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Home My WebLink About12-06-2023 Special Meeting_Open Session_General Comment_Just SB_RedactedRe: Public Comment for Housing Element i U Monday November 20, 2023 290 North D Street San Bernardino, CA 92401 Dear City of San Bernardino, On behalf of the undersigned organizations, we are writing to provide comments and feedback on the City of San Bernardino's November 2023 version of the 2021- 2029 Housing Element. The Just San Bernardino (Just SB) Collaborative, comprising eight organizations, united in 2020 to engage residents and community members in assessing resources and developing a plan to actively address the conditions contributing to San Bernardino's decline. Members of the Just SB collaborative include Arts Connection Network, BLU Educational Foundation, Congregations United for Prophetic Engagement (COPE), Inland Congregations United for Change (ICUC), Inland Empire Labor Council (IELC), People's Collective for Environmental Justice (PC4EJ), Time for Change Foundation (TFCF), and warehouse worker Resource Center (WWRC). Our collective efforts aim to create innovative models and strategies for economic growth in the City of San Bernardino, emphasizing participatory and inclusive community engagement. By conducting comprehensive surveys and interviews, and engaging with over 4,000 residents and workers in San Bernardino, we crafted the People's Plan for Economic Inclusion. This plan stands as a guiding framework for economic policies and projects firmly rooted in grassroots -based solutions. Consequently, we emphasize the critical importance of conveying the needs of our community whenever public input opportunities arise. Firstly, we express our gratitude to the team involved in the creation and editing of this document, recognizing the dedication required to complete such an essential piece of work. Acknowledging the complexity of the development process and the challenges faced by the city staff, who often operate under constraints, we appreciate the effort in producing the revised housing element draft. 4 Re: Public Comment for Housing Element i U Upon reviewing the 7 chanters, we would like to raise specific concerns: • Chapter 2 - Page 2-24: The City notes the existence of 46 mobile home parks and highlights that none were suspended in 2022 or 2023, which is commendable. To gain further insight, could you provide information on the most recent inspections conducted by HCD, given their seven-year cycle? Additionally, is there available data published by HCD regarding the current repair status of these parks? • Chapter 3 - Page 3-19: The absence of a program regarding density standards is noted. Additionally, while Page 3-53 explains the emergency shelter management plan, further clarity is needed on the amendments to the current regulations in the municipal code. Page 3-54, addressing the anti -camping ordinance, requires clarification on the specifics of the items removed and storage procedures at the City Yard. • Chapter 3 - Page 3-53: It outlines specific requirements for the emergency shelter ordinance, we ask for a particular emphasis on ensuring the clarity of the ordinance's commitment to being anti -discriminatory. Recognizing the need for distinct housing accommodations for individuals with 409s, this aspect could be explicitly defined within the ordinance or municipal code. • Chapter 3 - Page 3-54: This section indicates, "However, should the personal property not be removed by encampment residents, the City will remove the items and leave a notice of how and where to retrieve items at the City Yard at 205 S. Pershing Avenue. Items removed from encampments are stored for 90 days at the City Yard." while we have trust in the City's commitment to respecting its residents, there appears to be a disconnection in the implementation of this process. Residents have recounted instances where their personal belongings were discarded, and they did not receive proper receipts for the disposed items. Page 2 of e Re:PalT9c C6 MMttorHOLMIng.Ele"Wra. i U . Chapter 4- Page 4-17: The section highlighting Housing Unsheltered residents describes different projects, however, some of the language is outdated and some of the differences don't provide details regarding when the project started and it would be helpful to have a timeline of where these projects are. Chapter 4- Page 4-26: "A 15% affordability covenant is required on land sold or leased after no entity responds to the NOA during the 60 days or after price or terms cannot be reached during the 90-day good faith negotiation period. (Gov. Code, §§ 54233):' We hope that the City will contemplate increasing the affordable housing requirement to 20-25% on projects. Additionally, we encourage the consideration of establishing a standard process for community benefit agreements or exploring alternative models for community involvement. . Chapter 4- Page 4-40: We express concern regarding emergency overlay areas 3 and 6, which fall within the 76th and 95th percentiles for hazardous waste. To uphold environmental justice principles, the city could consider utilizing infill strategies aimed at mitigating pollution for populations already at risk. . Chapter 5- Page 5-30-34: The statement regarding problems existing equally between single-family and multiple -family homes contradicts the displacement risk map in Chapter 5. While the EDR model relies on a statistical formula and doesn't pinpoint the cause of displacement, the city must remain vigilant about displacement risks. We propose considering a map that illustrates the neighborhoods built during different time frames and how that may or may not be in alignment with the information provided in the map included in Chapter 5. To enhance accuracy, the city might explore more precise data sets or conduct canvassing to gather information on the causes of displacement. This approach would enable more effective remediation of housing issues. Page 3of8 • Chapter 5-Page 5-75: It's positive that the disadvantages of Muscoy and other unincorporated regions are acknowledged. We propose that these areas be considered for rezoning with an agricultural designation, facilitating the construction of additional housing under farmworker housing initiatives. Additionally, providing incentives for residents to establish legal farms could be a valuable strategy. • Chapter 5-Page 5-61: Central and West Side San Bernardino, designated as R/ECAP areas, should not bear the majority of low-income housing projects. Instead, the objective should be to decentralize poverty from these regions by exploring the construction of low-income housing in areas with more abundant resources. • Chapter 6- Page 6-31: As entrusted leaders of the community, it is our responsibility to ensure that the needs of the community are met. Therefore, we should all strive to make quality long-term and short-term