordable)

o 2236 Jimmy Durante Blvd parcels 0.34 acres (5 market rate/1 affordable)

- In the PC Zone, all four parcels are already developed and would require redevelopment.

8. What is the maximum number of lots that could be created by subdivision under the current NC zone?

- Any proposed Subdivisions would require discretionary map approvals.

- The lot size development standards are the same for the NC zone and PC zone: minimum lot size is 6,000 square feet; and each lot must have at least 35 feet of street frontage, at least a width of 50 feet and at least a depth of 90 feet.

- This means that the existing lots in the NC zone could request discretionary approval to be subdivided. However, at the project level, analysis would occur to determine how the proposed subdivision would affect the developable area and whether the requested subdivision would be consistent with the Community Plan and zoning. Parcels constrained with environmentally sensitive resources (i.e. NCTD owned parcel) are less likely to be allowed to be subdivided. The two City owned parcels in the NC zone contain existing public sidewalks and could not be subdivided.

- Subdivisions will have affordable housing requirements imposed upon approval of the subdivision map (in lieu fee payment per lot created) and also when housing development is proposed (a set aside of affordable units on-site for each proposed development). Note that single dwelling unit development is not a permitted use in NC (proposed or existing).

9. At one dwelling unit (DU) per lot under current zoning allowances, what is the potential number of units that could be added to the NC and PC zone now?

- The current provision allows for one dwelling unit to be developed accessory to an existing permitted use on-site with parking required per the R2 zone. There are eight parcels in the NC zone with existing commercial uses that could develop a DU per this

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provision, so the potential number is 8 DUs max as an accessory residential use to existing commercial development.

- In the PC zone there is potential for 4 DUs max as units accessory to existing office development on-site (one on each of the four parcels).

10. Am I right that under the scenario above (at buildout with all DUs), we could end up with a significant number of dwelling units (DUs) (+ Accessory Dwelling Units); however, by obtaining one DU at a time under current zoning, none would be restricted to set aside affordable units?

- That is correct that none of the dwelling units allowed per the zone’s accessory provision of one dwelling unit per lot would be required to be affordable.

- The assumption of ending up with a significant number of dwelling units and accessory dwelling units is not correct. As mentioned above, only 8 accessory units could be yielded under the existing NC zone and only 4 under the current PC zone (based on existing development conditions). There is no allowance for “ADUs” on top of that.

- None of the units allowed as an accessory use to non-residential development could have “ADUs” developed in addition to the maximum one dwelling unit allowed as an accessory use.

11. By obtaining one DU at a time under current zoning, would units have to pay an in-lieu fee?

- None of the DUs allowed by current zoning would be subject to an in-lieu fee or any other affordable requirement.

12. The EIR analyzes the maximum buildout in the NC zone, but what is the estimated “realistic” max buildout in the NC zone?

- A total of 89 dwelling units is projected in the NC Zone (including 19 affordable units)

- Up to 46 units on three developable vacant properties:

o Watermark two parcels on 2.3 acres (40 units: 30 market rate, 10 affordable)

o 2236 Jimmy Durante Blvd. 0.34 acres owned by Terry Marten (6 units: 5 market rate, 1 affordable)

- Up to 43 units on three properties where office development is likely to be converted:

o 2126 Jimmy Durante Blvd. 0.50 acres owned by Read LLC (9 units: 8 market rate, 1 affordable)

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o 2002 Jimmy Durante Blvd. 1.38 acres owned by Westech Realty (28 units: 22 market rate, 6 affordable)

o 2148 Jimmy Durante Blvd. 0.34 acres owned by Erin Matthews (6 units: 5 market rate, 1 affordable)

13. If the proposed Community Plan amendment(s) do not pass by super-majority vote, can the Council still consider passing the LCP amendments by simply majority vote?

- A vote to not pass the one or both of the necessary Community Plan amendments will trigger a net loss of adequate sites required for compliance with State Housing law that will negate the requested actions as a whole. Council would not be able to act on the corollary amendments to the LCP.

