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HomeMy WebLinkAbout2022-02-01 PC Regular Meeting Agenda Packet SUPPLEMENTAL INFORMATION ttt January 27, 2022 Eric Ceja Deputy Director Development Services City of Palm Desert 73 -5 10 Fred Waring Drive Palm Desert, CA 92260 Subject: APN 694-510-013 and Housing Element Inventory Dear Mr. Ceja: I am writing to you on behalf of my client Freeway Lanes, LLC and the Subject property location in the City of Palm Desert. My office is in receipt of the city's letter addressed to my client dated October 29, 2021, addressing the Regional Housing Needs Assessment for the State of California (RHNA). I have reviewed the city's Housing Element Plan covering the period 2006 through 2014 and I have attached hereto a copy of page 35 from the plan. The Subject APN is not listed on page 35. I would like to bring to your attention the fact that it appears none of the Housing Element Plans that have been made available and/or are found on the city's website have a date on them nor is there any type of reference showing the iteration for the plans. No date or iteration on the plans makes it complicated when trying to review and understand what took place and when. During the last Planning Commission meeting and again in our subsequent telephone call January 25th, 2022, I mentioned that the Housing Element Plan downloaded from the city website covering the period 2014 through 2021 does not list the Subject APN. Attached hereto is a copy of Page III-49 from the Housing Element Plan where Table III-38 shows APN's subject to the Housing Element and the Subject APN is not on the list. During the planning commission meeting I was directed to the Draft Plan for 202(1)2-2029 where the Subject Parcel now appears. The Subject APN is referenced as site "F", however, when looking at page 78 of the same plan (copy attached and highlighted) the document states that "F" is 66 units at Millennium, this is not our site. During the planning commission presentation of the Draft Plan, the page entitled "Policy Direction" again listed site "F" as the 66-unit Millennium site. I was told that this is a mistake. 44835 Portola Avenue, Palm Desert, CA 922601 Tel: 760.341.5100 1 www.CPMCRealty.com l DRE #0124582 Mr. Eric Ceja January 27, 2022 Page 2. The Subject APN was not listed and now it is, albeit, not listed correctly. How are we supposed to determine whether the allocation is intended to be our site or not? Based on the preceding the only conclusion I can come to is that the Subject APN was not to be on the list as evidenced by the two (2) prior Housing Element Plans. Please remember, over a year ago we had a meeting at the City's office where Mr. Whipple, Mr. Busby, and I were informed at that time by you that there is requirement to build a minimum of 302 units on the site and no requirement for any low- or moderate -income units. In a subsequent meeting several months later, again at the City's office, Liliana Figueroa from my office and I met with Mr. Martin Alvarez and Ms. Jessica Gonzales to discuss the Housing Element. During this meeting we were told that the Subject APN was on this list and that we had to build affordable units. I said that we had not seen the Subject Parcel on the list and how did this come to be between the time of our first meeting and the second meeting. I asked for how the requirement came about, and I was not provided with anything that says there is a requirement for the Subject APN to provide any affordable housing. Further, during this meeting I requested to know how many units were expected to be affordable and Ms. Gonzales told me she would need an estimated break down of the quantity of units, approximate square footages, and how many one, two, and three -bedroom units etc. Ms. Gonzales was supplied the requested information and as of our last inquiry as to when we would get the information, I was informed the city wants us to provide our proforma financials for the project. After making several inquiries it is my understanding that the only time a Developer may have to provide a financial proforma to the City would be in an event where the City was contributing funds to the project. If the City were contributing funds, then things like financial proformas would be covered in a Development and Disposition Agreement "DDA". There is currently no DDA for the Subject location. January 25th, 2022 I received an email from you where you provided me with a copy of a memo from the City's Attorney to you citing the City's constitutional rights and their rights related to Police Powers etc. (copy attached) and this was forwarded to me in response to my questions about how the affordable housing allocation came to be on the Subject APN. The memo says how it may be done, but not that it was done, further suggesting that the Subject APN has not been identified as being requested to provide affordable housing. While I believe I understand the City's rights as explained by the City Attorney's memo, I still have not heard, read, nor seen any evidence of how the Subject APN was added to the most recent Draft Housing Element list. On the contrary based on what I have seen and read to date, it appears to me, while the city has the right to add the site to the list I cannot find where it was decided that the Subject APN became listed nor any explanation as to the reported mistake mentioned herein above. Mr. Eric Ceja January 27, 2022 Page 2. As I was finishing this letter and continuing to review the Draft Plan there are a couple of other points which are important to note in the attached Draft Housing Element Plan. 1. Page III-78 shows the 66 units at Millennium, noted on the Plan as Map Key "F", (which you have stated "F" is actually meant to be our site) and according to the report it falls under Program IA in the report. When looking