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HomeMy WebLinkAbout08-02-2023_Open Session_Item 16_ACLU Foundation_links sanitizedINLAND EMPIRE OFFICE • 3400 CENTRAL AVE, SUITE 230 • RIVERSIDE, CA 92506 • T 909.380.7510 • F 951.534.0453 • ACLUSOCAL.ORG August 1, 2023 Mayor and City Council City of San Bernardino Via email: publiccomments@sbcity.org RE: Public Comment on Agenda Item #16, 2021-2029 Draft Housing Element Dear Mayor and City Councilmembers: Please find attached for your consideration our public comment on the City of San Bernardino’s 2021-29 Draft Housing Element, which was previously submitted as a comment to you, to futuresb2050@sbcity.org and to the Planning Commission. Consistent with Council’s action at the April 5, 2023 City Council meeting, during which you voted to move forward with repeal of the Crime Free Multi Housing Ordinance, we ask you to take the following actions at tomorrow’s City Council Meeting: 1. Provide direction to staff to revise the 2021-29 Draft Housing Element in order to eliminate Program 3.2, the Crime Free Multi-Housing Program, and to remove the sections of the Draft Housing Element that make inaccurate statements about that program; 2. Authorize, by motion, staff to make changes to the 2021-29 Draft Housing Element based on Council’s directions to remove Program 3.2, the Crime Free Multi-Housing Program and sections of the Draft Housing Element that make inaccurate statements about that program, and in light of the issues raised in the attached public comment letter. 3. Authorize, by motion, the Community, Housing, and Economic Development Department to submit the revised document to the State Department of Housing and Community Development (HCD) for review only after making the changes urged here and in the attached comment letter. Sincerely, Adrienna Wong Sr. Staff Attorney Mayor Helen Tran and City Councilmembers 290 North D Street San Bernardino, CA 92401 mayor@sbcity.org council@sbcity.org Sonia R. Carvalho, City Attorney 290 North D Street Third Floor San Bernardino, CA 92401 Attorney@SBCity.org Charles McNeely, City Manager 290 North D Street San Bernardino, CA 92401 McNeely ch@sbcity.org Via Email: FutureSB2050@sbcity.org Re: Comments on City of San Bernardino’s Draft 2021-2029 Housing Element Dear Mayor Tran and City Councilmembers, We write on behalf of the ACLU of Southern California to provide public comment on the City of San Bernardino (“City”) Draft 2021-2029 Housing Element (“Housing Element”). Specifically, we write to correct certain factual and legal misstatements in the draft Housing Element regarding: (1) the Crime Free Multi-Housing (“CFMH”) Program and the City’s compliance with fair housing laws (see pages 1-7, below), and (2) the City’s plans concerning homeless services and enforcement of its anti-camping ordinance (see pages 7-9, below). Given the serious consequences that the CFMH Program and failure to adhere to Housing First best practices approaches will cause to our members and the communities we serve, we call on the City to terminate the CFMH Program and to amend its Homeless Services and anti-camping enforcement plans outlined in the draft Housing Element. I.THE DRAFT HOUSING ELEMENT SHOULD BE REVISED TO ELIMINATE PROGRAM 3.2 – CRIME FREE MULTI-HOUSING PROGRAM The draft Housing Element states that the City’s CFMH Program will be continued in the Housing Element. The sections of the draft Housing Element describing the CFMH Program contain multiple inaccuracies and conflict with the City’s Fair Housing Assessment. Further, the draft Housing Element proposes that the City increase the resources it dedicates to staffing the CFMH Program; these are public resources that could be more appropriately invested in housing Page 2 AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF SOUTHERN CALIFORNIA instead, especially given that the draft Housing Element fails to propose sufficient housing to meet the needs of unhoused residents of the City (as discussed further below). For all the reasons discussed below, the draft Housing Element should be revised to eliminate the CFMH Program. A. The Draft Housing Element Misstates How The CFMH Program Operates The draft Housing Element makes multiple claims about the City’s CFMH Program that are simply false. The draft Housing Element must be revised to remove these factually inaccurate statements so that the City does not provide false information to the California Department of Housing and Community Development and to the people of San Bernardino. First, the draft Housing Element inaccurately claims: “In implementing the crime-free lease agreement, neither the City nor the Sheriff’s Department is involved in any way in a landlord's decision on whether or not to exercise the rights under the addendum.” However, the reality is that City Code Enforcement encourages law enforcement officers to