14. Are the proposed NC/PC Community Plan amendments inconsistent with the City’s Sea Level Rise (SLR) Adaptation Plan that was put in the Community Plan? Would the adoption of the NC/PC amendments render the Community Plan internally inconsistent? Are the NC/PC amendments consistent with the SLR provisions of the Community Plan?

- There is no conflict between the proposed NC/PC amendments and the City’s adopted Adaptation Plan or implementing ordinances relating to sea level rise.

- The City’s Vulnerability and Risk Assessment analyzed projected impacts of sea level rise through year 2100, and concluded the PC Zone has zero risk of sea level rise, flooding, or bluff erosion impacts; and that portions of certain properties in the NC zone have some risk of flooding due to projected sea level rise, but the flood risk is relatively low and affects the same properties already mapped in FEMA flood zones related to San Dieguito Lagoon/River flooding.

- The City’s Floodplain Overlay Zone will continue to effectively regulate and control all future development in flood prone areas of the NC zone – consistent with the Community Plan. All new development in the Floodplain must comply.

- The adopted Sea Level Rise Adaptation Plan (AP) is a plan with policies and strategies to address projected bluff erosion, flooding, and sea level rise. The AP is incorporated by reference in the City’s Community Plan. The priority strategies identified were beach nourishment, more frequent dredging of sand trapped in the Lagoon, better sand management, and a desire to explore the concept of a living levee along the river banks (west of the NC zone). There is no conflict between the City’s priority SLR strategies and the proposed amendments to allow housing as a primary use or mixed use in NC.

- The City also prepared a Lagoon Wetland Habitat Migration Assessment (informational technical document). The Assessment identifies that if increasingly high sea level rise occurs, the City can expect to see a change in the San Dieguito Lagoon’s wetland habitat as it experiences an increase in saltwater intrusion and converts from freshwater habitat

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to more open water and mudflats. The report did not impose any limit on future development to address the projected changes in Lagoon habitat types.

- It would be incorrect to assume that the AP could have established a new limit on future development in proximity to the Lagoon as that was not a part of any action taken by the City Council in October 2018. In fact, the opposite occurred because managed retreat was resoundingly rejected by the City Council. Note that California Coastal Commission staff has been actively working with the owner of the proposed Watermark project site to identify the developable portion of their parcels - outside of the existing Environmentally Sensitive Habitat Areas (ESHA) – as part of their review of the Draft EIR circulated for the Watermark Specific Plan (currently NC Zone). CCC staff has not tried to reduce development area based on projected habitat migration due to SLR.

15. How much money have we spent on consultants (since 2014) on the issue of affordable housing (does not have to be an exact amount but an approximate of what part of our budget goes to the affordable housing issue)?

- To clarify, staff can give a ballpark on what has been budgeted for “Housing” since 2014, but we won’t be able to parse out how much was attributed toward “affordable” housing. But it is generally all related as it is the affordable housing component that the State is targeting and, hence, most of the Housing policy work the City needs to complete.

- Five efforts come to mind that Council has budgeted for in past/current FYs. Totals approximately $717,500. Here’s the run-down: o $98,000 for 22 in 5 Affordable Housing Report – This was LeSar on policy and Keyser-Marsten on economic analysis o $50,000 for In-Lieu Housing Mitigation Fee Update and Nexus Study o $4,500 for Adam Birnbaum preparation of Implementation items for 5th Cycle o $150,000 for Implementation of 5th Cycle NC/PC Amendments – CEQA consultant – Adam Birnbaum also charged City for work on implementation tasks o $415,000 for Production of 6th Cycle Housing Element – CEQA consultant and Housing consultant

16. Approximately how much money have we received in grants to help us pay for this effort (over last six years since 2014 when we got the housing plan certified)?