at Program IA neither our site nor the Millennium sites are mentioned. Program 1A page III-4 shows 200 units at Portola and Dinah Shore. Page III-5 states that the city is currently negotiating an agreement for at least 200 units on 10 acres. This is not the Subject Site. 2. Page III-6 Program LC shows "Approximately 302 units at Dinah Shore and 35t' Avenue (Southeast Corner, I believe this to be Dick Kelly)" and while this is the same amount of units I was originally told that we needed to build without any requirement for affordable housing, the Subject APN is located on the North side of the street. Again, not the Subject APN. Notwithstanding all of the above, it is my client's intention to submit a proposed Land Use Plan for the Subject APN to you and City planning to further discuss this project. While my client cannot find any specific requirements related to affordable housing, my client may be willing to consider a reasonable percentage of the proposed moderate income units. If there is a requirement to build affordable units at the low or very low rates, my client has said they will not likely proceed with the project. In conclusion, what I surmise from all of this is that the Subject Site as it stands today has no specific "requirement" to build any number of affordable units, however, when we submit our plans for the project the city may have a right to require some reasonable percentage of the units to be affordable housing. In other words, it seems to all be discretionary. I hope to have a Conceptual Land Use Plan and Summary available for the site before the end of this week for informal review and input. I will ask, when I submit the plan, you to meet my team and I either in person or via video conference as soon as possible. I will also ask that you include any other staff you believe relevant to the process to attend the meeting. If you have any questions, please contact me. I can be reached at (760) 341-5100. Respectfully, Mark Stein. Mark Stein TN/City of Palm Desert General Plan/Housing Element been identified to accommodate all housing types. The City will continue to evaluate any amendment to the General Plan, including updating of the Housing Element, as required by State law, to assure that internal consistency is maintained. Evaluation of Existing Housing Element Policies and Programs The City's 2014-2021 Housing Element included policies and action items to address housing needs for the 2014-2021 planning period. Their effectiveness is reviewed below. Goal 1 A variety of housing types that meet all of the housing needs for all income groups within the City. Goal 2 The preservation and maintenance of the high quality of the City's affordable housing supply. Policy 1 New affordable housing projects shall be encouraged in all areas of the City. Special attention will be made to distributing the units so that large concentrations of affordable housing in any one area are avoided. Program LA The City shall work with affordable housing developers, non-profit agencies and other stakeholders to implement the following affordable housing projects for extremely low, very low, low and moderate income households during the planning period. For Carlos Ortega Villas and Sagecrest Apartments, the Housing Authority shall market these projects to the development community through direct mail, announcements on the City's web site and Requests for Proposals, once funding sources have been identified. 0 31 units at Canterra Phase Il • 21 units at Palm Desert 103 • 200 units at Dinah Shore and Portola • 72 units at Carlos Ortega Villas • 16 units at Sagecrest Apartments Responsible Agency: Community Development Department and Housing Authority Schedule: 2014-2021 Evaluation: The City has made progress in moving projects forward during the 2014-2021 planning period, as follows: Canterra Phase II: Now known as The Sands, was entitled for 388 units, including 78 reserved for very low income households. The project entitlements remain active, but the project has failed to secure funding. The project is shown as site DD on the City's inventory, and will be carried forward into the 2022-2029 planning period, in anticipation of its construction. Housing Element 1I1-4 TN/City of Palm Desert General Plan/Housing Element • Palm Desert 103: This project would result in 103 apartments, 20% (21 units) of which would be restricted to moderate income households. This project was inactive during the planning period, but the requirement for affordable units remains. It will be included in the City's inventosy.for the 2022-2029 planning period. • Dinah Shore and Portola: The City is currently negotiating an agreement for the development of at least 200 units on 10 acres. This site will remain on the City's inventory as site C. • Carlos Ortega Villas: This site was developed in the 2014-2021 planning period, and contains 36 units affordable to very low income households, 36 units affordable to low income households, and one manager's unit. The project was successfully completed and will be removed from the City's inventory and added to its list of existing affordable communities. • Sagecrest Apartments: I'he Housing Authority will market the project to the development community during the 2022-2021 planning period. Progress on the implementation of this project is expected in the forthcoming planning period. This program has been successful and will be modified to address current projects. Program LB The City shall pursue the planning and implementation of the following projects for extremely low, very low, low and moderate income households during the planning period. The City will utilize public -private partnerships, grants and third party funding for these projects, and affordable housing funds if restored by the State Legislature. • 520 units that will include single