# General plan documents — fresno-california Assembled by OpenPublica from the documents it serves for this government. Each section below is a separate publication by the government; page anchors (``) refer to pages of that section's own source PDF, linked in its heading. **Contains 6 documents.** OpenPublica has pinned these slots for this government: circulation, community_facilities, community_health_design, conservation, economic_development, general_plan_implementation, general_plan_introduction, historic_preservation, housing, housing_element_consistency, housing_element_multi_jurisdictional, land_use, noise, open_space, safety. That is what we have looked for, not a statement that the government publishes nothing else — a plan element absent here may simply not have been reviewed yet. Last reviewed 2026-09-10. --- ## Land Use — Fresno General Plan, Chapter 3: Urban Form, Land Use, and Design Element (amended October 2022) - Source: https://www.fresno.gov/wp-content/uploads/2023/03/upload_temp3-Urban-Form-10-13-22.pdf - Pages: 78 - Covers: land_use # 3 URBAN FORM, LAND USE, AND DESIGN The Urban Form, Land Use, and Design Element focuses on establishing a structural framework for the city, enhancing the character of neighborhoods and districts, creating vibrant centers of activity and a public realm that is engaging and livable, crafting a tapestry of distinctive, connected communities, and strengthening Fresno's identity and sense of place. How land use underlies the experience of living, working, and visiting Fresno is also critical. Besides policy direction on urban form, this element provides a basis for land use decision-making. It establishes a land use classification system, intensity and height standards, and citywide and area-specific land use policies. # 3.1 CONTEXT Land use is one of the seven general plan topics or elements required by California’s Planning and Zoning Law. While a city is required to address the mandatory seven topics or elements, State law allows a general plan format that best fits the unique circumstances of the city. The City of Fresno has chosen to combine the required components of a land use element within the larger context of an Urban Form, Land Use, and Design Element because of the close relationship that these topics have to one another in Fresno. In preparing this element, the City considered the impact of new growth on military readiness activities, and future development under the Plan is not anticipated to have any discernible impact on the Fresno Air National Guard military installation. Continuing enforcement of the Airport Land Use Plan for Fresno Yosemite International Airport will avoid interference with the military readiness activities at the military installation. Finally, given the absence of timber, forest land, and timber harvesting industry within the Planning Area, no land use classifications provide for timber production, nor are objectives and policies needed to address this subject. Plan Horizon and Buildout calculations are presented in the Introduction. Commonly used terms are defined in the Glossary. ## RELATIONSHIP TO GENERAL PLAN GOALS The objectives and policies of this element support the following General Plan goals:[^p2-1] 1. Increase opportunity, economic development, business, and job creation. *Use urban form, land use, and Development Code policies to streamline permit approval, promote local educational excellence and workforce relevance, significantly increase business development and expansion, retain and attract talented people, create jobs and sustained economic growth, strategically locate employment lands and facilities, and avoid over-saturation of a single type of housing, retail,, or employment.* [^p2-1]: The commentary in italics following certain goals is not part of the goal itself, but is instead advisory language intended to further discuss and clarify the goal, and to help guide the objectives of this General Plan. Chapter 3: Urban Form, Land Use, and Design 2. Support a successful and competitive Downtown. *Emphasize infill development and a revitalized central core area as the primary activity center for Fresno and the region by locating substantial growth near the Downtown core and along the corridors leading to the Downtown. Use vision-based policies in a development code specific to the Downtown, when adopted, to ensure the creation of a unique sense of place in the central core.* 3. Emphasize conservation, successful adaptation to climate and changing resource conditions, and performance effectiveness in the use of energy, water, land, buildings, natural resources, and fiscal resources required for the long-term sustainability of Fresno. 7. Provide for a diversity of districts, neighborhoods, housing types (including affordable housing), residential densities, job opportunities, recreation, open space, and educational venues that appeal to a broad range of people throughout the City. 8. Develop Complete Neighborhoods and districts with an efficient and diverse mix of residential densities, building types, and affordability which are designed to be healthy, attractive, and centered by schools, parks, and public and commercial services to provide a sense of place and that provide as many services as possible within walking distance. *Intentionally plan for Complete Neighborhoods as an outcome, rather than collections of subdivisions which do not result in Complete Neighborhoods.* 9. Promote a city of healthy communities and improve quality of life in established neighborhoods. *Emphasize supporting established neighborhoods in Fresno with safe, well maintained, and accessible streets, public utilities, education and job training, proximity to jobs, retail services, and health care, affordable housing, youth development opportunities, open space and parks, transportation options, and opportunities for home grown businesses.* 10. Emphasize increased land use intensity and mixed-use development at densities supportive of greater use of transit in Fresno. *Greater densities can be achieved through encouragement, infrastructure, and incentives for infill and revitalization along major corridors and in Activity Centers.* 12. Resolve existing public infrastructure and service deficiencies, make full use of existing infrastructure, and invest in improvements to increase competitiveness and promote economic growth. *Emphasize the fair and necessary costs of maintaining sustainable water, sewer, streets, and other public infrastructure and service systems in rates, fees, financing, and public investments to implement the General Plan. Adequately address accumulated deferred maintenance, aging infrastructure, risks to service continuity, desired standards of service to meet quality-of-life goals, and required infrastructure to support growth, economic competitiveness and business development.* 13. Emphasize the City as a role model for good growth management planning, efficient processing and permit streamlining, effective urban development policies, environmental quality, and a strong economy. Work collaboratively with other jurisdictions and institutions to further these values throughout the region. *Positively influence the same attributes in other jurisdictions of the San Joaquin Valley—and thus the potential for regional sustainability—and improve the standing and credibility of the City to pursue appropriate State, LAFCO, and other regional policies that would curb sprawl and prevent new unincorporated community development which compete with and threaten the success of sustainable policies and development practices in Fresno.* 15. Improve Fresno's visual image and enhance its form and function through urban design strategies and effective maintenance. 17. Recognize, respect, and plan for Fresno's cultural, social, and ethnic diversity, and foster an informed and engaged citizenry. *Emphasize shared community values and genuine engagement with and across different neighborhoods, communities, institutions, businesses and sectors to solve difficult problems and achieve shared goals for the success of Fresno and all its residents.* ## 3.2 CITYWIDE URBAN FORM Urban form is the configuration of the combined physical components of the city; it is created by the interrelationship of those components as they form a cohesive whole. The components of urban form include: circulation (streets, sidewalks, transit, and bikeways), open space, buildings, and natural features. A healthy and vibrant Downtown as the Primary Activity Center of the City is an essential aspect of a diverse, attractive, and successful urban form for the City. How these Chapter 3: Urban Form, Land Use, and Design components relate to one another determines the degree to which Fresno will be walkable, with inter-related uses forming Complete Neighborhoods. Many people see urban form as the ultimate determinate of “livability.” Visualize for a moment a favorite place to vacation or take a walk. What is it about such places that draw you to them? Do you feel safe? Are there others eating, shopping, or just people watching? Is the area shaded? How wide are the sidewalks? How fast do cars move? How tall are the buildings? Is this a good place to call home, raise a family, and pursue a career? Often it may be difficult to articulate exactly what brings a sense of attraction and satisfaction to an area. Yet no one would dispute that some cities and neighborhoods are more desirable than others. Ultimately, a number of components interconnect to make a place work well and thrive, though it is clear that significant contributions are made by physical components of a space that influence how people navigate, dwell, and work within a city. The future growth of Fresno offers the opportunity to create new neighborhoods that support a satisfying and productive lifestyle as well as to improve many established neighborhoods through careful planning. Urban form is what organizes the city, focuses growth, creates the best possible relationships between uses, provides services and mobility, and supports a quality of life that is so important to Fresnans. The major urban form themes in this element are: * Understanding the suburban style, auto-oriented development patterns that characterize much of Fresno today and the potential of improving that pattern in the future with walkable, pedestrian and transit-oriented development. * Identifying areas for growth through self-supporting communities and efficient infrastructure and considering strategies for accepting future growth. * Enhancing established neighborhoods that lack identity and an active core that supports a mix of uses and services interconnected to residences with a convenient network of pedestrian ways and bike paths. * Supporting Downtown as the Primary Activity Center of Fresno. * Defining parameters for growth within the City’s Sphere of Influence (SOI) that will ultimately be annexed to the City. * Establishing policies for Urban Form to achieve General Plan goals and objectives. Making the Most of Existing Conditions: A New Emphasis Fresno has generally grown out over the years from its first origins, Downtown. For decades that growth has been mostly of a low density suburban style development that relies heavily on the auto as the single means of mobility. This has created a condition of sprawl, sometimes leaving neglected neighborhoods and developed land uses adjacent to a number of major streets either vacant or underutilized. This can be seen in Downtown today, as well as other areas surrounding Downtown. A 1957 California Department of Highways plan called for construction of State Routes 99, 41, and 180 to form a freeway loop around Downtown, redirecting traffic around the City’s core rather than through it. The construction of this freeway loop system beyond State Route 99, starting in the 1980s, had a devastating impact on Downtown Fresno and its surrounding neighborhoods. Formerly unified neighborhoods were cut in two by freeways without surface crossings. Facilitated by the freeways, the City continued to stretch onto inexpensive land to the north and east, aiding the flight of people and businesses away from the center of the city. By 2009, Fresno had reached a population just under 495,000 in an area of 113 square miles. Infill opportunities in and around the center of Fresno, particularly in underutilized areas, hold great promise for recasting Fresno as a city of vibrant and Complete Neighborhoods. This can be done by creating a land use pattern and implementing policies that envision the revitalization of established neighborhoods and development of complete communities in growth areas, connected by multi-use corridors served by Bus Rapid Transit (BRT) and enhanced bus service. Through the Urban Form, Land Use, and Design Element of the General Plan, there is opportunity to enhance existing infrastructure to support a more urban and moderately higher density model of growth in the future. This can inspire creative thinking about Fresno’s urban form by its increasingly diverse population. Major Strategic Directions for Future Growth This General Plan shifts emphasis from a city dominated by suburban growth to one that also shares increased urban development in the form of infill and rehabilitation, along with new Activity Centers with mixed-uses and neighborhoods in growth areas. The basis of this Plan’s concepts are formed by balancing more efficient infill, Downtown, and neighborhood revitalization; Chapter 3: Urban Form, Land Use, and Design transit-oriented development along major streets; mixed-uses in new Activity Centers in growth areas; and the building of Complete Neighborhoods. Major urban form components include Activity Centers with mixed-uses, intensification, and infill development. Some of these Activity Centers are generally located on land along the first phase of the BRT system. The first phase is composed of BRT corridors along Blackstone Avenue between Downtown and the major shopping centers from Herndon Avenue to Nees Avenue, and along Ventura Avenue-Kings Canyon Road from Downtown to Clovis Avenue. Concurrently there will be enhanced bus service along Shaw Avenue. As demand necessitates, later phases of BRT may include: * The California Avenue BRT corridor, which will connect southwest Fresno from the area located between Hughes and Marks Avenues to Downtown; and * The Shaw Avenue corridor, which will support the opportunity for focused intensity at the West Shaw Activity Center proposed at Veterans Boulevard and Shaw Avenue west of State Route 99, extending south along Grantland Avenue to the Grantland Transit Village between Ashlan and Shields Avenues. The Mobility and Transportation Element contains policies on developing and implementing effective, convenient, and safe public transportation and parking programs to meet the interrelated needs of Downtown and proposed BRT corridor land use development. Employment centers in existing developed areas and in growth areas, composed of high concentrations of office, business parks and districts, and industrial clusters, are also important components of urban form. These areas have traditionally been served by freeways, freight rail, and major streets, and now will be additionally served by proposed BRT corridors with more intense land uses generating many new business and employment opportunities. New smaller scale business parks and larger scale regional business park campuses are shown on Figure LU-1: General Plan Land Use Diagram, in addition to traditional light and heavy industry locations, and will be designed to be more compatible and appropriate to co-exist next to residential neighborhoods, retail, and mixed-use districts. The General Plan does not expand the City’s SOI[^p8-2] beyond its extent as of December 31, 2012 for residential and commercial development.[^p8-3] This strategy supports the goals of this General Plan, particularly the success of Downtown, protection of agriculture, improvement of established neighborhoods, and efficient use of existing and future public infrastructure. The Land Use section addresses annexation policy. ### Concepts for Focus Areas Infill and development in growth areas will be in accord with General Plan land use designations, goals, objectives, and policies, and updated zoning and subdivision provisions. It is anticipated that policy direction for the Downtown Planning Area will be refined by community, Specific Plans, and neighborhood plans and further implemented by a Downtown Development Code after the General Plan is approved. In growth areas and large infill areas outside of the Downtown Planning Area, subsequent Specific Plans or Concept Plans are also anticipated to refine more discreet land use and transportation design integration and intensity with necessary public facilities, maintenance, and services financing. CEQA streamlining will facilitate this refinement because the City will have a Master Environmental Impact Report (MEIR) in place that may address the major issues from these “subsequent projects” for identified growth areas and certain large infill areas. These subsequent projects are described for CEQA purposes in the MEIR. It is anticipated that these subsequent Specific Plans will include preparation of design guidelines and standards, and infrastructure financing programs. The sheer scale of existing developed land in need of reinvestment, coupled with Fresno’s fiscal constraints, means that near-term actions need to focus on smaller geographic areas where there are opportunities to leverage public and private [^p8-2]: Except for a possible expansion south for industry and employment, proximate to the SOI boundary between SR41 and SR99, to accommodate a maintenance yard and facilities, and industrial parks surrounding and supporting High Speed Rail functions. See Policy LU-1-g: SOI Expansion. [^p8-3]: The SOI has not been expanded since 2006. Chapter 3: Urban Form, Land Use, and Design investment concurrently and build on existing assets. These areas have the best development potential and targeted investments can put in motion a positive feedback cycle, whereby a sustained level of public and private investment signals to the marketplace that something positive is happening. ### Infill Incentives This General Plan emphasizes and builds on the City’s interest in supporting infill development, which includes a number of fiscal, environmental, economic, social, transportation, and resource related benefits. Land Use policies listed here establish a more cohesive city environment with vibrant neighborhoods, BRT corridors, and Activity Centers that are implemented through increased infill development. See Figure IM-1 (Chapter 12). Infill incentives, priority areas, and project application process streamlining are the focus of the Infill Development Act (IDA) approved by the Fresno City Council on November 1, 2012 and the Fresno General Plan Implementation and Infill Finance Task Force (Task Force) Final Report prepared by the Task Force in in late 2013. Both the IDA and the recommendations in the Task Force Final Report are discussed in the Implementation Element of this General Plan which set the framework for the implementation strategies that will facilitate increased infill development in the city of Fresno. A key recommendation from the Task Force is to prioritize and incentivize rehabilitation and new construction in the Downtown Planning Area, along BRT Corridors, and within established neighborhoods generally south of Herndon Avenue. ### Complete Neighborhoods Much of Fresno has been built as discrete residential tracts bordered by strip retail centers, many of which are not accessible from the adjacent homes due to security walls or other barriers. By contrast, the Complete Neighborhoods concept will enable Fresnans to live in communities with convenient services, employment, and recreation within walking distance. Complete Neighborhoods are not and should not be all alike. In fact, each neighborhood should express the needs, character, and values of its residents through the specific arrangement of the many possible characteristics that make up each neighborhood. All elements of a neighborhood do not need to be of the same architectural style to create a Complete Neighborhood. While it is important to use common design components to create interest and character, individuality of the various parts of the neighborhood is more important. The defining characteristic of a Complete Neighborhood is a neighborhood that is mostly self-sufficient, walkable, and interconnected. It provides residents with most all they need on a daily basis nearby. In other words, a Complete Neighborhood anticipates and plans in advance all amenities needed in a neighborhood to ensure quality and lasting property values before the residential units are built instead of trying to piecemeal those amenities after the fact. This convenient and healthy lifestyle is the benefit of a Complete Neighborhood. While total self-sufficiency or even completeness is unlikely to be accomplished in each neighborhood, all or most of the following characteristics can be combined to create an enhanced quality of life and retained and increased property values: * A range of housing choices; * Neighborhood-serving retail; * A range of employment opportunities; * Public services, such as health clinics; * Entertainment and cultural assets; * Parks and public schools within or near the neighborhood; * Community services, such as a library, recreation center, senior center, and/or community garden; * Public plaza/civic space; and * Access to public transit. This list can be combined and arranged in each specific neighborhood in such a way as to create a true sense of place and community that improves quality of life and increases property values. ### Connectivity and Walkability In Fresno, the early street grid pattern created neighborhoods with relatively small blocks, which can still be easily walked today due to their interconnected nature. However, as Fresno developed, the street and lot patterns changed, particularly after the advent of the automobile. Rather, the norm became blocks of 200 feet wide by 600 to 1300 feet in length, which are not as easily walked. The orientation of these blocks also directly impacted the number of access points to the major roadways, with the longer block lengths running parallel to major roadway frontages, thus providing less connectivity and walkability. As subdivision design introduced the cul-de-sac and further interrupted the traditional grid patterns, neighborhoods were intentionally cut off, becoming isolated and disconnected from other adjacent uses and neighborhoods. Chapter 3: Urban Form, Land Use, and Design Wide streets and long blocks result in the need to drive for even the shortest of trips, leading to more traffic congestion and worse air quality. Smaller block sizes in a connected pattern create the opportunity to easily walk to the corner store, visit a friend, or even to work. <
> *Complete Streets can include a substantial tree canopy and landscaping to create a sense of place, provide shade, and reduce heat build-up, as shown above.* A centerpiece of the Mobility and Transportation Element is a Complete Streets system. Complete Streets are designed and operated to enable safe, attractive, and comfortable access and travel for all users such as pedestrians, bicyclists, motorists and public transport users of all ages and abilities. Among their advantages, Complete Streets are intended to encourage health through walking and biking, create a sense of place, improve social interaction, and generally improve adjacent property values. Complete Streets can also incorporate landscaping and a substantial tree canopy as a feature to reduce heat build-up and create a tunnel effect, shown to slow down vehicle traffic. OBJECTIVE | | | | :--- | :--- | | **UF-1** | Emphasize the opportunity for a diversity of districts, neighborhoods, and housing types. | IMPLEMENTING POLICIES **UF-1-a** **Diverse Neighborhoods.** Support development projects that provide Fresno with a diversity of urban and suburban neighborhood opportunities. *Commentary:* Future growth will occur in a range of higher, medium, and lower densities in existing and new mixed-use urban centers, compact neighborhoods, and suburban areas. This policy also envisions making use of underutilized land, reducing long-term farmland conversion, supporting transit and multiple transportation modes, mixing and balancing compatible residential and retail uses in new growth areas, and existing infill areas to produce economic opportunities, jobs, housing options, recreation, and other choices. **UF-1-b** **Revitalized Downtown Planning Area.** Support adoption of community plans or Specific Plans, Downtown Development Code, programs, and streamlined regulations to support a revitalized Downtown Planning Area as the Primary Activity Center for Fresno and the surrounding region. *Commentary:* The General Plan anticipates the Downtown Planning Area will be further refined through specific and community plans, such as the proposed Downtown Neighborhoods Community Plan (DNCP) and the Fulton Corridor Specific Plan (FCSP), and further implemented through the adoption of a new Development Code for regulations specific to Downtown Planning Area. **UF-1-c** **Identifiable City Structure.** Focus integrated and ongoing planning efforts to achieve an identifiable city structure, comprised of a concentration of buildings, people, and pedestrian-oriented activity in Downtown; along a small number of transit-oriented, mixed-use corridors and strategically located Activity Centers; and in existing and new neighborhoods augmented with parks and connected by multi-purpose trails and tree lined bike lanes and streets. **UF-1-d** **Range of Housing Types.** Provide for diversity and variation of building types, densities, and scales of development in order to reinforce the identity of individual neighborhoods, foster a variety of market-based options for living and working to suit a Chapter 3: Urban Form, Land Use, and Design large range of income levels, and further affordable housing opportunities throughout the city. *Commentary: The Development Code will provide guidance to promote continuity in development scale and character and transitions between densities and design typologies.* **UF-1-e** **Unique Neighborhoods.** Promote and protect unique neighborhoods and mixed use areas throughout Fresno that respect and support various ethnic, cultural and historic enclaves; provide a range of housing options, including furthering affordable housing opportunities; and convey a unique character and lifestyle attractive to Fresnans. Support unique areas through more specific planning processes that directly engage community members in creative and innovative design efforts. **UF-1-f** **Complete Neighborhoods, Densities, and Development Standards.** Use Complete Neighborhood design concepts and development standards to achieve the development of Complete Neighborhoods and the residential density targets of the General Plan. ### 3.3 INFILL DEVELOPMENT An Objective of this General Plan is to plan for infill development. The terms “infill area” and “infill development” are intended to be used interchangeably, and shall be defined as consistent with the definition of “infill area” set forth in Objective UF-12. However, the City acknowledges that various statutes articulate alternative definitions for “infill.” To the extent that the City must comply with those alternative statutory definitions, the definitions of “infill” contained within Public Resources Code 21061.3 and CEQA Guidelines 15332 may apply. **The Downtown Planning Area and the Fulton Street Corridor** The centerpiece of Fresno is the Downtown Planning Area. The General Plan anticipates the Downtown Planning Area will be further refined through specific and community plans, such as the proposed DNCP and the FCSP, and further implemented through the adoption of a new Development Code for regulations specific to the Downtown Planning Area. The General Plan, as well as these proposed plans, envisions a new focus on land use and design along major streets and in neighborhoods that support Downtown, with an emphasis on Fulton Street. This new focus includes proposals for increased density and vibrant mixed-use centers that will emanate from the Downtown area along the Blackstone Avenue, Ventura Avenue-Kings Canyon Road, and California Avenue transportation corridors (described below), extending the reach of and connections with Downtown in all directions. ### OBJECTIVES | | | | :--- | :--- | | **UF-2** | Enhance the unique sense of character and identity of the different subareas of the Downtown neighborhoods. | | **UF-3** | Revitalize the Downtown to be the economic and cultural heart of Fresno and the region. | | **UF-4** | Support and encourage arts and culture in the Downtown neighborhoods. | | | *Commentary: As part of Plan implementation, the City will prepare and adopt regulations and programs to support and encourage arts and culture in the Downtown neighborhoods.* | | **UF-5** | Promote a greater concentration of buildings and people in the Downtown. | | **UF-6** | Support new development in the Downtown through investment in public infrastructure. | | **UF-7** | Promote a diverse mix of uses in the Downtown in order to create a community with a 24 hour entertainment district. | | **UF-8** | Develop each of Downtown’s neighborhoods and districts, according to its unique character. | | **UF-9** | Capitalize on the High Speed Train system to help revitalize the Downtown neighborhoods. | | | *Commentary: As part of Plan implementation, the City intends to prepare and adopt a station area plan to capitalize on the High Speed Train system to compliment and encourage revitalization in the Downtown Planning Area.* | UF-10 Calibrate parking according to the Downtown’s parking needs and make it efficient and easy to find. UF-11 Revitalize the Fulton Corridor consistent with the reconstruction project. ### BRT Corridors & Centers Fresno’s BRT corridors offer great opportunities for future growth over time in the form of mixed-use development on sites that are now underutilized or vacant. Vibrant Activity Centers with public spaces, medium-high and high-density residential, retail, and employment uses will be located on these major street corridors. The Activity Centers will also support surrounding neighborhoods, multi-modal transportation including the BRT system, and Downtown. BRT corridors proposed in the General Plan include the following: ### Blackstone Avenue Corridor Blackstone Avenue is currently the most prominent major street corridor connecting the Downtown area to the northern areas of Fresno, including the major commercial centers concentrated between Herndon and Nees Avenues. This major street is part of the first phase planned BRT route for transit supportive corridor related land use development and contains many “opportunity sites” that may be developed into Activity Centers in the future. Naturally, this development will occur over time as properties become available or landowners choose to re-develop. Initially, the BRT stops will occur every half-mile. Eventually, Blackstone Avenue is planned to have major BRT stations and surrounding mixed-use centers at one-mile intervals, located at the intersections of major east-west avenues such as Bullard, Shaw, Ashlan, Shields, and McKinley. Ultimately, the BRT stations will be the focus of mixed-use development that is pedestrian-oriented and closely ties the stations with the surrounding neighborhood. ### Ventura Avenue - Kings Canyon Road Corridor Ventura Avenue and Kings Canyon Road link the Downtown with the Southeast Development Area (SEDA) to the east. Much of the major street corridor is contained in the area anticipated to be encompassed by the DNCP, and the General Plan contains urban form and land use concepts and strategies from that proposed plan. Both north and south sides of this corridor are planned with existing and new residential neighborhoods. Like the Blackstone Avenue Corridor, the Ventura Avenue - Kings Canyon Road Corridor offers many opportunities for mixed-use development on both under-utilized properties and vacant land. This corridor is envisioned to be developed in the future with areas of multi-family housing facing directly on the street and retail centers integrated with housing at the one-mile and half-mile road intersections. At certain intersections, such as the Clovis Avenue intersection, more intense sub-regional mixed-use development is planned to occur. Much of the Ventura Avenue – Kings Canyon Road west of Chestnut Avenue is expected to evolve over time as a “Main Street” environment. Main Street Commercial designation encourages a traditional “Main Street” character with active storefronts, outdoor seating, and pedestrian-oriented design. This land use and design type promotes primarily one to two story retail uses, with moderate office and minimal multi-family as supportive uses. ### Clovis Avenue – State Route 180/Belmont Corridor The Clovis Avenue – State Route 180/Belmont Corridor is essentially an extension of the Ventura Avenue - Kings Canyon Road Corridor and BRT system up Clovis Avenue to State Route 180 interchange area, including land along Belmont Avenue. The intent for this corridor is to promote mixed-use, transit-oriented development surrounding the planned Fancher Creek Town Center, which is to be located at the intersection of Clovis Avenue and Tulare Street. It is envisioned as an area of highly integrated residential uses with a variety of densities and types designed in and around a regional activity and commercial center. Development in this corridor will involve a combination of infill, revitalization, and new construction on large, by-passed parcels. Because of its proposed density, mix of uses, and connectivity, the area could also host a Park-and- Ride lot, especially near the State Route 180/Clovis Avenue interchange. ### Shaw Avenue Corridor The Shaw Avenue Corridor will be served by enhanced bus service and is envisioned as the primary transit corridor connecting Fresno and Clovis. This enhanced service in Fresno will extend along Shaw Avenue as far east as the intersection of State Route 168 and the California State University, Fresno, campus and as far west as the West Development Area located west of State Route 99. Shaw Avenue has been an important corridor in Fresno for decades, with much of the area’s retail and employment uses located there. As opportunities arise, it is envisioned that the Shaw Avenue Corridor will be developed as mixed-use infill with a variety of building types and sizes. Particular attention will be paid to urban design to make sure that the scale and form of new buildings are always coordinated with existing development. This includes improving connectivity with new development along the Shaw Avenue Corridor with the surrounding and adjoining neighborhoods. Chapter 3: Urban Form, Land Use, and Design California Avenue and West Shaw Avenue Future Transit Corridors The West Shaw Avenue Corridor (west of State Route 99) is discussed in the “West Development Area” section below. The California Avenue Corridor is discussed in the “Southwest Development Area” section. Non-Corridor Infill Fresno needs to promote well-designed infill and rehabilitation throughout the city, not just along the corridors. This includes single-family lots, small multi-family lots and small subdivisions. There will also be revitalization and rehabilitation over the years of small retail centers, employment centers and some multi-family properties. These infill developments and redevelopments will focus on creating Complete Neighborhoods in existing areas. Some tools that can be used to accomplish this include: connectivity, financial incentives for investing in established neighborhoods, design compatibility, providing missing uses such as recreation, enhanced landscaping and maintenance of public right-of-way areas, and providing community-based services. OBJECTIVE UF-12 | Locate roughly one-half of future residential development in infill areas—defined as being within the City on December 31, 2012—including the Downtown core area and surrounding neighborhoods, mixed-use centers and transit-oriented development along major BRT corridors, and other non-corridor infill areas, and vacant land. *Commentary: The Planning Director will provide an annual report describing the City’s compliance with the Plan and progress toward meeting the goals and objectives to City Council, and prepare, every five years, an updated plan for achieving this goal, with recommended appropriate policy amendments and also new implementation strategies necessary to meet this goal by 2035. The rate of progress toward meeting this goal is not expected to occur in a linear or “one-to-one” pattern. Development in infill areas versus growth areas may progress in an uneven pattern, depending upon the schedule of relevant key incentive programs (such as those related to BRT) and the impact of market forces. However, the City expects to make steady progress toward all the goals and objectives and anticipates meeting them at or near the close of General Plan Horizon in 2035. See the Implementation Element for additional implementation strategies for this objective.