- $143,000 from SB2 grant 2019 (note that only $13,000 reimburses a portion of the $150,000 NC/PC amendment cost; the remaining amount cover the side projects Council has not budgeted for – preparation of ADU floor plans, and design/entitle future affordable housing project)

- $65,000 from LEAP grant 2020 (reimburses $65,000 portion of $415,000 6th Cycle cost)

17. In a table in the staff report, why are the Watermark, NCTD, and the City parcels marked with an “N/A”?

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- The table published in the staff report is correct that Watermark Limited Partnership (Watermark LP) is the owner of the two vacant parcels that are referred to as “Watermark”, as is NCTD and the City for the parcels identified by APN. The “N/A” simply refers to these parcels not having a corresponding street address. Staff relies upon the APN to identify each parcel in this case.

18. How many responses did we get on the EIR?

- 22 comment letters were received as described and responded to in the Final NC/PC Program EIR. Here’s the list: 1) Don Glatthorn and Property Owners; 2) Don Countryman; 3) Brad Walters; 4) Joseph and Nancy Weiss; 5) Josh Rubin; 6) Gwynn Thomas; 7) Wade Walker; 8) Matt Weis; 9) Augustus Wiesel; 10) Annette Wiesel; 11) Tracy Martinez and Dr. Alan Wittgrove; 12) Karla and Bill Leopold; 13) Neal Gobar; 14) Delano & Delano (on behalf of Del Mar Highlands Community Association; 15) Jonathan and Patricia Polikoff; 16) Elizabeth Wohlford; 17) Burnet Wohlford; 18) Lucy Eskeland; 19) Ruth Evans; 20) Mary Welsh; 21) Arnold Wiesel and family; 22) Laura DeMarco.

- Their letters are part of the Program EIR but can also be viewed here: http://www.delmar.ca.us/DocumentCenter/View/6443/NCPC-Draft-PEIR---Comment- Letters

19. Can you clarify the City Council timeframe that led up to its adoption of the 5th Cycle Housing Element?

- 3/26/2011: City Council discussed the planned Housing Element as Council Priority Project requiring funding - 4/11/2011: SANDAG Housing Needs Assessment Allocation Presented to City Council - 11/7/2011: Housing Element Consulting Contract approved for Veronica Tam - During 2012, meetings were conducted with a Council-appointed Housing Element Advisory Committee - 10/8/2012: Draft Housing Element presented to City Council - 1/14/2013: City Council received the draft Housing Element and directed staff to submit to State HCD for preliminary review - 5/20/2013: City Council adopted Resolutions 2013-27 and 2013-28 incorporating the Housing Element into the Community Plan; and certifying the Mitigated Negative Declaration

20. Who was on City Council in May 2013 when the 5th Cycle Housing Element was adopted in the Community Plan? What was the vote?

- The 5th Cycle Housing Element was adopted on May 20, 2013 by Resolution No. 2013- 27 in a 5-0 vote by Mayor Terry Sinnott, Deputy Mayor Lee Haydu, and Councilmembers Al Corti, Don Mosier, and Sherryl Parks

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21. Who served on the Council-appointed Housing Element Advisory Committee for the 5th Cycle? Who were the Council liaisons?

- The advisory committee appointed for the 5th Cycle included four members, three of which represented various groups with one community member at-large: o Robin Nordhoff, representative, Planning Commission o Bud Emerson, representative, Del Mar Housing Corporation o Nate McCay, representative, Del Mar Community Connections o Barbara Stegman, citizen at-large - Council liaisons: o Don Mosier o Lee Haydu

22. Will this zoning change encourage owners of the property to actually build that housing?

- The NC/PC amendments create the opportunity for owners to develop housing simply by making it an allowed use in these zones. The market is currently showing a strong demand for housing, which should provide the encouragement. In the meantime, they can’t develop housing in NC and PC zones until we get our amendments processed.

23. Many of the owners down there were asking for increased allowable FAR, increase lot coverage for mixes use and then money around with the flood plain elevations.