complete “Crime Free Housing Referrals/Complaints” when “dealing with a tenant causing issues or [who are] not cooperative with law enforcement efforts,” which Code Enforcement then “handles” with landlords. See Attachment A. Additionally, as a condition of certification as a “Crime Free property,” the City requires landlords to “actively pursue the eviction of tenants who violate the terms of the lease and/or crime-free lease addendum.”1 Second, the draft Housing Element incorrectly claims, “Nothing in the City’s program sanctions or in any way condones any actions by a landlord that would violate any law related to fair housing or anti-discrimination, and the requirement applies equally to all tenants regardless of income or other household status.” However, the program only applies to tenants of multi-family rental properties, not tenants of single-family homes, which means it will likely be applied more often to lower-income and minority tenants.2 Moreover, the City’s “Crime-Free Multi-Housing Referral Card” indicates that the program encourages violations of state fair housing law, in that it not only ties potential housing consequences to “arrest information” but also specifically tracks whether the tenant identified is in Section 8 housing.3 See Attachment B. And the CFMH ordinance states that certification as a “Crime Free property” may be revoked “if there are 10 or more calls for service in a one-year period" associated with a property.4 By punishing landlords for calls for service originating from their properties, the CFMH ordinance violates the Right to a Safe Home Act, Cal. Gov. Code sec. 53165(b). Further, the draft Housing Element self-contradictorily states “that neither the City's ordinance, nor the training program nor the City or Sheriff’s Department encourages or discourages property owners to conduct criminal background checks of tenants, although the potential benefits of doing so are discussed in the training.” By admitting that the CFMH Program training focuses on the benefits of criminal background checks, the draft Housing Element also admits that the program effectively encourages such background checks. Our review of the CFMH 1 San Bernardino Municipal Code sec. 15.27.060(a)(1)(d). 2 See Draft Housing Element at p. 5-7 (noting that affordable apartment properties and rent-stabilized mobile home parks are concentrated in an area of City with much higher prevalence of minorities than the rest of the County). 3 2 CCR § 12269(a)(1); 2 CCR § 12141. 4 San Bernardino Municipal Code sec. 15.27.060(b). Page 3 AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF SOUTHERN CALIFORNIA program training has confirmed that it encourages use of criminal history information to deny or encourage self-screening in housing applications, without providing adequate guidance on how such practices may violate fair housing laws.5 Indeed, the sample rental application provided as part of that training both describes its purpose as enabling the landlord to “accept potential residents who . . . do not have a criminal background” and specifically states that information about participation in a deferred entry of judgment program is considered as part of the rental application process, in violation of state housing regulations.6 B. Continuing The CFMH Program Conflicts With City Council Intent And Community Input The draft Housing Element states that the CFMH Program is in effect per the current municipal code. However, at the April 5, 2023 City Council meeting, the Council voted to agendize a motion to repeal the Crime Free Multi Housing ordinance, at the urging of community members giving public comment at that meeting, and in recognition of multiple lawsuits and federal enforcement actions in the region challenging similar ordinances.7 No such motion has been considered yet at any City Council meeting since. The CFMH Program should be removed from the Housing Element given this pending repeal process. C. The CFMH Program Conflicts With The Draft Housing Element’s Fair Housing Assessment And With Fair Housing Laws The draft Housing Element claims that the City complies with fair housing law and is committed to affirmatively furthering fair housing. However, it is well-established that nuisance and crime- free housing programs like the City’s CFMH Program conflict with state and federal fair housing laws.8 Indeed, the City has already been sued for the CFMH Program’s violations of the Fair Housing Act and the Violence Against Women Act. See Gracia v. City of San Bernardino, Case No. CIV SB 2301828 (filed Feb. 10, 2023).9 And the draft Housing Element itself notes that the California Department of Housing and Community and federal agencies have raised concern that the CFMH Program’s crime free lease agreement may violate CCR § 12264 and have a disparate impact on Latinos, African Americans, and other minorities. 