* IMPLEMENTING POLICIES **UF-12-a** **BRT Corridors.** Design land uses and integrate development site plans along BRT corridors, with transit-oriented development that supports transit ridership and convenient pedestrian access to bus stops and BRT station stops. *Commentary:* Developments close to major streets encourages walking and can be connected with the adjacent neighborhoods through a network of pedestrian ways. Parking will be concealed from the street, and predominant residential uses will be considered an acceptable use in all mixed-use areas. **UF-12-b** **Activity Centers.** Mixed-use designated areas along BRT and/or transit corridors are appropriate for more intensive concentrations of urban uses. Typical uses could include commercial areas; employment centers; schools; compact residential development; religious institutions; parks; and other gathering points where residents may interact, work, and obtain goods and services in the same place. *Commentary:* Activity Centers are typified by a full range of uses, including residential, retail, employment, education, recreation, public amenities, and/or open space features. Near the mixed-use central area of the Activity Center, there are typically higher residential densities, typically 15 to 45 dwelling units per acre, but away from the center of the Activity Center, uses become predominantly residential at lower densities. **UF-12-c** **Local-Serving Neighborhood Centers.** Design Neighborhood Centers for local services and amenities that build upon the character and identity of surrounding neighborhoods and communities. **UF-12-d** **Appropriate Mixed-Use.** Facilitate the development of vertical and horizontal mixed-uses to blend residential, commercial, and public land uses on one or adjacent sites. Ensure land use compatibility between mixed-use districts in Activity Centers and the surrounding residential neighborhoods. *Commentary:* Vertical mixed-use may be achieved within the same building with multiple compatible uses in multiple stories, and horizontal mixed use may be achieved across an integrated Chapter 3: Urban Form, Land Use, and Design development site with a mix of compatible and complementary uses housed in different buildings. **UF-12-e** **Access to Activity Centers.** Promote adoption and implementation of standards supporting pedestrian activities and bicycle linkages from surrounding land uses and neighborhoods into Activity Centers and to transit stops. Provide for priority transit routes and facilities to serve the Activity Centers. **UF-12-f** **Mixed-Use in Activity Centers.** Adopt a new Development Code which includes use regulations and standards to allow for mixed-uses and shared parking facilities. **UF-12-g** **Impacts on Surrounding Uses.** Establish design standards and buffering requirements for high-intensity Activity Centers to protect surrounding residential uses from increased impacts from traffic noise and vehicle emissions, visual intrusion, interruption of view and air movement, and encroachment upon solar access. **UF-12-h** **Parking Standards for Shared Parking.** Explore opportunities to provide shared parking within mixed-use designations to reduce the need to construct large parking lots or structures needed for peak use times only. ### 3.4 DEVELOPMENT AREAS[^p19-4] The pace of new development in the Development Areas needs to be balanced with the City’s goals for achieving significant reinvestment within the 2012 City Limits. Development Areas are generally depicted on Figure I-3: Residential Capacity Allocation. Figure LU-1: General Plan Land Use Diagram shows the general mix of compatible uses recommended residential designations for the Development Areas. Concept Plans will achieve the optimum benefits of designing new neighborhoods as Complete Neighborhoods. As discussed earlier, Complete Neighborhoods are a key planning concept for development of new residential areas in designated Development Areas. [^p19-4]: Development Area descriptions, densities, illustrative diagrams, land uses, circulation network, etc., are based on the August 9, 2012 Land Use Diagram Draft Figure 2 of the Initiation Draft. Complete Neighborhoods are neighborhoods connected with a range of housing types; employment, supporting retail and service uses; parks and open space; and public/civic uses. ## Concept Planning The General Plan aims to achieve efficient, attractive, and resilient development in the Development Areas through the implementation of Complete Neighborhoods. Some key attributes of Concept Plans are described below. * Much of the implementation will involve coordinating a harmonious integration of new growth areas and existing development. * Subdivision and proposed commercial developments should depict how the project may impact surrounding properties, including how street connectivity will be achieved within the Concept Plan area. * Concept Plans should envision parks, and in some cases a school, with higher densities located around the park and school, and predominantly residential development with a mix of housing types beyond the core. * Concept Plans should capture the Complete Neighborhood potential of the area. * Retail and employment centers should be allowed to serve the neighborhood. ## West Development Area The West Development Area (see Figure UF-1: West Development Area Land Use Diagram below) provides many opportunities for the development of Complete Neighborhoods. New neighborhoods will be integrated with the urbanized areas of Fresno to the east through the connections afforded by roadways and future BRT corridors. As each neighborhood evolves, existing subdivisions will become an integrated part of the overall plan. ## West Shaw Avenue Corridor & Transit Village The Shaw Avenue Corridor from State Route 99 to the Grantland Avenue intersection is envisioned to be developed as a mixed-use corridor supported by enhanced transit service, which includes high density and urban neighborhood residential components, along with retail, employment and civic uses. There is a proposal for a Community Park, up to 40 acres in size, along the east side of Veterans Boulevard between Shaw Avenue and Barstow Avenue, which will anchor the West Shaw Transit Village. The park is bisected by a Class 1 bike trail along the Herndon Canal. A regional mixed-use center is designated between Veterans Boulevard and Grantland Avenue. These land uses will be mixed both Chapter 3: Urban Form, Land Use, and Design vertically and horizontally, and represent the transit-oriented cores of Complete Neighborhoods connected with surrounding residential areas. ### Grantland Avenue Transit Village A mixed-use transit-oriented center is contemplated along the east side of Grantland Avenue between Ashlan and Shields Avenues, as part of the proposed Grantland-East Communities. Initial development is contemplated in the area bounded by Ashlan, Bryan, Shields, and Grantland Avenues, with multi-family, retail, park, and school uses along the east side of Grantland Avenue. The Grantland Avenue Transit Village will be an area of focus for a Complete Neighborhood, as a high density and urban neighborhood with residential development around a 15-acre Community Park and 15-acre mixed-use neighborhood shopping center, complementing a Central Unified School site on the west side of Grantland Avenue. ### Grantland-East Communities The Grantland-East Communities, generally bounded by Ashlan, Polk, Clinton, and Grantland Avenues, will be coordinated with the Grantland Avenue Transit Village developments, and support their land uses and plan configurations. Of the 12 quarter sections (160 acres per section, generally formed by the half-grid of major streets) within the Grantland-East Communities boundary, the nine sections south of Ashlan Avenue will develop via Concept Plans. This design creates access to over 600 acres of useable, but currently inaccessible land, within these quarter sections, ringed by rural residential lots. The City will work closely with property owners and developers to develop Concept Plans that capture the Complete Neighborhood potential of these areas. The concept envisions parks, and in some cases a school, located at the center, with medium-high and urban residential density multiple-family and townhome development clustered around the park and school, and predominantly medium-density residential development with a mix of housing types beyond the core. Figure UF-1: West Development Area Land Use Diagram <
> **Southwest Development Area** The Southwest Development Area (see Figure UF-2: Southwest Development Area Land Use Diagram) contains a significant amount of the vacant residentially designated land within the City’s SOI, but the area has not yet exhibited much market demand to develop typical suburban neighborhoods with desired commercial and retail services. The area is generally characterized by a patchwork of un-coordinated existing subdivisions, industry, and farmland. However, the General Plan envisions great opportunities in southwest Fresno that can be created by focusing on the development of Complete Neighborhoods: eventually providing a BRT corridor along California Avenue, creating a Transit Village between Hughes and Marks Avenues, and building a regional shopping center and community park with surrounding neighborhood development Chapter 3: Urban Form, Land Use, and Design between Church and Jensen Avenues along Martin Luther King Boulevard (MLK) west of the Rutherford B. Gaston Middle School. California Avenue is a primary corridor connecting the Southwest Development Area to Downtown, the Blackstone Avenue Corridor north, and the Ventura Avenue-Kings Canyon Road Corridor east to SEDA. Over time, this corridor will contain substantial new development, infill and redevelopment providing market feasible opportunities for mixed-use development that furthers the goals of the General Plan. California Avenue will have a Complete Street system and transit network to connect southwest Fresno to other metro area communities. The Veteran’s Community Activity Center will be centered by a community park next to the Veteran’s Home Complex located on the southeast corner of Marks and California Avenues. This area is envisioned for high density and urban neighborhood residential density around the core with Complete Neighborhoods to the north, south, and east. The Veteran’s Community Activity Center will anchor the western terminus of the California Avenue Transportation Corridor system, supplying a unique and desirable destination and urban living environment in southwest Fresno. ### Southwest Neighborhoods In addition to the California Avenue Corridor and Veteran’s Community Activity Center, one other focus area is the Southwest Neighborhoods, which is generally bounded by Church, Marks, North, and Elm Avenues. New medium and medium low density neighborhoods adjoining existing residential areas are designed with local streets, centered by parks, multi-family, townhomes, and in some cases, schools to form a network of Complete Neighborhoods, as is proposed in other Development Areas. Neighborhood shopping centers are located to serve these new clusters of neighborhoods. ### Martin Luther King Boulevard (MLK) Activity Center A regional shopping center on the northwest corner of Jensen Avenue and MLK Boulevard is proposed to be integrated with a higher density neighborhood district between Church and Jensen Avenues along MLK, centered by a community park across from the new Fresno Unified School District Rutherford B. Gaston Middle School complex. This regional retail use will serve the Southwest Development Area, established neighborhoods in southwest Fresno, proximate residential areas in southeast Fresno, and rural areas to the south and west of Fresno. The MLK Village is on the southern edge of the Downtown Planning Area and will also serve residents in that area. Figure UF-2: Southwest Development Area Land Use Diagram <
> ### Southeast Development Area (SEDA) The original Southeast Growth Area Specific Plan (see Figure UF-3: Southeast Development Area Land Use Diagram), or SEGA, contains approximately 9,000 acres and was formally designated as a Growth Area in the 2025 Fresno General Plan. While originally called SEGA, this area is now referred to as the Southeast Development Area (SEDA). SEGA was approved in 2006 by the Local Agency Formation Commission (LAFCO) for incorporation into the City with a number of provisions that included preparation of a Specific Plan and associated environmental assessment documents before any annexations of land to the City could be approved. The City started the process of preparing a Specific Plan for SEGA, but due to delays, the planning for SEGA was rolled into the City-wide General Plan Update, as the supporting environmental analysis required by CEQA was not completed, nor the Chapter 3: Urban Form, Land Use, and Design draft Specific Plan approved by the City. The planning concepts for SEGA have been used to guide the planning for the SEDA. Planning concepts for SEGA included design and development concepts for street, block, and lot patterns; bike and pedestrian access and circulation; open spaces; mixed-use centers; neighborhoods; building orientations; energy and water saving approaches; employment areas; subdivisions; site planning; and more. These items are illustrative of configuration types suitable for the Southeast Development Area to the extent they are not inconsistent with this General Plan. Planning now for ultimate urban land uses, circulation, intensities, and urban design for SEDA is imperative for preserving land and protecting the surrounding agriculture and rural areas. Absent new technology, treated water sources, additional recharge or offsets, or significant reduction in consumption achieved through conservation or other methods, metropolitan surface water treatment and wastewater infrastructure systems are also needed to support Fresno, Clovis, and eventual SEDA development. This Development Area also has the unique feature of an eastern border designated as a permanent buffer, which is designed to separate and preserve long-term agriculture to the east and outside SOI boundary from urban uses further to the west inside the SOI boundary. In SEGA, each subarea was proposed to be developed with a master plan, and potentially, property owner agreements to achieve the scale and intensity required to support independent district type financing structures for necessary public infrastructure, and ongoing maintenance and public service costs. General Plan Development Areas generally follow SEGA subarea descriptions. These areas will require additional planning, such as a Specific Plan and/or concept planning in conformance with the City-County MOU for development of this area. ### North SEDA (North of McKinley Avenue) The North SEDA subarea is planned with two community centers that are surrounded by Residential-Urban Neighborhood and Residential-Medium Density land uses. A K-12 educational complex planned by Clovis Unified School District is anticipated to be located adjacent to the community center at Clinton and Highland Avenues. It is anticipated that there will also be two neighborhood centers located amidst the residential areas that are designated Public Facilities – Neighborhood Center. Central SEDA (between McKinley & Jensen Avenues) Central SEDA is bounded by McKinley, Highland, Jensen and Temperance Avenues. This subarea would be characterized by a regional center designated as Regional Mixed Use, three community centers designated as Corridor/Center Mixed Use, and fourteen neighborhood centers designated as Public Facilities – Neighborhood Center. It is anticipated that the regional center also will contain three employment centers. It would be desirable to integrate the regional center and community centers with mixed residential, while locating the neighborhood centers in either neighborhood residential or existing rural residential areas designated as low density residential. Peach – Jensen Avenues Neighborhood The Peach-Jensen Avenues Neighborhood subarea, generally bounded by Peach, Jensen, Minnewawa, and North Avenues, is deemed appropriate for long-term residential uses. It represents an additional growth subarea opportunity in southeast Fresno for development of Complete Neighborhoods. It is just outside the SEDA boundary to the west and complements SEDA development planned around the regional education and vocational training complex proposed by the State Center Community College District (SCCCD) at Clovis and North Avenues. It is anticipated that this new neighborhood will adjoin and support a proposed Activity Center with a future community college at Clovis Avenue to the east and a business park and light industrial employment center to the west. Primarily a residential area, the area would be served with local streets, park and recreational trails, and multi-family townhomes, and it will be filled-out by medium density residential to conform with adjacent centers. South SEDA (South of Jensen Avenue) South SEDA is generally bounded by Temperance Avenue to North Avenue, North Avenue to Minnewawa Avenue, Minnewawa to Jensen Avenue, and Jensen back to Temperance Avenue. This subarea is also planned with two community centers and four neighborhood centers, with surrounding mixed residential and neighborhood residential beyond the centers. This area is also intended to feature a major education and vocational training complex proposed by the SCCCD and significant land designated for employment in regional business parks with light industry and a range of businesses and enterprises. Land use in South SEDA is proposed with Complete Neighborhoods anchored by mixed-use centers to be integrated and compatible with these larger institutional and employment users. Chapter 3: Urban Form, Land Use, and Design Figure UF-3: Southeast Development Area Land Use Diagram <
> OBJECTIVE **UF-13** Locate roughly one-half of future residential development in the Growth Areas—defined as unincorporated land as of December 31, 2012 SOI—which are to be developed with Complete Neighborhoods that include housing, services, and recreation; mixed-use centers; or along future BRT corridors. *Commentary: The Planning Director will provide an annual report describing the City’s compliance with the Plan and progress toward meeting the goals and objectives to City Council and every five years prepare an updated plan for achieving this goal, with recommended appropriate policy amendments and also new implementation strategies necessary* to meet this goal by 2035. The rate of progress toward meeting this goal is not expected to occur in a linear or “one-to-one” pattern. Development in infill areas versus growth areas may progress in an uneven pattern, depending upon the schedule of relevant key incentive programs (such as those related to BRT) and the impact of market forces. However, the City expects to make steady progress toward all the goals and objectives and anticipates meeting them at or near the close of General Plan Horizon in 2035. See the Implementation Element for additional implementation strategies for this objective. ### IMPLEMENTING POLICIES **UF-13-a** | **Future Planning to Require Design Principles.** Require future planning, such as Specific Plans, neighborhood plans or Concept Plans, for Development Areas and BRT Corridors designated by the General Plan to include urban design principles and standards consistent with the Urban Form, Land Use, and Design Element. *Commentary:* The General Plan requirements and regulations will be further defined through Specific Plans, neighborhood plans and Concept Plans to coordinate more discreet land use and transportation design integration and intensity with necessary public facilities, maintenance, and services financing for Development Areas following General Plan adoption and the subsequent adoption of a new Development Code. ### OBJECTIVE **UF-14** | Create an urban form that facilitates multi-modal connectivity. *Commentary.* Multi-modal connectivity creates the opportunity for people to travel through a variety of modes of transportation, including biking, walking, driving, and using public transit. ### IMPLEMENTING POLICIES **UF-14-a** | **Design Guidelines for Walkability.** Develop and use design guidelines and standards for a walkable and pedestrian-scaled environment with a network of streets and connections for pedestrians and bicyclists, as well as transit and autos. Chapter 3: Urban Form, Land Use, and Design *Commentary.* These guidelines will highlight how to achieve these design ideas and avoid barriers to access, such as: * *Walls and fences that separate related uses or isolate neighborhoods;* * *Over reliance on cul-de-sacs and dead end streets that cut off access within neighborhoods;* * *Disconnected bike and pedestrian paths;* * *Wide streets that lack pedestrian support, such as sidewalks, median strips, and a landscaped strip that separates pedestrians from the street;* * *Street front parking lots that separate pedestrian from commercial operations;* * *Retail centers that are exclusively auto-oriented;* * *Transit stops that are not easily accessible from an individual’s starting point and destination; and* * *Long blocks that discourage walking.* **UF-14-b** **Local Street Connectivity.** Design local roadways to connect throughout neighborhoods and large private developments with adjacent major roadways and pathways of existing adjacent development. Create access for pedestrians and bicycles where a local street must dead end or be designed as a cul-de-sac to adjoining uses that provide services, shopping, and connecting pathways for access to the greater community area. **UF-14-c** **Block Length.** Create development standards that provide desired and maximum block lengths in residential, retail, and mixed-use districts in order to enhance walkability. *Commentary: When preparing such standards the City should assess the desirability of varying maximum block length requirements between single family residential, multi-family residential, mixed use, and commercial districts.* 3.5 LAND USE The following sections provide the General Plan’s required land use information with use classifications, maximum densities and intensities on Figure LU-1: Fresno General Plan Land Use Diagram. The City has reviewed those areas covered by the General Plan that are subject to flooding identified by flood plain mapping prepared by the Federal Emergency Management Agency (FEMA), which can be found at Figure NS-7: Floodplains. The City will annually review those areas covered by the Plan as set out in the Implementation Element. ### Land Use Diagram The Land Use Diagram is the City’s master designation of land uses for Fresno including the City’s SOI. The Land Use Diagram includes the Downtown Planning Area, shown in an inset, and its designations are anticipated to be further refined and implemented through specific and community plans, such as the proposed FCSP and the DNCP. Land use designations for the Downtown Planning Area are generalized to facilitate implementation by providing some flexibility for the detailed plans. ### Dual Designations All new parks, open space, and public facilities (such as school sites) carry dual land use designations, so that if that facility is not needed, private and public development consistent with zoning and development standards may be approved. These dual land use designations are shown in Figure LU-2: Dual Designation. Chapter 3: Urban Form, Land Use, and Design *This page intentionally left blank* City of Fresno General Plan Land Use and Circulation Map Development and Resource Management Planning Division <
> | PLAN ADOPTION | | | :--- | :--- | | Resolution Number | Date | | 2014 - 226 | 18-Dec-14 | | 2014 - 227 | 18-Dec-14 | | PLAN AMENDMENTS | | | :--- | :--- | | Resolution Number | Date | | 2015 - 133 | 16-Jul-15 | | 2016 - 21 | 4-Feb-16 | | 2016 - 23 | 4-Feb-16 | | 2016 - 69 | 12-May-16 | | 2016 - 148 | 18-Aug-16 | | 2016 - 160 | 1-Sep-16 | | 2016 - 166 | 1-Sep-16 | | 2016 - 186 | 22-Sep-16 | | 2016-238 | 17-Nov-16 | | 2016-251 | 1-Dec-16 | CIRCULATION LEGEND --- Freeway --- Super Arterial --- Scenic Drive --- Expressway --- Arterial --- Collector --- Scenic Expressway --- Scenic Arterial --- Scenic Collector BOUNDARIES [ ] Fresno Planning Area Boundary [ ] Fresno Sphere of Influence [//] Southeast Development Area (SEDA) This map is believed to be an accurate representation of the City of Fresno GIS data. However, we make no warranties either expressed or implied for the correctness of this data. *Dual land use designations for public facilities and open space are shown in Figure LU-2: Dual Designation Diagram. Figure LU-1: Fresno General Plan Land Use Diagram RESIDENTIAL [ ] Low Density (1-3.5 D.U./acre) [ ] Medium Low Density (3.5-6 D.U./acre) [ ] Medium Density (5.0-12 D.U./acre) [ ] Medium High Density (12-16 D.U./acre) [ ] Urban Neighborhood (16-30 D.U./acre) [ ] High Density (30-45 D.U./acre) COMMERCIAL [ ] Main Street [ ] Community [ ] Recreation [ ] General [ ] Highway & Auto [ ] Regional EMPLOYMENT [ ] Office [ ] Business Park [ ] Regional Business Park [ ] Light Industrial [ ] Heavy Industrial MIXED USE [ ] Neighborhood Mixed Use [ ] Corridor/Center Mixed Use [ ] Regional Mixed Use DOWNTOWN [ ] Downtown Core [ ] Downtown General [ ] Downtown Neighborhood OPEN SPACE [ ] Clear Zone [ ] Commercial-Recreational [ ] Community Park [ ] Flood Control Project [ ] Golf Course [ ] Lake, Pond [ ] Multi-Use [ ] Neighborhood Park [ ] Outdoor Environmental Education Area [ ] Open Space [ ] Park [ ] Ponding Basin [ ] Ponding Basin (Park use) [ ] Regional Park PUBLIC FACILITIES [ ] Public/Quasi-public Facility [ ] Special School [ ] Elementary School [ ] Elementary & Middle School [ ] Elementary, Middle & High School [ ] Middle School [ ] High School [ ] College [ ] School with Park [ ] Airport [ ] Cemetery [ ] Church [ ] Community Activity Center [ ] Convalescent Hospital [ ] Fairgrounds [ ] Fire Station [ ] Government Offices [ ] Hospital [ ] Medical Center [ ] Neighborhood Center [ ] PG & E Substation [ ] Police Dressing Station [ ] Water Recharge Basin [ ] Waste Water Treatment Facility BUFFER [ ] Buffer This page intentionally left blank. Figure LU-2: Dual Designation Diagram | PLAN ADOPTION | | | :--- | :--- | | Resolution Number | Date | | 2014 - 226 | 18-Dec-14 | | 2014 - 227 | 18-Dec-14 | | PLAN AMENDMENTS | | | Resolution Number | Date | | 2015 - 133 | 16-Jul-15 | | 2016 - 23 | 4-Feb-16 | | 2016 - 166 | 1-Sep-16 | Residential [ ] Low Desnisty (1-3.5 D. U./Acre) [ ] Medium Low Desnisty (3.5-6 D. U./Acre) [ ] Medium Desnisty (5-12 D. U./Acre) [ ] Medium High Desnisty (12-16 D. U./Acre) [ ] Urban Neighborhood (16-30 D. U./Acre) [ ] High Density (30-45 D. U./Acre) Commercial [ ] Community [ ] Main Street [ ] General Employment [ ] Office [ ] Business Park [ ] Regional Business Park [ ] Light Industrial [ ] Heavy Industrial Mixed Use [ ] Corridor/Center Mixed Use [ ] Regional Mixed Use [ ] Neighborhood Mixed Use Boundaries [ ] Southeast Development Growth Area (SEDA) [ ] Fresno Planning Area Boundary [ ] City Limit [ ] Sphere of Influence <
> Note: All planned land uses for future parks, open space, ponding basins, schools (e.g. special, elementary, middle, high, and colleges) and schools with parks carry dual planned land use designations so that if facility is not needed private and public development consistent with zoning and development standards may be approved. This map shows the additional land use designations. Date: 4/7/2017 MA *This page intentionally left blank* Chapter 3: Urban Form, Land Use, and Design ### Density and Intensity The General Plan calculates density on net acreage, defined as the land area of a lot remaining after dedication of all areas for major streets, schools, regional trails, certified wetlands or floodplains, and land underneath electric transmission lines. For residential uses, the density and intensity standards are expressed as the number of housing units per net acre. For non-residential uses, a measure known as Floor Area Ratio (FAR) is specified. FAR is defined as the permitted ratio of gross floor area to site area. It is a measure of building bulk that controls both visual prominence and traffic generation, as shown in the diagram below. <
> .5 1.0 1.5 The citywide density and intensity standards, established in Table 3-1, are intended to establish minimum and maximum densities per net acre allowed in each General Plan land use category, exclusive of the Downtown Planning Area. Minimum and maximum densities, intensities, and required land use mixes will be more precisely defined within the Development Code for purposes of determining the consistency of a proposed zone district and a property development entitlement with an applicable land use designation. Minimum lot/parcel sizes (and corresponding lot frontage minimums and other lot design requirements) will be defined in the Development Code for each zone district. The Development Code will also provide procedures and criteria for preparing and implementing “planned development” for a given area to allow for limited reconfiguration of the planned land uses for that area and variations from base zoning district development standard, while maintaining the equivalent densities, intensities and mix of uses. Finally, the General Plan land use designation may provide overlap in the defined densities, intensities and land uses described for various land uses. TABLE 3-1: CITYWIDE STANDARDS FOR DENSITY AND DEVELOPMENT INTENSITY | Land Use | Minimum to Maximum Residential Density (du/net acre)[^p37-1],[^p37-2],[^p37-3] | Maximum Floor Area Ratio | | :--- | :--- | :--- | | Buffer | Max = 0.05 (1 unit per 20 net acres) | - | | **Residential** | | | | Low Density | Min = 1 unit per 5 acres
Max = 3.5 units per acre | - | | Medium Low Density | Min = 3.5 units per acre
Max = 6 units per acre | - | | Medium Density | Min = 5 units per acre
Max = 12 units per acre | - | | Medium High Density | Min = 12 units per acre
Max = 16 units per acre | - | | Urban Neighborhood Density | Min = 16 units per acre
Max = 30 units per acre | - | | High Density | Min = 30 units per acre
Max = 45 units per acre | - | | **Commercial** | | | | Main Street | | 1.0 | | Community | | 1.0 | | Recreation | | 0.5 | | General | | 2.0 | | Highway & Auto | | 0.75 | | Regional | | 1.0 | | **Mixed-Use** | | | | Neighborhood Mixed-Use | Min = 12 units per acre
Max = No Limit | 1.5 | | Corridor/Center Mixed-Use | Min = 16 units per acre
Max = No Limit | 1.5 | | Regional Mixed-Use | Min = 30 units per acre
Max = No Limit | 2.0 | | **Downtown** | | | | Downtown Neighborhood | Min = No limit
Max = No limit | No limit | | Downtown General | Min = No limit
Max = No limit | No limit | | Downtown Core | Min = No limit
Max = No limit | No limit | | **Employment** | | | | Office | - | 2.0 | | Business Park | - | 1.0 | | Regional Business Park | - | 1.0 | | Light Industrial | - | 1.5 | | Heavy Industrial | - | 1.5 | 1. Based on Net Acreage. 2. Residential density refers to the ratio of residential dwelling units per acre (43,560 square feet) of land which is calculated by dividing the number of existing or proposed residential dwelling units by the land area of the property designated for, or proposed for development with, a residential use. The residential land area includes property upon which the residential and ancillary structures are located, together with yards and other private or common open spaces, and includes vehicle access drives and parking areas together with public and private roadways. The residential land area does not include major streets or State Routes designated by Figure MT-1: General Plan Circulation Diagram, and does not include schools or regional trails. 3. Additional density may be allowed for affordable housing or provision of community benefits (pursuant to California Government Code Sections 65915 – 65918, as may be amended). [^p37-1]: Based on Net Acreage. [^p37-2]: Residential density refers to the ratio of residential dwelling units per acre (43,560 square feet) of land which is calculated by dividing the number of existing or proposed residential dwelling units by the land area of the property designated for, or proposed for development with, a residential use. The residential land area includes property upon which the residential and ancillary structures are located, together with yards and other private or common open spaces, and includes vehicle access drives and parking areas together with public and private roadways. The residential land area does not include major streets or State Routes designated by Figure MT-1: General Plan Circulation Diagram, and does not include schools or regional trails. [^p37-3]: Additional density may be allowed for affordable housing or provision of community benefits (pursuant to California Government Code Sections 65915 – 65918, as may be amended). Chapter 3: Urban Form, Land Use, and Design ### Land Use Classifications These land use classifications cover the entire Planning Area, with the exception of the Downtown Planning Area. The land use classifications for the Downtown Planning Area are described later in this element. ### Residential Residential land uses provide for a wide range of neighborhoods and housing types. **LOW DENSITY** This designation is intended to provide for large lot residential development. Low Density residential allows one to 3.5 housing units per acre. The resulting land use pattern is large lot residential in nature, such as rural residential, ranchettes, or estate homes. **MEDIUM LOW DENSITY** The Medium Low Density designation is intended to provide for single family detached housing with densities of 3.5 to 6 units per acre. **MEDIUM DENSITY** Medium Density residential covers developments of 5 to 12 units per acre and is intended for areas with predominantly single-family residential development, but can also accommodate a mix of housing types, including small-lot starter homes, zero-lot-line developments, duplexes, and townhouses. Much of the City’s established neighborhoods fall within this designation. **MEDIUM HIGH** Medium High Density residential is intended for neighborhoods with a mix of single-family residences, townhomes, garden apartments, and multi-family units intended to support a fine-grain, pedestrian scale. This land use accommodates densities from 12 to 16 units per acre overall. **URBAN NEIGHBORHOOD** Urban Neighborhood residential covers densities from 16 to 30 units per acre, which will require multi-family dwellings but still allows for a mix of housing types including single-family houses. This land use is intended to provide for a compact community that includes community facilities and walkable access to parkland and commercial services; it also supports efficient, frequent transit service. Urban Neighborhood is designated for targeted areas with complementary land uses adjacently located. <