- As part of a proposed housing program with the 6th Cycle Housing Element Update, the City will be monitoring to see if any further zone modifications are needed to facilitate the development of affordable housing. If we don’t see any housing applications, we may need to explore and address potential incentives that may include flexibility with some of the development standards.

- State law already provides some relief for owners by way of the Density Bonus law. Once housing is an allowed use in the zones, an owner can request approval of a project that provides a greater number of affordable units than would otherwise be required by the City’s code. This is type of strategy is relevant to projects with at least 5 units.

24. The conditional use permit (CUP) required in the NC/PC zones, what does that mean or cover exactly?

- There is no CUP requirement in the PC zone. In the NC zone, a CUP is required on properties that are located in the Lagoon Overlay Zone and/or the Bluff, Slope, and Canyon Overlay Zone. For example, development on the Watermark properties is subject to a CUP requirement because it is located in both of these overlay zones. This permit requirement becomes moot where a project is processed pursuant to Density Bonus law (because the City is not able to require any discretionary permits).

25. On a different note, how many Accessory Dwelling Unit (ADU) applications or buildings have been constructed in the David Way and San Dieguito neighborhoods?

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- None have been applied for on David Way. Two have been applied for on San Dieguito, but they have not been constructed yet.

26. How many total ADUs have been applied for? Are they all over town or just in the hill area?

- ADUs are allowed in any zone that allows residential as a primary use. This means they are allowed in all residential zones, the RC zone, and would be allowed in the NC zone and PC zone if the amendments are passed.

- It is a key part of the City’s overall housing strategy to encourage ADU’s citywide, particularly those that are deed restricted as affordable ADU’s. Otherwise, the City is able to count the ADUs as moderate income units towards our RHNA.

- To date, we have 27 ADU applications (23 from 2020). In terms of the distribution across the City: o North Hills has 19 applications: . 4 on Avenida Primavera . 4 on Kalamath . 3 on 15th Street . 2 on San Dieguito . 1 each on Bellaire, Luzon, Carolina, Amphitheatre, Hoska, La Amatista o North Beach has 5 applications: . 2 on Camino del Mar . 1 each on 27th Street, Sandy Lane, and Ocean Front o South Beach has 2 applications: . 2 on Stratford Court o South Hills has 1 application: . 1 on Pine Needles

27. How many residential units, ADUs and Junior ADUs could be built in the NC zone without changing to 20 units per acre?

- There are 16 parcels in NC zone, of which 4 are undevelopable (2 NCTD and 2 City of Del Mar). Take out the two vacant Watermark sites, and 10 lots remain. Each lot is allowed one unit accessory to a primary commercial use (these units are not ADUs as defined by State law, meaning, they do not get the streamlining provisions and exemptions as ADUs do, and are subject to all development standards including FAR, etc).

- Under current zoning, ADUs and JrADUs are not a feasible strategy currently in NC or PC because neither are allowed. JrADUs are only allowed inside a single dwelling unit (so are not allowed in these zones - See Govt Code 65852.22). ADUs are not currently allowed these zones because residential is not an allowed primary use.

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28. If a developer were to build 20 units per acre in the NC zone, how many square feet would each unit be if the lot coverage, FAR and height limitation is not changed?

- Unfortunately, this question does not have a straight forward answer. This is because every project will be different, site constraints will need to be considered, common area sf is unknown, and projecting the potential development profile includes more than calculating lot size x FAR / # of units. That said, here’s a very general sketch of potential. . By using the simple formula just noted, this is what the current development regulations would allow. With an FAR of 30%, a lot that was exactly 1 acre in size (43,560 sf) would have a buildable FAR of 13,068 sf. That would mean that each unit, assuming 20 dwelling units on the acre, would have a maximum FAR of 653 sf. It is also reasonable to assume there would be a mix of units in terms of number of bedrooms/size. Per our regulations, this sample development would have to set aside 20% of the 20 units as affordable. The four units that will be set aside as affordable will most likely be studio size apartments/condos. Assuming these are 400 sf studios, they would total 1,600 sf (4x400sf), which would leave a little over 716 sf per unit for the remaining 16. But again, this does not account for other factors that could impact unit sf, such as site constraints and building code requirements, nor accounts for other space that could also dip into the site’s FAR (e.g., common area sf, etc).