family for -sale and multi -family for rent units at Gerald Ford Drive and Portola • an additional 52 units at the Vineyards Responsible Agency: City Schedule: 2014-2021 Evaluation: This program is still being implemented, as follows: • Gerald Ford and Portola: This project site is currently proposed for 269 apartments affordable to very low and low income households, and 3 managers ' units. Application for entitlement is pending. The project is proposed on 12f acres of'a larger City holding owned by the Successor Agency (SARDA). The balance of the acreage continues to be marketed for affordable housing projects. The site will be maintained in the City's inventory, and is shown as site B. • The Vineyard: This site consists of 260 existing apartments, 52 of which are currently restricted to moderate income households. An additional 52 may be offered as affordable to low or moderate income households, but were not during the 2014-2021 planning period. The agreement between the developer and the City remains effective, and the units could be subsidized in the future. This program continues to be implemented, and will be modified and maintained in the 2022-2029 planning period. Housing Elcmcnt 111-5 TN/City of Palm Desert General Plan/Housing Element Program 1.0 The City shall encourage and facilitate the development by private parties of the following projects for extremely low, very low, low and moderate income units: 432 units at Key Largo 194 units at Frank Sinatra and Cook Street Approximately 302 units at Dinah Shore and 35" Avenue (southeast corner) The City shall annually contact the owners/developers of these lands and review with them the incentives and financing options available through State and federal loan and grant programs, and local non-profit agencies to assure that all potential financial mechanisms are being considered for the project(s). Responsible Agency: City Schedule: 2014-2021 Evaluation: The City continues to work with the land owners associated with these ,sites as.follows: Key Largo: The land owners are currently preparing a Specific Plan for the site, which would include apartments. Up to 200 units could be restricted to low and moderate income households. This project is still active, and will remain on the City's inventory as site A. Frank Sinatra and Cook Street: This project was inactive during the planning period, and is not considered viable for the fixture. It will be removed from the City :s inventory. Dinah Shore and 35' Avenue: This project remains under consideration, and the City believes that it could move forward. The City will continue to work with the landowner and encourage the development of affordable housing units into the next planning period. In addition, the City approved Tentative Tract Map 37506, for land located on the south side of Gerald Ford Drive, between Portola and Technology Drive in the University Park area. This site includes a mix of'.single. family homes, townhome and apartment .sites, totaling 1, 069 units. The City will continue to work with the developer to encourage the inclusion of affordable housing units in the project. This program remains active, and will be modified for the 2022-2029 planning period. Program 1.D The City shall continue to implement the Self Help Housing program when funds are available. The City will work with agencies such as Habitat for Humanity and Coachella Valley Housing Coalition to identify funding and the location of these units. Responsible Agency: City Schedule: 2016-201 S, as funding is identified Evaluation: During the 2014-2021 planning period, Habitat.for Humanity developed 2 homes for very low income households, which were all completed and are now occupied. In May of 2020, the City awarded the Coachella Valley Housing Coalition a contract to construct 14 .self-help housing units on Merle, near Cook Street. These homes are expected to be built during the next planning period. The program will be modified and maintained to assure construction, and the project will be included in the City's inventory as ,site PP. Housing Element 1I1-6 TN/City of Palm Desert General Plan/Housing Element Table III-33 Inventory of Available Vacant Lands Assessor's Parcel No. General Plan/Zone Size (Acres) Potential Units 694-130-017 D R-M, R-HO/PC* 10.21 176 694-130-021 (G) R-M, R-HO/PC* 24.16 200 694-130-018 D R-M, R-HO/PC* 3.48 72 694-190-008 H MU/PC* 15 of29.36 160 694-200-014 (.1) R-M, R-HO, MU/PC* 11.46 194 694-130-012 E R-M, R-HO/PR-5 33.71 235 694-130-003 (F) R-M, R-HO/PC* 18.92 302 685-010-005 A C-R/PC* 30 432 694-310-001 & 005 C-R/PR-5 35 520 694-120-012 (C) I-BP/PC* 10 200 627-273-018 R-M/R-3 0.3 7 627-273-005 R-M/R-3 0.3 7 625-171-001 R-M/R-3 0.3 7 627-121-044 R-H/R-3 0.25 6 627-121-045 R-H/R-3 0.25 6 627-301-022 R-H/R-3 0.31 7 627-153-007 R-H/R-3 0.22 5 627-101-033, -038, -039, -002, -017 R-M/OP* 1.64 22 627-041-010 through 013, -29, 031 - 033 R-M/OP* and R-2 1.20 19 627-051-002 R-M/R-2 0.16 2 627-031-030 RM/R-2 0.17 2 627-052-006 R-M/R-2 0.17 2 627-052-031 R-M/R-2 0.16 2 627-052-033 R-M/R-2 0.16 2 627-084-001 R-M/R-2 0.22 2 627-084-003 R-M/R-2 0.19 2 627-182-004 R-M/R-1 0.20 1 627-182-005 R-H/R-1 0.20 1 627-182-006 R-H/R-1 0.17 1 627-351-042 R-M/R-2 0.20 2 627-351-019 R-M/R-1 0.17 1 625-224-001 R-M/R-1 0.19 1 625-126-009 R-H/R-3 0.14 2 625-061-018 R-M/R-1 0.15 1 625-021-008 R-M/R-1 0.19 1 625-031-011 R-M/R-1 2.20 1 625-032-011 R-M/R-1 0.21 1 624-241-008 R-M/R-1 0.12 1 Total Units 2,605 *Requires re -zoning. Property designated Office Professional or Medium Density Residential / High Density Overlay in General Plan As shown in the inventory, approximately 2,605 units could be constructed on lands which are currently available for multiple family residential development. In addition to the vacant lands included above, the Redevelopment Agency currently has commitments for