> *An example of Fresno’s established residential neighborhoods, with wide streets, sidewalks, and large trees.* HIGH DENSITY High Density residential is intended to accommodate attached homes, two- to four-plexes, and apartment buildings, and it will be supported by walkable access to frequent transit, retail and services, and community facilities such as parks and schools. High Density allows for 30 to 45 units per acre. Commercial Commercial land use designations allow a wide range of retail and service establishments intended to serve local and regional needs. MAIN STREET Main Street Commercial encourages a traditional Main Street character with active storefronts, outdoor seating and pedestrian-oriented design. This designation promotes primarily one to two story retail uses. It also preserves small-scale, fine-grain character in neighborhoods where single-family residential and townhomes are predominant. The maximum FAR is 1.0. Chapter 3: Urban Form, Land Use, and Design COMMUNITY Community Commercial is intended for commercial development that primarily serves local needs such as convenience shopping and small offices. Many of the city’s current commercial districts fall into this designation. Specific uses allowed include medium-scale retail, office, civic and entertainment uses, supermarkets, drug stores and supporting uses. The maximum FAR is 1.0. RECREATION The Recreation designation is intended for areas of private commercial recreation uses, such as bowling alleys and golf driving ranges. The maximum FAR is 0.5. GENERAL The General Commercial designation is intended for a range of retail and service uses that are not appropriate in other areas because of higher volumes of vehicle traffic and potential adverse impacts on other uses. Development such as strip malls fall into this designation. Examples of allowable uses include: building materials, storage facilities with active storefronts, equipment rental, wholesale businesses, and specialized retail not normally found in shopping centers. The maximum FAR is 2.0. HIGHWAY & AUTO The Highway & Auto designation is intended for limited areas near State Route 99 to accommodate uses that depend on or are supported by freeway access but do not generate a large volume of traffic. Hotels, restaurants, and auto malls are typical land uses. The maximum FAR is 0.75. REGIONAL The Regional Commercial designation is intended to meet local and regional retail demand, such as large-scale retail, office, civic and entertainment uses; shopping malls, with large format or “big-box” retail allowed; and supporting uses such as gas stations, and hotels. Buildings typically have relatively large footprints. Development and design standards will create a pedestrian orientation within centers and along major corridors. The maximum FAR is 1.0. Employment OFFICE The Office designation is intended for administrative, financial, business, professional, medical, and public offices. This designation is mainly intended to apply to existing office uses on smaller lots, generally located on arterial roadways. This designation is also considered compatible with existing residential neighborhoods given the smaller level of noise and traffic generated compared to commercial uses. Retail uses would be limited to business services, food services, and convenience goods for those who work in the area. The maximum FAR is 2.0. BUSINESS PARK The Business Park designation provides for office/business parks in campus-like settings that are well suited for large offices or multi-tenant buildings. This designation is intended to accommodate and allow for the expansion of small businesses. Given its proximity to residential uses, only limited outdoor storage will be permitted, while adequate landscaping is imperative to minimize the visual impacts. Typical land uses include research and development, laboratories, administrative and general offices, medical offices and clinics, professional offices, prototype manufacturing, testing, repairing, packaging, and printing. No free-standing retail is permitted, except for small uses serving businesses and employees. The maximum FAR is 1.0. REGIONAL BUSINESS PARK The Regional Business Park designation is intended for large or campus-like office and technology development that includes office, research and development, manufacturing, and other large-scale, professional uses, with limited and properly screened outdoor storage. Permitted uses include incubator-research facilities, prototype manufacturing, testing, repairing, packaging, and printing, as well as offices and research facilities. Small-scale retail and service uses serving local employees and visitors are permitted as secondary uses. The maximum FAR is 1.0. LIGHT INDUSTRIAL The Light Industrial designation accommodates a diverse range of light industrial uses, including limited manufacturing and processing, research and development, fabrication, utility equipment and service yards, wholesaling, warehousing, and distribution activities. Small-scale retail and ancillary office uses are also permitted. Light Industrial areas may serve as buffers between Heavy Industrial and other land uses and otherwise are generally located in areas with good transportation access, such as along railroads and State Routes. The maximum FAR is 1.5. Chapter 3: Urban Form, Land Use, and Design HEAVY INDUSTRIAL The Heavy Industrial designation accommodates the broadest range of industrial uses including manufacturing, assembly, wholesaling, distribution, and storage activities that are essential to the development of a balanced economic base. Small-scale commercial services and ancillary office uses are also permitted. The maximum FAR is 1.5. Mixed-Use[^p42-5] Mixed-use designations are based on commercial uses and also require a residential or upper-floor office component. NEIGHBORHOOD MIXED-USE This designation allows a minimum of 50 percent residential uses and provides for mixed-use districts of local-serving, pedestrian-oriented commercial development, such as convenience shopping and professional offices in two- to three-story buildings. Development is expected to include ground-floor neighborhood retails uses and upper-level housing or offices, with a mix of small lot single family houses, townhomes, and multi-family dwelling units on side streets, in a horizontal or vertical mixed-use orientation. The built form will have a scale and character that is consistent with pedestrian-orientation, to attract and promote a walk-in clientele, with small lots and frequent roadway and pedestrian connections permitting convenient access from residences to commercial space. Automobile-oriented uses are not permitted. CORRIDOR/CENTER MIXED-USE The Corridor/Center Mixed-Use designation is higher intensity than Neighborhood Mixed-Use, and is intended to allow for horizontal and vertical mixed-use development in multiple story buildings along key circulation corridors where height and density can be easily accommodated. Ground-floor retail and upper-floor residential or offices are the primary uses, with personal and business services and public and institutional space as supportive uses. Development will facilitate the transformation of existing transportation corridors into vibrant, highly walkable areas with broad, pedestrian-friendly sidewalks, [^p42-5]: The General Plan is long-term in nature, and recognizes the importance of providing for an orderly evolution of existing, legal non-conforming uses during the planning period in a manner that acknowledges their current economic contributions while providing for a transition into conforming uses consistent with applicable land use designations. trees, landscaping, and local-serving uses with new buildings that step down in relationship to the scale and character of adjacent neighborhoods. This designation will largely apply along major roadways, at targeted locations between regional Activity Centers. A minimum of 40 percent residential uses is required, and the maximum FAR is 1.5. REGIONAL MIXED-USE The Regional Mixed-Use land use designation is intended to accommodate mixed-use development in urban-scale buildings and retail establishments that serve residents and businesses of the region at large. Medium-scale retail, residential, office, civic and entertainment uses, and shopping malls (with large format or “big-box” retail) are allowed, as are supporting uses such as gas stations and hotels in mixed-use or single use buildings. Design standards will support a pedestrian orientation within centers and along major corridors, with parking on the side or rear in general, but automobile-oriented uses also will be accommodated on identified streets and frontages. A minimum of 30 percent residential uses is required, and the maximum FAR is 2.0. Open Space The Open Space designations (Parks and Recreational Facilities; Other Public Open Space) apply to open space areas that are not parks or trails, such as riparian corridors, the clear zone around Fresno-Yosemite International Airport, and the San Joaquin River bottom, which is primarily designated as open space even though it includes a limited number of existing homes. Public Facilities This designation applies to public facilities, such as City Hall, county buildings, schools, colleges, the municipal airports, and hospitals. It also includes public facilities, such as fire and police stations, City-operated recycling centers, sewage treatment plants, neighborhood, community and regional parks, recreational centers, and golf courses. Finally, it applies to multi-purpose trails that serve both regional and neighborhood needs. Buffer This designation is intended to separate urban uses from long-term agricultural uses in order to preserve long-term viable agricultural areas and intensive farming operations adjoining but outside the Planning Area. The Buffer designation will serve to prevent urban residential and related uses from developing near agricultural operations and infringing on full operation of important farmland. A variety of uses are compatible with the purpose of the Buffer, which will be defined in detail in the Development Code. General Chapter 3: Urban Form, Land Use, and Design categories include environmental habitats; water conveyance, retention and recharge; preservation and preparation of gravel resources for beneficial uses related to permanent water resource facilities; limited agriculture and necessary supportive uses, such as agricultural processing, excluding animal processing or uses that have the potential to create nuisances; and residential uses with 20 acres of land required per residence. ### Downtown Downtown designations allow a wide range of uses and the most intense development patterns in the region while creating pedestrian-oriented urban environments. ### Downtown Core The Downtown Core (DTC) is the cultural, civic, shopping, and transit center of Fresno and the region. This designation is applied to the traditional central business district of the city near the proposed High Speed Rail station and oriented around the restored section of Fulton Street. New buildings will be up to 15 stories in height and will be located at or near the sidewalk. Ground floor spaces will have active frontages with commercial, retail, multi-family housing, and office activity to support active streetscapes and walking. Upper floors and the floor area behind storefronts will accommodate a wide variety of office, civic, lodgings, housing, or additional commercial uses. ### Downtown General The Downtown General (DTG) designation will support a high concentration of regional activity generators such as governmental buildings and convention centers within a pedestrian-oriented, mixed-use urban setting. New buildings will be up to 10 stories in height and will be located at or near the sidewalk. Ground floor spaces will have active frontages with commercial, retail, multi-family housing, and office activity to support active streetscapes and walking. Upper floors and the floor area behind storefronts will accommodate a wide variety of office, civic, lodging, housing, or additional commercial uses. ### Downtown Neighborhood The Downtown Neighborhood (DTN) designation will create lively, walkable, mixed-use urban neighborhoods surrounding the Downtown Core and Downtown General areas. New buildings will be up to 6 stories in height and will be located at or near the sidewalk. Ground floor spaces will have active frontages with commercial, retail, multi-family housing, and office activity to support active streetscapes and walking. Upper floors and the floor area behind storefronts will accommodate a wide variety of office, civic, lodging, housing, or additional commercial uses. <
> *Downtown Neighborhood areas feature a mix of uses, including retail, office, civic, housing, and entertainment.* ### General Plan and Zoning Consistency Table 3-2 summarizes the proposed zoning districts that will contain detailed development guidelines and regulations for the land uses in the General Plan. Chapter 3: Urban Form, Land Use, and Design | TABLE 3-2: GENERAL PLAN LAND USE DESIGNATIONS AND ZONING DISTRICTS CONSISTENCY | | | | :--- | :--- | :--- | | **General Plan Land Use Designation** | **Development Code Zoning District** | | | Buffer | B | Buffer | | **Residential** | | | | Low Density | RE | Residential Estate | | | RS-1 | Residential Single Family, Extremely Low Density | | | RS-2 | Residential Single Family, Very Low Density | | | RS-3 | Residential Single Family, Low Density | | Medium Low Density | RS-4 | Residential Single Family, Medium Low Density | | Medium Density | RS-5 | Residential Single Family, Medium Density | | Medium High Density | RM-MH | Mobile Home Park | | | RM-1 | Residential Multi-Family, Medium High Density | | Urban Neighborhood | RM-2 | Residential Multi-Family, Urban Neighborhood | | High Density | RM-3 | Residential Multi-Family, High Density | | **Mixed-Use** | | | | Neighborhood | NMX | Neighborhood Mixed Use | | Corridor/Center | CMX | Corridor/Center Mixed Use | | Regional | RMX | Regional Mixed Use | | **Commercial** | | | | Main Street | CMS | Commercial - Main Street | | Community | CC | Commercial - Community | | Regional | CR | Commercial - Regional | | General | CG | Commercial - General | | Highway and Auto | CH | Commercial - Highway and Auto | | Recreation | CRC | Commercial - Recreation | | **Downtown** | | | | Downtown Neighborhood | DTN | Downtown Neighborhood | | Downtown General | DTG | Downtown General | | Downtown Core | DTC | Downtown Core | | **Employment** | | | | Office | O | Office | | Business Park | BP | Business Park | | Regional Business Park | RBP | Regional Business Park | | Light Industrial | IL | Light Industrial | | Heavy Industrial | IH | Heavy Industrial | | **Other** | | | | Open Space | OS | Open Space | | | PR | Parks and Recreation | | Public Facilities | PI | Public and Institutional | ### Local Plans The City has adopted a number of plans that apply to defined areas throughout Fresno. Under the City's Local Planning and Procedures Ordinance (LPPO), Specific and Community Plans prevail when inconsistent with the General Plan. As a practical matter, this means full implementation of the General Plan may require certain Specific or Community plans to be either repealed or amended to allow consistency. As part of this process, policies and portions from certain plans have been considered in developing the General Plan, essentially resulting in a consolidation and update of planning documents through this repeal and amendment of plans. See Implementing Policy D-7-a for the list of plans being amended or repealed. ### Annexation As specified by Policy LU-1-g, this General Plan promotes the principle that the SOI not be expanded. The one exception to SOI expansion is to allow for the siting of a maintenance yard proximate to and south of the SOI boundary associated with the California High Speed Train project. ### Regional Cooperation Fresno is part of an eight-county region, each with its own Metropolitan Planning Organization. Collectively, they have approved the San Joaquin Valley Blueprint along with the Smart Growth principles listed below, which have been integrated into the General Plan. The adopted San Joaquin Valley Blueprint 12 Smart Growth principles: 1. Create a range of housing opportunities and choices; 2. Create walkable neighborhoods; 3. Encourage community and stakeholder collaboration; 4. Foster distinctive, attractive communities with a strong sense of place; 5. Make development decisions predictable, fair, and cost-effective; 6. Mix land uses; 7. Preserve open space, farmland, natural beauty, and critical environmental areas; 8. Provide a variety of transportation choices; 9. Strengthen and direct development towards existing communities; 10. Take advantage of compact building design; 11. Enhance the economic vitality of the region; and 12. Support actions that encourage environmental resource management. The City of Fresno is also partnering with 13 of the other 15 federally defined Urbanized Areas in the San Joaquin Valley as part of the Smart Valley Places network, to plan and implement smart growth, livability, and sustainability through revised land use and transportation systems in the respective cities within all the Urbanized Areas in the eight-county Valley region. The City of Fresno also seeks to develop a regional cooperative planning and development strategy with all the city, county, and special district jurisdictions in Fresno, Madera, Tulare, and Kings counties in order to better achieve increased air quality, lower greenhouse gas emissions, farmland preservation, water and energy conservation, increased regional transportation infrastructure and economic development, and sustainable fiscal resource and mutual quality-of-life goals in the region. OBJECTIVE LU-1 Establish a comprehensive citywide land use planning strategy to meet economic development objectives, achieve efficient and equitable use of resources and infrastructure, and create an attractive living environment. IMPLEMENTING POLICIES LU-1-a Promote Development within the Existing City Limits as of December 31, 2012. Promote new development, infill, and rehabilitation of existing building stock in the Downtown Planning Area, along BRT corridors, in established neighborhoods generally south of Herndon Avenue, and on other infill sites and vacant land within the City. LU-1-b Land Use Definition and Compatibility. Include zoning districts and standards in the Development Code that provide for the General Plan land use designations and create appropriate transitions or buffers between new development with existing uses, taking into consideration the health and safety of the community. LU-1-c Provision of Public Facilities and Services. Promote orderly land use development in pace with public facilities and services needed to serve development. *Commentary: Proposed school sites, parks, and storm water retention basin sites are shown in their most probable location, but the General Plan Land Use Diagram only represents probable placement for many of these prospective future public uses, and these various future public facility sites may be relocated or purchased in alternate locations.* **LU-1-d** **Orderly Transition of Existing Uses.** Implement updates to the Fresno Municipal Code to provide for the orderly transition of existing, legal non-conforming uses on the BRT Corridors. *Commentary: The goals, objectives and policies of this General Plan are long-term in nature. The General Plan recognizes the importance of providing for an orderly evolution of existing, legal non-conforming uses in a manner that acknowledges their current economic contributions while providing for a full transition into conforming uses consistent with applicable land use designations.* **LU-1-e** **Annexation Requirements.** Adopt implementing policies and requirements that achieve annexations to the City that conform to the General Plan Land Use Designations and open space and park system, and are revenue neutral and cover all costs for public infrastructure, public facilities, and public services on an ongoing basis consistent with the requirements of ED-5-b. *Commentary: If initiated directly with LAFCO without application by the City, the City is likely to oppose the proposed annexation unless it is consistent with the General Plan and the sequence of development discussed in the Implementation Element.* Regarding Disadvantaged Unincorporated Communities, the City will partner with the community, if there is wide support for annexation, to coordinate terms to initiate and support the annexation process. **LU-1-f** **Coordination with Fresno County Land Use Planning.** Seek a Memorandum of Understanding (MOU) with the County of Fresno to prohibit development inconsistent with this General Plan on unincorporated land within the City’s SOI. Chapter 3: Urban Form, Land Use, and Design *Commentary: The MOU should also require all new development within the SOI to comply with all City development standards and policies.* **LU-1-g** **SOI Expansion.** Maintain the City’s current SOI boundaries without additional expansion, except to allow for the siting of a maintenance yard for the California High Speed Train project and related industrial and employment priority areas proximate to and south of the SOI boundary between State Route 41 and State Route 99. Prohibit residential uses in the expansion area. OBJECTIVE **LU-2** Plan for infill development that includes a range of housing types, building forms, and land uses to meet the needs of both current and future residents. IMPLEMENTING POLICIES **LU-2-a** **Infill Development and Redevelopment.** Promote development of vacant, underdeveloped, and re-developable land within the City Limits where urban services are available by considering the establishment and implementation of supportive regulations and programs. **LU-2-b** **Infill Development for Affordable Housing.** Establish a priority infill incentive program for residential infill development of existing vacant lots and underutilized sites within the City as a strategy to help to meet the affordable housing needs of the community. **LU-2-c** **Infill Design Toolkit.** Develop and distribute an infill design toolkit, consistent with the City's Infill Development Act to support and encourage infill development. *Commentary: The toolkit will use photos and diagrams to:* * *Explain design and permit requirements and priority infill development incentives;* * *Illustrate context-responsive best practices for prototype development; and* * *Address detailed issues such as parking, scale, privacy, outdoor spaces, housing types, transitions, building design,* siting and street orientation, setbacks, windows, and general material guidelines and buffering for adjacent uses. **LU-2-d** | **Infrastructure Upgrades.** Facilitate urban infill by building and upgrading community and neighborhood public infrastructure and services to enhance public health and convenience, and improve the overall experience and quality of city living. :---|:--- **LU-2-e** | **Neighborhood Preservation.** Incorporate standards in the Development Code to preserve the existing residential quality of established neighborhoods. **LU-2-f** | **Lot Consolidation.** Include incentives in the Development Code for streamlining the consolidation of very small, oddly shaped, and difficult to develop lots to create more efficient and developable parcels. # OBJECTIVE **LU-3** | Support the successful fulfillment of plans when adopted for the Downtown Planning Area. # IMPLEMENTING POLICIES **LU-3-a** | **Downtown Planning Area Plans.** Prepare and adopt community plans and Specific Plans for the revitalization and continued development of the Downtown Planning Area neighborhoods, including the Fulton Street corridor, accompanied by implementing regulations that will govern future development in the area. **LU-3-b** | **Mixed-Use Urban Corridors that Connect the Downtown Planning Area.** Support the development of mixed-use urban corridors that connect the Downtown Planning Area with the greater Fresno-Clovis Metropolitan Area with functional, enduring, and desirable urban qualities along the Blackstone Avenue, Shaw Avenue, California Avenue, and Ventura Avenue/Kings Canyon Road corridors, as shown on Figure LU-1: General Plan Land Use Diagram. **LU-3-c** | **Zoning for High Density on Major BRT Corridors.** Encourage adoption of supportive zoning regulations for compact development along BRT corridors leading to the Chapter 3: Urban Form, Land Use, and Design Downtown Core that will not diminish the long-term growth and development potential for Downtown. **OBJECTIVE** **LU-4** Enhance existing residential neighborhoods through regulations, code enforcement, and compatible infill development. **IMPLEMENTING POLICIES** **LU-4-a** **Neighborhood Nuisance Abatement.** Continue proactive and responsive code enforcement and nuisance abatement programs to improve the attractiveness of residential neighborhoods. **LU-4-b** **Neighborhood Reinvestment.** Promote and consider partnerships with lending institutions that provide a variety of financing alternatives and adhere to the provisions of the federal Community Reinvestment Act. **LU-4-c** **Housing Task Force.** Establish an interagency housing task force to coordinate the housing programs of the City with similar programs of other local jurisdictions and the Fresno Housing Authority to develop a coordinated affordable housing implementation plan. **OBJECTIVE** **LU-5** Plan for a diverse housing stock that will support balanced urban growth, and make efficient use of resources and public facilities. **IMPLEMENTING POLICIES** **LU-5-a** **Low Density Residential Uses.** Promote low density residential uses only where there are established neighborhoods with semi-rural or estate characteristics. **LU-5-b** **Medium-Low Density Residential Uses.** Promote medium-low density residential uses to preserve existing uses of that nature or provide a transition between low and medium density residential areas. **LU-5-c** **Medium Density Residential Uses.** Promote medium density residential uses to maximize efficient use of residential property through a wide range of densities. LU-5-d | **Medium-High Density Residential Uses.** Promote medium-high density residential uses to optimize use of available or planned public facilities and services and to provide housing opportunities with convenient access to employment, shopping, services, and transportation. ---|--- LU-5-e | **Urban Neighborhood Residential Uses.** Promote urban neighborhood residential uses to support compact communities and Complete Neighborhoods that include community facilities, walkable access to parkland and commercial services, and transit stops. LU-5-f | **High Density Residential Uses.** Promote high-density residential uses to support Activity Centers and BRT Corridors, and walkable access to transit stops. LU-5-g | **Scale and Character of New Development.** Allow new development in or adjacent to established neighborhoods that is compatible in scale and character with the surrounding area by promoting a transition in scale and architectural character between new buildings and established neighborhoods, as well as integrating pedestrian circulation and vehicular routes. LU-5-h | **Housing Offering Amenities.** Support housing that offers residents a range of amenities, including public and private open space, landscaping, and recreation facilities with direct access to commercial services, public transit, and community gathering spaces. LU-5-i | **Housing for Seniors.** Facilitate the development of senior housing projects that are accessible to public transportation and services. LU-5-j | **Campus-Centered Communities.** Encourage development of campus-centered communities by focusing growth around existing and planned academic facilities and by directing infrastructure to those areas. OBJECTIVE | ---|--- LU-6 | Retain and enhance existing commercial areas to strengthen Fresno’s economic base and site new office, retail, and lodging use districts to serve neighborhoods and regional visitors. Chapter 3: Urban Form, Land Use, and Design IMPLEMENTING POLICIES LU-6-a | **Design of Commercial Development.** Foster high quality design, diversity, and a mix of amenities in new development with uses through the consideration of guidelines, regulations and design review procedures. LU-6-b | **Commercial Development Guidelines.** Consider adopting commercial development guidelines to assure high quality design and site planning for large commercial developments, consistent with the Urban Form policies of this Plan. *Commentary: The guidelines should address:* * *Architectural finishes, coordinated color palette, massing, and hierarchy in scale;* * *Pedestrian-scaled amenities, signage, and lighting;* * *Site improvements, including parking lot landscaping, perimeter landscaping, foundation landscaping, walkways, and passageways;* * *Ground floor transparency requirements along shopping streets and limitations on blank walls in these areas;* * *Anti-theft glass on windows, rather than bars or roll-down metal screens, that are architecturally compatible with building design;* * *Screening of truck loading, parking, mechanical equipment, transformers, ventilation systems, storage containers, and refuse collection areas from the street;* * *Shading and its relationship and effects on surrounding buildings;* * *Building entries; and* * *Design standards for perimeter walls and fencing.* LU-6-c | **Appropriate Office Development.** Promote the establishment of development standards for new offices, addressing location, size, and intensity necessary to the City’s needs. Integrate and support employment in adjacent and proximate neighborhoods. * *Locate office projects to provide a transition between more intensive commercial uses and residential areas;* * Facilitate office uses in conjunction with, and adjacent to, institutions and employment centers; and * Avoid over concentrating office uses in any one part of Fresno when new office developments would create excessive vacancy rates in other established office areas. **LU-6-d** **Neighborhood and Community Commercial Center Design.** Plan for neighborhood mixed use and community commercial uses to implement the Urban Form concepts of this Plan, promote the stability and identity of neighborhoods and community shopping areas, and allow efficient access without compromising the operational effectiveness of the street system. * Neighborhoods will be anchored by community commercial centers with a mix of uses that meet the area’s needs and create a sense of place; and * Community commercial centers will be located within Activity Centers. **LU-6-e** **Regional Center Planning and Design.** Promote economic growth with regional commercial centers. * New regional commercial centers will be located with access to State Routes and/or other major transportation facilities to ensure access from throughout the region; and * Regional shopping centers will have internally-unified building design, landscaping, and signage standards. **LU-6-f** **Auto-Oriented Commercial Uses.** Direct highway-oriented and auto-serving commercial uses to locations that are compatible with the Urban Form policies of the General Plan. Ensure adequate buffering measures for adjacent residential uses, noise, glare, odors, and dust. **LU-6-g** **Lodging Facilities Location.** Site lodging facilities and related accommodations near major transportation facilities. **OBJECTIVE** **LU-7** Plan and support industrial development to promote job growth. Chapter 3: Urban Form, Land Use, and Design IMPLEMENTING POLICIES **LU-7-a** **Incentives for a Diversity of Industries, Increased Food Processing and Manufacturing, and Related Employment Opportunities in Fresno.** Use the City’s Capital Improvement Program to set priorities for locations and timing of water, sewer, and transportation infrastructure investments by the City and initiate implementation programs to encourage development of targeted industries as identified under Policy ED-3-c, in employment land use areas designated on Figure LU-1: Land Use Diagram. *Commentary:* The South Industrial Area, located generally south of Jensen Avenue within the City’s SOI, intersected by State Routes 41 and 99, and containing over 1,100 vacant acres designated for industry, is one such priority industrial development area for major infrastructure improvements (See Figure I-3). **LU-7-b** **Business and Industrial Parks.** Promote business and industrial park sites that are of sufficient size, unified in design, and diversified in activity to attract a full range of business types needed for economic growth. **LU-7-c** **Efficiency of Industrial Uses.** Promote industrial land use clusters to maximize the operational efficiency of similar activities. * Provide access to a range of transportation modes through plans and incentives, ensuring that local, regional, and national connections are available to industrial uses; * Develop a strategy to promote rail-accessible sites for industries that need such capability; and * Ensure timely access to the full range of urban services for industrial development by coordinating proposed plans with the annual and long-range City infrastructure planning. **LU-7-d** **Industrial Waste.** Establish appropriate development standards and review procedures in the Development Code for industrial waste recycling operations and waste transfer stations. LU-7-e | **Shared Parking for Industrial Uses.** Promote use of shared surface parking and other arrangements necessary to meet industrial needs with updated parking regulations. ### OBJECTIVE LU-8 | Provide for the development of civic and institutional land uses to meet the educational, medical, social, economic, cultural, and religious needs of the community. ### IMPLEMENTING POLICIES LU-8-a | **Civic and Institutional Use Compatibility.** Protect civic and institutional areas from incompatible uses that could affect their vitality and contributions to the city. LU-8-b | **Access to Public Facilities.** Ensure that major public facilities and institutions have adequate multi-modal access and can be easily reached by public transit. LU-8-c | **Zoning for Public Facilities.** Allow public facility uses in zoning districts where appropriate. LU-8-d | **Public Facilities and Institutions Meeting City Standards.** Request that federal, State, and local agencies locating public facilities and institutions in the City or designated growth area, meet City standards for public streets and sidewalks, access, parking, water supply, wastewater disposal, landscaping, and amenities. ### OBJECTIVE LU-9 | Plan land uses, design, and development intensities to supplement and support, and not compete with, the Downtown. ### IMPLEMENTING POLICIES LU-9-a | **Residential Locations.** Plan for new residential uses and types in a manner that help make the Downtown Planning Area a convenient destination for employment and regional retail shopping. LU-9-b | **Activity Centers.** Plan for future Activity Centers at appropriate locations that avoid competition with Downtown businesses. Chapter 3: Urban Form, Land Use, and Design LU-9-c | **Primacy of Downtown.** Maintain the Downtown mixed-use areas as the Primary Activity Center within the city with the tallest buildings to enhance its profile and visibility. | | *Commentary:* Activity Centers outside of Downtown may include, but not be limited to, the vicinity of Woodward Park and the Blackstone Avenue, Kings Canyon Avenue, and Shaw Avenue corridors. LU-9-d | **Directional Signage.** Direct travelers to the Downtown with directional signage throughout the city and along regional routes. LU-9-e | **Downtown Sightline.** Require new development to preserve existing sightlines to Downtown to the extent feasible. LU-9-f | **View Corridors.** Promote new view corridors that highlight the Downtown skyline. LU-9-g | **Improve Access.** Provide opportunities to enhance the existing physical accessibility of Downtown in order to encourage the inclusion of individuals with disabilities. OBJECTIVE LU-10 | Promote regional cooperation and coordination on land use and planning issues among local jurisdictions. IMPLEMENTING POLICIES LU-10-a | **Regional Land Use and Transportation Planning Program.