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Required Contents
State law requires the housing element to address particularly detailed statutory requirements. For more information on these
requirements, see the HCD’s
website
. A housing element must generally include the following parts, which are described in
further detail below and through links:
• Review of previous element
• Housing needs assessment
• Inventory and analysis of adequate sites
• Analysis of potential governmental and non-governmental constraints
• Housing policies and programs
• Quantified objectives
Planning and Zoning Law also requires planning agency staff to: 1) collect and compile public comments regarding a proposed
housing element; and 2) provide the comments to each member of the legislative body prior to adoption (
Gov. Code § 65585(b)
(2)
). The scope of the housing element requires a strong relationship to other elements of the general plan, and linkages
between sections should be taken in to consideration. The housing element should integrate
community health
,
climate
change
, and other considerations affecting and affected by housing throughout each section. More information on additional
considerations is presented at the end of this
chapter
.
Public Engagement:
Housing issues affect the entire community, and can be confusing and contentious. The public participation requirement of
housing element law presents an opportunity to engage constituents in a dialogue – defining problems and creating solutions.
Public participation should include community stakeholders, including residents, and examine how different housing strategies
are identified, evaluated, developed, and implemented. An inadequate public participation process may lead to community
conflict or anti-development initiatives. Public engagement strategies to address multiple communities are outlined in
Chapter
3
of these Guidelines. The housing element must document how outreach and public engagement is carried out, from planning
through implementation (
Gov. Code § 65583(c)(7)
). This documentation should include current and future plans to involve a
cross-section of the community in the full process.
Review and Revise:
The review and revise requirement is an important feature of the housing element update. A review facilitates a comprehensive
update and ensures that the housing element can be effectively implemented in the next planning period (
Gov. Code § 65588
).
Review and revise requires analysis in three areas:
Progress in implementation:
A description of the actual results or outcomes of the prior element’s goals, objectives, policies,
and programs. The results should be quantified where possible (e.g., number of units rehabilitated) and may be qualitative
where necessary (e.g., mitigation of governmental constraints).
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Effectiveness of the element:
An evaluation of the effectiveness
in achieving the objectives of each program, such as analyzing
differences between what was projected or planned in the
earlier element and what was achieved.
Appropriateness of goals, objectives, policies and programs:
A description of what has been learned based on the analysis
of progress and effectiveness of the previous element. A
description of how the goals, objectives, policies, and programs
in the updated element are being changed or adjusted to
incorporate what has been learned from the results of the
previous element.
Examples of review and revise analysis can be found
here
.
General Plan Consistency:
The goals, policies, and objectives and various accompanying
analyses and text of the housing element must be reviewed
in the context of the rest of the elements of the general plan
such the
land use
,
circulation
, and
open space
elements (
Gov.
Code § 65300.5
). The element must include a discussion of
how internal consistency within the general plan has been
achieved and how internal consistency will be maintained
throughout the planning period (
Gov. Code § 65583(c)
(7)
). If appropriate, other elements may need to be updated
concurrently with the housing element.
Coastal Zone Requirements:
To assist a locality’s determination of whether the affordable
housing stock in the coastal zone is being protected and
provided as required by
Government Code Section 65590
,
the element must contain data on the new construction,
demolition, conversion and replacement housing units for
low- and moderate-income households
within the coastal
zone
.
Based on this analysis, localities should consider appropriate
programs to provide incentives and regulatory concessions
in order to preserve housing for low- and moderate-income
households within the coastal zone. See also the
Coastal Act
section
of the GPG.
Aligning transportation and land use increases access and vibrancy
for all residents
Image by Urban Advantage, Santa Clara Valley Transportation Authority
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Internal Consistency in Updates:
Updates to other sections of the general plan often require a review of
land use
, with consideration to the potential impacts to
existing housing stock and the housing element land inventory. For example, should the update of these elements demonstrate
that certain parcels within the community would not be able to be developed or require significant mitigation; the sites
inventory of the housing element should be updated to reflect these constraints. As a result, new parcels to accommodate the
Regional Housing Needs Allocation (RHNA) may need to be identified.
Land Use Element:
Government Code section 65302.10(a)
requires that each city and county review and update the
land use
element of its general
plan, based on available data, including, but not limited to, the data and analysis developed pursuant to
Government Code
section 56430
, of
unincorporated island, fringe, or legacy communities
inside or near its boundaries.
Safety and Conservation Elements:
Government Code Section 65302
requires amendment of the
safety
and
conservation
elements of the general plan to include analysis and policies regarding flood hazard and management information. In
addition, the
safety
element must be updated to analyze risk and include policies for the protection of the community from any
unreasonable risks associated with the effects of wildland and urban fires.
Environmental Justice Element:
Government Code Section 65302(h) (1)
requires cities and counties with identified disadvantaged communities to create an
environmental justice element
, or related goals, policies, and objectives integrated in other elements. The environmental justice
element must include objectives and policies to promote safe and sanitary homes.
Analysis of Existing Housing Needs
Requirement Description:
An assessment of existing housing needs must include an analysis of population and employment trends and documentation
of projections and a quantification of the locality’s existing and projected housing needs for all income levels, including
extremely low-income households (
Gov. Code §65583(a)(1and 2)
). The assessment must also include an analysis of household
characteristics such as tenure (whether renting or owning) and overpayment; housing characteristics such as overcrowding; and
housing stock conditions. The purpose of the assessment is to evaluate existing housing needs to formulate appropriate policies
and programs. The assessment can be combined with other areas of the housing element such as evaluation of past programs
and comments through public participation. An assessment of housing needs can utilize a variety of quantitative and qualitative
information and should use current information when available. An assessment may also evaluate trends over time and consider
Neighborhood-based Policies and Programs: Some jurisdictions will evaluate household and housing characteristics
at a neighborhood level to target funding and other programs. For example a jurisdiction could evaluate housing
conditions at a neighborhood level to target revitalization efforts or consider tenure and income to better utilize
resources for conserving and improving affordable housing stock.
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