5 See, e.g., 2 CCR § 12269(a)(3)-(5), (b); see also U.S. Dep’t of Housing & Urban Dev., Office of General Counsel Guidance on Application of Fair Housing Act Standards to the Use of Criminal Records by Providers of Housing and Real Estate-Related Transactions (Apr. 4, 2016), https://www.hud.gov/sites/documents/HUD_OGCGUIDAPPFHASTANDCR.PDF. 6 2 CCR § 12269(a)(2). 7 See Regular Meeting of the Mayor and City Council 4-05-2023, https://www.youtube.com/watch?v=N_XtKunQkXM&t=9566s, at 2:39:34. 8 See Letter for Attorney General Rob Bonta to All Cities & Counties, Re: Crime-Free Housing Policies (“AG Letter”) (Apr. 21, 2023), https://oag.ca.gov/system/files/attachments/press- docs/Crime%20Free%20Housing%20Guidance 4.21.23.pdf; Office of General Counsel Guidance on Application of Fair Housing Act Standards to the Enforcement of Local Nuisance and Crime-Free Housing Ordinances Against Victims of Domestic Violence, Other Crime Victims, and Others Who Require Police or Emergency Services (Sept. 13, 2016), https://www.hud.gov/sites/documents/FINALNUISANCEORDGDNCE.PDF. 9 The draft Housing Element omits any discussion of this litigation in its section on “Findings, Lawsuits, Enforcement Actions, Settlements, or Judgments.” Page 4 AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF SOUTHERN CALIFORNIA The draft Housing Element acknowledges that the lease addendum likely violates state and federal fair housing law – yet it proposes continuing the current program even though the proposed timeline for updating the lease addendum is not until the end of 2024.10 For this reason alone – that it proposes continuation of an admittedly illegal program – the draft Housing Element must be revised to provide for termination of the CFMH Program. Further, the draft Housing Element incorrectly suggests that by revising the lease addendum alone, the City can bring the CFMH Program into compliance with fair housing laws. But the content of the lease addendum is, in part, specified in the municipal code.11 Accordingly, the CFMH ordinance must also be substantially amended or repealed. Further, the Attorney General’s guidance on Crime-Free Housing Policies and the corresponding state fair housing regulations make clear that it is not merely lease addenda and eviction requirements, but also Crime-Free Housing “ordinances, programs, and training materials” that may raise conflict with fair housing law.12 The Attorney’s General guidance specifically identifies several Crime-Free Housing practices as potentially running afoul of fair housing laws.13 The City’s CFMH Program includes each of those identified problematic practices as set forth below: Practice Identified by AG Guidance San Bernardino CFMH Program Practice “Using dehumanizing, derogatory, or racially charged or coded language in . . . training materials, manuals, and workbooks on Crime- Free Housing Policies” CFMH training refers to “criminals” as a “two-legged urban breed of predator” (emphasis added), compares “criminals” to “weeds” and a dinosaur that must be killed in the egg. “Instructing or encouraging property owners to adopt screening practices or rental policies under which landlords broadly deny tenancy to applicants with a criminal history or encourage tenants to ‘screen themselves’” Draft Housing Element states that CFMH Program training highlights benefits of conducting criminal background checks. CFMH Program training states that it is not illegal to deny housing on the basis of criminal history. States that if an applicant is made aware of screening criteria, especially a thorough check of criminal history, they are less likely to apply (“self refusal”). Example of housing application provided in CFMH training states: “RENTAL POLICIES ARE GUIDELINES, WHICH ENABLE US TO ACCEPT AS PROSPECTIVE RESIDENTS THOSE INDIVIDUALS WHO . . . DO NOT 10 See City of San Bernardino draft 2021-2029 Housing Element (May 2023) (“Draft Housing Element”) at p. 7-31. 11 See San Bernardino Municipal Code sec. 15.27.050(C). 12 AG Letter at p. 4. 13 Id. at p. 7. Page 5 AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF SOUTHERN CALIFORNIA HAVE A CRIMINAL BACKGROUND.” Example of housing application states that information about participation in a deferred entry of judgment program will be considered. “[I]nducing landlords to evict tenants based solely on arrests or other interactions with law enforcement” “Taking adverse actions against tenants who seek law enforcement assistance, or discouraging tenants from seeking such assistance” Code Enforcement in cooperation with police issues “Crime Free Housing Referrals/Complaints” for law enforcement interactions with tenants, including tenants “not cooperati[ng] with law enforcement efforts.” CFMH Referral Card specifically documents “arrest information.” CFMH Ordinance threatens termination of Crime-Free Property certification based solely on