** Continue participation efforts in a coordinated Regional Land Use and Transportation Planning Program with the City of Clovis, Fresno and Madera counties, and other cities in the region. | *Commentary:* This program can undertake mutually-agreeable development strategy to: * Identify areas suitable for development; * Direct urban development to incorporated cities; * Propose programs to meet federal, State, and local air quality requirements; * Identify future regional facilities and services, including transportation corridors, water, and sewerage; * Conserve agricultural land and prevent its premature conversion including requirements for an economic assessment, phasing plan, and criteria to prevent leapfrog development; and * Discourage the creation of new rural residential lots and subdivisions. **LU-10-b** Integrity of the General Plan. Urge neighboring jurisdictions to support the integrity and implementation of the General Plan. **LU-10-c** Memorandum of Understanding (MOU). Comply with the most recent Master Settlement Agreement and Amended and Restated MOU between the City of Fresno and County of Fresno. Update the existing MOU and Agreement as necessary to implement the goals of this Plan. ### OBJECTIVE **LU-11** Encourage coordination with adjacent jurisdictions in providing public services, infrastructure and cooperative economic development. ### IMPLEMENTING POLICIES **LU-11-a** Regional Programs. Coordinate with the County of Fresno, County of Madera, the City of Clovis and other cities or special districts to: * Promote resource management programs to avoid overlap and duplication of effort; * Promote the development of a regional justice system program to meet future needs of the justice system, both adult and juvenile, including the judicial system and law enforcement; * Promote the development of a regional public health program to meet future needs including community, environmental and mental health services; and * Promote the development of a regional program to meet future library, recreational and social service needs of the region. LU-11-b **Regional Economic Development.** Promote cooperative efforts with the County of Fresno, the County of Madera, the City of Clovis, other cities, or special districts to develop a regional approach to economic development that: * Identifies regional economic development programs to create jobs and provide cost-effective incentives to assist business development of regional significance; and * Promotes an agricultural-industrial synergy that will enable a significant portion of agricultural products to be fully prepared and processed locally. LU-11-c **General Plan Consistency.** Pursue coordinated planning and development project reviews with relevant federal, State, and local public agencies to ensure consistency with this General Plan. ### 3.6 BUILDINGS AND DESIGN Many well-known areas in Fresno are easily identified by their urban design and architecture. Both new and old, these areas can also serve as a basis for community dialogue when discussing design in general or specific proposed design guidelines and standards. Areas such as the Tower District, Huntington Boulevard, Wilson Island, Van Ness Boulevard in the Fresno High area, and Old Fig Garden possess architectural and urban design characteristics that are highly valued by local residents and businesses. There are other areas in Fresno that are not so well known, but are highly regarded by their neighborhood because of urban design features. For the most part, higher density and high-rise buildings are focused in Downtown. The State Route 41/Blackstone Avenue corridor is designated in the 2025 General Plan as a high-rise/mid-rise district, originally proposed in 1984, but has not yet developed as such. Once outside Downtown, the intensity and overall mass of buildings with a few exceptions in the River Park area are relatively low and homogenous. Generally, one- and two-story buildings predominate, although in distinct areas some structures rise up to four and six stories. Going forward and in support of Downtown, LU-9 policies provide desirable guidance. Many buildings in Fresno are conservative in design, with some exceptions, such as the City Hall and the Robert E. Coyle Federal Building. Pre-World War II homes are highly valued and exhibit considerable variety and texture. The California ranch home movement produced notable homes in Old Fig Garden. Also, some garden office buildings are notable for the quality of their landscape and low-lying design. OBJECTIVE D-1 Provide and maintain an urban image that creates a “sense of place” throughout Fresno. IMPLEMENTING POLICIES D-1-a **Direct Access to Units.** Require all new multi-family residential development located within Activity Centers and/or along BRT and other transit or pedestrian-oriented streets (Collector and Local), including high-rise, townhomes or other units, to provide direct pedestrian street access and to promote walkable connectivity, individualization, family-friendly development, identity, and street safety to the maximum extent reasonably feasible. D-1-b **Active Ground Floor Frontage.** Encourage all new development located within Activity Centers and/or along BRT corridors to incorporate active ground floor frontages that engage pedestrians to the maximum extent feasible. Establish pedestrian-oriented design standards in the Development Code for building frontages, transparency, fenestration, and entries to create active streetscapes. D-1-c **Privately Owned Public Spaces.** Consider creating and adopting design standards and incentives for providing privately owned open spaces and plazas for gathering to enhance the pedestrian realm and provide opportunities for social interaction. D-1-d **Public Art.** Continue to promote a citywide public art program that contributes to an awareness of the City’s history and culture. D-1-e **Graphic Identity.** Continue the preservation, promotion, procurement and strategic location of landmarks, monuments and artwork that provide orientation and represent Fresno's cultural heritage and artistic values. D-1-f **Update Street Signs.** Consider updating street sign regulations to create a way-finding system and graphic identity without dominating city and district appearance. Chapter 3: Urban Form, Land Use, and Design **D-1-g** | **Reducing Surface Parking.** Consider adopting and implementing incentives to replace existing large surface parking lots in centers with parking structures, and to incorporate them into high-density mixed-use developments. :--- | :--- **D-1-h** | **Screening of Parking.** Consider requiring all new development with parking in Activity Centers and along corridors to be screened or concealed. Locate principal pedestrian entrances to new non-residential buildings on the sidewalk; any entrances from parking areas should be incidental or emergency use only. **D-1-i** | **Wrapping Parking Structures.** Consider requiring new development of above-grade parking structures to be wrapped with and provide direct access to active uses, such as dwelling units, offices, and shopping spaces. | *Commentary: If active uses are not feasible on the ground floor of parking garages, frontages should be architecturally attractive. This may be accomplished by including unique designs and materials, such as glass, articulated masonry, murals or landscaping setbacks.* **D-1-j** | **Lighting Standards.** Update lighting standards to reflect best practices and protect adjoining uses from glare and spillover light. | *Commentary: Security and interior lighting should not be visible from the exterior of parking garages.* OBJECTIVE --- | --- **D-2** | Enhance the visual image of all "gateway" routes entering the Fresno Planning Area. IMPLEMENTING POLICIES --- | --- **D-2-a** | **Design Requirements for Gateways.** Create unified design requirements for gateways to welcome travelers to the City’s Activity Centers. | *Commentary: Gateway route designation will be considered for application to key access routes such as State Routes 99, 41, 168, and 180; passenger rail rights-of-way; Peach Avenue, McKinley Avenue, and Clinton Way where air travelers enter Fresno; Van Ness Avenue; Fulton, Divisadero, Tulare, and* Fresno Streets; Belmont and Olive; and Blackstone, Abby, Shaw and Herndon Avenues. **D-2-b** | **Funding for Gateway Enhancements.** Pursue funding to implement gateway enhancement plans and programs. --- | --- **D-2-c** | **Highway Beautification.** Work with Caltrans, the Fresno Council of Governments, Tree Fresno, neighboring jurisdictions, and other organizations to obtain funding for highway beautification programs. # OBJECTIVE **D-3** | Create unified plans for Green Streets, using distinctive features reflecting Fresno’s landscape heritage. # IMPLEMENTING POLICIES **D-3-a** | **Green Street Tree Planting.** Create a Green Street Tree Planting Program, with a well-balanced variety and spacing of trees to establish continuous shading and visual continuity for each streetscape. Strive to achieve coherent linkages between public and private spaces, prioritizing tree planting along tree-deficient Arterial Roadways in neighborhoods characterized by lower per capita rates of vehicle ownership. **D-3-b** | **Funding for Green Street Tree Planting Program.** Pursue funding for the Green Street Tree Planting Program, including landscaping of median islands. **D-3-c** | **Local Streets as Urban Parkways.** Develop local streets as "urban parkways," where appropriate, with landscaping and pedestrian spaces. **D-3-d** | **Undergrounding Utilities.** Partner with utility companies to continue to pursue the undergrounding of overhead utilities as feasible. # OBJECTIVE **D-4** | Preserve and strengthen Fresno’s overall image through design review and create a safe, walkable and attractive urban environment for the current and future generations of residents. Chapter 3: Urban Form, Land Use, and Design # IMPLEMENTING POLICIES **D-4-a** **Design Review for Large Buildings.** Consider adopting and implementing a streamlined design review process for new construction and visible exterior alterations of large and significant multi-family, mixed-use and non-residential developments. *Commentary: Thresholds of size and significance will need to be defined and review processes designed not to impede investment and development time frames.* **D-4-b** **Incentives for Pedestrian-Oriented Anchor Retail.** Consider adopting and implementing incentives for new pedestrian-friendly anchor retail at intersections within Activity Centers and along corridors to attract retail clientele and maximize foot traffic. *Commentary: Examples of incentives include increased floor area ratios, deferred impact fees, and priority processing.* **D-4-c** **Appropriate Day and Night Activity.** Promote new residential, commercial and related forms of development that foster both day and appropriate night time activity; visual presence on the street level; appropriate lighting; and minimally obstructed view areas. **D-4-d** **Design for Safety.** Continue to involve the City’s Police Department in the development review process to ensure new buildings are designed with security and safety in mind. **D-4-e** **Flexibility through Overlay Districts.** Allow innovative lot designs and patterns to enhance community livability in residential neighborhoods through new zoning provisions, with flexible development standards. **D-4-f** **Design Compatibility with Residential Uses.** Strive to ensure that all new non-residential land uses are developed and maintained in a manner complementary to and compatible with adjacent residential land uses, to minimize interface problems with the surrounding environment and to be compatible with public facilities and services. D-4-g **Development Code Update for Design Concepts.** Ensure that standards in the Development Code implement General Plan design concepts for each land use type. *Commentary:* The following will be considered in the new Development Code: * Appropriate space is provided for activities proposed (e.g., indoor area for display of merchandise, as opposed to sidewalk/parking lot display); * Sufficient space and access is provided for support functions, (e.g., storage, loading, parking, waste disposal/recycling); * Location of customer parking areas does not discourage pedestrian and bicycle access; * Access for the disabled is incorporated into project designs as required; * Buildings in shopping centers are linked by pedestrian walkways; * Business and industrial parks have campus-like settings, with uniformity of improvements and shared facilities for parking, loading, mass transit, and with internal and external bicycle and pedestrian access; and * Structural conversions and changes of occupancy demonstrate compliance with building and zoning codes. D-4-h **Metal Buildings.** Promote the establishment of standards and guidelines for metal buildings to be acceptable and economical forms of structures. * New buildings with metal walls or metal roofs shall be painted or have other appropriate finishes, as approved by the City; and * Mechanical equipment shall be screened with parapet walls, mechanical wells, or other means. Roof vent color must match that of the roof. The distinctive pattern of ribs and joints in standing seam and other metal roofing materials should coordinate dimensionally with similar elements in exterior walls. Chapter 3: Urban Form, Land Use, and Design OBJECTIVE **D-5** Maintain and improve community appearance through programs that prevent and abate blighting influences. IMPLEMENTING POLICIES **D-5-a** **Code Enforcement.** Continue enforcement of the Fresno Municipal Code to remove or abate public nuisances in a timely manner. **D-5-b** **Clean Streets.** Promote community partnerships and continued City efforts toward litter clean-up and abatement of trash stockpiles on public and private streets. **D-5-c** **Façade Improvements.** Pursue funding for, and support of, building facade improvement programs. **D-5-d** **Graffiti Prevention and Abatement.** Seek ways to end graffiti, continue and expand the City's effective Graffiti Abatement Program. **D-5-e** **Community Sanitation.** Continue efforts in Operation Clean-Up to address rubbish/debris associated with homelessness. OBJECTIVE **D-6** Encourage design that celebrates and supports the cultural and ethnic diversity of Fresno. IMPLEMENTING POLICIES **D-6-a** Consult with neighboring populations, including non-English speaking groups, to inform the architecture, landscape, programming, and interior design of City-owned facilities such as parks, offices, street lighting, and other visible features. *Commentary: The intent of this policy is to incorporate local needs and desires into the design and function of local-serving public facilities, as appropriate.* **D-6-b** Consider adopting and implementing incentives for, and support efforts by, private development to incorporate culturally-specific architectural elements in areas with a predominant ethnic population. OBJECTIVE D-7 Continue applying local urban form, land use, and design policies to specific neighborhoods and locations. IMPLEMENTING POLICIES D-7-a Amend or repeal the Community and Specific Plans as listed below. As appropriate, relocate specific street setback requirements found in the various plans to the Development Code. Repeal the Local Planning and Procedures Ordinance (LPPO) after adoption of the General Plan. *To Be Amended:* Bullard Community Plan (becomes Pinedale Neighborhood Plan) Sierra Sky Park Land Use Policy Plan (for consistency with the Airport Land Use Commission’s Sierra Sky Park Plan) Tower District Specific Plan Butler-Willow Specific Plan North Avenue Industrial Plan Sun Garden Acres Specific Plan Hoover Community Plan (becomes El Dorado Park Neighborhood Plan) *To Be Repealed:* West Area Community Plan Roosevelt Community Plan Fulton/Lowell Specific Plan Woodward Park Community Plan Central Area Community Plan McLane Community Plan Fresno-High Roeding Plan Yosemite School Area Specific Plan Dakota-First Street Specific Plan Edison Community Plan Civic Center Master Plan Highway City Specific Plan Chapter 3: Urban Form, Land Use, and Design **D-7-b** | Consider preparing new community, neighborhood, and/or Specific Plans for neighborhoods and locations that were covered by repealed plans. | | **Commentary:** The City will work with community members in the preparation of new community, neighborhood, and/or Specific Plans after the adoption of the General Plan. **D-7-c** | **Forestiere Underground Gardens.** In the event that the Highway City Specific Plan is repealed, those goals and implementation policies in the Highway City Specific Plan that are pertinent to the Forestiere Underground Gardens shall be incorporated in their entirety into this General Plan and will remain in effect. ## 3.7 DISADVANTAGED UNINCORPORATED COMMUNITIES California Senate Bill 244 (Wolk, 2011; SB 244) requires local municipalities to identify Disadvantaged Unincorporated Communities (DUCs) within or adjacent to their Sphere of Influence (SOI), analyze the infrastructure needs of the DUCs (including water, wastewater, stormwater drainage, and structural fire protection), and evaluate potential funding mechanisms to make service extension feasible. Disadvantaged Unincorporated Communities are defined as settled places not within city limits where the median household income is 80 percent or less than the statewide median household income.[^p69-6], [^p69-7] Under the policy set forth by the Fresno Local Agency Formation Commission (LAFCO), a DUC must also have at least 15 residences with a density of one unit per acre or greater.[^p69-8] In 2015, Fresno LAFCO identified a total of 20 DUCs that are located within or adjacent to the City of Fresno SOI and which meet the full definition of a DUC (See Figure LU-3). ### Infrastructure Conditions Summary of Fresno Area DUCs #### Water Water access for DUCs is served through either the City of Fresno Public Utilities Department or through private wells. Adequate water infrastructure is defined as having existing infrastructure connecting a parcel that contains one or more residences to the City’s water system. The analysis does not include parcels that do not contain residences (i.e. vacant land or businesses) nor does it consider whether or not a residence has active service. #### Wastewater Similar to water, wastewater service is provided either through the City of Fresno Public Utilities Department or through private septic tanks. Adequate [^p69-6]: State of California Office of Planning and Research. Technical Advisory to SB 244. [^p69-7]: Flegal, C., Rice, S., Mann, J., & Tran, J. California Unincorporated: Mapping Disadvantaged Communities. PolicyLink, 2013 [^p69-8]: Fresno Local Agency Formation Commission. City of Fresno Municipal Service Review Public Review Draft, prepared by Policy Consulting Associates, LLC. October 20, 2015. Chapter 3: Urban Form, Land Use, and Design wastewater infrastructure is likewise defined as having existing infrastructure connecting a parcel that contains one or more residences to the City’s system. The analysis does not include parcels that do not contain residences nor does it make a distinction of active versus inactive service. ### Stormwater Drainage The stormwater drainage analysis includes review of the existing curb and gutter facilities in the DUC areas. Adequate stormwater drainage is defined as having curb and gutter located between a parcel containing one or more residences and the adjacent street(s) throughout the entire DUC area. FEMA Flood Zones are also given to indicate the likelihood that an area would face a significant flood threat.[^p70-9] | | | | :--- | :--- | | Zone X: | Areas determined to be outside the 0.2% annual chance floodplain. | | Zone XS: | Zone X (shaded). Areas of 0.2% annual chance flood; areas of 1% annual chance flood with average depths of less than 1 foot or with drainage areas less than 1 square mile; and areas protected by levees from 1% annual chance flood. | | Zone A: | No Base Flood Elevations determined. | | Zone AE: | Floodway Areas. The floodway is the channel of a stream [or canal] plus any adjacent floodplain areas that must be kept free of encroachment so that the 1% annual chance flood can be carried without substantial increases in flood heights. | ### Structural Fire Protection Fire protection service is provided through the City of Fresno Fire Department and through response agreements with the City of Clovis Fire Department and the Fresno County Fire Protection District. Adequate structural fire protection is defined as having all parcels located within a four minute-response area. Only two DUC areas are not completely within this area. [^p70-9]: Flood Insurance Rate Map for Fresno County. Federal Emergency Management Agency, 2009. Accessibility to fire hydrants is also important to the structural fire protection of DUCs, yet it was not possible to give an accurate analysis for fire hydrant coverage due to the constraints in mapping the (conservative) 500 foot range of coverage from a hydrant to a parcel via travel path. However, maps showing the 500 foot circular radius around fire hydrants is given in Appendix A to denote a general awareness of where fire hydrant coverage is sparse and where it is abundant. It should be noted that in areas without fire hydrant protection, the fire department will deploy a water tender and draft from seasonal irrigation canals as available to supplement the 500-700 gallons of fire suppression water carried on each apparatus. However, this alternate means of fire suppression results in significant delays or inability to mount an interior fire attack in a house, which affects rescue of the inhabitants and the deployment of adequate hose streams to protect adjacent structures. Chapter 3: Urban Form, Land Use, and Design In the following table, information is given for each DUC that exhibits the extent to which adequate infrastructure (as defined for each category) exists in those areas. | # | Water[^p72-1] | Wastewater[^p72-1] | Stormwater Drainage | Structural Fire Protection | | :--- | :--- | :--- | :--- | :--- | | | Connected Line | Connected Line | Curb & Gutter | FEMA Flood Zone | Within 4 Minute Zone | | 1 | 4 of 18 \| 22% | 7 of 18 \| 39% | No | Zone X | 100% | | 2 | 8 of 39 \| 21% | 1 of 39 \| 3% | No | Zone X | 100% | | 3 | 0 of 249 \| 0% | 0 of 249 \| 0% | No | Zone X & Zone XS | 100% | | 4 | 131 of 221 \| 59% | 53 of 221 \| 24% | No | Zone X & Zone XS | 100% | | 5 | 0 of 14 \| 0% | 0 of 14 \| 0% | No | Zone X & Zone XS | 3.6% | | 6 | 0 of 39 \| 0% | 0 of 39 \| 0% | No | Zone X & Zone A | 100% | | 7 | 0 of 12 \| 0% | 0 of 12 \| 0% | No | Zone X | 100% | | 8 | 0 of 25 \| 0% | 0 of 25 \| 0% | No | Zone X | 100% | | 9 | 1 N/A[^p72-2] | 1 N/A[^p72-2] | N/A | Zone X | 60% | | 10 | 0 of 4 \| 0% \| 12 N/A[^p72-2] | 0 of 4 \| 0% \| 12 N/A[^p72-2] | No | Zone X | 100% | | 11 | 0 of 15 \| 0% | 0 of 15 \| 0% | No | Zone X | 100% | | 12 | 327 of 330 \| 99% | 324 of 330 \| 98% | Yes | Zone X & Zone XS | 100% | | 13 | 13 of 14 \| 93% | 0 of 14 \| 0% | No | Zone XS | 100% | | 14 | 104 N/A[^p72-3] | 83 of 104 \| 80% | No | Zone X, Zone XS, & Zone AE | 100% | | 15a | 462 N/A[^p72-3] | 416 of 462 \| 90% | No | Zone X & Zone XS | 100% | | 15b | 122 of 131 \| 93% \| 5 N/A[^p72-3] | 125 of 136 \| 92% | No | Zone X & Zone XS | 100% | | 16 | 159 of 159 \| 100% \| 441 N/A[^p72-3] | 587 of 600 \| 98% | No | Zone XS | 100% | | 17 | 976 of 976 \| 100% | 976 of 976 \| 100% | No | Zone X & Zone XS | 100% | | 18 | 1195 of 1195 \| 100% | 1195 of 1195 \| 100% | Yes | Zone X, Zone XS, & Zone AE | 100% | | 19 | 56 of 60 \| 93% | 60 of 60 \| 100% | No | Zone XS | 100% | | 20 | 272 of 272 \| 100% | 264 of 272 \| 97% | No (missing 3 parcels) | Zone X | 100% | [^p72-1]: Counts of parcels with one or more residences are considered as a close approximation. [^p72-2]: These parcels are located within the boundaries of the Malaga Water District. [^p72-3]: These parcels are located within the boundaries of the Bakman Water District. The number of parcels with residences within each DUC was determined through visual interpretation of aerial maps and Google Maps Street View. Maps and additional data are included in Chapter 3, Appendix A. 3-71 ### Water Districts As noted in Table 3-4, some DUCs or portions of DUCs are served by the Malaga and Bakman Water Districts. While the active service in these areas may be more limited than the actual district boundaries, they are nevertheless excluded from the analysis because an activation or system upgrade in these areas would be managed by the respective water district, not the City. ### Potential Funding Mechanisms to Address Deficiencies SB 244 does not require cities to provide infrastructure directly to DUC areas, however, it does require cities to evaluate potential funding mechanisms that would make such service extensions feasible. The following alternatives are provided as potential funding mechanisms that could be utilized by entities within the governmental, private, and non-profit realms. ### New Development One way to address existing deficiencies is through new private development where the installation, upgrade, or expansion of infrastructure would be required to serve the new development. This type of development typically occurs on a limited, site-specific basis and is thus unlikely to address area-wide infrastructure needs within large areas that are nonadjacent to the city limits. However, for small areas like DUC Area 1 or in areas like DUC Area 15b, where infrastructure is missing from only a small number of parcels, private development could be effective in completing the community’s total infrastructure needs. ### Service Districts Another mechanism to provide infrastructure is to establish an assessment district to bond for infrastructure construction and pay for it over time. A district would fund the cost of the infrastructure within a designated area through the fairly proportioned financial contributions of each benefiting landowner. To form a district, property owners vote to affirm the establishment of the district and assessment through a special election. This method would be most effective in areas that are missing significant portions of infrastructure such as water and sewer mains along major corridors. ### Grants and Loans There are numerous state, federal, and regional grants and loans that can provide funding for infrastructure projects within DUCs. Some examples include: Chapter 3: Urban Form, Land Use, and Design STATE WATER RESOURCES CONTROL BOARD DRINKING WATER STATE REVOLVING FUND[^p74-10] The DWRSF is a State-managed fund that can supply low-interest to no-interest loans to provide drinking water infrastructure to disadvantaged communities. Eligible applicants include cities, counties, districts, for-profit and non-profit community water systems, public school districts and other non-community water systems, and systems that are created by the project. The repayment terms are 20 years or longer and the principal balance may be forgiven for publicly owned water systems or non-profit mutual water companies that serve disadvantaged communities. STATE WATER RESOURCES CONTROL BOARD CLEAN WATER STATE REVOLVING FUND[^p74-10] The CWSRF provides low interest financing agreements (dependent on General Obligation Bond Rate) for wastewater and stormwater treatment projects. Eligible applicants include cities, counties, districts, state agencies, tribal governments/organizations, agencies approved under Section 208 of the Clean Water Act, 501(c)(3)s, and National Estuary Programs. The repayment terms are up to 30 years or the useful life of the project. A percentage of the total project cost up to the full amount may be waived for projects benefiting DACs.[^p74-11] STATE WATER RESOURCES CONTROL BOARD DIVISION OF FINANCIAL ASSISTANCE The Division of Financial Assistance is in charge of implementing the State Water Resources Control Board’s financial assistance programs and contains a link to current funding sources on its website at www.waterboards.ca.gov/water_issues/programs/grants_loans GROUNDWATER QUALITY FUNDING ASSISTANCE[^p74-12] The Groundwater Grant Program holds approximately $744 million dollars for the prevention and cleanup of contamination of groundwater-sourced drinking water. Up to $160 million has been specifically set aside for project serving disadvantaged communities (DACs) and economically distressed areas (EDAs). Eligible applicants include public agencies, non-profits, tribal organizations, public utilities, and mutual water companies. Grants range from $100,000 - $1 million for planning and $500,000 - unrestricted for implementation. Funds are [^p74-10]: “Below-Market Financing for Wastewater & Water Quality.” State of California Clean Water State Revolving Fund. [^p74-11]: “Proposition 1 - Small Community Wastewater." State Water Resources Control Board, 15 Sept. 2015. [^p74-12]: “Water Board Groundwater Funding Programs.” California Water Boards. available from 2018 to 2021. Minimum local matching is 50%, however this may be reduced or waived for projects that benefit a DAC or EDA. INTEGRATED REGIONAL WATER MANAGEMENT (IRWM) GRANT PROGRAM[^p75-13] The IRWM Grant is administered by the Department of Water Resources and contains approximately $474.3 million in funding to be applied to projects that will adapt water systems to climate change, improve collaboration in regional water management, and increase regional water self-reliance (reducing reliance on the Sacramento-San Joaquin Delta). Of this $102 million is set aside for assistance to disadvantaged communities (DACs). Eligible applicants include public agencies, non-profits, tribal organizations, public utilities, and mutual water companies. Minimum local matching is 50%, however this may be reduced or waived for projects that benefit a DAC or EDA. INFRASTRUCTURE STATE REVOLVING FUND (ISRF) LOAN PROGRAM[^p75-14] The California Infrastructure and Economic Development Bank manages the ISRF program to provide low-cost financing for infrastructure projects in amounts ranging from $50,000 to $25 million with terms of up to 30 years. Municipal agencies and non-profit entities with municipal sponsors are eligible for funding. USDA RURAL DEVELOPMENT WATER & WASTE DISPOSAL LOAN & GRANT PROGRAM[^p75-15] The United States Department of Agriculture manages a Water & Waste Disposal Loan & Grant Program that offers long-term (up to 40 years), low-interest loans (sometimes combined with grants) for the construction or improvement of drinking water, sewer, solid waste, and storm water facilities in rural communities. The program may be pursued by state and local government entities, non-profits, and federally recognized tribes. [^p75-13]: “Proposition 1 IRWM Grant Program.” California Department of Water Resources. 22 Feb. 2016. [^p75-14]: California Infrastructure and Economic Development Bank. Criteria, Priorities and Guidelines for the Selection of Projects for Financing Under the Infrastructure State Revolving Fund (ISRF) Program. Adopted August 25, 2015. [^p75-15]: “Water & Waste Disposal Loan & Grants Program..” United States Department of Agriculture, Rural Development. Chapter 3: Urban Form, Land Use, and Design COMMUNITY DEVELOPMENT BLOCK GRANT FUND[^p76-16] Administered by the United States Department of Housing and Urban Development, CDBG Funds are used to benefit low- and moderate-income communities, blighted communities, and communities that face issues of health and welfare. The fund may be used by the state and by cities and counties and can be applied toward infrastructure improvements.[^p76-17] [^p76-16]: "CDBG Entitlement Program Eligibility Requirements." US Department of Housing & Urban Development, 2014. [^p76-17]: "Expenditure Report: Use of CDBG Funds by Fresno County, CA." US Department of Housing & Urban Development, Office of Community Planning and Development. 12 Jan. 2015 # City of Fresno ## Figure LU-3: ## Disadvantaged Unincorporated Communities Prepared by: Development and Resource Management Planning Division <
> NOTICE: This map is believed to be an accurate representation of the City of Fresno GIS data, however, we make no warranties either expressed or implied for the correctness of this data. Data Source: Fresno County Lafco Policies, Standards, and Procedures, Fresno Local Agency Formation Commission, Policy 108 - DUCs http://www.fresnolafco.org/lafco/h20Annex.asp Terms and Methodology: This map shows County of Fresno Geographic Information System (GIS) parcel mapping and US Census information to quantify the economic composition of all the census block groups within the vicinity of the Fresno city boundaries. Locations identified as DUCs display characteristics that indicate the presence of a DUC pursuant to Fresno LAFCO's Policy 108 and C.H. Each identified DUC area is designated with a number on the map and a corresponding description that identifies the location, number of properties within the DUC, its US Census tract-block group number, and the MHI level reported by ACS five-year estimates between 2006 and 2010. 3-76 FRESNO GENERAL PLAN Chapter 3: Urban Form, Land Use, and Design City of Fresno Figure LU-4: DUCs & District Boundaries Prepared by: Development and Resource Management Planning Division <