an additional 103 Housing Element 111-35 TN/City of Palm Desert General Plan/Housing Element the higher densities do not allow them to create communities that they can lease, because they cannot provide the services and amenities that create a healthy living environment. Table III-38 Inventory of Available Vacant Lands Assessor's Parcel No. General Plan/Zone Size (Acres) Potential Units 694-130-017 D R-M, R-HO/PCD 10.21 176 694-130-021 (G) R-M, R-HO/PR-20 24.16 200 694-130-018 D R-M, R-HO/PR-20 3.48 72 694-190-008 H MU/PR-20 15 of29.36 160 694-200-014 (H R-M, R-HO, MU/PR-20 11.46 194 694-130-012 E R-M, R-HO/PR-5 33.71 235 694-130-003 F R-M, R-HO/PR-20 18.92 302 685-010-005 A C-R/PR-20 30 432 694-310-001 & 005 B C-R/PR-22 10 200 694-120-012 C I-BP/PR-20 10 200 627-273-018 R-M/R-3 0.3 7 627-273-005 R-M/R-3 0.3 7 625-171-001 R-M/R-3 0.3 7 627-121-044 R-H/R-3 0.25 6 627-121-045 R-H/R-3 0.25 6 627-301-022 R-H/R-3 0.31 7 627-153-007 R-H/R-3 0.22 5 627-101-033,-038,-039,-002,-017 R-M/R-3 1.64 22 627-041-010 through 013, -29, 031 - 033 R-M/OP- and R-2 1.20 19 627-051-002 R-M/R-2 0.16 2 627-031-030 RM/R-2 0.17 2 627-052-006 R-M/R-2 0.17 2 627-052-031 R-M/R-2 0.16 2 627-052-033 R-M/R-2 0.16 2 627-084-001 R-M/R-2 0.22 2 627-084-003 R-M/R-2 0.19 2 627-182-004 R-M/R-1 0.20 1 627-182-005 R-H/R-1 0.20 1 627-182-006 R-H/R-1 0.17 1 627-351-042 R-M/R-2 0.20 2 627-351-019 R-M/R-1 0.17 1 625-224-001 R-M/R-1 0.19 1 625-126-009 R-H/R-3 0.14 2 625-061-018 R-M/R-1 0.15 1 625-021-008 R-M/R-1 0.19 1 625-031-011 R-M/R-1 2.20 1 625-032-011 R-M/R-1 0.21 1 624-241-008 R-M/R-1 0.12 1 Total Units 2,294 Housing Element III-49 TN/City of Palm Desert General Plan/Housing Element Table 111-47 Vacant Land inventory of Sites for Extremely Low, Very Low, Low and Moderate Income Units Map Assessor's Zoning Allowable Realistic Potential Parcel No. CP all HOD)** Acreage Density Density Units -Key Vacant Entitled Sites Town Center DD 624-040-037 Neighborhood P.R.-17.5 17.66 17.5 17.5 78 Town Center DD* 624-040-037 Neighborhood P.R.-17.5 17.66 17.5 17.5 310 Small Town 694-520-013, - Neighborhood; 014, -015, -017, Employment E* -019 and -020 Center P.R.-19 8.05 19 18 21 Subtotal Entitled Sites 409 Vacant Sites in the Entitlement Process 627-122-013 Small Town LL and -003 Neigh orhood R-2 HOD 1.43 3 to 10 20 28 694-310-002, - Town Center 12 of B 006, & -007 Neighborhood P.R.-20 68.2 4 to 20 22.5 269 Town Center H 694-190-087 Neighborhood P.R.22 14.97 22 22 44 Town Center H* 694-190-087 Neighborhood P.R.22 14.97 22 22 286 Town Center Neighborhood; Suburban P.C.-(3), 10 of C 694-120-028 Retail Center FCOZ 20.18 7 to 40 24 240 Public Facility/Institu KK 622-370-014 tional P 1.84 N/A N/A 36 Subtotal Sites in Entitlement Process 903 Vacant Sites Regional P.C.-(3), 15 of A 685-010-005 Retail P.C.D. 64.26 10 to 15 14 200 694-130-017 &- Town Center D 018 Neighborhood P.R.-22 10.95 22 20 219 Town Center F 694-510-013 Neighborhood P.R.-22 16.32 22 20 326 624-441-014 Small Town PP through -022 Neighborhood P.R.-6 1.31 3 to 10 8 10 624-440-032 Small Town QQ through -036 Neighborhood P.R.-6 0.72 3 to 10 8 6 Small Town 627-041-010 Neighborhood/ through 013, - Neighborhood T 29,031 - 033 Center R-3 1.36 7 to 40 15 20 Subtotal Vacant Sites 781 Total All Vacant Sites 2,093 * Moderate Income Site ** All sites in this Table have been assigned the Housing Overlay District. Housing Element 111-72 TN/City of Palm Desert General Plan/Housing Element GOALS, POLICIES AND PROGRAMS Goal 1 A variety of housing types that meet all of the housing needs for all income groups within the City. Goal 2 The preservation and maintenance of the high quality of the City's affordable housing supply. Policy 1 New affordable housing projects shall be encouraged in all areas of the City. Special attention will be made to distributing the units so that large concentrations of affordable housing in any one area are avoided. Program LA The City shall work with affordable housing developers, non-profit agencies and other stakeholders to implement the following affordable housing projects for extremely low, very low, low and moderate income households during the planning period. 0 21 units at Palm Desert 103 (Site E): annually contact the landowner and provide them with current City programs and incentives for the construction of the remaining units within the project. • 36 units at Arc Village (Site KK): continue to work with Desert ARC and affordable housing developers to secure funding for these units for developmentally disabled persons. The City will participate in the preparation of applications for State funding and reinstate funding assistance when an application is prepared. 0 66 units at Millennium (Site F): the City will continue to work with the developer to process the pending entitlements and finalize the affordable housing covenants consistent with the existing Development Agreement. Responsible Agency: Community Development Department and Housing Authority Schedule: Continuous as these projects move forward Program l.B The City shall pursue the planning and implementation of the following projects for extremely low, very low, low and moderate income households during the planning period. The City will utilize public -private partnerships, grants and third party funding for these projects, and density bonus incentives. • 240 units at Millennium City Site (Site C): the City shall enforce the terms of its existing agreement with the developer of this project, including maintaining project schedules and expediting processing of applications. A minimum of 15% of the units will be reserved for extremely low income residents. • 28 units at Sagecrest Apartments (Site LL): the City will complete the RFP process in 2022, and establish an agreement with the successful developer for construction of the units by 2025. A minimum of 15% of the units shall