calls for service, incentivizing landlords to impose housing consequences on tenants responsible for such calls. Moreover, the CFMH Program is essentially discriminatory, because it ascribes criminality to tenants of multi-unit housing that the City does not attribute to homeowners and residents of single-family homes. This is blatant economic and racial discrimination.14 Data shows Black and Latine residents of San Bernardino are more likely to be renters and are less likely to become homeowners than White residents.15 The discriminatory stereotyping and disparate impact inherent in this program are made further evident by the City’s suggestion that it may expand the program to cover mobile homes – but no other types of homes.16 Because the CFMH Program is an impediment to fair housing for all the reasons stated above, it should be removed from San Bernardino’s draft Housing Element. D. The Draft Housing Element Makes Unsupported And Inaccurate Claims About The CFMH Program’s Deterrence Of Crime The draft Housing Element states, without any evidentiary support, that the CFMH Program has been an effective deterrent for crime. Studies show that Crime-Free Rental Housing programs do 14 See supra n. 2. 15 See Race Counts - San Bernardino, https://www.racecounts.org/county/san-bernardino/ (citing US DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT (HUD), COMPREHENSIVE HOUSING AFFORDABILITY STRATEGY (CHAS) (2014-2018)); San Bernardino County, Housing Affordability, https://indicators.sbcounty.gov/housing/housing-affordability (citing Ford, Carmen. Homeownership Rates by Race and Ethnicity. NAHB Economics and Housing Policy Group. Special Studies March 1, 2018) (“In San Bernardino County, the Black homeownership rate in 2018 was 37.5% compared to 68.1% for White households for a homeownership gap of 30.6 between Black and White households. The Latino homeownership rate in 2018 was 53.7% for a homeownership gap of 14.4 between Latino and White households.”). 16 See supra n.10. Page 6 AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF SOUTHERN CALIFORNIA not achieve the goals they purport to serve, but instead undermine public safety.17 As a matter of common sense, there are at least three ways that the CFMH Program hurts public safety: 1. It deters people from reporting crime. The CFMH Program requires tenants to sign a lease addendum that addresses consequences for criminal activity. The lease addendum links the occurrence of any criminal activity on a multi-housing property with housing consequences (i.e. the possibility of eviction). That lease addendum creates the threat of eviction for a resident when “any member of the resident’s household, a guest, or other person under the resident’s control” is accused of illegal activity.18 Thus, the CFMH Program threatens the housing of innocent residents, by indiscriminately targeting the housing of victims and bystanders as well as perpetrators of alleged criminal activity. The program could threaten a young child with the loss of her home if, for example, a lone member of her household or even a one-time guest caused a disturbance on a single occasion. This deters crime victims, family members, and concerned neighbors and bystanders from coming forward to report crime or reaching out for help— because doing so could lead to housing consequences for them. The program also places a tenant in a terrible, dangerous dilemma when her safety is threatened by a co-tenant. In order to call the police for help, she may trigger a "Crime-Free Housing Referral” or call for service notice to her landlord, which could be construed as a violation of the lease addendum. If victims or concerned family members know that calling 911 can cause them and/or their children to lose their homes, they may avoid seeking protection from the police and suffer the abuse in silence or take matters into their own hands. In short, the CFMH Program gives criminals greater leeway to harass, control, and torment their victims. Similarly, as discussed, the CFMH Program imposes consequences on landlords for the number of calls for service originating from their property. This deters landlords, property managers, neighbors, and tenants from calling for help. 2. It forces people onto the street. The program encourages and provides a basis for more evictions. Forcing someone onto the street does not ensure that the person will leave town or refrain from engaging in harmful conduct. Rather, eviction destabilizes people’s lives and undermines public health and safety, which is detrimental for the community’s wellbeing. 