Housing Element Review: City Commissions Contradict Housing Element Commitments Commissions in Redwood City and Half Moon Bay vote against affordable homes

Over the last three weeks, city commissions in various parts of San Mateo County have stalled plans for affordable homes on sites included in the housing element. In Redwood City, the Architectural Design Review Commission unanimously recommended the council reject plans for 85 affordable homes at 847 Woodside Road. Half Moon Bay’s planning commission has twice rejected plans for 40 homes affordable to farmworkers planned for 555 Kelly Road. Both projects are included in their cities’ housing elements. 

Nonprofit Mercy Housing has applied to build 40 100% affordable homes in Half Moon Bay.

If cities like Half Moon Bay and Redwood City want local control over land use, they need to be responsive to the housing needs of their communities. The shortage of affordable homes for farmworkers and others may have no immediate impact on the individuals that serve on commissions and their comfortably housed supporters, but it has a huge impact on the working class members of our communities. Redwood City’s planning commission and Half Moon Bay’s architectural design review commission should support their respective affordable housing proposals to move forward without further subjective stipulations.

Both cities are responsible for planning for housing on these sites due to commitments in their housing elements. Redwood City’s housing element includes plans for housing at 847 Woodside Road based on an earlier proposal to build 44 homes for ownership on the site, including 37 market-rate and 7 affordable (see page 155 of the RWC housing element). Though the current proposal at 847 Woodside Road is larger than originally planned in the housing element, the increased density is necessary to make a new project pencil under tighter market conditions. 

HLC sent a public comment to Redwood City on Monday, May 6 detailing steps the city can take to facilitate development at 847 Woodside Road and remove barriers to future projects. Most significantly, the city should encourage eligible projects to take advantage of SB 35 and other environmental streamlining lawsfor infill housing, which is inherently sustainable. 

On April 30, 2024, HLC sent a comment letter to Half Moon Bay’s planning commission describing the legal justification for approving the farmworker housing. Under current law, the planning commission has an opportunity to work with the developer to make marginal improvements. However, if the planning commission continues to make infeasible demands, developer, Mercy Housing, could use state laws coming into effect in 2025 to propose a much larger project. 

One of the most significant laws, SB 423, builds off existing state law, SB 35, to streamline an eligible housing proposal. SB 35, passed in 2017, requires ministerial processing–meaning no public hearings–of eligible housing projects in jurisdictions that do not meet their Regional Housing Needs Allocation (RHNA) target. SB 423 extends SB 35 to most properties in the coastal zone. The City of Half Moon Bay will be subject to SB 423.

Another law, AB 1633, makes it harder to abuse environmental laws to stall housing production. Specifically, AB 1633 expands the Housing Accountability Act’s definition of what it means to “disapprove the housing project” to include a city’s failure to make a determination of whether the project is exempt from CEQA or commits an abuse of discretion in that determination. This opens up a cause of action for applicants to sue local agencies that use CEQA delays as a means to effectively disapprove, render financially infeasible, or downsize a project without having actually voted to do so.

Read HLC’s public comment letter to Half Moon Bay’s planning commission to better understand these laws.