be reserved for extremely low income residents. Housing Element II1-78 ttt January 27, 2022 Eric Ceja Deputy Director Development Services City of Palm Desert 73 -5 10 Fred Waring Drive Palm Desert, CA 92260 Subject: APN 694-510-013 and Housing Element Inventory Dear Mr. Ceja: I am writing to you on behalf of my client Freeway Lanes, LLC and the Subject property location in the City of Palm Desert. My office is in receipt of the city's letter addressed to my client dated October 29, 2021, addressing the Regional Housing Needs Assessment for the State of California (RHNA). I have reviewed the city's Housing Element Plan covering the period 2006 through 2014 and I have attached hereto a copy of page 35 from the plan. The Subject APN is not listed on page 35. I would like to bring to your attention the fact that it appears none of the Housing Element Plans that have been made available and/or are found on the city's website have a date on them nor is there any type of reference showing the iteration for the plans. No date or iteration on the plans makes it complicated when trying to review and understand what took place and when. During the last Planning Commission meeting and again in our subsequent telephone call January 25th, 2022, I mentioned that the Housing Element Plan downloaded from the city website covering the period 2014 through 2021 does not list the Subject APN. Attached hereto is a copy of Page III-49 from the Housing Element Plan where Table III-38 shows APN's subject to the Housing Element and the Subject APN is not on the list. During the planning commission meeting I was directed to the Draft Plan for 202(1)2-2029 where the Subject Parcel now appears. The Subject APN is referenced as site "F", however, when looking at page 78 of the same plan (copy attached and highlighted) the document states that "F" is 66 units at Millennium, this is not our site. During the planning commission presentation of the Draft Plan, the page entitled "Policy Direction" again listed site "F" as the 66-unit Millennium site. I was told that this is a mistake. 44835 Portola Avenue, Palm Desert, CA 922601 Tel: 760.341.5100 1 www.CPMCRealty.com l DRE #0124582 Mr. Eric Ceja January 27, 2022 Page 2. The Subject APN was not listed and now it is, albeit, not listed correctly. How are we supposed to determine whether the allocation is intended to be our site or not? Based on the preceding the only conclusion I can come to is that the Subject APN was not to be on the list as evidenced by the two (2) prior Housing Element Plans. Please remember, over a year ago we had a meeting at the City's office where Mr. Whipple, Mr. Busby, and I were informed at that time by you that there is requirement to build a minimum of 302 units on the site and no requirement for any low- or moderate -income units. In a subsequent meeting several months later, again at the City's office, Liliana Figueroa from my office and I met with Mr. Martin Alvarez and Ms. Jessica Gonzales to discuss the Housing Element. During this meeting we were told that the Subject APN was on this list and that we had to build affordable units. I said that we had not seen the Subject Parcel on the list and how did this come to be between the time of our first meeting and the second meeting. I asked for how the requirement came about, and I was not provided with anything that says there is a requirement for the Subject APN to provide any affordable housing. Further, during this meeting I requested to know how many units were expected to be affordable and Ms. Gonzales told me she would need an estimated break down of the quantity of units, approximate square footages, and how many one, two, and three -bedroom units etc. Ms. Gonzales was supplied the requested information and as of our last inquiry as to when we would get the information, I was informed the city wants us to provide our proforma financials for the project. After making several inquiries it is my understanding that the only time a Developer may have to provide a financial proforma to the City would be in an event where the City was contributing funds to the project. If the City were contributing funds, then things like financial proformas would be covered in a Development and Disposition Agreement "DDA". There is currently no DDA for the Subject location. January 25th, 2022 I received an email from you where you provided me with a copy of a memo from the City's Attorney to you citing the City's constitutional rights and their rights related to Police Powers etc. (copy attached) and this was forwarded to me in response to my questions about how the affordable housing allocation came to be on the Subject APN. The memo says how it may be done, but not that it was done, further suggesting that the Subject APN has not been identified as being requested to provide affordable housing. While I believe I understand the City's rights as explained by the City Attorney's memo, I still have not heard, read, nor seen any evidence of how the Subject APN was added to the most recent Draft Housing Element list. On the contrary based on what I have seen and read to date, it appears to me, while the city has the right to add the site to the list I cannot find where it was decided that the Subject APN became listed nor any explanation as to the reported mistake mentioned herein above. Mr. Eric Ceja January 27, 2022 Page 2. As I was finishing this letter and continuing to review the Draft Plan there are a couple of other points which are important to note in the attached Draft Housing Element Plan. 1. Page III-78 shows the 66 units at Millennium, noted on the Plan as Map Key "F", (which you have stated "F" is actually meant to be our site) and according to the report it falls under Program IA in the report. When looking at Program IA neither our site nor the Millennium sites are