3. It builds barriers to housing. By encouraging landlords to conduct criminal background checks and to use the results of those background checks to discriminate against or deter prospective tenants, the program encourages greater discrimination against prospective tenants based on information about their pasts. Permanently increasing the difficulty for people to obtain stable, independent housing only serves to benefit no one. It stands in the way of people’s efforts to 17 See, e.g., Emily Werth, Sargent Shriver Nat. Ctr. On Poverty Law, The Cost of Being “Crime Free”: Legal and Practical Consequences of Crime Free Rental Housing and Nuisance Property Ordinances 4 (2013), http://povertylaw.org/files/docs/cost-of-being-crime-free.pdf. 18 Draft Housing Element at p. 3-32. Page 7 AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF SOUTHERN CALIFORNIA make positive change in their lives as it threatens to drive individuals and families into homelessness. By deterring people from reporting crimes, forcing people onto the street, and building barriers to housing, the CFMH Program only serves to enable criminal activity and harm public safety. At the same time, it diverts public resources that could be invested in real public safety supports and affirmatively furthering fair housing. For all of these reasons, the draft Housing Element should be revised to remove the CFMH Program. II. THE DRAFT HOUSING ELEMENT SHOULD BE REVISED TO AMEND THE SECTIONS ON ANTI-CAMPING ENFORCEMENT AND PROGRAM 5.5 – HOMELESS SERVICES A. The Homeless Services Program Is A Bad Faith Effort In Addressing The Needs Of Unhoused Community Members The City describes its approach to addressing houselessness as a commitment to the implementation of a “housing first” strategy and “provision of a full continuum of housing and services to address homelessness” as outlined in Program 5.5 of the draft Housing Element.19 While the City has done laudable work to secure some initial grant funding to address houselessness, its plan to spend $20 million on “Housing Unsheltered Residents” is not fully committed to a best practices “housing first” model, wherein safe, permanent, adequate and affordable housing is provided to unhoused people as an immediate response to their needs. Currently, the City’s plan includes some promising permanent supportive housing projects – including the All Star Lodge and U.S. VETS Inland Empire projects.20 The draft Housing Element describes other projects listed in the plan as providing emergency and transitional “shelter beds,” however, and it is unclear whether those will be congregate shelter beds. Studies have shown that congregate shelters are not an effective solution to houselessness and often do not provide pathways to permanent housing. Congregate shelters subject individuals to higher rates of communicable diseases like COVID-19, due to their tight quarters and requirements that many people share facilities.21 Further, crowding large numbers of people together can lead to social withdrawal, psychological distress, and other mental and physical health conditions, and often do not put residents on a path to obtaining permanent housing.22 Importantly, people do not want to live in congregate settings: in a recent research study of individuals experiencing houselessness in Los Angeles, 70% of individuals surveyed stated they 19 See Housing Element, p. 7-25. 20 Id. 21 National Low Income Housing Coalition, Moving Away from Congregate Shelter, https://nlihc.org/resource/moving-away-congregate-shelter (Jun. 9, 2020). 22 Id. at 8, citing Gove, W., Hughes, M., & Galle, O. (1979). Overcrowding in the home: An empirical investigation of possible pathological consequences. American Sociological Review 44(1), 59-80. See also Ann Oliva, Ending Homelessness: Addressing Local Challenges in Housing the Most Vulnerable, CENTER ON BUDGET AND POLICY PRIORITIES, https://www.cbpp.org/research/housing/ending-homelessness-addressing-local-challenges- in-housing-the-most-vulnerable (Feb. 2, 2022). Page 8 AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF SOUTHERN CALIFORNIA would not accept offers to stay in group shelters, citing lack of privacy as a concern, suggesting a limited role for congregate shelters in effectively moving people off the streets.23 We note that “Housing First” is the national best practice for solving houselessness, and that the buildup of temporary or interim placements would create a bottleneck of unhoused community members waiting for permanent and affordable housing. Under the state’s official Housing First policy, placements for unhoused residents should be low-barrier and allow for people to stay with their loved ones, pets, and personal property.24 We ask the City to ensure that all the funds for “Housing Unsheltered Residents” go toward low-barrier, non-congregate, permanent housing solutions based on Housing First principles. Additionally, the City demonstrates its continued dedication to the criminalization of houselessness through the proposed enforcement of its anti-camping ordinance. As outlined in the draft Housing Element, “City has adopted plans that will result in the development