decisions. We appreciate the acknowledgment of the collaborative's work and efforts in addressing the community's concerns. While recognizing these efforts, we also acknowledge the ongoing work that the City and community partners must continue to undertake to achieve impactful change. • Chapter 6- Page 6-32: There is a section highlighting the City's environmental justice efforts. While we commend these efforts, we are aware that the City initiated a truck route study without a final version for enforcement of these routes. To accurately reflect this, the language could be adjusted to state that the City Staff has initiated a truck route study and will work towards adopting enforceable truck routes. Although we appreciate the ongoing remediation efforts at Casa Ramona, we are uncertain about the specific role of environmental justice concerning this project. Additionally, we believe it's important to highlight collaborative partnerships and work with entities such as So Cal Edison, SBCTA, Omnitrans, etc., especially if there are ongoing projects aimed at reducing pollution and emissions. While recognizing the significance of the efforts already listed, we urge the City to explore alternative strategies to address environmental injustices. This could involve zoning considerations for green zones, providing incentives for contractors using eco- friendly materials in public works and capital improvement projects, and exploring the possibility of purchasing micro -grids in partnership with So Cal Edison to mitigate the impact of rolling blackouts experienced by residents annually. We anticipate making more suggestions when the health/environmental element is released.o Page 4 of 8 t — 0 . Chapter 7-Page 7-15&16: We commend the City for the prudent decision to repeal the Multi -Family Crime Free Housing Program. While recognizing the remaining Rental Housing Program Maintenance Standards, which presently focus on the exterior, we acknowledge that additional efforts are needed to establish an inspection program that encompasses interior concerns. It is essential to create a program that not only addresses internal issues but also avoids potential loopholes leading to 11renovictions" for all renters. . Chapter 7-Page 7-19: We anticipate providing additional feedback with the release of the Health/Environmental Justice Element. Chapter 7-Page 7-20: We hope to see a commitment to collecting data and conducting an analysis of the Mobile Home Park Rent Stabilization program. This effort will provide a clear understanding of the program's effectiveness by the next housing element cycle. We are also appreciative to see the commitment to contracting with fair housing experts to offer tenants education on rent stabilization and just -cause eviction. In addition to the comments provided, we express severe concern regarding the zoning outlined in the housing element. While the document acknowledges Valley Truck Farm, a historically black neighborhood, it permits the zoning of this neighborhood and its surroundings as industrial, potentially allowing for logistics industry developments in Southern San Bernardino. The city fails to address how it plans to rectify racially motivated rezoning and the placement of industrial buildings, light industrial structures, and truck routes in areas historically inhabited by minorities or people with lower incomes. rage 5 of 8 Re: Public Comment for Housing Element i U We propose reconsidering the minimum unit sizes for the RE zone. Currently set at 1,700 sq ft, we suggest implementing a range of 1,400 - 11700 sq ft for greater flexibility, especially for infill development where residents and builders may require options tailored to their needs. For Bachelor/Studio units, we recommend a minimum size of 400 sq ft. Allowing smaller studio units could lead to more affordable rents compared to a 500 sq ft studio. Moreover, we find the building height for RH restrictive. We encourage a broader range of units and floors for CR-2 and RH to better accommodate diverse housing needs. The proposed density for both COR-1 and COR-2 zones is deemed insufficient for a major corridor aiming to become a walkable and bikeable community. To foster a vibrant community with a high demand for services like grocery stores, restaurants, and entertainment, we recommend increasing the density to 80+ units per acre. This elevated density would support the creation of a lively and pedestrian -friendly environment. Without achieving this higher density, there is a risk of the E Street Corridor becoming primarily a thoroughfare for cars. While recognizing the importance of cars and the positive impact of public transportation, such as sbX, the current zoning proposals for COR-1 and COR-2 seem incongruent with the city's future planning goals and the desire to diminish reliance on automobiles. Reconsidering and adjusting the zoning to support a more sustainable and walkable community would align with the city's forward -looking vision. The zoning codes in this housing element appear too basic and may not fully meet the community's needs. We seek more information on how the city plans to facilitate developments such as rowhomes, cluster housing, mid -rise, and high- rise housing to address housing demand introduce a more diverse housing supply, and reduce dependency on cars. Page 6 of 8 Re: PubIcComment forHousing Elwnehf L - i U Lastly, the community urgently requires the following programs to flourish: Retrofit pilot program httF2s7//www.boston.gov/housingLh-e-(Lith-y-and-green- retrofit- in lot-"rggram https://www.boston.gov/departments/housing t n Homebuyer program -home-center/one-boston-homebuyer--p�r gram Resilient Buildings Plan https:/ /www.boston.gov/bostons-resilient-buildinga- plan TOPA/COPA (Tenant/Community https://www.policylink.org/resources-tools/tools/all- opportunity to Purchase in-cities/housing-anti-displacement/topa-copa Act) program https://housing2.lacity.org/residents/handyworker- Handy worker program program Home Enhancement Loan https://www.cityofpasadena.net/housing/home- Program (HELP) enhancement -loan -program -help/ REIT, Co-operative and https://www.bloomberg.com/news/articles/2019-04- Community Land Trust 29/alternative-homeownership-land-trusts-and-co- programs ops www.justsb.org I @justsanbernardino Re: Public Comment for Housing Element U Program Description/Example https://www.santa-ana.org/renter-protections/ Rent stabilization/justcause https://www.pomonaca.gov/government/department s/rent-stabilization https:/ /planning.lacou nty.gov/I ong-range- planning/green-zones-program/ Green zones https://oag.ca.gov/sites/default/files/AG%20Letter%20t o%20LA%20County%20%28Green%20Zones%20Ordinan ce%29%20.pdf Adaptive reuse ordinance https://www.santa-ana.org/documents/adaptive- reuse-ord i nance-and-eligible-I ocati ons- map/ Sincerely, Rocio Aguayo, JustSB Policy Research Associate Page 8 of 8