> NOTICE: This map is believed to be an accurate representation of the City of Fresno GIS data, however, we make no warranties either expressed or implied for the correctness of this data. Data Source: Fresno County LAFCo Policies, Standards, and Procedures, Fresno Local Agency Formation Commission, Policy 106 - DUCs http://www.fresnolafco.org/stand/fn106annex.asp Terms and Methodology: This map shows County of Fresno Geographic Information System (GIS) parcel mapping and US Census information to quantify the concern composition of all the census block groups within the vicinity of the Fresno city boundaries. Locations identified as DUCs display characteristics that indicate the presence of a DUC pursuant to Fresno LAFCo's Policy 106 and CKH. Each identified DUC area is designated with a number on the map and a corresponding description that identifies the location, number of properties within the DUC, its US Census tract-block group number, and the MHI level reported by ACS five-year estimates between 2006 and 2010. DECEMBER 2014 3-77 --- ## Circulation — Fresno General Plan, Chapter 4: Mobility and Transportation Element (amended September 2021) - Source: https://www.fresno.gov/wp-content/uploads/2023/03/upload_temp4-Mobility-and-Transportation-9-30-2021.pdf - Pages: 50 - Covers: circulation # 4 MOBILITY AND TRANSPORTATION The purpose of the Mobility and Transportation Element is to provide an efficient, multi-modal transportation system that will meet the needs of all residents throughout the planning period. The Element is based on a fundamental philosophy that travel needs can be met through a comprehensive program of transportation planning, land use planning, growth management strategies, and a new Complete Streets concept. This Element includes objectives and policies for all modes and all users of streets and highways, transit, sidewalks and trails, and bicycle transportation modes, as well as parking, goods movement strategies, and the City's airports. # 4.1 CONTEXT This element has a strong connection to the Urban Form, Land Use, and Design Element, as the intensity, type, and location of land uses directly affects demand for transportation, and the idea of Complete Neighborhoods and pedestrian-oriented shopping districts must be supported by a well-connected system of Complete Streets, transit, and pedestrian and bicycle networks. A good transportation system also is critical to achieving the economic goals of this General Plan. Issues of transportation and connectivity also influence issues in other elements, such as supporting healthy communities; a resilient city; fiscal sustainability; improving air quality; access to police, fire, and medical services; and the ability to go for a walk. The appearance and function of public roadways is also one of the major components of a city’s character and functionality, and one of the City government’s main investments in the public realm and sense of place of its community. Relationship to General Plan Goals The Mobility and Transportation Element supports a number of General Plan goals, in particular the following: 1. Increase opportunity, economic development, business and job creation.[^p2-1] *Use urban form, land use, and Development Code policies to streamline permit approval, promote local educational excellence and workforce relevance, significantly increase business development and expansion, attract and retain talented people, create jobs and sustained economic growth, strategically locate employment lands and facilities, and avoid over-saturation of a single type of housing, retail or employment.* 3. Emphasize conservation, successful adaptation to climate and changing resource conditions, and performance effectiveness in the use of energy, water, land, buildings, natural resources, and fiscal resources required for the long-term sustainability of Fresno. 9. Promote a city of healthy communities and improve quality of life in established neighborhoods. *Emphasize supporting established neighborhoods in Fresno with safe, well maintained, and accessible streets, public utilities, education and job training, proximity to jobs, retail services, and health care, affordable housing, youth development opportunities, open space and parks, transportation options, and opportunities for home grown businesses.* [^p2-1]: The commentary in italics following certain goals is not part of the goal itself, but is instead advisory language intended to further discuss and clarify the goal to help guide the objectives of this General Plan 11. Emphasize and plan for all modes of travel on local and Major Streets in Fresno. *Facilitate travel by walking, biking, transit, and motor vehicle with interconnected and linked neighborhoods, districts, major campuses and public facilities, shopping centers and other service centers, and regional transportation such as air, rail, bus and highways.* 13. Emphasize the City as a role model for good growth management planning, efficient processing and permit streamlining, effective urban development policies, environmental quality, and a strong economy. Work collaboratively with other jurisdictions and institutions to further these values throughout the region. *Positively influence the same attributes in other jurisdictions of the San Joaquin Valley –and thus the potential for regional sustainability - and improve the standing and credibility of the City to pursue appropriate State, LAFCO, and other regional policies that would curb sprawl and prevent new unincorporated community development which compete with and threaten the success of sustainable policies and development practices in Fresno.* 14. Provide a network of well-maintained parks, open spaces, athletic facilities, and walking and biking trails connecting the city's districts and neighborhoods to attract and retain a broad range of individuals, benefit the health of residents, and provide the level of public amenities required to encourage and support development of higher density urban living and transit use. 16. Protect and improve public health and safety. ## 4.2 STRATEGIC INITIATIVES Fresno has an effective and well-planned transportation system that is one of the strengths of the city. Looking ahead, however, the City has unmet transportation needs. A “re-think” is needed to consider how to meet them, given emerging concerns about urban form and economic development, performance measures for multi-modal planning, fiscal realities, and environmental considerations, as well as the State mandate that the concept of Complete Streets be integrated into the local general plan. How all of these ideas can be brought together is the focus of this section. ### Complete Streets The California Complete Streets Act (Act) requires general plans updated after January 30, 2011 to develop a plan for a multi-modal transportation system. The goal of the Act is to encourage cities to rethink policies that emphasize automobile circulation and prioritize motor vehicle improvements, and come up with creative solutions that emphasize all modes of transportation. Complete Streets design has many advantages. When people have more transportation options, there are fewer traffic jams and the overall capacity of the transportation network increases. Additionally, increased transit ridership, walking, and biking can reduce air pollution, energy consumption, and greenhouse gas emissions, while improving the overall travel experience for road users. Providing more transportation options will allow the City to meet its future travel demands without solely relying on motorized vehicles. Specifically, the legislation requires roadways to be designed to accommodate all users and provide a balance of multiple uses. Users could include motorists, pedestrians, bicyclists, children, older adults, persons with disabilities, and users of public transportation. Each street segment is not required to be Complete Street on its own; rather, all streets within the system as a whole must be considered. However, major thoroughfares such as Fresno’s Arterials are among those roadways that should be Complete Streets along their entire length. The only exception would be if an immediately proximate roadway offered a faster, safer, and more convenient route, such as a bike boulevard running parallel to a heavy traffic corridor. While there is no standard design template for a Complete Street, it generally includes one or more of the following features: bicycle lanes, wide shoulders, well-designed and well placed crosswalks, crossing islands in appropriate midblock locations, bus pullouts or special bus lanes, audible and accessible pedestrian signals, sidewalk bulb-outs, center medians, street trees, planter strips and ground cover. Complete Streets create a sense of place and improve public safety due to their emphasis on comprehensively encouraging pedestrian activity. ### Using Performance Standards for Multi-Modal Systems The City’s current method of evaluating roadway performance needs to be updated to bring it in line with best practices for transportation planning and the Complete Streets legislation and align with General Plan goals for a multi-modal system. The current performance criteria dictate the number of street lanes constructed in order to prevent traffic congestion from exceeding a certain level, without consideration of other transportation modes that also should be accommodated. Issues with the City’s traditional approach to roadway performance include: * The current “one size fits all” approach that treats all areas of the city the same; * The absence of other modes of travel—walking, bikes, transit—from the criteria; and * The City’s past practice of giving relatively high priority to vehicle travel level of service. This emphasizes keeping traffic congestion low but requires a roadway system that is expensive to construct and maintain to serve the city's peak 15-minute travel time (rush hour). This also distorts the land development market and does not support the General Plan's urban form concepts. ### System Capacity Design Related to the City's high performance standards, Fresno's roadway system is built to handle a very short peak period of usage. The city does not have a full rush “hour,” but rather a peak 15-minute period at most major intersections. Similar to a giant parking lot built to accommodate shoppers on the busiest day of the year only, but which is relatively empty most of the time, the street system is designed for a very small portion of overall demand. This approach does create minimal traffic congestion at peak times, but results in an over-supply of capacity the majority of the time. It also requires a large amount of land to be devoted to streets, using up land that could be used for residential and commercial development, parks, schools and civic facilities. It creates environmental impacts and discourages travel by other modes—which paradoxically increases the amount of traffic on Fresno's streets. It is also expensive for the City to maintain this robust roadway system. ### Making Use of Excess Capacity Fresno's existing street system has excess capacity in several key areas due to the recent construction of the freeway system. The City can take advantage of this situation by promoting denser development on these streets, which will make the most efficient use of an existing public resource, increase opportunities for economic development and property values, and encourage a diversity of development types. ### Comprehensive Connectivity Fresno has transportation facilities that meet most modes of circulation, but the systems for pedestrians and bicycles are largely incomplete. In certain areas of Fresno, there is also difficulty in getting from one neighborhood to another, and to local stores, services, and public facilities such as schools and parks, by any means other than private automobile. Completing these citywide networks will encourage faster and simpler travel routes for work, errands, and recreation. A well-connected street system offers a choice of routes and enables more direct connections. At the neighborhood scale a street grid facilitates walking, as convenience and direct routes are very important to pedestrians. What is good for walking is also good for transit: in a well-connected street system, buses can travel along routes easily reached on foot from the neighborhood interior. At a district or city scale, a grid provides ideal conditions for a robust bicycle network. Cyclists prefer direct routes with moderate or low auto traffic; streets meeting both these descriptions can only be found in a system where streets connect across and not only within neighborhoods. Critically, a connective pattern is good for automobile traffic. With many routes to choose from, cars are able to distribute across the system rather than relying on a few major roads. This is also a valuable component of safe and efficient emergency vehicle response. ## Air Transportation Regional, national and global connectivity is provided by the City's two public airports, Fresno Yosemite International (FYI) and Fresno Chandler Executive Airport (FCH), and one private airport open to public use, Sierra Sky Park. FYI has excellent connectivity throughout the United States and world with ten airlines serving 12 non-stop destinations (five of which are major gateways). This also fosters healthy competition between the air carriers and stabilizes airfares. As of February 2014, FYI has connectivity to 242 domestic destinations and 74 international destinations across all seven continents - through just one connecting flight. FCH serves as a critical reliever airport to FYI and is the busiest general aviation airport in the Central Valley. It plays a significant role in accommodating business and corporate connectivity to the region and throughout California. The airport-related Objectives and Implementation Policies identified in this element address the continued viability of both FYI and FCH. ## Parking and Goods Movement Fresno does not have any particular issue with parking and goods movement, but faces similar concerns of many other cities, which is ensuring adequate infrastructure and logistics to keep the costs of economic development low, while simultaneously aiming to improve visual appearance, enhance the safety of walking and biking, and reduce the costs of road maintenance. The reliance of both inter-regional and local goods movement on State Route 99 is an important issue for both Fresno and the San Joaquin Valley, and plans for future development will need to avoid loading unnecessary personal traffic onto this crucial corridor when possible. ## 4.3 ROADWAYS AND AUTOMOBILES <
> A well-connected, multi-modal transportation system serves all Fresnans. The City and County public roadway network, together with State highway routes, comprise the predominant transportation infrastructure in and around Fresno. Although this network primarily serves travel by private automobiles, it also accommodates persons travelling by most modes, as well as the distribution of goods and services. Streets and highways are also the most widespread element of the public realm, constitute a prominent urban form defining feature, and establish a common environment and image of the city. Automobile travel has been the main emphasis of transportation planning and is the dominant mode in Fresno. According to Fresno Council of Governments’ (FCOG) Travel Demand Model (2012), about 91.2 percent of the total average daily trips beginning or ending in the County are made by private vehicles. About 7.4 percent of the daily average trips are made by walking and bicycling, and less than one percent (0.86 percent) use transit, based on the most recent U.S Census journey to work data. In Fresno, the roadway system configuration has been primarily based on a traditional grid pattern. The oldest part of the city (the traditional Downtown area) is an urban grid oriented to the Union Pacific (originally Southern Pacific) railroad alignment that traverses the San Joaquin Valley in a northwest to southeast direction. Outside of this area the grid shifts to a north-south orientation based on Township, Range and Section lines. Almost all of the Arterial and Collector Streets (roadways) within the Metropolitan Area are regularly spaced at half-mile intervals. This roadway pattern has been modified in the past several decades to include several curvilinear and diagonal alignments, and neighborhood street patterns have sometimes deviated from the grid pattern. Over time, Fresno’s street circulation system and developed urban form have also been framed by limited access State highways that traverse the city. State Route 99 traverses the city from northwest to southeast, connecting Fresno to other communities throughout the central and southern San Joaquin Valley. State Routes 41 and 180 bisect the city north-south and east-west connecting Fresno to Yosemite and Kings Canyon National Parks, respectively. State Route 168 links Fresno to Clovis and Sierra Nevada recreational attractions at Shaver and Huntington Lakes to the northeast. The construction of the freeway system removed a substantial amount of the “through” traffic from the local roadway network (e.g.: Blackstone Avenue, Golden State Boulevard, Kings Canyon Road), freeing up capacity on the local streets except at intersections near freeway interchanges. This urban freeway system has shortened commute times from the northern areas of the city and Clovis, and to the east for bedroom communities and foothill communities, thus supporting the continued spread of urbanization onto productive agricultural land, increasing commute lengths, and vehicle miles travelled each day to and from work. ### Roadway System Figure MT-1: Circulation Diagram designates the planned roadway network of the General Plan. The planned roadway system focuses primarily upon roadways, which includes the Expressway, Superarterial, Arterial, and Collector Streets. For some roadways, especially in areas that are not yet developed with urban uses, the diagram indicates the future and not the present character of the road. The construction of planned roadways occurs during the course of a general plan’s implementation through the execution of the City’s capital improvements program utilizing funds from a variety of sources. In addition, portions of roadways are constructed by private property owners and developers in accordance with applicable property development standards. ### Street Typologies This General Plan establishes a refined street classification system to categorize roadways and other transportation facilities, as shown in Figure MT-1: Circulation Diagram. Each classification reflects the character of the facility as well as its function within the context of the entire transportation system. Each classification has standards considering a facility’s relation to surrounding land uses, existing rights-of-way, accessibility via other roadways, and appropriate travel speeds. While roadway classification types were originally based upon a priority given to various types and lengths of motor vehicle tips, they now give substantial consideration to the accommodation of multiple travel modes and trips (public transportation, bicycle, pedestrian). This classification system will be used for engineering design and traffic operation standards. Scenic Corridors apply the corresponding classification listed here. **Freeway:** Multiple-lane divided (median island separation) roadways on adopted State route alignments servicing through and crosstown traffic, with no access to abutting property and no at-grade intersections. Freeways are under the jurisdiction of the State, outside the control of the City. They have been assessed for the purposes of this General Plan due to their location within the Planning Area for the General Plan. **Expressway:** Four- to six-lane divided (median island separation) roadways primarily serving through and crosstown vehicle traffic, with at-grade major street intersections located at approximately one-half mile intervals and no driveways for direct motor vehicle access to abutting property. **Superarterial:** Four- to six-lane divided (median island separation) roadways with a primary purpose of moving multiple modes of travel traffic to and from major traffic generators and among subregions. A select number of motor vehicle access points to adjacent properties or local streets between the major street intersections may be approved by the City. Access points will be limited to right-turn entrance and exit vehicular movements, as well as select left-turn partial openings in medians from the Superarterials to surrounding properties or neighborhoods, limited to one location per half-mile. No left turns are allowed out of local streets or properties. **Arterial:** Four- to six-lane divided (median island separation) roadways, with somewhat limited motor vehicle access to abutting properties, and with the primary purpose of moving traffic within and between neighborhoods and to and from freeways and expressways. In addition to major street intersections, appropriately designed and spaced local street intersections may allow left-turn movements to and from the arterial streets. **Collector:** Two- to four-lane undivided (opposing travel lanes generally not separated by a median island) roadways, with the primary function of connecting local streets and arterials and neighborhood traffic generators and providing access to abutting properties. Local street intersections and motor vehicle access points from abutting properties are allowed consistent with the City’s engineering standards and accepted traffic engineering practices. Collectors typically have a center two-way left-turn lane. **Local:** Two- to three-lane roadways designed to provide direct access to properties, while discouraging excessive speeds and volumes of motor vehicle travel incompatible with neighborhoods being served through the implementation of multiple, well connected routes and traffic calming measures. The alignments of future local streets are typically not specified by the General Plan Circulation Diagram, but existing local streets may be depicted for informational purposes. In specific circumstances local streets are designated where necessary to assure adequate access and implementation of Complete Neighborhoods with well-connected routes for motor vehicle, bicycle and pedestrian travel. Drive: A street that in addition to its transportation function provides opportunities for the enjoyment of natural and man-made scenic resources. The aesthetic values of scenic drives may be protected. <
> Figure MT-1: Major Street Circulation Diagram 1. See Policies MT-3-a and MT-3-b for Scenic Corridors[^p11-1]. Note: The Fresno Air National Guard Base, a military airport, and the Fresno Yosemite International Airport are located in the area represented as Fresno Yosemite International Airport. [^p11-1]: See Policies MT-3-a and MT-3-b for Scenic Corridors. Street Design Standards Over the past 35 years, the planned roadway hierarchy has shifted from being singularly focused on moving automobiles to a more complete multi-modal network. However, the relationship of street function to land use characteristics has continued to focus upon ameliorating adverse impacts of traffic nuisances with landscaped setbacks, walls and parking areas separating buildings from the street and sidewalk public realm. This system does not adequately account for land uses along streets that may be more focused on pedestrians, cyclists, and transit riders, as seen in Downtown, Activity Centers, and BRT Corridors. A new approach to street classification must now be considered to account for the specific characteristics sought in these areas. The General Plan expands the roadway classification descriptions to include specific characteristics, such as pedestrian realm, on-street parking, number of vehicle lanes, bike lanes, and landscaped median, as shown in Table 4-1. | TABLE 4 1: ROADWAY CHARACTERISTIC MATRIX | | | | | | | :--- | :--- | :--- | :--- | :--- | :--- | | Roadway Type | Number of Vehicle Lanes | Bike Lanes | Pedestrian Facilities | On-Street Parking | Median | | Expressway | 4 to 6 | No | Trail | No | Yes | | Superarterial | 4 to 6 | Yes | Sidewalks[^p12-1] | No | Yes | | Arterial | 4 to 6 | Yes | Sidewalks[^p12-1] | Possible | Yes | | Collector | 2 to 4 | Yes | Sidewalks | Yes | Possible | | Local | 2 to 3 | Possible (or Trail) | Sidewalks | Yes | Possible | Source: Fehr & Peers, 2011. 1. Where called for by the General Plan, a trail may be required instead of a sidewalk. Standards for Multi-Modal Level of Service This General Plan calls for the City to use a more flexible system of multi-modal measures or indicators of “Level of Service” (LOS) provided by public roadways to evaluate current and projected conditions for each mode of travel and identify congestion points or deficiencies which need to be addressed in planning for future improvements. Historically, LOS analysis has been auto-oriented and relied upon a conventional perspective of the primary use of public streets by motor vehicles rather than considering all modes of travel, including public transportation, bicycling and walking. This system provides a ranking of the efficiency of a street segment or intersection with six categories ranging from A (free traffic flow with individual vehicles virtually unaffected by the presence of other vehicles) to F (forced, stop-and-go travel with the volume of vehicles substantially exceeding the capacity of the street and often [^p12-1]: Where called for by the General Plan, a trail may be required instead of a sidewalk. referred to as “gridlock”). A multi-modal LOS system would address the frequency of bus service or the width of sidewalk clear zones for pedestrians and how many people are served by a facility, whatever their mode of travel, rather than just how many cars get through an intersection. Level of service is typically evaluated using a peak hour travel condition rather than a 24-hour average daily travel condition - when is traffic at its worst. LOS A, therefore, would appear to be a good grade to achieve. But it is actually a result of overbuilding the system, resulting in wasted money, resources, land, and increased impacts from the facility, such as encroaching closer than necessary to existing houses or removing of houses unnecessarily. However, LOS F is not always good either, resulting in increased commute times, more idling cars resulting in increased emissions, and driver frustration. In analyzing current and future projected conditions there needs to be exceptions to standards where it would not be reasonably feasible to provide the sufficient street width to make improvements necessary to accommodate projected peak hour traffic volumes to attain the set LOS for that roadway or intersection. Congestion, especially if only for short periods of time, can be more fiscally prudent compared to the costs and impacts of facility improvements and maintenance that at the same time may contribute to an overbuilt system. Additionally, congestion can incentivize the use of transit or other modes of transportation that more efficiently move people, save tax dollars, and are better for local air quality. ### Context-Sensitive LOS A more dense urban development pattern will focus traffic increases within the urban core of the city when compared to a less dense pattern where development is located on the urban fringe. However, a denser development pattern brings with it more travel mode choices and can result in shorter trips and more trips made by bus, by bicycle or on foot, compared to a more dispersed pattern. Thus, more compact infill development tends to have a smaller impact per dwelling unit on roadway level of service and the demand for street widening and extension as compared with more dispersed development at the urban edge. An example of this is the congestion that currently occurs on Friant Road during the AM and PM peak periods in northeast Fresno due to low-density development on the urban fringe, as compared to the low level of congestion that occurs in the area around the Tower District. The General Plan envisions that a context-sensitive LOS system can be developed which will be more responsive to the City’s needs and support achieving the urban form concepts of the Plan. All-Day vs. Peak Period Use LOS is measured based on traffic conditions during the morning and evening peak periods. Good or satisfactory conditions ("free flow" at LOS A to "tolerable delays" at LOS D) are ascribed to roadways where congestion does not become acute even during rush hour. Meeting this standard requires the construction of roadways that provide far more capacity than is needed for most hours of the day. Accommodating a LOS of D or better for vehicular traffic may necessitate six- and eight-lane roadways with dual left turn lanes. These roadways then become extremely wide and unfriendly for pedestrian and bicycle use. Responding to this problem, the General Plan sets a direction for a Complete Streets system that will be more efficiently used. This may mean a greater emphasis on distributing traffic across a more connective network, and a greater tolerance for peak-hour congestion. Multi-Modal LOS As mentioned above, the General Plan proposes a balanced transportation system that serves public transit, bicyclists and pedestrians as well as motor vehicles. This multi-modal system will support more compact development patterns, which in turn will support other goals, including farmland preservation and neighborhood walkability. Less reliance on the automobile is critical for Fresno if the city is to improve air quality and reduce greenhouse gas emissions. A multi-modal system will ensure mobility for all community members. Ultimately, a truly multi-modal system is more resilient from a transportation perspective, giving Fresno attributes it needs to manage congestion over the long-term. Fresno can create a transportation system that performs well for all modes, in part by measuring performance with qualitative indicators for each mode based on inputs covering facility design, facility controls, and volumes. This multi-modal LOS concept is illustrated in Table 4-2. Implementing a multi-modal LOS standard would require the consideration of all travel modes when evaluating traffic congestion such that widening roads at the expense of walking and bicycling—a result that ironically is much more expensive for private development to build, the public sector to maintain, and adds more traffic to streets since other travel modes are no longer possible - would not explicitly be considered reasonable. A multi-modal LOS system will also help support the development of more intense land uses where desired by permitting localized automobile congestion if walking, biking, and transit systems operate at high levels. A multi-modal LOS standard does not define an overall grade for a roadway section, but provides information for each travel mode to properly assess, for that facility, the best approach to improve its travel capacity with the financing available. Based on a project's location, the proposed improvements will be different. A more suburban intersection may add capacity with a double left turn lane where at a Downtown intersection it may be determined infeasible due to the lack of available right-of-way, or pedestrian islands are required to improve pedestrian flow and intersection wait times. TABLE 4 2: MULTI MODAL LEVEL OF SERVICE INDICATORS | LOS | Transit | Bicycle | Pedestrian | | :--- | :--- | :--- | :--- | | A | (Good walk access to bus stops, frequent service, good bus stop amenities.) | (Few driveway and cross street conflicts, good pavement condition, ample width of outside lane, including parking and bike lanes.) | (Low traffic volumes, wide buffer separating sidewalk from traffic, numerous street trees, and high parking occupancy.) | | B | | | | | C | <
> | <
> | <
> | | D | | | | | E | | | | | F | (Poor walk access to bus stops, infrequent service, poor schedule adherence, no bus stop amenities.) | (Poor pavement condition, narrow width of outside lane, frequent driveways and cross streets.) | (High traffic volumes, limited buffer separating sidewalk from traffic, few street trees, low parking occupancy.) | Source: Dowling Associates, 2010. ### Designing for Sustainable Transportation Four approaches have guided policy development for transportation: 1. **Reduce Vehicle Miles Traveled (VMT).** Reducing VMT frequently involves providing more and better transportation options and improving land use so that frequent origins and destinations are closer. The main benefit of reducing VMTs is the benefit to Fresno’s air quality since vehicle emissions are one of the main sources of air pollution in our air basin. Reducing VMT frees up discretionary income for Fresno families by reducing money spent on fuel and vehicle wear and tear. Reducing VMT supports economic development by shifting trips that don't need to drive, preserving scarce roadway capacity for goods movement and trips that do need to drive. Finally, reducing VMT helps people by (usually) increasing walking, bicycle and transit use, all of which increase physical activity and therefore health. 2. **Prioritize Funding for Improvements in Areas That Have Reported Fatalities and Injuries.** Reducing unanticipated congestion due to accidents adds benefits through trip reliability for freight and other high value trips. Reducing unanticipated congestion also reduces braking, acceleration and idling, all of which reduce fuel consumption and, therefore, greenhouse gas emissions. 3. **Improve Travel Time Reliability.** For high value trips (e.g., freight and commute), predictable/reliable travel times are often more valuable to users than improvements to average travel time. Improving travel time reliability supports the economy by creating more reliable freight trips. Improving travel time reliability helps people by allowing them to avoid wasting time by leaving early in order to deal with unpredictable trip times. It also helps reliability and performance of emergency response vehicles. 4. **Improve Speed Consistency.** Improving speed consistency can help reduce fuel consumption. It is a measure based on speed, braking and acceleration. Pursuing traffic synchronization on major roadways will result in reduced travel time, smoother vehicle and transit flows, as well as reduced vehicle emissions and improved air quality. ## 4.4 BIKES AND PEDESTRIANS Fresno has made a strong commitment to improving non-motorized travel. The City established a Bicycle-Pedestrian Advisory Committee in 2002 and subsequently completed the Bicycle, Pedestrian and Trails Master Plan (BMP), which was adopted by the City Council in 2010. In 2017, the City adopted the Active Transportation Plan (ATP) which is replaces the BMP. Although the ATP is a separate document and not part of this Plan, the General Plan supports the ATP’s aspirations for a comprehensive bicycle and pedestrian facilities network consisting of sidewalks, lanes, paths and trails while recognizing that the ATP identifies more facilities and programs than discussed in the General Plan. The ATP also identifies more detailed implementation strategies with cost estimates and prospective funding sources, evaluates priorities of prospective improvements, and identifies a complete inventory of both short-and long-range bicycle improvements. ### Pedestrian Facilities and the Pedestrian Realm #### Sidewalks The presence of sidewalks and the quality of the pedestrian realm is a critical factor in the ability to walk around the city. Certain areas of Fresno lack continuous sidewalks, leaving pedestrians to share road space with cars. The City began addressing this problem with the “No Neighborhood Left Behind” program in 2005, which added new gutters, curbs, sidewalks, and streetlights to inner city neighborhoods at a budget of $45 million over six years starting in FY 2005, and has since been completed. ### Accessible Design Most of the city was built before the federal Americans with Disabilities Act (ADA) required streets to be accessible to persons in wheelchairs or with impaired mobility. The City made significant progress in rebuilding sidewalks to add curb cuts or Chapter 4: Mobility and Transportation accessibility ramps and will continue striving to do so with a focus on areas with the highest pedestrian usage. <
> Sidewalks and trails throughout Fresno offer residents alternative methods of moving through the city, including walking and bicycling. Figure MT-2: Paths and Trails <
