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8.A. - Page 109 <br /> The draft should include discussions around additional policies and program responses <br /> that the City can more closely study for those at risk of displacement, such as tenant <br /> protections, as a response to this chronic and growing problem. This is consistent <br /> with CA Government Code Section 65583(c)(4). <br /> PERSONS WITH SPECIAL NEEDS (SECTION 65583(a)(7)) <br /> • Comments made in the previous section apply to special needs populations as well. <br /> These individuals and families have little or no prospect of finding permanent housing <br /> solutions once they have utilized existing emergency shelter and transition housing <br /> resources. <br /> POTENTIAL GOVERNMENTAL AND NON - GOVERNMENTAL CONSTRAINTS <br /> • HLC lauds the City of Redwood City for its participation in the countywide impact fee <br /> nexus study, aka the "Grand Nexus Study," which will among other things justify an <br /> impact fee on all new residential and commercial development. Fees and new sources <br /> of funds like this are particularly important in light of the loss of Redevelopment <br /> Agencies in 2012. <br /> • There is no discussion of Priority Development Areas (PDA) as a governmental <br /> constraints, given that land costs in and around PDAs will command higher prices and <br /> thus add to the difficulty of construction of affordable housing there and added cost <br /> pressures to renters as price increases in transit accessible areas push out lower- income <br /> residents. <br /> SITES INVENTORY AND ANALYSIS <br /> • We are happy to see that there are a number of sites that may be candidates for further <br /> density consideration and the City's commitment to encouraging and monitoring the <br /> construction of second units. However, in identifying opportunity sites for very low - <br /> and low- income housing, the City should take into consideration their competitiveness <br /> for Low Income Housing Tax Credits (LIHTC), which are used to fund the vast <br /> majority of affordable housing given the shortage of other funding sources. <br /> Specifically, opportunity sites are competitive when they are in proximity to transit, <br /> grocery stores, schools, libraries, senior centers and other key services and amenities. <br /> MidPen Housing recently performed a preliminary scoring of sites the city had <br /> designated for RHNA 4, which are again being used in RHNA 5. Several of the sites <br /> that were scored are located in areas that will be problematic for LIHTC eligibility <br /> should an affordable housing developer pursue development of the sites. The City <br /> should reflect these considerations in the sites inventory, given that affordable housing <br /> development will most likely not be feasible without being tax credit competitive. The <br />