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8.A. - Page 123 <br /> housing choice. (2007 -2014 Housing Element, Program H -23.) While the current draft <br /> touts the Inner Harbor Precise Plan process as having the potential to facilitate alternative <br /> housing models (H -141), the draft housing element does not anywhere discuss the risks to <br /> the continued existence of Docktown or the risk of displacement of its residents, many of <br /> whom are lower- income and/or seniors. <br /> Constraints to the Development of Housing for People with Disabilities <br /> We applaud the City's adoption of a reasonable accommodation ordinance during the <br /> prior planning period. However, we are concerned that one aspect of the ordinance may <br /> create an unnecessary constraint to the development of housing for people with <br /> disabilities. Specifically, the Zoning Code provides that a reasonable accommodation <br /> request must not be granted unless "the request is the minimum necessary to provide the <br /> necessary relief from the city's zoning ordinance to meet the needs of the individual." <br /> (Redwood City Mun. Code, § 56.7, subd. (C).) This requirement is contrary to existing <br /> law regarding reasonable accommodations, which assumes that the person with a <br /> disability, not the agency granting it, is in the best position to decide whether an <br /> accommodation is appropriate to meet his or her needs. The question from the City's <br /> perspective in determining reasonableness should not be whether the requested <br /> accommodation is the minimum possible accommodation but whether it creates an undue <br /> administrative or financial burden or fundamentally alters the City's exercise of its land <br /> use power. As drafted, the reasonable accommodation ordinance appears to place too <br /> heavy of a burden on people with disabilities to obtain accommodations, and this <br /> language should be analyzed as a potential constraint. <br /> Sites Inventory and Analysis <br /> Redwood City argues that its Housing Sites Inventory (H -112 to H -120, Appendix B) <br /> shows that it can accommodate 3,333 units, or 175 percent of its RHNA (H -119). <br /> However, several deficiencies exist with the inventory, which need to be addressed. <br /> In general, the City assumes that every single unit developed on higher density parcels <br /> will be affordable to low- and very low- income households. This is a highly unrealistic <br /> assumption given the difficulty of developing such housing and the current market's <br /> strong emphasis on market -rate housing. <br /> As to the vacant land table (Table H -57), both of the sites listed as being able to <br /> contain affordable housing are very small (.75 and .44 acres). These parcels are <br /> unlikely to actually support this type of housing, despite the high current allowable <br /> densities for these sites (40 dwelling units per acre). Because the sites will only allow for <br /> the development of a small number of units, it is unclear whether these sites could <br /> realistically support the development of housing affordable to lower- income households. <br /> 3 <br />