> 1. Conceptual alignment of existing and proposed path and trail. All planned Parkway access and projects, their features, uses, and locations, are subject to the acquisition of lands and/ or easements from willing sellers, and project-specific, site-specific environmental review. 2. Required unless there is an existing railroad. Should existing railroad lines be vacated, they shall be converted to a greenbelt. 3. Conceptual alignment, subject to City/County cooperative planning adoption, and implementation. City preferred location depicted. Note: Paths and Trails adjacent to neighboring jurisdictions may be developed jointly with that jurisdiction. Note: Complete detail of the proposed bike network can be found in the Active Transportation Plan. Note: Trails shall be developed on side of road represented in the Active Transportation Plan, to do otherwise would require Active Transportation Plan Amendment and minimum length of 2 miles. Comfort and Amenities In a typical neighborhood, continuous sidewalks and ADA-compliant curb cuts may be satisfactory to provide for pedestrian movement. In areas where high pedestrian use exists or is desired, a successful pedestrian environment also requires street design that is comfortable and attractive to people on foot. While sidewalk capacity is not generally an issue, sidewalks should be designed to comfortably accommodate people on foot, some of whom will walk in groups, use wheelchairs, or push strollers or delivery trolleys. The sidewalk should be ample enough to signal that walking is expected and encouraged. Trees should be provided at an adequate spacing, and placed to help provide a buffer between cars and pedestrians and shading in summer. On-street parking can be an important supporting component by providing an additional buffer between the sidewalk and vehicle travel lanes and an important vehicle calming mechanism encouraging lower vehicle operating speeds. Finally, benches, fountains, and other amenities help to make pedestrian use a reality and a pleasure. Bicycle Facilities Bicycle facilities consist of three types of classification, as follows: * Class I: Bicycle or multi-use (bicycle-pedestrian) path which is completely separated from vehicle traffic and typically a 10- to 12-foot wide concrete/asphalt-concrete paved surface with two-foot wide shoulders; * Class II: Designated on-street bicycle lane which is identified with painted pavement striping and signing and is typically at least five feet in width; and * Class III: On-street bicycle route which is designated by signs and markings and utilizes the paved surface shared with a low volume of motorized vehicles. * Class IV: Separated on-street bicycle lane, commonly known as “cycle track,” which is physically separated from motor vehicle traffic by a minimum three foot buffer and vertical element, distinct from the sidewalk, designed exclusively for bicyclists, and seven feet in width. As of 2017, Fresno has approximately 38 miles of Class I trails or paths, 426 miles of Class II bike lanes, and 21 miles of Class III bicycle routes, built over an approximately 40-year period generally beginning with adoption of the 1974 Fresno General Plan. Class I paths have been built within abandoned rail spur lines and municipal parkland, and dedications have been made adjacent to canals or Expressways as a condition of property development, and on land along the San Joaquin River. The City is working to resolve issues identified by the Fresno Irrigation District to accomplish development of path or trail improvements along canals. Currently within the urban area, the City has only been successful where new development has provided additional space adjacent to the canal. However, in the future the City will continue efforts to resolve impediments and implement paths along canal alignments. ## Planned Improvements ### Pedestrian During the past 10 years, the City Council has made constructing improvements to meet ADA accessibility requirements for public street sidewalks a City priority. As resources have become available, the City has also pursued the construction of missing segments of partially completed bicycle-pedestrian paths. The objectives and policies in this element generally present the following ideas for improving the pedestrian environment: * Continuous sidewalks will be required along public streets on both sides, within all new development. Sidewalks or alternative pedestrian routes will also be required within developments that utilize private street access; * New or improved pedestrian crossings and additional industry standard safety features such as pedestrian refuges, raised or lighted crossing areas, and signals will be built, as funding is available, where there is high pedestrian traffic; * Where freeways and railroads create major barriers to pedestrian travel, identify improvements for safe, grade separated pedestrian crossings to be built as funding is available; * Lighting that provides comfort and visibility to pedestrians will be a priority on streets where pedestrian use is high and on streets transitioning from a more auto-oriented to more mixed-use character; * Develop connectivity requirements and/or maximum block size or block length standards to apply to new development to ensure support for pedestrian travel; * Certain areas where walking is or has the potential to be most common may be identified for the implementation of improvements to promote a high-quality pedestrian experience. These areas might include arboretum corridors, Main Street commercial; mixed-use centers or corridors; transit corridors; and areas around schools, following a safe routes to school model, which is addressed in the Healthy Communities Element; and * Complete Streets and Multi-Modal roadway measures and performance characteristics, discussed elsewhere in this element, will also support greater walkability. Bicycle The City's planned bikeway network will support significant increases in bicycle use. It strives to ensure that major destinations are well-served by Class II bike lanes, well-marked Class III bike routes are extended into nearly all neighborhoods, an attractive system of Class I bike paths is provided in new growth areas and along key corridors where right-of-way exists, and Class IV separated bikeways are located along key streets to encourage the casual rider to bike to destinations outside their neighborhood. These four bicycle transportation components are described more below. SEPARATE MULTI-USE PATHS (CLASS I) Bike or multi-use (bicycle-pedestrian) paths are completely separated from vehicle traffic (Class I bikeways) and may be considered the most desirable type in terms of comfort, particularly by the casual bicyclist. New Class I bikeways will be investigated for all new growth areas, and will be developed in existing parts of the city where opportunities to obtain right-of-way may exist which would provide meaningful pathway connections. IMPROVED BIKE LANES (CLASS II) Providing Class I facilities may not be practical or cost effective in many parts of the developed urban area, and not necessarily preferable in terms of convenience and travel utility. Bike lanes (Class II facilities) are the heart of the bicycle network and will be accommodated along all roadways in new growth areas. They can often also be accommodated within already developed areas with the reconfiguration of travel lanes and on-street motor vehicle parking. Bike lanes will have a minimum width of at least five feet whenever possible. While this is adequate, bike lanes should be wider where space is available. They must be well striped and marked. IMPROVED SHARED BIKE ROUTES (CLASS III) Bike routes or bikeways (Class III facilities), which are identified with signage and lane markings indicating a shared roadway, have been identified as especially appropriate for bicycle use. As “the capillaries of the bikeway system,” Class III segments allow the bike system to provide critical links even where roadways are constrained and to extend into all neighborhoods. Class III facilities (routes and bikeways) will be expanded citywide and included in new development. IMPROVED SEPARATED BIKEWAYS/CYCLE TRACKS (CLASS IV) Separated Bikeways or cycle tracks (Class IV facilities) are on-street bicycle facilities that include a vertical physical barrier between the bikeway and moving traffic. These facilities have been identified as appropriate in areas with high motor traffic volume where Class II or Class III facilities would cause many bicycles to feel high levels of stress. Cycle tracks necessitate wider right-of-way than Class II and III facilities and are best placed in areas with fewer driveways. Table 4-3 summarizes Fresno’s existing bikeway system compared to the planned bikeway system in terms of mileage by facility type. TABLE 4-3: BICYCLE NETWORK | Facility Type | Existing System - 2017 (miles) | Planned System (miles) | Change | | :--- | :--- | :--- | :--- | | Class I | 38 | 165 | 203 | | Class II | 426 | 703 | 1129 | | Class III | 21 | 67 | 88 | | Class IV | 0 | 2 | 2 | Source: City of Fresno, 2017, ## 4.5 TRANSIT SERVICE Transit is a term used to cover all forms of public transportation, such as buses and various forms of rail (light rail, subways, heavy rail). ### Existing Transit Service The City operates Fresno Area Express (FAX), the city's major provider of urban public transportation services. The FAX fixed route conventional bus transportation system integrates with the City of Clovis' fixed route system; together these systems potentially serve a population of 650,000. The FAX fixed route system is comprised of routes that typically follow many of the city's Arterial roadways, which are generally spaced with a one-mile separation. The system currently includes 15 standard fixed routes of bus service and one express bus connection between the Riverpark regional commercial center, located at North Blackstone and East Nees Avenues, and Children's Hospital of Central California, located on Avenue 9 in Madera County. Many routes converge on Downtown and meet at the main transit center located on “M” and Fresno Streets (County of Fresno’s Courthouse Park). Most of the FAX routes operate at 30-minute frequencies, with four routes providing 20-minute frequencies during peak commute periods. A demand-response service, Handy Ride, provides transportation for older adults and persons with disabilities. The Fresno County Rural Transit Agency provides transit services to communities located outside of the Fresno Clovis Metropolitan Area. In addition, the Fresno County Economic Opportunities Commission provides transportation for access to specific social services. The FAX bus system provides connections to the Amtrak passenger rail station and the Greyhound bus station, both of which are located in Downtown. Amtrak’s San Joaquin line provides seven trains daily traveling both northbound to the San Francisco Bay Area and southbound to Los Angeles. Greyhound has eleven daily buses to Los Angeles and five to San Francisco. Intercity bus service is also provided by Orange Belt Stages and Transportation Inter-Californias. <
> *The FAX bus system has a fixed route system, primarily on major Arterial streets in the city, which offers residents another convenient method of moving around the city without their vehicles.* ### Access to Transit Fresno’s bus lines travel along many of the city’s heavily traveled major Arterial roads that serve the most densely populated neighborhoods and most intense office and commercial employment centers. With the expansive urban growth that occurred during the past decade, there are notable exceptions to transit accessibility, primarily in the west, northwest, northeast, and southeastern edges of the urban area. The bus system has not been expanded commensurate with peripheral urban development over the past decade, leaving predominantly lower density developed areas on the city’s outer edges without public transit services. This appears generally due to a combination of insufficient resources and decreasing performance (excessive cost per passenger and low farebox recovery) of routes serving lower density urban edge development. Bus Rapid Transit (BRT) A first phase Bus Rapid Transit (BRT) system is planned and funded to run along the Ventura Street/Kings Canyon Road and the Blackstone Avenue corridors, meeting in Downtown. This system is presently in the design stage with a planned implementation anticipated over the next few years. The General Plan supports the proposed BRT system through its designation of complementary land uses along and near its routes, such as higher-density development and land uses that may gravitate toward use of BRT. The Fresno General Plan Land Use Diagram (Figure LU-1) designates mixed-use, multi-family residential uses, and Activity Centers along the BRT routes. In addition, Shaw Ave. will be served by enhanced bus service while BRT is envisioned on California Ave. as part of the second phase. High Speed Train (HST) In addition to airport, train, and bus travel mentioned above, the California High Speed Train (HST) will also serve as a regional transportation system (see MT-3: Regional Transportation) for Fresno and surrounding communities. The proposed HST line, if approved and funded, would ultimately extend through the San Joaquin Valley, linking San Francisco with Los Angeles. The Initial Construction Section is planned to start in Madera County to just north of Bakersfield, with a station located in Fresno’s Downtown, aligned with Mariposa Street. The HST tracks through Fresno’s Metropolitan Area would run generally parallel to the Union Pacific Railroad tracks and primarily at-grade, with some shorter sections being depressed (below surface grade) to clear existing structures, such as the interchange of State Routes 99 and 180. However, any road proposed to cross the HST alignment will be grade-separated from the HST (go over or under). Implementation of a HST system would significantly increase the accessibility of Fresno to the major population and economic hubs of California. It also provides an opportunity for the redevelopment of the area around the station with a walkable district that includes offices, retail, and multi-family housing that takes advantage of the proximity of the HST station and captures value from disembarking passengers. Although this General Plan anticipates the building of the HST, it is not necessary to carry out the purposes or to implement the intent of the General Plan. While detailed planning has not yet occurred for the HST station, the City is examining and proposing to accommodate the access and space requirements and the potential effects upon surrounding properties and land uses through community and Specific Plans in the Downtown Planning Area and a HST Station Area Master Plan. When HST is built, the City ultimately plans to link the FAX and BRT systems with the HST station. Figure MT-3: Regional Transportation <
> Source: City of Fresno DARM, 2014 ## 4.6 OBJECTIVES AND POLICIES **OBJECTIVE** **MT-1** Create and maintain a transportation system that is safe, efficient, provides access in an equitable manner, and optimizes travel by all modes. **IMPLEMENTING POLICIES** **MT-1-a** **Transportation Planning Consistent with the General Plan.** Continue to review local, regional and inter-regional transportation plans and capital improvement plans, and advocate for the approval and funding of State highway and rail projects, consistent with the General Plan and discourage projects inconsistent with the General Plan. **MT-1-b** **Circulation Plan Diagram Implementation.** Design and construct planned streets and highways that complement and enhance the existing network, as well as future improvements to the network consistent with the goals, objectives and policies of the General Plan, as shown on the Circulation Diagram (Figure MT-1), to ensure that each new and existing roadway continues to function as intended. **MT-1-c** **Plan Line Adoption.** Prepare and adopt Official Plan Lines, or other appropriate documentation such as Director Determinations, for transportation corridors, roadways, and bicycle/pedestrian paths/trails, as necessary to preserve and/or obtain right-of-way needed for planned circulation improvements. **MT-1-d** **Integrate Land Use and Transportation Planning.** Plan for and maintain a coordinated and well integrated land use pattern, local circulation network and transportation system that accommodates planned growth, reduces impacts on adjacent land uses, and preserves the integrity of established neighborhoods. **MT-1-e** **Ensure Interconnectivity Across Land Uses.** Update development standards and design guidelines applicable to public and private property to achieve Activity Centers, neighborhoods and communities which are well connected by pedestrian, bicycle, appropriate public transportation and automobile travel facilities. **MT-1-f** **Match Travel Demand with Transportation Facilities.** Designate the types and intensities of land uses at locations such that related travel Chapter 4: Mobility and Transportation demands can be accommodated by a variety of viable transportation modes and support Complete Neighborhoods while avoiding the routing of excessive or incompatible traffic through local residential streets. **MT-1-g** **Complete Streets Concept Implementation.** Provide transportation facilities based upon a Complete Streets concept that facilitates the balanced use of all viable travel modes (pedestrians, bicyclists, motor vehicle and transit users), meeting the transportation needs of all ages, income groups, and abilities and providing mobility for a variety of trip purposes, while also supporting other City goals. Implementation actions will include: * Meeting the needs of all users within the street system as a whole; each individual street does not need to provide all modes of travel, but travel by all modes must be accommodated throughout the Planning Area; * Continuing to adopt refined street cross-section standards as appropriate in response to needs identified; * Encouraging conversion of one-way streets to two-way streets to improve location circulation, access, and safety; * Considering the impact of streets on public health by addressing storm water runoff quality, air quality, and water conservation among other factors; and * Adhering to the water efficient landscape standards adopted by the City for median and streetscape plantings and irrigation methods. **MT-1-h** **Update Standards for Complete Streets.** Update the City’s Engineering and Street Design Standards to ensure that roadway and streetscape design specifications reflect the Complete Streets concept, while also addressing the needs of through traffic, transit stops, bus turnouts, passenger loading needs, bike lanes, pedestrian accommodation, and short- and long-term parking. *Commentary:* For instance, transit stops and bus turnouts may have higher priority than through traffic on important transit corridors; through traffic may have higher priority than parking on Arterials; and pedestrian and bicycle movement may have high priority in areas with high pedestrian interest and activity such as the Downtown Planning Area. MT-1-i **Local Street Standards.** Establish and implement local roadway standards addressing characteristics such as alignment, width, continuity and traffic calming, to provide efficient neighborhood circulation; to allow convenient access by residents, visitors, and public service and safety providers; and to promote neighborhood integrity and desired quality of life by limiting intrusive pass-through traffic. MT-1-j **Transportation Improvements Consistent with Community Character.** Prioritize transportation improvements that are consistent with the character of surrounding neighborhoods and supportive of safe, functional and Complete Neighborhoods; minimize negative impacts upon sensitive land uses such as residences, hospitals, schools, natural habitats, open space areas, and historic and cultural resources. In implementing this policy, the City will design improvements to: * Facilitate provision of multi-modal transportation opportunities; * Provide added safety, including appropriate traffic calming measures; * Promote achievement of air quality standards; * Provide capacity in a cost effective manner; and * Create improved and equitable access with increased efficiency and connectivity. MT-1-k **Multi-Modal Level of Service Standards.** Develop and use a tiered system of flexible, multi-modal Level of Service standards for streets designated by the Circulation Diagram (Figure MT-1). Strive to accommodate a peak hour vehicle LOS of D or better on street segments and at intersections, except where Policies MT-1-m through MT-1-p provide greater specificity. Establish minimum acceptable service levels for other modes and use them in the development review process. MT-1-l **Level of Service in the Downtown Area.** Within the Downtown Planning Area accept vehicle LOS F conditions during peak hours for street segments and intersections specified in community and Specific Plans as may be adopted by the City. Where there is an overlap in policies regarding LOS in the Downtown Planning Area, this policy shall supersede. MT-1-m **Standards for Planned Bus Rapid Transit Corridors and Activity Centers.** Independent of the Traffic Impact Zones identified in MT-2-i Chapter 4: Mobility and Transportation and Figure MT-4, strive to maintain the following vehicle LOS standards on major roadway segments and intersections along Bus Rapid Transit Corridors and in Activity Centers: * LOS E or better at all times, including peak travel times, unless the City Traffic Engineer determines that maintaining this LOS would be infeasible and/or conflict with the achievement of other General Plan policies. * Accept LOS F conditions in Activity Centers and Bus Rapid Transit Corridor only if provisions are made to improve the overall system and/or promote non-vehicular transportation and transit as part of a development project or a City-initiated project. In accepting LOS F conditions, the City Traffic Engineer may request limited analyses of operational issues at locations near Activity Centers and along Bus Rapid Transit Corridors, such as queuing or left-turn movements. * Give priority to maintaining pedestrian service first, followed by transit service and then by vehicle LOS, where conflicts between objectives for service capacity between different transportation modes occur. * Identify pedestrian-priority and transit-priority streets where these modes would have priority in order to apply a multi-modal priority system, as part of the General Plan implementation. MT-1-n Peak Hour Vehicle LOS. For planning purposes and implementation of Capital Improvement Projects, maintain a peak-hour vehicle LOS standard of D or better for all roadway areas outside of identified Activity Center and Bus Rapid Transit Corridor districts, unless the City Traffic Engineer determines that maintaining this LOS would be infeasible and/or conflict with the achievement of other General Plan policies. MT-1-o LOS Deviations Outside of Activity Centers and Areas Designated for Mixed-Use. Accept vehicle LOS E or F conditions outside of identified multi-modal districts only if provisions commensurate with the level of impact and approved by the City Traffic Engineer are made to sufficiently improve the overall transportation system and/or promote non-vehicular transportation as part of a development project or City-initiated project. MT-1-p Participate in Sustainable Communities Strategy/ Regional Transportation Plan. Continue to work with the Fresno Council of Governments in developing and updating the Sustainable Communities Strategy and Regional Transportation Plan, consistent with the goals, objectives and policies of the General Plan. # OBJECTIVE **MT-2** Make efficient use of the City's existing and proposed transportation system and strive to ensure the planning and provision of adequate resources to operate and maintain it. # IMPLEMENTING POLICIES **MT-2-a** **Intensification of Bus Rapid Transit Corridors.** Where traffic has previously been diverted to freeways, encourage incentives for more intense development along transportation corridors, such as the Blackstone Corridor, where there is now additional capacity. *Commentary: The General Plan Land Use Diagram (Figure LU-1) shows corridors where increases in allowable densities are permitted.* **MT-2-b** **Reduce Vehicle Miles Traveled and Trips.** Partner with major employers and other responsible agencies, such as the San Joaquin Valley Air Pollution Control District and the Fresno Council of Governments, to implement trip reduction strategies, such as eTRIP, to reduce total vehicle miles traveled and the total number of daily and peak hour vehicle trips, thereby making better use of the existing transportation system. **MT-2-c** **Reduce VMT through Infill Development.** Provide incentives for infill development that would provide jobs and services closer to housing and multi-modal transportations corridors in order to reduce citywide vehicle miles travelled (VMT). *Commentary: This policy is intended to reduce regional trips and citywide congestion. Even if local congestion increases due to an increase in population from infill, this will eventually improve air quality by reducing per capita vehicle emissions and VMT through shorter commutes and increase in transit and non-motorized modes of travel. This will also reduce the need for regional travel demand transportation improvements.* **MT-2-d** **Street Redesign where Excess Capacity Exists.** Evaluate opportunities to reduce right of way and/or redesign streets to support non-automobile travel modes along streets with excess roadway capacity where adjacent land use is not expected to change over the planning period. *Commentary:* Such strategies could include narrowing roads (road diets), adding landscape medians, adding street parking, and adding bike lanes. **MT-2-e** Driveway and Access Consolidation. Take advantage of opportunities to consolidate driveways, access points, and curb cuts along designated major roadways when a change in development or a change in intensity occurs or when traffic operation or safety warrants. **MT-2-f** Optimization of Roadway Operations. Optimize roadway operations by continuing to expand the use of techniques such as the City’s intelligent transportation system (ITS) to manage traffic signal timing coordination in order to improve traffic operations and increase traffic-carrying capacity, while reducing unnecessary congestion and decreasing air pollution emissions. In order to facilitate roadway optimization and as a potential revenue source for the optimization, the following strategies need to be implemented: * Dig Once Policy. Install conduit for telecommunications use when trenching or construction occurs. * Telecommunications Strategy. Develop a costing mechanism for allowing the use of excess conduit within the City for use by communication carriers. The Policy shall follow regulations of the California Public Utilities Commission. * Grant Funding. Pursue grant funding to assist in construction and/or implementation of fiber-optic or other telecommunication infrastructure for additional public services such as education, economic development, reaching underserved populations, and public safety communications. **MT-2-g** Transportation Demand Management and Transportation System Management. Pursue implementation of Transportation Demand Management and Transportation System Management strategies to reduce peak hour vehicle traffic and supplement the capacity of the transportation system. *Commentary:* The City anticipates these strategies will reduce demand on the regional transportation system, limiting the need for major capital investments in those systems. MT-2-h | Update TIS. Update the City's Traffic Impact Study guidelines to address all modes of transportation and Complete Streets concepts consistent with the General Plan. The name should be expanded to encompass its assessment of various modes of transportation and connectivity in addition to traffic impacts. Once a regional fee plan or program is in place, the TIS may be used to carry out that plan or program. --- | --- MT-2-i | Transportation Impact Studies. Require a Transportation Impact Study (currently named Traffic Impact Study) to assess the impacts of new development projects on existing and planned streets for projects meeting one or more of the following criteria, unless it is determined by the City Traffic Engineer that the project site and surrounding area already has appropriate multi-modal infrastructure improvements. * When a project includes a General Plan amendment that changes the General Plan Land Use Designation. * When the project will substantially change the off-site transportation system (auto, transit, bike or pedestrian) or connection to the system, as determined by the City Traffic Engineer. * Transportation impact criteria are tiered based on a project's location within the City's Sphere of Influence. This is to assist with areas being incentivized for development. The four zones, as defined on Figure MT-4, are listed below. The following criteria apply: * Traffic Impact Zone I (TIZ-I): TIZ-I represents the Downtown Planning Area. Maintain a peak hour LOS standard of F or better for all intersections and roadway segments. A TIS will be required for all development projected to generate 200 or more peak hour new vehicle trips. * Traffic Impact Zone II (TIZ-II): TIZ-II generally represents areas of the City currently built up and wanting to encourage infill development. Maintain a peak hour LOS standard of E or better for all intersections and roadway segments. A TIS will be required for all development projected to generate 200 or more peak hour new vehicle trips. * Traffic Impact Zone III (TIZ-III): TIZ-III generally represents areas near or outside the City Limits but within the SOI as Chapter 4: Mobility and Transportation of December 31, 2012. Maintain a peak hour LOS standard of D or better for all intersections and roadway segments. A TIS will be required for all development projected to generate 100 or more peak hour new vehicle trips. o Traffic Impact Zone IV (TIZ-IV): TIZ-IV represents the southern employment areas within and planned by the City. Maintain a peak hour LOS standard of E or better for all intersections and roadway segments. A TIS will be required for all development projected to generate 200 or more peak hour new vehicle trips. **MT-2-j** | **Funding for Multi-Modal Transportation System.** Continue to seek and secure adequate financing to construct and maintain a complete multi-modal system through such measures as development impact fees, local sales tax measures, special tax measures, assessment/improvement districts, and regional, state and federal transportation funds and grants. | | | | *Commentary: This policy will be coordinated with policies and objectives for fiscal sustainability in the Economic Development and Fiscal Sustainability Element.* **MT-2-k** | **Funding for Complete Streets Retrofits.** Continue to participate in a comprehensive analysis of transportation needs and the funding of transportation improvements, including State and federal grant funding to support Complete Street retrofit improvements, within the Fresno-Clovis Metropolitan Area. | | | | *Commentary: This will be done cooperatively with the Fresno Council of Governments, other government agencies, and public interest groups.* <
> Figure MT-4: Traffic Impact Zones (TIZ) * TIZ I * TIZ II * TIZ III * TIZ IV * County Islands * ---- Planning Area * --- Sphere of Influence * ........ City Limits Note: Descriptions of each TIZ can be found in Implementing Policy MT-2-i: Transportation Impact Studies. Source: City of Fresno DARM, 2014 MT-2-I **Region-Wide Transportation Impact Fees.** Continue to support the implementation of metropolitan-wide and region-wide transportation impact fees sufficient to cover the proportional share of a development's impacts and need for a comprehensive multi-modal transportation system that is not funded by other sources. Work with the Council of Fresno County Governments, transportation agencies (e.g. Caltrans, Federal Transportation Agency) and other jurisdictions in the region to develop a method for determining: * Regional transportation impacts of new development; * Regional highways, streets, rail, trails, public transportation, and goods movement system components, consistent with the General Plan, necessary to mitigate those impacts and serve projected demands; * Projected full lifetime costs of the regional transportation system components, including construction, operation, and maintenance; and * Costs covered by established funding sources. *Commentary: This policy is consistent with and supports policies and objectives for fiscal sustainability in the Economic Development and Fiscal Sustainability Element.* MT-2-m **Use VMT Analysis for CEQA.** Use Vehicle Miles Traveled (VMT) as the criteria for evaluating transportation impacts under the California Environmental Quality Act (CEQA), pursuant to Senate Bill 743. Level of Service (LOS) may still be used for planning purposes and implementation of Capital Improvement Projects, however VMT shall be used for determining mitigation under CEQA beginning in July of 2020. *Commentary: In 2013, the State of California passed Senate Bill 743, which eliminated automobile Level of Service (LOS) from transportation analysis under CEQA and replaced it with VMT. This shift from LOS to VMT is intended to better align with other statewide transportation goals, including reduction of GHG emissions, the creation of multimodal networks, and the promotion of integrated land uses.* OBJECTIVE MT-3 Identify, promote and preserve scenic or aesthetically unique corridors by application of appropriate policies and regulations. IMPLEMENTING POLICIES **MT-3-a** Scenic Corridors. Implement measures to preserve and enhance scenic qualities along scenic corridors or boulevards, including: * Van Ness Boulevard - Weldon to Shaw Avenues * Van Ness Extension - Shaw Avenue to the San Joaquin River Bluff * Kearney Boulevard - Fresno Street to Polk Avenue * Van Ness/Fulton couplet - Weldon Avenue to Divisadero * Butler Avenue - Peach to Fowler Avenues * Minnewawa Avenue - Belmont Avenue to Central Canal * Huntington Boulevard - First Street to Cedar Avenue * Shepherd Avenue - Friant Road to Willow Avenue * Audubon Drive - Blackstone to Herndon Avenues * Friant Road - Audubon to Millerton Roads * Tulare Avenue - Sunnyside to Armstrong Avenues * Ashlan Avenue- Palm to Maroa Avenues **MT-3-b** Preserve street trees lining designated scenic corridors or boulevards. Replace trees of the predominant type and in a comparable pattern to existing plantings if there is no detriment to public safety. OBJECTIVE **MT-4** Establish and maintain a continuous, safe, and easily accessible bikeways system throughout the metropolitan area to reduce vehicle use, improve air quality and the quality of life, and provide public health benefits. IMPLEMENTING POLICIES **MT-4-a** Active Transportation Plan. To the extent consistent with this General Plan, continue to implement and periodically update the Active Transportation Plan to meet State standards and requirements for recommended improvements and funding proposals as determined appropriate and feasible. **MT-4-b** Bikeway Improvements. Establish and implement property development standards to assure that projects adjacent to designated bikeways provide adequate right-of-way and that necessary Chapter 4: Mobility and Transportation improvements are constructed to implement the planned bikeway system shown on Figure MT-2 to provide for bikeways, to the extent feasible, when existing roadways are reconstructed; and alternative bikeway alignments or routes where inadequate right-of-way is available. **MT-4-c** **Bikeway Linkages.** Provide linkages between bikeways, trails and paths, and other regional networks such as the San Joaquin River Trail and adjacent jurisdiction bicycle systems wherever possible. **MT-4-d** **Prioritization of Bikeway Improvements.** Prioritize bikeway components that link existing separated sections of the system, or that are likely to serve the highest concentration of existing or potential cyclists, particularly in those neighborhoods with low vehicle ownership rates, or that are likely to serve destination areas with the highest demand such as schools, shopping areas, recreational and park areas, and employment centers. **MT-4-e** **Minimum Bike Lane Widths.** Provide not less than 10 feet of street width (five feet for each travel direction) to implement bike lanes for designated Class II bikeways along roadways. Strive for 14 feet of street width (seven feet for each travel direction) for curbside bike lanes where right-of-way is available. **MT-4-f** **Bike Detection Devices.** Include bicycle detection devices when new intersection traffic control signals are installed and strive to retrofit existing traffic control signals to provide bicycle detection and retiming of signal phases to make them more bicycle friendly. **MT-4-g** **Advocacy for Bike Accommodation.** Advocate for the accommodation of bike facilities in new or upgraded State Route interchanges and railroad construction projects, and construction of bicycle crossings of freeways and railroads. **MT-4-h** **Bicycle Parking Facilities.** Promote the installation of bicycle locking racks and bicycle parking facilities at public buildings, transit facilities, public and private parking lots, and recreational facilities. Establish standards for bicycle parking in the Development Code. **MT-4-i** **Bicycling and Public Transportation.** Promote the integration of bicycling with other forms of transportation, including public transit. Continue to provide bike racks or space for bicycles on FAX buses. MT-4-j | **Street Maintenance for Bicycle Safety.** Provide regular sweeping and other necessary maintenance to clear bikeways of dirt, glass, gravel, and other debris and maintain the integrity of the bicycling network. MT-4-k | **Bicycle Safety, Awareness, and Education.** Promote bicycle ridership by providing secure bicycle facilities, promoting traffic safety awareness for both bicyclists and motorists, promoting the air quality benefits, promoting non-renewable energy savings, and promoting the public health benefits of physical activity. OBJECTIVE MT-5 | Establish a well-integrated network of pedestrian facilities to accommodate safe, convenient, practical, and inviting travel by walking, including for those with physical mobility and vision impairments. IMPLEMENTING POLICIES MT-5-a | **Sidewalk Development.