mentioned. Program 1A page III-4 shows 200 units at Portola and Dinah Shore. Page III-5 states that the city is currently negotiating an agreement for at least 200 units on 10 acres. This is not the Subject Site. 2. Page III-6 Program LC shows "Approximately 302 units at Dinah Shore and 35t' Avenue (Southeast Corner, I believe this to be Dick Kelly)" and while this is the same amount of units I was originally told that we needed to build without any requirement for affordable housing, the Subject APN is located on the North side of the street. Again, not the Subject APN. Notwithstanding all of the above, it is my client's intention to submit a proposed Land Use Plan for the Subject APN to you and City planning to further discuss this project. While my client cannot find any specific requirements related to affordable housing, my client may be willing to consider a reasonable percentage of the proposed moderate income units. If there is a requirement to build affordable units at the low or very low rates, my client has said they will not likely proceed with the project. In conclusion, what I surmise from all of this is that the Subject Site as it stands today has no specific "requirement" to build any number of affordable units, however, when we submit our plans for the project the city may have a right to require some reasonable percentage of the units to be affordable housing. In other words, it seems to all be discretionary. I hope to have a Conceptual Land Use Plan and Summary available for the site before the end of this week for informal review and input. I will ask, when I submit the plan, you to meet my team and I either in person or via video conference as soon as possible. I will also ask that you include any other staff you believe relevant to the process to attend the meeting. If you have any questions, please contact me. I can be reached at (760) 341-5100. Respectfully, Mark Stein. Mark Stein TN/City of Palm Desert General Plan/Housing Element been identified to accommodate all housing types. The City will continue to evaluate any amendment to the General Plan, including updating of the Housing Element, as required by State law, to assure that internal consistency is maintained. Evaluation of Existing Housing Element Policies and Programs The City's 2014-2021 Housing Element included policies and action items to address housing needs for the 2014-2021 planning period. Their effectiveness is reviewed below. Goal 1 A variety of housing types that meet all of the housing needs for all income groups within the City. Goal 2 The preservation and maintenance of the high quality of the City's affordable housing supply. Policy 1 New affordable housing projects shall be encouraged in all areas of the City. Special attention will be made to distributing the units so that large concentrations of affordable housing in any one area are avoided. Program LA The City shall work with affordable housing developers, non-profit agencies and other stakeholders to implement the following affordable housing projects for extremely low, very low, low and moderate income households during the planning period. For Carlos Ortega Villas and Sagecrest Apartments, the Housing Authority shall market these projects to the development community through direct mail, announcements on the City's web site and Requests for Proposals, once funding sources have been identified. 0 31 units at Canterra Phase Il • 21 units at Palm Desert 103 • 200 units at Dinah Shore and Portola • 72 units at Carlos Ortega Villas • 16 units at Sagecrest Apartments Responsible Agency: Community Development Department and Housing Authority Schedule: 2014-2021 Evaluation: The City has made progress in moving projects forward during the 2014-2021 planning period, as follows: Canterra Phase II: Now known as The Sands, was entitled for 388 units, including 78 reserved for very low income households. The project entitlements remain active, but the project has failed to secure funding. The project is shown as site DD on the City's inventory, and will be carried forward into the 2022-2029 planning period, in anticipation of its construction. Housing Element 1I1-4 TN/City of Palm Desert General Plan/Housing Element • Palm Desert 103: This project would result in 103 apartments, 20% (21 units) of which would be restricted to moderate income households. This project was inactive during the planning period, but the requirement for affordable units remains. It will be included in the City's inventosy.for the 2022-2029 planning period. • Dinah Shore and Portola: The City is currently negotiating an agreement for the development of at least 200 units on 10 acres. This site will remain on the City's inventory as site C. • Carlos Ortega Villas: This site was developed in the 2014-2021 planning period, and contains 36 units affordable to very low income households, 36 units affordable to low income households, and one manager's unit. The project was successfully completed and will be removed from the City's inventory and added to its list of existing affordable communities. • Sagecrest Apartments: I'he Housing Authority will market the project to the development community during the 2022-2021 planning period. Progress on the implementation of this project is expected in the forthcoming planning period. This program has been successful and will be modified to address current projects. Program LB The City shall pursue the planning and implementation of the following projects for extremely low, very low, low and moderate income households during the planning period. The City will utilize public -private partnerships, grants and third party funding for these projects, and affordable housing funds if restored by the State Legislature. • 520 units that will include single family for -sale and multi -family for rent units at Gerald Ford Drive