of additional beds that will address 60 percent of the unmet need” (i.e. Program 5.5).25 Based on a flawed interpretation of the settlement agreement for Orange County Catholic Worker v. County of Orange, 2019 U.S. Dist. LEXIS 247189 (2019), the City has determined that by achieving the 60 percent need threshold as identified in the settlement agreement, the City will then be given free rein to enforce its anti-camping ordinance.26 We note that the Orange County Catholic Worker v. County of Orange settlement is a private agreement that is binding only on the parties involved and does not establish a legal precedent for San Bernardino County or any other jurisdiction to follow. Further, the City misrepresents the nature of this settlement agreement in its Housing Element draft. The Catholic Worker case did not permit Orange County to enforce its anti-camping ordinances upon 60 percent of its unhoused population becoming housed. Rather, the reference to 60 percent in the settlement was a requirement that a county planning area create enough placements for at least 60 percent of its unsheltered population. This requirement was unrelated to the anti-camping code, and there has not been any anti-camping enforcement in the jurisdictions subject to the settlement, despite the opening of shelters. Importantly, this settlement agreement does nothing to change the binding Ninth Circuit precedent in Martin v. City of Boise, which struck down an anti-camping ordinance and held that that cities may not criminalize people for their unhoused status. 920 F.3d 584 (9th Cir. 2019). As long as there are more unhoused individuals in the City than housing options available to them, it remains unconstitutional to criminalize individuals for engaging in life-sustaining activities like camping in public. Further, building shelters to enable the City to enforce its anti-camping ordinance is an adversarial policy that does nothing to end houselessness. This strategy also implies that the City can effectively force unhoused community members into shelters, segregating them in what are often unsafe and highly inappropriate places to live long term. The 23 Jason M. Ward, et al. Recent Trends Among the Unsheltered in Three Los Angeles Neighborhoods: An Interim Report on the Los Angeles Longitudinal Enumeration and Demographic Survey (LA LEADS) Project, RAND Corporation, https://www rand.org/pubs/research reports/RRA1890-1.html (last visited Oct. 15, 2022). 24 See SB 1380, Homeless Coordinating and Financing Council (Sept. 29, 2016). 25 See Housing Element, p. 3-48. 26 Id. Page 9 AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF SOUTHERN CALIFORNIA City’s goal of enforcing its anti-camping code is misplaced. The goal should not be to criminalize people, but rather to find ways to solve the underlying problem of lack of affordable housing that forces people to live on the street in the first place. We urge the City to pivot away from carceral and coercive approaches to what is, in essence, a housing affordability crisis. The City should focus instead on meeting the immediate affordable housing and service needs of its unhoused population. Any interim accommodations the City provides while it develops sufficient permanent affordable housing should be non-congregate (e.g., motel vouchers), voluntary, and free from restrictive rules and protocols. The City’s top priority should be to meet the expressed needs and preferences of its unhoused residents while committing maximum resources toward permanent and dignified housing solutions. B. The Draft Housing Element Fails To Identify With Specificity The Services That The City Intends to Provide As Part Of Its Homeless Services Program Program 5.5 fails to identify with specificity the exact “health, social, and employment” services that the City is providing.27 Given the City’s intentions in its Homeless Services proposal and its dedication towards the enforcement of its anti-camping ordinance, the ambiguity in what these services entail is concerning. As such, while the provision of services for unhoused residents is potentially laudable, further clarification of the exact services to be provided is required. *** The monetary and societal costs of Program 3.2 far outweigh any benefits. In addition, Program 5.5 fails to genuinely address houselessness as it serves to enable the City’s subsequent enforcement of the anti-camping ordinance. Consequently, we urge you to take this opportunity to eliminate the Crime Free Multi-Housing Program and to amend its Homeless Services and anti-camping enforcement plans outlined in the draft Housing Element. Sincerely, Adrienna Wong, Senior Staff Attorney Kath Attorney, Staff Attorney CC: Melinda Coy, Melinda.Coy@hcd.ca.gov David Zisser, David.Zisser@hcd.ca.gov Cassandra Searcy, searcy ca@sbcity.org 27 See Housing Element, p. 7-25. ATTACHMENT A ATTACHMENT B