** Pursue funding and implement standards for development of sidewalks on public streets, with priority given to meeting the needs of persons with physical and vision limitations; providing safe routes to school; completing pedestrian improvements in established neighborhoods with lower vehicle ownership rates; or providing pedestrian access to public transportation routes. MT-5-b | **Sidewalk Requirements.** Assure adequate access for pedestrians and people with disabilities in new residential developments per adopted City policies, consistent with the California Building Code and the Americans with Disabilities Act. MT-5-c | **New Subdivision Design.** Do not approve new single-family residential subdivisions with lots that front and access onto a major roadway, unless the City Traffic Engineer determines that no other feasible alternative means of vehicle access can be provided and that sufficient design measures can be implemented, such as an on-site driveway turnaround, landscaped buffering, or an on-street parking lane to assure a desirable and enduring residential environment. **Commentary:** To make this determination, the City Traffic Engineer may require an evaluation of alternative means of access, including frontage roads, backup treatment, and substantial redesign of the subdivision proposal. **MT-5-d** **Pedestrian Safety.** Minimize vehicular and pedestrian conflicts on both major and non-roadways through implementation of traffic access design and control standards addressing street intersections, median island openings and access driveways to facilitate accessibility while reducing congestion and increasing safety. Increase safety and accessibility for pedestrians with vision disabilities through the installation of Accessible Pedestrian Signals at signalized intersections. **MT-5-e** **Traffic Management in Established Neighborhoods.** Establish acceptable design and improvement standards and provide traffic planning assistance to established neighborhoods to identify practical traffic management and calming methods to enhance the pedestrian environment with costs equitably assigned to properties receiving the benefits or generating excessive vehicle traffic. **MT-5-f** **Modifications to Street Standards.** Continue to evaluate and adopt modifications to City street standards to achieve overall objectives of providing good access and travel opportunities while calming traffic, promoting pedestrian and other transportation options, and reducing the amount of land devoted to streets. ### OBJECTIVE **MT-6** Establish a network of multi-purpose pedestrian and bicycle paths, as well as limited access trails, to link residential areas to local and regional open spaces and recreation areas and urban Activity Centers in order to enhance Fresno's recreational amenities and alternative transportation options. ### IMPLEMENTING POLICIES **MT-6-a** **Link Residences to Destinations.** Design a pedestrian and bicycle path network that links residential areas with Activity Centers, such as parks and recreational facilities, educational institutions, employment centers, cultural sites, and other focal points of the city environment. **MT-6-b** **Multi-Agency Planning for Paths and Trail System.** Continue to participate in multi-agency planning and implementation partnerships for the coordinated development of the Fresno-Clovis Metropolitan Area planned path and trail system and with Madera County for the San Joaquin River Parkway trail system. **MT-6-c** **Link Paths and Trails and Recreational Facilities.** Strive to provide path or trail connections to recreational facilities, including parks and community centers where appropriate, and give priority to pathway improvements within neighborhoods characterized by lower vehicle ownership rates and lower per capita rates of parks and public open space. **MT-6-d** **Link Paths and Trails and Cultural Resources.** Strive to designate and implement paths and trails to pass by environmental amenities, historic sites, and other cultural resources, where appropriate, and provide informational signage or other interpretation of those resources to the public. **MT-6-e** **Utilize Public Rights of Way.** Pursue the attainment of path and trail corridors within abandoned railroad rights-of-way, canal alignments, PG&E transmission tower easements, limited access streets (Expressways, freeways), riverbottom/bluff areas, or other such rights-of-way. Offer existing easements and rights-of-way to local agencies before selling them to private parties. **MT-6-f** **Path and Trail Designation Process.** Develop a network of multi-purpose path and trail corridors by using the Official Plan Line process or other processes as provided by the Development Code to obtain appropriate linear rights-of-way along riparian corridors, drainage and irrigation easements, utility easements, abandoned railroad rights-of-way, and major street corridors. **MT-6-g** **Path and Trail Development.** Require all projects to incorporate planned multi-purpose path and trail development standards and corridor linkages consistent with the General Plan, applicable law and case-by-case determinations as a condition of project approval. *Commentary:* This should be done pursuant to Figure MT-2: Paths and Trails, and the adopted ATP, as may amended. **MT-6-h** **Preference for Public Ownership.** Avoid path and trail alignments that involve private ownership of sections of public path or trail right-of-way. Use the Director Determination process, if necessary, to adjust planned path or trail rights-of-way to avoid these situations by realigning along more visible, publicly owned routes. **MT-6-i** **Path and Trail Design Standards.** Designate and design paths and trails in accordance with design standards established by the City that give consideration to all path and trail users (consistent with design, terrain and habitat limitations) and provide for appropriate widths, surfacing, drainage, design speed, barriers, fences, signage, visibility, intersections, bridges, and street cleaning. **Commentary:** Trail improvements and characteristics (e.g. accessibility, continuity, width and location, and surface treatment) within the Fancher Creek water conveyance and riparian corridor, and other alignments immediately adjacent to existing or planned residential land, will be determined by the City Council after providing for appropriate public participation. **MT-6-j** Variety in Path and Trail Design. Provide for different levels and types of usable pedestrian and bicycle corridors, including broad, shaded sidewalks; jogging paths; paved and all terrain bicycle paths; through-block passageways; and hiking trails. Where a designated multi-purpose path route is adjacent to a public right-of-way which accommodates bike lane, allow for flexibility in path design, so that bike lanes may be substituted for the bicycle component of the multi-purpose path where it is safe and appropriate to do so. **Commentary:** This should be done pursuant to Figure MT-2: Paths and Trails, and the adopted ATP, as may amended. **MT-6-k** Path and Trail Buffers. Use landscaping with appropriate and adequate physical and visual barriers (e.g., masonry walls, wrought-iron, or square-tube fencing) to screen path and trail rights-of ways and separate paths and trails from mining operations, drainage facilities, and similar locations as warranted. **MT-6-l** Environmentally Sensitive Path and Trail Design. Develop paths and trails with minimum environmental impact by taking the following actions: * Surface paths and trails with materials that are conducive to maintenance and safe travel, choosing materials that blend in with the surrounding area; * Design paths and trails to follow contour lines where the least amount of grading (fewest cuts and fills) and least disturbance of the surrounding habitat will occur; * Beautify path and trail rights-of-way in a manner consistent with intended use, safety, and maintenance; * Use landscaping to stabilize slopes, create physical or visual barriers, and provide shaded areas; and * Preserve and incorporate native plant species into the landscaping. **MT-6-m** | **Path and Trail Crossings.** Limit vehicle access, to the extent feasible, where paths or trails are designated parallel and adjacent to roadways, with consideration given to other transportation, land use, and site design priorities and constraints. **MT-6-n** | **Emergency Vehicle Access along Paths and Trails.** Provide points of emergency vehicle access within the path and trail corridors, via parking areas, service roads, emergency access gates in fencing, and firebreaks. *Commentary:* Service roads will be interconnected, where possible, to permit through travel by emergency vehicles. OBJECTIVE **MT-7** | Pursue a variety of funding sources to maximize implementation and development of the City's path and trail system. IMPLEMENTING POLICIES **MT-7-a** | **Urban Path and Trail Development Funds.** Continue to seek grants and other funding sources for trail construction and maintenance, and support the enactment of State and federal legislation that will expand urban path and trail development funds. **MT-7-b** | **Supporting Nonprofit Organizations.** Support and assist nonprofit organizations whose purpose or charter is to promote and support public path and trail construction and maintenance. Establish an “Adopt a Path/Trail” program that allows private entities to maintain segments. **MT-7-c** | **Citywide Funding Program for Path and Trail Network.** Strive to establish an equitable citywide funding program for construction and maintenance of the path and trail network, in order to: * Acquire right-of-way needed for paths and trails in already-developed neighborhoods and other areas, as identified in community plans, Specific Plans, and neighborhood plans; * Reimburse developers for public path and trail development costs that they may incur in excess of the trail cost attributable to the impact of their development project (this may require a citywide nexus study); and • Seek funding sources to add to and adequately maintain the citywide path and trail network. *Commentary: This program could be folded into a comprehensive parks and trails funding program, supported by voter-approved sales tax revenues.* # OBJECTIVE **MT-8** Provide public transit options that serve existing and future concentrations of residences, employment, recreation and civic uses and are feasible, efficient, safe, and minimize environmental impacts. *Commentary: Public transit services must meet accessibility standards for individuals with disabilities as required by applicable state and federal regulations.* # IMPLEMENTING POLICIES **MT-8-a** **Street Design Coordinated with Transit.** Coordinate the planning, design, and construction of the major roadway network with transit operators to facilitate efficient direct transit routing throughout the Planning Area. *Commentary: Neighborhoods with circuitous and discontinuous streets are more difficult for public transit to serve efficiently than those with consistently spaced linear or semi-grid patterns.* **MT-8-b** **Transit Serving Residential and Employment Nodes.** Identify the location of current and future residential and employment concentrations and Activity Centers throughout the transit service area in order to facilitate planning and implementation of optimal transit services for these uses. Work with California State University, Fresno to determine locations within the campus core for bus stops. **MT-8-c** **New Development Facilitating Transit.** Continue to review development proposals in transportation corridors to ensure they are designed to facilitate transit. Coordinate all projects that have residential or employment densities suitable for transit services, so they are located along existing or planned transit corridors or that otherwise have the potential for transit orientation to FAX, and consider FAX's comments in decision-making. **MT-8-d** **Coordination of Transportation Modes.** Plan, design, and implement transportation system improvements promoting coordination and continuity of transportation modes and facilities, such as shared parking or park and ride facilities at Activity Centers. MT-8-e **Regional Coordination.** Continue to work with local and regional governmental institutions to promote efficient transportation policies and coordinated programs. MT-8-f **Multi-modal Downtown Transportation Facility.** Support the development of a multi-modal transportation facility in Downtown. *Commentary:* Additional details for the facility are anticipated to be addressed in a future community or Specific Plan, such as the proposed DNCP or FCSP. MT-8-g **High Speed Train.** If the State moves forward with HST, ensure it is constructed through Fresno in a manner that minimizes impacts to surrounding property owners and creates the most opportunity for redevelopment around the HST station. MT-8-h **Move Forward with High Speed Train Station Area Planning.** Work with local residents, property and business owners, and other stakeholders to develop a station area plan to provide the most opportunity for growth and prosperity in concert with development of the Fresno HST station. MT-8-i **Legislative Support.** Monitor State and federal legislation that creates incentives to reduce auto dependency and support the use of alternatives to the single occupant vehicle and support legislation that is consistent with the General Plan. MT-8-j **Transit Services.** Emphasize expansion of transit service in low income neighborhoods that lack appropriate service levels. ### OBJECTIVE MT-9 Provide public transit opportunities to the maximum number and diversity of people practicable in balance with providing service that is high in quality, convenient, frequent, reliable, cost- effective, and financially feasible. ### IMPLEMENTING POLICIES MT-9-a **Equitable Transit Provision.** Provide transit that can serve all residents, including older residents and persons with disabilities. Chapter 4: Mobility and Transportation **MT-9-b** **Transit Service Productivity Evaluation.** Continue to evaluate transit service productivity and cost efficiency indicators in the City’s Short-Range Transit Plan, and make necessary and appropriate service adjustments when operationally and financially feasible. *Commentary:* *Short-range transportation planning is a federal requirement for continued funding.* **MT-9-c** **Addressing Unmet Transit Needs.** Continue to participate in the Council of Fresno County Governments’ annual unmet transit needs evaluation process, particularly with respect to identifying need for access to medical and educational services; perform market analysis to identify potential transit choice riders; and pursue public education and information programs to identify changes in demand characteristics and opportunities to increase ridership. **MT-9-d** **Long-Range Transit Options.** Advocate and participate in regional transportation analyses and identify appropriate long-range measures to support incorporation of light rail transit and other advanced transit service within major transportation corridors, freeway and railroad alignments. **MT-9-e** **Area Specific Transit Improvements.** Continue to evaluate and pursue the planning and implementation of area specific transit improvements, such as street car facilities. **MT-9-f** **Encourage Telecommuting.** Support measures that will facilitate expanded use of telecommunications technologies to reduce congestion, expansion of regional transportation facilities consistent with this General Plan, energy use, and air emissions (i.e., work at home, dispersed telecommute work centers, teleconferencing). OBJECTIVE **MT-10** Establish parking standards that are strategically tuned to support neighborhoods, shopping districts and employment centers that have a complete range of transportation choices. IMPLEMENTING POLICIES **MT-10-a** **Updating Parking Standards.** Update off-street parking standards to reflect the context and location within activity areas of multiple uses and reductions appropriate for mixed residential and non-residential uses and proximity to existing or planned transit service. MT-10-b MT-10-c MT-10-d MT-10-e MT-10-f **Shared Parking.** Establish a strategy to promote the sharing of excess parking between uses within Activity Centers and BRT corridors, including specific provisions for this in the Development Code. **Transportation Demand Management Guidelines.** Establish transportation demand management guidelines to allow for reduced off-street parking requirements. **Parking Maximums.** Explore maximum off-street parking limits within Activity Centers proximate to BRT corridors, if such an Activity Center is determined compatible with promotion of a healthy and vigorous business environment. **Parking Cash-Out.** Educate employers of 50 or more persons on their obligation to provide a “parking cash-out program” under State law and enforce compliance. *Commentary:* Under such a program, an employer offers a cash allowance to an employee equivalent to the cost of parking the employer would otherwise provide, as an incentive to using alternative modes of transportation for commuting. These programs must be offered in any non-attainment area for air quality. A 2009 amendment to State law on parking cash-out provides authority for cities to enforce these requirements, including penalties to be imposed on employers who do not provide the “parking cash-out” allowance to employees.[^p46-2] **Parking Benefit Districts.** Establish parking benefit districts to fund consolidated public parking where supported by local businesses. *Commentary:* Net revenues collected from on-street parking pricing and permit revenues can be dedicated to funding public improvements within designated Parking Benefit Districts, ensuring that revenue is used to benefit the blocks where the money is collected. State laws provide for public parking facility construction, operation and maintenance.[^p46-3] [^p46-2]: California Health & Safety Code §43845. [^p46-3]: Vehicle Parking District of 1943, Parking District Law of 1951, and Parking and Business Improvement Area Law of 1989. Substantive requirements for assessment districts were changed with passage of Proposition 218 in 1996, and the law is evolving, so the City will determine the appropriate statutory authority to use for creation of parking benefit assessment districts and note statutory restrictions on the potential use of such funds. Chapter 4: Mobility and Transportation OBJECTIVE MT-11 Achieve necessary capacity increasing and inter-modal connectivity enhancing improvements to the goods movement transportation system to support the growth in critical farm product and value added industries. *Commentary:* Connectivity enhancing improvements and strategies will be used to address necessary capacity and inter-modal connectivity. IMPLEMENTING POLICIES MT-11-a **Improve Goods Movement for Product Export.** Advocate for and pursue all appropriate and available local, regional, state and national planning and implementation opportunities to achieve necessary improvements to regional, interregional and international export opportunities beneficial to the Fresno area. MT-11-b **Railroad Improvements.** Continue to participate in and advocate for collaborative efforts to improve railroad transportation facilities and reduce conflicts with the street system, including relocation and/or consolidation of the BNSF and UP mainline railroad track facilities. MT-11-c **Truck Route Designations.** Continue to plan and designate truck routes within the Metropolitan Area to facilitate access to and from goods production and processing areas while minimizing conflicts with other transportation priorities. MT-11-d **Appropriate Truck Route Roadway Design.** Incorporate provisions for trucks in design of routes designated for truck movement. Ensure that truck routes meet federal standards for intersections, pavement, and turning movements. MT-11-e **Railroad Crossing Improvements.** Continue to improve and maintain the condition and safety of existing railroad crossings by upgrading surface conditions and installing signs and signals where warranted. MT-11-f **State Route 99 / Goods Movement.** Partner with Caltrans to prioritize goods movements along State Route 99. DECEMBER 2014 4-47 OBJECTIVE MT-12 Operate the City's municipal airport facilities to meet present and anticipated demands in a manner that maintains compliance with federal regulations, enhances safety to the public, minimizes the adverse effects of aircraft operations on people, and promotes the economic health of the community. IMPLEMENTING POLICIES MT-12-a **Funding for Airport Capital Improvements.** Pursue appropriate funding sources and capital improvement budget enhancements that will: * Provide a modern, safe, and efficient municipal airport terminal facility including the Federal Inspection Station and airfield; * Maintain airfield compliance with FAA Part 139 operating requirements; * Maintain financial self-sufficiency and long-term sustainability; and * Continue to implement the master plans for FYI Airport and Fresno Chandler Executive Airport to meet projected air passenger travel, air cargo transportation and general aviation demands. MT-12-b **Airport Ground Movement Improvements.** Obtain and install a FAA-approved Surface Movement Guidance and Control System to allow for ground movement on the airfield in lower visibility conditions. MT-12-c **Airport Management and Viability.** Pursue management policies to keep Fresno Yosemite International Airport and Fresno Chandler Executive Airport self-sustaining and financially viable in compliance with FAA grant assurances. * Implement aircraft rescue and firefighting transition plan; * Implement the police transition plan; * Seek alternate ways to improve the financial viability of the airports; and * Seek non-reimbursable Port of Entry status with the U.S. Department of Homeland Security. OBJECTIVE MT-13 Improve the competitiveness of domestic and international air carrier service, and air cargo operations to and from Fresno Yosemite International Airport (FYI). IMPLEMENTING POLICIES MT-13-a **Increase Competitiveness.** Work with incumbent air carriers and new air carriers to increase the competitiveness of commercial air service to and from Fresno. MT-13-b **Marketing Air Travel.** Create a marketing plan to attract the traveling public to the FYI and encourage tourists to use FYI Airport as a gateway to Yosemite and Sequoia/Kings Canyon National Parks. MT-13-c **Expanding Service.** Continually solicit new airlines and seek expanded service from incumbent air carriers for both domestic and international flights. Provide incentives as market conditions dictate. MT-13-d **Airport Property Development.** Develop airport properties as outlined in the applicable airport and environs master plans to support economic growth. MT-13-e **Aviation Support Services.** Ensure necessary aviation support services are provided while promoting a business friendly, but competitive environment through appropriate land use policies. MT-13-f **Environmental Remediation of Hammer Field.** Ensure that environmental remediation activities are conducted with the active participation of previous landowners and tenants. *Commentary:* This will be done in accordance with the Settlement Agreement reached among the City, the Boeing Corporation, and the United States government regarding Hammer Field (Portions now site of FYI Airport). *This page intentionally left blank.* --- ## Housing — City of Fresno 2023-2031 Housing Element (Appendix 1E of the Fresno Multi-Jurisdictional Housing Element, adopted December 12, 2024) - Source: https://www.fresno.gov/wp-content/uploads/2026/03/Appendix-1E-HE_MJHE_Adopted_12.12.24_updated-0115_2025.pdf - Pages: 810 - Covers: housing - **Transcription findings were recorded for this document;** check figures against the source. <
> # APPENDIX 1E: CITY OF FRESNO # Fresno Multi-Jurisdictional 2023-2031 Housing Element ## Adopted December 12, 2024 <
> ### A Regional Plan for Addressing Housing Needs Fresno County • Coalinga • Firebaugh • Fowler • Fresno City • Huron • Kerman Kingsburg • Mendota • Orange Cove • Parlier • Reedley • San Joaquin • Sanger • Selma (blank page) # APPENDIX 1E: CITY OF FRESNO ## Table of Contents **Section 1E-0: Summary of Needs and Conditions ..................................................... 1E-0-1** Housing Needs Assessment ............................................................................................ 1E-0-1 **Section 1E-1: Action Plan............................................................................................. 1E-1-1** Published by City of Fresno ........................................................................................... 1E-1-1 Published by Other Entities........................................................................................... 1E-1-1 **Goals and Policies ........................................................................................................ 1E-1-2** 1. New Housing Development......................................................................................... 1E-1-2 2. Affordable Housing..................................................................................................... 1E-1-3 3. Housing and Neighborhood Conservation ................................................................. 1E-1-4 4. Special Needs Housing............................................................................................... 1E-1-4 5. Fair and Equal Housing Opportunities ...................................................................... 1E-1-5 6. Energy Conservation and Sustainable Development................................................. 1E-1-6 7. Prevent Displacement and Homelessness ................................................................. 1E-1-6 **Implementation Programs.......................................................................................... 1E-1-7** Goal 1: New Housing Development................................................................................1E-1-9 Program 1– Maintain Adequate Sites .......................................................................... 1E-1-9 Program 2 – Variety of Housing Opportunities in High Resource Areas..................... 1E-1-10 Program 3 – Encourage and Facilitate Accessory Dwelling Units and Small Homes ........................................................................................................... 1E-1-12 Program 4 – Streamline Development Review Process ............................................... 1E-1-13 Program 5 – Large and Small Lot Development.......................................................... 1E-1-14 Program 6 – Objective Design Standards.................................................................... 1E-1-16 Program 7 – Adaptive Reuse ....................................................................................... 1E-1-16 Program 8 – List of Local Labor Unions and Apprenticeship Programs ..................... 1E-1-17 Program 9 – Use of Sites in Previous Housing Elements ............................................ 1E-1-17 Program 10 – Annual Reporting Program.................................................................... 1E-1-18 Goal 2: Affordable Housing ........................................................................................... 1E-1-18 Program 11 – Incentives for Housing Development..................................................... 1E-1-18 Program 12 – Local Housing Trust Fund ..................................................................... 1E-1-19 Program 13 – Pursue State and Federal Funding Sources for Housing Development ............................................................................................ 1E-1-20 Program 14 – Partnerships with Affordable Housing Developers ................................ 1E-1-21 Program 15 – Land Bank ............................................................................................. 1E-1-22 Program 16 – Community Land Trust.......................................................................... 1E-1-23 Program 17 – Surplus Public Lands ............................................................................ 1E-1-23 Program 18 – Mixed Income Neighborhood Trust (MINT)........................................... 1E-1-24 Program 19 – Home Buyer Assistance ........................................................................ 1E-1-25 Program 20 – Housing Choice Voucher Incentive Program ........................................ 1E-1-26 Program 21 – Advocate for Repeal of Article 34.......................................................... 1E-1-28 Goal 3: Housing and Neighborhood Conservation......................................................... 1E-1-28 Program 22 – Housing Rehabilitation .......................................................................... 1E-1-28 Program 23 – Comprehensive Code Enforcement ...................................................... 1E-1-30 APPENDIX 1E: TABLE OF CONTENTS Goal 4: Special Needs Housing ..................................................................................... 1E-1-31 Program 24 – Special Needs Housing ........................................................................ 1E-1-31 Program 25 – Development Code Amendments for Compliance with State Law and to Reduce Barriers to Housing Development................................................................... 1E-1-34 Goal 5: Fair and Equal Housing Opportunities............................................................... 1E-1-36 Program 26 – Fair Housing Services ........................................................................ 1E-1-36 Program 27 –Environmental Justice ......................................................................... 1E-1-37 Program 28 – Equitable Community Investments ...................................................... 1E-1-39 Program 29 – Equitable Engagement ........................................................................ 1E-1-42 Program 30 – Workforce Development...................................................................... 1E-1-42 Goal 6: Energy Conservation and Sustainable Development .......................................... 1E-1-43 Program 31 – Reduce or Waive Fees for Vehicle Miles Traveled (VMT)...................... 1E-1-43 Goal 7: Prevent Displacement and Homelessness ......................................................... 1E-1-44 Program 32 – Opportunity to Purchase Act ............................................................... 1E-1-44 Program 33 – Mobile Home Parks ............................................................................ 1E-1-44 Program 34 – Eviction Protection Program ................................................................ 1E-1-47 Program 35 – Replacement Units ............................................................................. 1E-1-47 Program 36 – Homeless Assistance .......................................................................... 1E-1-48 Program 37 – At-Risk Housing.................................................................................. 1E-1-50 Quantified Objectives ................................................................................................ 1E-1-52 Section 1E-2: Sites Inventory ....................................................................................... 1E-2-1 Introduction .............................................................................................................. 1E-2-1 Regional Housing Needs Allocation........................................................................... 1E-2-1 Approved Residential Projects .................................................................................. 1E-2-2 Sites Inventory ......................................................................................................... 1E-2-11 Accessory Dwelling Units ......................................................................................... 1E-2-69 RHNA Summary........................................................................................................ 1E-2-70 Availability of Infrastructure and Services .................................................................. 1E-2-71 Environmental Constraints and Hazards..................................................................... 1E-2-74 Financial Resources.................................................................................................. 1E-2-78 Section 1E-3: Local Assessment of Fair Housing ......................................................... 1E-3-1 Introduction .............................................................................................................. 1E-3-1 Background .............................................................................................................. 1E-3-1 Outreach .................................................................................................................. 1E-3-2 Fair Housing Assessment ......................................................................................... 1E-3-6 Patterns of Integration and Segregation .................................................................... 1E-3-9 Concentrated Areas of Race and Income .................................................................. 1E-3-25 Access to Opportunity .............................................................................................. 1E-3-47 Housing Mobility ....................................................................................................... 1E-3-72 Disproportionate Housing Needs and Displacement Risk........................................... 1E-3-79 Other Relevant Factors and Local Knowledge............................................................ 1E-3-108 Enforcement and Outreach Capacity ........................................................................ 1E-3-126 Housing Sites Analysis.............................................................................................. 1E-3-136 Fair Housing Issues, Contributing Factors, Meaningful Actions................................... 1E-3-161 # Section 1E-4: Constraints...........................................................................................1E-4-1 Land Use Controls ......................................................................................................... 1E-4-1 Site Improvements ......................................................................................................... 1E-4-16 Zoning for a Variety of Housing Types........................................................................... 1E-4-18 Density Bonus ............................................................................................................... 1E-4-35 Processing and Permit Procedures................................................................................ 1E-4-36 Building Codes and Enforcement................................................................................... 1E-4-49 Fees and Exactions........................................................................................................ 1E-4-57 Constraints on Housing for Persons with Disabilities ..................................................... 1E-4-62 At-Risk Analysis ............................................................................................................. 1E-4-65 # Section 1E-5: Review of Past Accomplishments..................................................1E-5-1 Major Accomplishments ................................................................................................. 1E-5-1 Progress Toward Meeting the RHNA.............................................................................. 1E-5-2 Program Evaluation........................................................................................................ 1E-5-2 # Section 1E-6: Public Outreach and Engagement ...................................................1E-6-1 Community Workshops and Meetings ........................................................................... 1E-6-1 Summary of Revisions Made During HCD Review Process ........................................... 