and Portola • an additional 52 units at the Vineyards Responsible Agency: City Schedule: 2014-2021 Evaluation: This program is still being implemented, as follows: • Gerald Ford and Portola: This project site is currently proposed for 269 apartments affordable to very low and low income households, and 3 managers ' units. Application for entitlement is pending. The project is proposed on 12f acres of'a larger City holding owned by the Successor Agency (SARDA). The balance of the acreage continues to be marketed for affordable housing projects. The site will be maintained in the City's inventory, and is shown as site B. • The Vineyard: This site consists of 260 existing apartments, 52 of which are currently restricted to moderate income households. An additional 52 may be offered as affordable to low or moderate income households, but were not during the 2014-2021 planning period. The agreement between the developer and the City remains effective, and the units could be subsidized in the future. This program continues to be implemented, and will be modified and maintained in the 2022-2029 planning period. Housing Elcmcnt 111-5 TN/City of Palm Desert General Plan/Housing Element Program 1.0 The City shall encourage and facilitate the development by private parties of the following projects for extremely low, very low, low and moderate income units: 432 units at Key Largo 194 units at Frank Sinatra and Cook Street Approximately 302 units at Dinah Shore and 35" Avenue (southeast corner) The City shall annually contact the owners/developers of these lands and review with them the incentives and financing options available through State and federal loan and grant programs, and local non-profit agencies to assure that all potential financial mechanisms are being considered for the project(s). Responsible Agency: City Schedule: 2014-2021 Evaluation: The City continues to work with the land owners associated with these ,sites as.follows: Key Largo: The land owners are currently preparing a Specific Plan for the site, which would include apartments. Up to 200 units could be restricted to low and moderate income households. This project is still active, and will remain on the City's inventory as site A. Frank Sinatra and Cook Street: This project was inactive during the planning period, and is not considered viable for the fixture. It will be removed from the City :s inventory. Dinah Shore and 35' Avenue: This project remains under consideration, and the City believes that it could move forward. The City will continue to work with the landowner and encourage the development of affordable housing units into the next planning period. In addition, the City approved Tentative Tract Map 37506, for land located on the south side of Gerald Ford Drive, between Portola and Technology Drive in the University Park area. This site includes a mix of'.single. family homes, townhome and apartment .sites, totaling 1, 069 units. The City will continue to work with the developer to encourage the inclusion of affordable housing units in the project. This program remains active, and will be modified for the 2022-2029 planning period. Program 1.D The City shall continue to implement the Self Help Housing program when funds are available. The City will work with agencies such as Habitat for Humanity and Coachella Valley Housing Coalition to identify funding and the location of these units. Responsible Agency: City Schedule: 2016-201 S, as funding is identified Evaluation: During the 2014-2021 planning period, Habitat.for Humanity developed 2 homes for very low income households, which were all completed and are now occupied. In May of 2020, the City awarded the Coachella Valley Housing Coalition a contract to construct 14 .self-help housing units on Merle, near Cook Street. These homes are expected to be built during the next planning period. The program will be modified and maintained to assure construction, and the project will be included in the City's inventory as ,site PP. Housing Element 1I1-6 TN/City of Palm Desert General Plan/Housing Element Table III-33 Inventory of Available Vacant Lands Assessor's Parcel No. General Plan/Zone Size (Acres) Potential Units 694-130-017 D R-M, R-HO/PC* 10.21 176 694-130-021 (G) R-M, R-HO/PC* 24.16 200 694-130-018 D R-M, R-HO/PC* 3.48 72 694-190-008 H MU/PC* 15 of29.36 160 694-200-014 (.1) R-M, R-HO, MU/PC* 11.46 194 694-130-012 E R-M, R-HO/PR-5 33.71 235 694-130-003 (F) R-M, R-HO/PC* 18.92 302 685-010-005 A C-R/PC* 30 432 694-310-001 & 005 C-R/PR-5 35 520 694-120-012 (C) I-BP/PC* 10 200 627-273-018 R-M/R-3 0.3 7 627-273-005 R-M/R-3 0.3 7 625-171-001 R-M/R-3 0.3 7 627-121-044 R-H/R-3 0.25 6 627-121-045 R-H/R-3 0.25 6 627-301-022 R-H/R-3 0.31 7 627-153-007 R-H/R-3 0.22 5 627-101-033, -038, -039, -002, -017 R-M/OP* 1.64 22 627-041-010 through 013, -29, 031 - 033 R-M/OP* and R-2 1.20 19 627-051-002 R-M/R-2 0.16 2 627-031-030 RM/R-2 0.17 2 627-052-006 R-M/R-2 0.17 2 627-052-031 R-M/R-2 0.16 2 627-052-033 R-M/R-2 0.16 2 627-084-001 R-M/R-2 0.22 2 627-084-003 R-M/R-2 0.19 2 627-182-004 R-M/R-1 0.20 1 627-182-005 R-H/R-1 0.20 1 627-182-006 R-H/R-1 0.17 1 627-351-042 R-M/R-2 0.20 2 627-351-019 R-M/R-1 0.17 1 625-224-001 R-M/R-1 0.19 1 625-126-009 R-H/R-3 0.14 2 625-061-018 R-M/R-1 0.15 1 625-021-008 R-M/R-1 0.19 1 625-031-011 R-M/R-1 2.20 1 625-032-011 R-M/R-1 0.21 1 624-241-008 R-M/R-1 0.12 1 Total Units 2,605 *Requires re -zoning. Property designated Office Professional or Medium Density Residential / High Density Overlay in General Plan As shown in the inventory, approximately 2,605 units could be constructed on lands which are currently available for multiple family residential development. In addition to the vacant lands included above, the Redevelopment Agency currently has commitments for an additional 103 Housing Element 111-35 TN/City of Palm Desert General