The state Housing and Community Development (HCD) agency has assigned a reviewer
for the Palo Alto draft Housing Element (HE). The reviewer has until the end of March to submit a review letter.
Council approved a draft HE in mid November 2022, which triggered a 30 day public comment period after which staff had 10 days to respond. Staff forwarded the draft HE to HCD at the end of the year including a summary of public comments and their response.
Prior to the November approval by council of the draft HE, staff worked with council, the PTC and the Housing Element Working Group during 2022. Some potential sites were removed during the year and others added. Staff continually worked to identify constraints and develop programs to address the RHNA and HE goals.
I do not know what the HCD review letter will say but HCD letters to other cities regularly have asked for more and detailed economic feasibility information with regard to sites, more specificity in delineating programs and generally have expressed concerns about the commitment to being proactive with respect to fair housing goals.
I expect Palo Alto could receive similar comments.
The review letter will begin a process of back and forth with HCD and the staff and with the staff, PTC, council and the public. According to what I know from other jurisdictions and from our Planning Director, that will probably take more than one round over several months. Right now meetings are planned through June with the PTC and council, which would be the earliest to submit a compliant HE.
Whether or not our HE is compliant is determined by HCD not by me or staff or posters on the Weekly online or our council.
I believe HCD and our staff have a good relationship and that HCD wants to work collaboratively to get a compliant HE and avoid serious penalties and possible lawsuits.