29. Can ADUs be larger than the “main house?”

- In residential zones, ADUs are allowed to their maximum size regardless of the main house. Specific to NC/PC, in terms of size, the detached ADU type that would be allowed accessory to a multi dwelling complex in the future would be limited to 1,200 square feet. The ADUs would be accessory to the complex as a whole and not to an individual unit. This is all per State law govt code 65852.2.

30. If North Commercial is rezoned to Residential/Commercial and there is no density change, how many residential units, ADUs and Junior ADUs could be theoretically be built?

- The question asks for the theoretical number of units that could be allowed should the NC zone be rezoned to the City’s Residential-Commercial (RC) zoning designation (DMMC Ch. 30.20). RC is a specific type of transition zone between the City’s CC zone (Central Commercial) and R2 zone (High Density Mixed Residential). The rezone action would constitute a change in density. Allowable uses in the RC zone are those within the CC and R2 zones, respectively. Should the NC zone be rezoned to RC, for residential there would only be two types of residential uses allowed – single dwelling unit, or duplex. Therefore, theoretically an RC rezone could net a maximum of two primary units and two ADUs per lot (four units maximum per lot) where developed as either one single dwelling unit with an ADU (inside the home, attached or detached) , or one duplex per lot with two ADUs (one per each primary unit inside the home, attached, or detached). JrADUs are only permitted in single dwelling unit zones and would not be permitted in the RC zone. Also, it is important to note that none of these units would be required to be affordable units for lower income households that would count towards the City’s RHNA obligation.

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- Of the 16 parcels comprising the current NC zone, there are three vacant parcels that could potentially be developed including the two Watermark properties and 2236 Jimmy Durante Boulevard. If developed with single dwelling units, there could potentially be up to 6 residential units per lot (3 homes and 3 ADUs). If developed with duplexes, there could be up to 12 residential units (6 homes within 3 duplexes and 6 ADUs). The remaining NC parcels are either undevelopable due to existing environmental constraints or infrastructure constraints (two City parcels, two NCTD parcels, and one Southern California Edison parcel), or are already built-out with commercial structures that would be rendered non-conforming. A tear-down/rebuild of existing developed sites for a single-family home or duplex does not appear realistic.

- Note that the “clustered dwelling units” use would not be permissible if the NC zone were rezoned to RC due to specific limitations in the RC zoning allowance. As such, the RC zone’s maximum density of 12.5 dwelling units/acre (du/ac) would not be possible under this rezone scenario. However, hypothetically, assume it was. A rezone to a density less than 20 du/ac (e.g., 12.5 du/ac per the RC) would pose several issues. Most notable, it would not meet the State’s mandate for adequate sites that can produce affordable housing, which requires the City have a zone or zones that allow at least 20 du/ac. In this case for the 5th cycle, the zones with 20 du/ac must be able to accommodate at least 22 affordable units and must have vacant land of sufficient size to produce at least half of the affordable units. The RC zone does not meet this criteria for a minimum density of 20 du/ac and as noted above would not produce any affordable units, which is the purpose of the NC zone amendment that is required by the City’s Housing Element.

- On a side, NC is the only zone in the City that allows for heavy commercial/light industrial and emergency shelter uses. The City has to have a zone that accommodates these uses per State law. Since RC is limited to the uses in the CC zone, a rezone to RC would not permit certain types of uses that are currently only allowed within the current NC zoning. It is also unlikely that such a rezone would be certified by the Coastal Commission due to the conflict it would present with the Coastal Act and City’s LCP by allowing for low density residential to replace commercial uses in a commercial zone.

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