Plan/Housing Element the higher densities do not allow them to create communities that they can lease, because they cannot provide the services and amenities that create a healthy living environment. Table III-38 Inventory of Available Vacant Lands Assessor's Parcel No. General Plan/Zone Size (Acres) Potential Units 694-130-017 D R-M, R-HO/PCD 10.21 176 694-130-021 (G) R-M, R-HO/PR-20 24.16 200 694-130-018 D R-M, R-HO/PR-20 3.48 72 694-190-008 H MU/PR-20 15 of29.36 160 694-200-014 (H R-M, R-HO, MU/PR-20 11.46 194 694-130-012 E R-M, R-HO/PR-5 33.71 235 694-130-003 F R-M, R-HO/PR-20 18.92 302 685-010-005 A C-R/PR-20 30 432 694-310-001 & 005 B C-R/PR-22 10 200 694-120-012 C I-BP/PR-20 10 200 627-273-018 R-M/R-3 0.3 7 627-273-005 R-M/R-3 0.3 7 625-171-001 R-M/R-3 0.3 7 627-121-044 R-H/R-3 0.25 6 627-121-045 R-H/R-3 0.25 6 627-301-022 R-H/R-3 0.31 7 627-153-007 R-H/R-3 0.22 5 627-101-033,-038,-039,-002,-017 R-M/R-3 1.64 22 627-041-010 through 013, -29, 031 - 033 R-M/OP- and R-2 1.20 19 627-051-002 R-M/R-2 0.16 2 627-031-030 RM/R-2 0.17 2 627-052-006 R-M/R-2 0.17 2 627-052-031 R-M/R-2 0.16 2 627-052-033 R-M/R-2 0.16 2 627-084-001 R-M/R-2 0.22 2 627-084-003 R-M/R-2 0.19 2 627-182-004 R-M/R-1 0.20 1 627-182-005 R-H/R-1 0.20 1 627-182-006 R-H/R-1 0.17 1 627-351-042 R-M/R-2 0.20 2 627-351-019 R-M/R-1 0.17 1 625-224-001 R-M/R-1 0.19 1 625-126-009 R-H/R-3 0.14 2 625-061-018 R-M/R-1 0.15 1 625-021-008 R-M/R-1 0.19 1 625-031-011 R-M/R-1 2.20 1 625-032-011 R-M/R-1 0.21 1 624-241-008 R-M/R-1 0.12 1 Total Units 2,294 Housing Element III-49 TN/City of Palm Desert General Plan/Housing Element Table 111-47 Vacant Land inventory of Sites for Extremely Low, Very Low, Low and Moderate Income Units Map Assessor's Zoning Allowable Realistic Potential Parcel No. CP all HOD)** Acreage Density Density Units -Key Vacant Entitled Sites Town Center DD 624-040-037 Neighborhood P.R.-17.5 17.66 17.5 17.5 78 Town Center DD* 624-040-037 Neighborhood P.R.-17.5 17.66 17.5 17.5 310 Small Town 694-520-013, - Neighborhood; 014, -015, -017, Employment E* -019 and -020 Center P.R.-19 8.05 19 18 21 Subtotal Entitled Sites 409 Vacant Sites in the Entitlement Process 627-122-013 Small Town LL and -003 Neigh orhood R-2 HOD 1.43 3 to 10 20 28 694-310-002, - Town Center 12 of B 006, & -007 Neighborhood P.R.-20 68.2 4 to 20 22.5 269 Town Center H 694-190-087 Neighborhood P.R.22 14.97 22 22 44 Town Center H* 694-190-087 Neighborhood P.R.22 14.97 22 22 286 Town Center Neighborhood; Suburban P.C.-(3), 10 of C 694-120-028 Retail Center FCOZ 20.18 7 to 40 24 240 Public Facility/Institu KK 622-370-014 tional P 1.84 N/A N/A 36 Subtotal Sites in Entitlement Process 903 Vacant Sites Regional P.C.-(3), 15 of A 685-010-005 Retail P.C.D. 64.26 10 to 15 14 200 694-130-017 &- Town Center D 018 Neighborhood P.R.-22 10.95 22 20 219 Town Center F 694-510-013 Neighborhood P.R.-22 16.32 22 20 326 624-441-014 Small Town PP through -022 Neighborhood P.R.-6 1.31 3 to 10 8 10 624-440-032 Small Town QQ through -036 Neighborhood P.R.-6 0.72 3 to 10 8 6 Small Town 627-041-010 Neighborhood/ through 013, - Neighborhood T 29,031 - 033 Center R-3 1.36 7 to 40 15 20 Subtotal Vacant Sites 781 Total All Vacant Sites 2,093 * Moderate Income Site ** All sites in this Table have been assigned the Housing Overlay District. Housing Element 111-72 TN/City of Palm Desert General Plan/Housing Element GOALS, POLICIES AND PROGRAMS Goal 1 A variety of housing types that meet all of the housing needs for all income groups within the City. Goal 2 The preservation and maintenance of the high quality of the City's affordable housing supply. Policy 1 New affordable housing projects shall be encouraged in all areas of the City. Special attention will be made to distributing the units so that large concentrations of affordable housing in any one area are avoided. Program LA The City shall work with affordable housing developers, non-profit agencies and other stakeholders to implement the following affordable housing projects for extremely low, very low, low and moderate income households during the planning period. 0 21 units at Palm Desert 103 (Site E): annually contact the landowner and provide them with current City programs and incentives for the construction of the remaining units within the project. • 36 units at Arc Village (Site KK): continue to work with Desert ARC and affordable housing developers to secure funding for these units for developmentally disabled persons. The City will participate in the preparation of applications for State funding and reinstate funding assistance when an application is prepared. 0 66 units at Millennium (Site F): the City will continue to work with the developer to process the pending entitlements and finalize the affordable housing covenants consistent with the existing Development Agreement. Responsible Agency: Community Development Department and Housing Authority Schedule: Continuous as these projects move forward Program l.B The City shall pursue the planning and implementation of the following projects for extremely low, very low, low and moderate income households during the planning period. The City will utilize public -private partnerships, grants and third party funding for these projects, and density bonus incentives. • 240 units at Millennium City Site (Site C): the City shall enforce the terms of its existing agreement with the developer of this project, including maintaining project schedules and expediting processing of applications. A minimum of 15% of the units will be reserved for extremely low income residents. • 28 units at Sagecrest Apartments (Site LL): the City will complete the RFP process in 2022, and establish an agreement with the successful developer for construction of the units by 2025. A minimum of 15% of the units shall be reserved for extremely low income residents. Housing Element II1-78