1E-6-19 Planning Commission and City Council Study Sessions (September 2022 and July 2023)................................................................................. 1E-6-20 Regional Focus Groups (October/November 2022)........................................................ 1E-6-21 Regional and Local Stakeholder Consultations (Summer/Fall 2022)............................... 1E-6-21 Noticing ......................................................................................................................... 1E-6-27 # Section 1E-7: Detailed Sites Inventory Tables.........................................................1E-7-1 # Section 1E-8: Public Comments Received on the Housing Element...................1E-8-1 # FIGURES Figure 1E-2.1: Housing Capacity on Vacant and Non-Vacant Sites by Category, All Income Levels .............................................................................................................. 1E-2-38 Figure 1E-2.2: Lower-Income Site Capacity by Category............................................... 1E-2-39 Figure 1E-2.5: IIGC Sites HD8 - HD9 (Bing Kong and Peacock Sites in Chinatown) ....... 1E-2-44 Figure 1E-2.6: West Shaw Avenue Town Center Sites, Fresno 2023 ............................. 1E-2-58 Figure 1E-2.7: Sites Inventory, City of Fresno, 2024 ...................................................... 1E-2-67 Figure 1E-2.8: Environmental Constraints and Hazards, 100-year Flood Zones, Fresno 2023 ................................................................................................................. 1E-2-76 Figure 1E-2.9: Environmental Constraints and Hazards, Airport Safety Zones, Fresno 2023 ............................................................................................................................. 1E-2-77 Figure 1E-3.1: Neighborhood Map, City of Fresno ......................................................... 1E-3-8 Figure 1E-3.2: Population by Race and Hispanic Origin, Fresno, 2019 ......................... 1E-3-10 Figure 1E-3.3: Racial Segregation/Integration by Census Tract, City of Fresno ............. 1E-3-13 Figure 1E-3.4: Median Household Income by Race, Fresno, 2020 ................................. 1E-3-15 Figure 1E-3.5: Median Household Income, Fresno, 2019 ............................................... 1E-3-16 Figure 1E-3.6: Percent of Households in Poverty by Race or Hispanic Origin, Fresno, 2020 ............................................................................................................................. 1E-3-17 Figure 1E-3.7: Distribution of Poverty, Fresno, 2019...................................................... 1E-3-18 Figure 1E-3.8: Percent of Children in Married Couple Households, Fresno, 2019......... 1E-3-20 APPENDIX 1E: TABLE OF CONTENTS Figure 1E-3.9: Percent of Children in Single-Female Headed Households, Fresno, 2019 ........................................................................................ 1E-3-21 Figure 1E-3.10: Percentage of the Population with a Disability in City of Fresno ............. 1E-3-24 Figure 1E-3.11: Racially/Ethnically Concentrated Areas of Poverty, Fresno, 2013 ........... 1E-3-27 Figure 1E-3.12: Racially/Ethnically Concentrated Areas of Affluence, Fresno, 2019 ....... 1E-3-45 Figure 1E-3.13: TCAC Opportunity Areas - Composite Score, Region, 2022 ................... 1E-3-50 Figure 1E-3.14: TCAC Opportunity Areas - Composite Score, Fresno, 2022.................... 1E-3-51 Figure 1E-3.15: TCAC Opportunity Areas - Education Score, Fresno, 2021 .................... 1E-3-53 Figure 1E-3.16: Jobs Proximity Index, Fresno, 2017 ........................................................ 1E-3-55 Figure 1E-3.17: Labor Market Engagement Index, Fresno.............................................. 1E-3-57 Figure 1E-3.18: AllTransit Performance Score, Fresno, 2019 ......................................... 1E-3-58 Figure 1E-3.19: Fresno Area Express (FAX) System Map ............................................. 1E-3-60 Figure 1E-3.20: Handy Ride Service Area Map, 2023 .................................................... 1E-3-61 Figure 1E-3.21: Transportation Cost Index, Fresno County Region, 2017 ...................... 1E-3-63 Figure 1E-3.22: Transportation Cost Index, Fresno, 2017 ............................................... 1E-3-64 Figure 1E-3.23: TCAC Opportunity Areas - Environmental Score, Fresno, 2022 ............. 1E-3-67 Figure 1E-3.24: CalEnviroScreen 4.0 Scores, Fresno ..................................................... 1E-3-68 Figure 1E-3.25: SB 535 Disadvantaged Communities ..................................................... 1E-3-71 Figure 1E-3.26: Housing Tenure by Race and Hispanic Origin ....................................... 1E-3-73 Figure 1E-3.27: Renter Households in Fresno, 2019 ....................................................... 1E-3-74 Figure 1E-3.28: Vacant Units by Type, City of Fresno, 2020............................................ 1E-3-75 Figure 1E-3.29: Housing Choice Voucher (HCV) Usage, Fresno ..................................... 1E-3-78 Figure 1E-3.30: Overcrowding in Fresno, 2020 ............................................................... 1E-3-82 Figure 1E-3.31: Percent of Renters Overpaying, Fresno, 2014-2019 ............................... 1E-3-86 Figure 1E-3.32: Percent of Homeowners Overpaying, Fresno, 2014-2019 ....................... 1E-3-87 Figure 1E-3.33: Locations of Unsheltered Camping (2023) and Supportive Infrastructure .............................................................................................. 1E-3-90 Figure 1E-3.34: Communities Sensitive to Displacement, Fresno..................................... 1E-3-95 Figure 1E-3.35: Estimated Displacement Risk - 2019 ...................................................... 1E-3-98 Figure 1E-3.36: Estimated Displacement Risk - 0% - 50% AMI (2019)........................... 1E-3-99 Figure 1E-3.37: Estimated Displacement Risk - 50% - 80% AMI (2019)......................... 1E-3-100 Figure 1E-3.38: Transform Fresno Displacement Program Area....................................... 1E-3-102 Figure 1E-3.39: HOLC Maps, Fresno, 1936 .................................................................... 1E-3-112 Figure 1E-3.40: Zoning Map, City of Fresno..................................................................... 1E-3-115 Figure 1E-3.41: Priority Areas for Development Incentives, City of Fresno....................... 1E-3-120 Figure 1E-3.42: Sequencing of Development, City of Fresno General Plan...................... 1E-3-122 Figure 1E-3.43: Public Housing Buildings......................................................................... 1E-3-125 Figure 1E-3.44: Sites Inventory by Census Tract, City of Fresno, September 2024 ....... 1E-3-142 Figure 1E-3.45: Distribution of Housing Capacity by Community Plan/Specific Plan Area .................................................................................................................. 1E-3-143 Figure 1E-3.46: Sum of Total Housing Capacity by Population Majority of Census Tract .................................................................................................................. 1E-3-148 Figure 1E-3.47: Housing Capacity and Median Income by Block Group .......................... 1E-3-150 Figure 1E-3.48: Sites Inventory and Racially/Ethnically Concentrated Areas of Poverty (R/ECAP)................................................................................................. 1E-3-152 Figure 1E-3.49: Sum of Total Housing Capacity by R/ECAP or RCAA .......................... 1E-3-153 Figure 1E-3.50: Sites Inventory and Racially Concentrated Areas of Affluence (RCAA) ................................................................................................................ 1E-3-154 APPENDIX 1E: CITY OF FRESNO Figure 1E-3.51: Sum of Total Housing Capacity and TCAC Opportunity Areas ................. 1E-3-156 Figure 1E-3.52: Sites Inventory and TCAC Opportunity Areas........................................ 1E-3-157 Figure 1E-3.53: Sum of Housing Capacity and Areas at Risk of Displacement ............... 1E-3-159 Figure 1E-3.54: Sites Inventory and Areas at Risk of Displacement .............................. 1E-3-160 Figure 1E-4.1: Assembly Bill 2097 Areas, Fresno 2023 ................................................. 1E-4-12 Figure 1E-4.2: Potential Sites For Emergency Shelters, Fresno, 2023 ........................... 1E-4-25 Figure 1E-6.1: Community Workshop For The Housing Element Update, August 31, 2022 ................................................................................................................ 1E-6-3 Figure 1E-6.2: Participant Responses “What do you think are the most critical housing issues in Fresno?........................................................................................ 1E-6-5 Figure 1E-6.3: Participant Responses to “Any suggestions for more community involvement?” ........................................................................................................ 1E-6-6 Figure 1E-6.4: One of the Five Community Workshops for the Housing Element Update....................................................................................................................... 1E-6-10 Figure 1E-6.5: One of the Six Community Workshops for the Draft Housing Element Update....................................................................................................................... 1E-6-13 ### TABLES Table 1E-1.1: Summary of Quantified Objectives, 2023-2031.......................................... 1E-1-52 Table 1E-2.1: Regional Housing Needs Allocation (June 30, 2023, to December 31, 2031) ......................................................................................................................... 1E-2-1 Table 1E-2.2: Analysis of Market-Rate Rental Affordability ............................................ 1E-2-3 Table 1E-2.3: Planned or Approved Projects, City of Fresno, February 2024................... 1E-2-5 Table 1E-2.4: Vacant Land with Final Subdivision Maps Under Construction, City of Fresno, June 2023 ....................................................................................................... 1E-2-11 Table 1E-2.5: Density Assumptions for Residential Districts ........................................... 1E-2-15 Table 1E-2.6: Density Assumptions for Mixed Use Zones.............................................. 1E-2-17 Table 1E-2.7: Density Assumptions for Downtown Districts ........................................... 1E-2-20 Table 1E-2.8: Downtown Fresno Infill Infrastructure Grant Sites .................................... 1E-2-41 Table 1E-2.9: Publicly-Owned Sites ............................................................................... 1E-2-45 Table 1E-2.10: Large Sites (Excluding West Shaw Avenue Town Center) ...................... 1E-2-52 Table 1E-2.11: West Shaw Avenue Town Center Sites ................................................... 1E-2-55 Table 1E-2.12: Summary of Recent Developments on Large Sites................................. 1E-2-59 Table 1E-2.13: AB 725 Compliance............................................................................... 1E-2-66 Table 1E-2.14: ADU Building Permits, 2018-2023......................................................... 1E-2-69 Table 1E-2.15: RHNA Summary, Fresno, September 2024 ............................................ 1E-2-70 Table 1E-2.16: Housing Funding Resources, City of Fresno, 2019-2022 ....................... 1E-2-79 Table 1E-2.17: Other Financial Resources and Programs .............................................. 1E-2-80 Table 1E-3.1: Population by Race and Hispanic Origin, Fresno, 2000-2020 ................... 1E-3-9 Table 1E-3.2: Dissimilarity Index Scores for City of Fresno and Fresno County, 2020 ..... 1E-3-11 Table 1E-3.3: Families with Children, Fresno, 1990-2020 .............................................. 1E-3-19 Table 1E-3.4: Domains and List of Indicators for Opportunity Maps ............................... 1E-3-48 Table 1E-3.5: Housing Tenure by Number of Bedrooms (2020) .................................... 1E-3-76 Table 1E-3.6: Demographics of Disproportionate Housing Needs, 2017 ........................ 1E-3-79 Table 1E-3.7: Tenure and Occupants per Room, Fresno, 2020...................................... 1E-3-81 Table 1E-3.8: Overview of Cost Burden in Fresno, 2019 ............................................... 1E-3-83 Table 1E-3.9: Cost Burden in Fresno, 2010-2019 ......................................................... 1E-3-84 Table 1E-3.10: Demographic Characteristics of the Homeless Population, Fresno-Madera COC, 2023 ................................................................................................... 1E-3-92 FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-v APPENDIX 1E: TABLE OF CONTENTS Table 1E-3.11: City and County of Fresno Services to Address Homelessness ................. 1E-3-92 Table 1E-3.12: Hired Farm Labor (Countywide), 2017 ..................................................... 1E-3-105 Table 1E-3.13: Migrant Student Enrollment ....................................................................... 1E-3-106 Table 1E-3.14: Residential Development Built Between July 2013 and July 2020 ........... 1E-3-114 Table 1E-3.15: Public Housing Units by Fresno Housing, 2023 ....................................... 1E-3-124 Table 1E-3.16: City of Fresno Compliance with Fair Housing Laws .................................. 1E-3-128 Table 1E-3.17: Fair Housing Advocacy Organizations, Fresno County .............................. 1E-3-130 Table 1E-3.18: Housing Discrimination Complaints Filed with HUD, Fresno County, 2006-2020 .......................................................................................................... 1E-3-131 Table 1E-3.19: Housing Discrimination Complaints Filed with HUD, City of Fresno, 2015-2019 .......................................................................................................... 1E-3-131 Table 1E-3.20: Fair Housing Cases Opened by FHCCC, City of Fresno, 2017-2020 ..... 1E-3-132 Table 1E-3.21: Discrimination Complaints, City of Fresno (March 1 – August 30, 2021) .................................................................................................................. 1E-3-133 Table 1E-3.22: Housing Capacity by Census Tract, City of Fresno, 2023-2031 ............. 1E-3-137 Table 1E-3.23: Housing Capacity by Community Plan/Specific Plan Area ....................... 1E-3-145 Table 1E-3.24: Housing Capacity and Median Income of Census Tract ........................... 1E-3-149 Table 1E-3.25: TCAC Opportunity Areas by Census Tract, City of Fresno ...................... 1E-3-155 Table 1E-3.26: Housing Capacity by Percent of Renter Overpayment .............................. 1E-3-158 Table 1E-3.27: Housing Capacity by Percent of Homeowner Overpayment ...................... 1E-3-159 Table 1E-3.28: Summary of Fair Housing Issues, Contributing Factors, and Meaningful Actions to AFFH, City of Fresno ..................................................... 1E-3-161 Table 1E-4.1: Fresno General Plan Land Use Designations .............................................. 1E-4-1 Table 1E-4.2: City of Fresno Development Standards by Zoning District .......................... 1E-4-6 Table 1E-4.3: Summary of Mixed-Use Density Increases ................................................... 1E-4-8 Table 1E-4.4: Residential Parking Requirements ............................................................... 1E-4-11 Table 1E-4.5: Minimum On-Site Open Space Requirements, City of Fresno ..................... 1E-4-13 Table 1E-4.6: Analysis of Multifamily Zone Requirements for Prototype Site Development ........................................................................................................ 1E-4-15 Table 1E-4.7: Summary of Potential Sites for Emergency Shelters, Fresno, 2023 ............ 1E-4-23 Table 1E-4.8: Potential Sites for Emergency Shelters, Fresno, 2023 ................................ 1E-4-27 Table 1E-4.9: Variety of Housing Types – Land Use Regulations ..................................... 1E-4-33 Table 1E-4.10: Planning Permits and Actions* .................................................................. 1E-4-37 Table 1E-4.11: Timelines for Permit Procedures ................................................................ 1E-4-43 Table 1E-4.12: Approvals and Processing Times for Typical Developments ..................... 1E-4-44 Table 1E-4.13: Fees for Residential Development as of July 1, 2022 ................................ 1E-4-58 Table 1E-4.14: Fees for Sample Residential Developments .............................................. 1E-4-61 Table 1E-4.15: Assisted Housing Developments At-Risk of Conversion by 2033, City of Fresno ............................................................................................................. 1E-4-66 Table 1E-4.16: Estimated Cost to Subsidize Rents, Fresno, 2022 ..................................... 1E-4-68 Table 1E-5.1: Building Permits Issued During Fifth Cycle RHNA Period ......................... 1E-5-2 Table 1E-5.2: Evaluation of Fresno 2015-2023 Housing Element Implementation Measures ............................................................................................................. 1E-5-11 Table 1E-6.1: Community Workshops and Meetings on the Fresno Housing Element to Date ................................................................................................................. 1E-6-2 Table 1E-7.1 Capacity on Vacant Sites, City of Fresno, July 2024 .................................. 1E-7-1 Table 1E-7.2 Capacity on Underutilized Non-vacant Sites, City of Fresno, July 2024 ...... 1E-7-41 # SECTION 1E-0: SUMMARY OF NEEDS AND CONDITIONS ## Housing Needs Assessment The following is a summary of major findings from the Housing Needs Assessment (Section 2) for the City of Fresno that informed the goals, policies, and programs of the updated Housing Element: * The City’s population increased by 1.2 percent on average between 2000 and 2022, which was lower than the countywide average annual growth rate of 2.0 percent. However, the number of households in Fresno increased by 0.7 percent between 2010 and 2020, a rate equal to the rate of growth countywide. * The largest group of residents in Fresno by age were young adults (25 to 44 years, 29.3 percent of residents). A similar percentage were school-age students (5 to 17 years, 28.3 percent of residents), and a slightly smaller percentage were middle-aged adults (45 to 64 years, 20.3 percent of residents). The city’s median age was 31.4 years. Typically, younger adult residents need multifamily options, homes with three or more-bedroom units, and ownership opportunities. A large proportion of school age students indicates that there may be a need for more affordable homes with adequate sizes for families. Younger adults and middle-aged adults, which make up the workforce, may need homes near employment or transit. * Just over half of the residents of Fresno, 50.5 percent, identified as Hispanic or Latino of any race. This is slightly lower than the countywide rate of 53.4 percent of residents. * The median household income in Fresno in 2020 was $53,568, slightly lower than the countywide median income of $57,109. In comparison, the California statewide median household income was $78,672 in 2022. * In 2020, the most common industry for employment in Fresno was educational services, and health care and social assistance, with 25.3 percent of employed residents working in this field. In 2022, 4.6 percent of Fresno residents were unemployed. * Over half of all households in Fresno (53.2 percent) were renters as of 2020. The rate of homeownership in Fresno was 46.8 percent, which was lower than the countywide average of 53.7 percent. * Fresno’s vacancy rate in 2022 was 3.8 percent across all housing units, regardless of tenure. This was a notable decrease from its 2010 vacancy rate of 7.6 percent. * Between 2021 and 2022, the average sale price of a home in Fresno increased by 19.8 percent. Average sale prices rose 15.4 percent in the county as a whole during the same period. Lower-income households typically require assistance through City, County, State, or federal homebuyers’ programs to purchase a home. For example, a down payment assistance loan program can help a household that can afford monthly mortgage payments and other housing-related costs but due to their limited income, has difficulty saving enough money for a down payment. In response to this need, the City has included Program 19 to continue the Llaves de tu Casa Iniciativa, which provides home buyer assistance to Fresno residents, as well as promote the availability of Fresno County’s Homebuyer Assistance Program. SECTION 1E-0: SUMMARY OF NEEDS AND CONDITIONS * The age of a community’s housing stock can provide a general indicator of overall housing conditions. In general, housing units over 30 years old are likely to exhibit signs of rehabilitation needs, such as new roofing, foundation work, and new plumbing. Over half of all housing units in Fresno (56.7 percent) were built more than 30 years ago, and 34.5 percent were built more than 50 years ago. Countywide, rates of housing stock in similar age brackets were 64.5 and 32.9 percent, respectively. If not already rehabilitated, these homes will likely need repair. * In response to this need, the City has included **Program 22**, which aims to connect lower-income households with rehabilitation resources during the planning period and complete a third of these in areas of concentrated poverty with older housing stock to facilitate place-based revitalization. * Additional resources to assist with home rehabilitation are listed in the Regional Multijurisdictional Housing Element in Section 4, Opportunities for Residential Development, in the subsection called Financial and Administrative Resources. * Although trends of overpayment in the city of Fresno have decreased since 2010, Fresno still had a higher rate of households overpaying for housing than the county as a whole in 2018, with 41.3 percent of all households in the city overpaying for housing compared to 37.8 percent across the county. Similarly, the number of lower-income households overpaying for housing was higher in Fresno (74.8 percent in Fresno compared to 70.6 percent countywide). This shows a need for financial support, affordable units, and homeowner assistance programs. For example, a down payment assistance loan program can help a renter household achieve homeownership with a loan that enables them to afford monthly mortgage payments and other housing-related costs. * To address the overpayment of housing, the City will maintain adequate sites to meet the lower- and moderate-income RHNA throughout the entire planning period. The City has included **Program 2** to provide for a variety of housing opportunities in high resource areas, **Program 11** to provide incentives for housing development, and **Program 25** to reduce barriers to housing development. * Federal and state resources such as the Housing Choice Voucher (HCV) program, HOME Investment Partnership Act Funds, CalHOME, the California Housing Finance Agency, as well as local resources such as the First Time Homebuyer Assistance Program and Habitat for Humanity are available to provide financial assistance to renters and homeowners. * Additional resources to fund affordable housing activities are described in the Regional Multijurisdictional Housing Element in Section 4, Opportunities for Residential Development, in the subsection called Financial and Administrative Resources. APPENDIX 1E: CITY OF FRESNO * Fresno had a lower rate of large households, those with five or more members, compared to the county as a whole (16.9 percent of households in Fresno compared to 18.1 percent countywide). Large households may experience difficulty finding housing that is affordable and has more than three bedrooms; as a result, overcrowding may occur. According to estimates from the U.S. Census American Community Survey (ACS), of the 170,137 housing units in the city as of 2020, approximately 68,131 units have at least three bedrooms and an additional 29,738 units have more than four bedrooms. Among these larger units, 69.4 percent are owner occupied (67,935 units) and 30.6 percent are renter occupied (29,934 units). Based on this data, the City concludes that there is a sufficient availability of units suitable for large family households. However, large households would benefit from the additional development of affordable rental multi-family units with three or more bedrooms. * In response to these needs, the City is including **Program 24**, which seeks to apply additional funding sources for a variety of housing types for special needs groups, including large households. * In 2020, the city had a similar rate of overcrowding (6.2 percent of households) compared to the county as a whole (6.1 percent of households). There was a higher rate of severe overcrowding in Fresno (4.6 percent of households) than in the county as a whole (3.6 percent). As shown in the Assessment of Fair Housing, overcrowding is more prevalent in Southwest Fresno, Downtown, and in central core neighborhoods of the city, which correspond with the racially concentrated areas of poverty. * To address overcrowding, the City will maintain adequate sites to meet the lower- and moderate-income RHNA throughout the entire planning period. The City has included **Program 2** to provide for a variety of housing opportunities in high resource areas, **Program 11** to provide incentives for housing development, and **Program 25** to reduce barriers to housing development. * In 2020, the percentage of Fresno’s population that was aged 65 or older was very similar to the percentage in the county as a whole (10.9 percent in Fresno compared to 12.0 percent of the county). Around two-thirds (66.1 percent) of Fresno’s senior households were homeowner households. Of the total number of seniors living in the city, 44.5 percent had a disability. Households headed by someone 65 or older often experience a combination of factors that can make accessing or keeping affordable housing a challenge. Seniors and persons with disabilities are especially likely to live on fixed incomes and require accessibility modifications to homes to support mobility and independent living. * Resources including the Fresno/Madera Area Agency on Aging (FMAAA) provide seniors with connections to programs, services, and resources that defray the cost of living, which can be a lifeline for seniors with lower incomes. In addition, the Central California Food Bank includes senior hunger programs to assist those seniors with their nutritional needs. * In response to these needs, the City has included **Program 22** to provide exterior repair services to seniors and provides funds to non-profits for home rehabilitation programs for lower-income households. In addition, **Program 24** seeks to apply additional funding sources for a variety of housing types for special needs groups, including seniors. SECTION 1E-0: SUMMARY OF NEEDS AND CONDITIONS * The percentage of Fresno households with single female heads of household was higher than the countywide rate (8.0 percent in the city compared to 7.3 percent in the county). Additionally, 36.1 percent of single-female-headed households in Fresno were living under the poverty level, which is higher than the rate in the county as a whole (34.0 percent countywide). * Key resources for this special-needs population include Centro La Familia, which provides support services to families and victims of domestic violence and sexual assault; California Rural Legal Assistance, which provides legal and housing counseling; Green Raiteros, which provides transportation, workforce development, and small business advancement; and Rural Mobile Health, which provides no-cost medical services. These services can be crucial for female-headed, single-parent households. In addition, the California Work Opportunity and Responsibility to Kids (CalWORKs) Program helps eligible needy families who have children under the age of 19 with cash assistance, Medi-Cal, and employment services. * In response to this need, the City has included Program 24, which seeks to apply additional funding sources for a variety of housing types for special needs groups, including single female heads of households. * Due to proximity to services, Fresno had a higher rate of residents with disabilities than the county as a whole (13.8 percent compared to 12.9 percent across the county). Ambulatory difficulties were the most commonly reported disability. * Key resources for persons with disabilities include the Fair Housing Council of Central California and Resources for Independence Central Valley. Other resources such as Rural Mobile Health allows for medical services and screenings at no-cost. * In response to this need, the City has included Program 24, which seeks to apply additional funding sources for a variety of housing types for special needs groups, including those with disabilities. * The 2023 Point-in-Time count estimated that 3,207 persons were experiencing homelessness in the city of Fresno at the time of the count. It is estimated that approximately 1,819 of those residents were unsheltered, representing a 7 percent increase in the unsheltered homeless population in Fresno. * Several services are available to homeless residents locally and in the region, including those provided by Catholic Social Services, Emergency Housing Center (Plaza Terrace), Evangel Home, Inc., United Way, Fresno Rescue Mission, and Marjaree Mason Center. A comprehensive list and description of resources is included in the Regional Multijurisdictional Housing Element in Section 2, Regional Housing Needs Assessment, in the subsection called Homeless. * To prevent displacement and homelessness in the City of Fresno, the City has included Programs 32, which allows for qualifying tenants and local non-profits the opportunity to purchase existing buildings to be used and/or maintained for affordable housing. Program 33 protects mobile home park residents from excessive rent increases, while Program 35 enforces the provision of replacement housing units. In addition, Program 36 invests in various housing and emergency shelters to serve people experiencing homelessness, Program 37 and preserves at-risk units from converting into market rate housing. APPENDIX 1E: CITY OF FRESNO * Of the 58,762 year-round and seasonal farmworkers across the county in 2017, 37,819 workers (64.3 percent) worked 150 days or more each year and 35.7 percent worked less than 150 days per year. An estimated 4.3 percent of Fresno’s employed population worked in agriculture, which is lower than the countywide rate (8.8 percent) and is the second-lowest rate of employment in agriculture in the county behind the City of Clovis. Looking at the U.S. Department of Agriculture (USDA) Census of Farmworkers data, the number of permanent farmworkers in Fresno County has decreased slightly from 2002 to 2017, decreasing from 18,751 to 16,876 farmworkers. * Farmworkers face unique challenges in securing affordable housing due to a combination of having limited English language skills, very low household incomes, and difficulty qualifying for rental units or home purchase loans. Farmworkers may face added affordable housing challenges due to their immigration status. Despite the decrease of farmworkers living in Fresno County on a permanent basis, farmworkers remain essential to Fresno County’s economy as well as to local and national food supplies, and their need to have safe and affordable housing resources must be addressed. * A list of organizations that provide resources and support to Central Valley farmworkers is included in Section 1E-3: Fair Housing. Additional resources to assist farmworkers are listed in the Regional Multijurisdictional Housing Element in Table 2-45, Resources for Farmworkers. * Through **Program 24**, the City will identify development opportunities for farmworker housing and meet with farmworker housing developers and advocates on a biannual basis to discuss their needs and offer assistance in the form of letters of recommendation for grant applications and discuss incentives for constructing farmworker housing. The City will also offer incentives such as density bonuses, streamlined processing, and the minor deviation process to facilitate development of farmworker housing. Extremely low-income residents (those earning 30 percent or less of median income) made up 15.5 percent of the total households in Fresno. Of those, 84.7 percent were renter households. This indicates a greater need for rental housing to support extremely low-income households. Extremely low-income households typically consist of minimum wage workers, seniors on fixed incomes, persons with disabilities, and farmworkers. Some extremely low-income households may also have large families or include household members with mental or other disabilities and special needs and require supportive services. This income group is disproportionately likely to live in overcrowded and substandard housing conditions. A total of 82.9 percent of extremely low-income households were overpaying for housing, a higher rate than low-income households (74.8 percent). Overall, 41.3 percent of households in Fresno are overpaying for housing. Given the significantly higher rates of overpayment among extremely low-income households, there is a great need for financial support and affordable units to meet the needs of this population. Without adequate assistance this group has a high risk of homelessness. Virtually all extremely low-income households are expected to need aid, including housing cost subsidies and social services. SECTION 1E-0: SUMMARY OF NEEDS AND CONDITIONS * Key resources such as Section 8 rental assistance (i.e., Housing Choice Vouchers), the Central California Food Bank, Emergency Shelter Grant Program, Rural Development Loans and Grants, and Rental Rehabilitation Program can assist extremely low-income households with providing essential social services, prevent homelessness, and connect individuals with affordable housing. Additional resources to fund affordable housing activities are described in the Regional Multijurisdictional Housing Element in Section 4, Opportunities for Residential Development, in the subsection called Financial and Administrative Resources. * While there are 26,300 extremely low-income households in the city, the total RHNA for both very low- and extremely low-income units for this Housing Element was 9,440. Therefore, there will still be an unmet need for housing extremely low-income households even if the City meets its quantified objectives for this Housing Element cycle. The City has included numerous programs to construct, rehabilitate, and conserve affordable housing for extremely low-, very low-, and low-income households. Program 11 calls for the construction of 1,200 extremely low-income units to prevent displacement and provide housing mobility opportunities, while Program 12 calls upon the City to establish a Local Housing Trust fund to develop 320 units for extremely low-, very low-, to low-income households. In addition, Program 24 seeks to apply additional funding sources for a variety of housing types for special needs groups, Program 20 seeks to increase availability of information and access to Section 8 rental assistance and units in resource-rich neighborhoods, Program 22 seeks to connect lower-income households with resources for the rehabilitation and conservation of very low- and extremely low-income units, and Program 36 calls upon the City to provide shelter, housing/rental assistance, and case management services for persons that are homeless, threatened with homelessness, or in need of housing assistance after completing a transitional living program. APPENDIX 1E: CITY OF FRESNO # SECTION 1E-1: ACTION PLAN The intent of the Housing Element is to ensure that the City makes a meaningful effort and commits available resources to meeting the housing needs of all economic segments of the community. The Housing Element sets forth long-term goals and policies, as do other General Plan Elements, but also provides specific implementation programs to meet those needs, as specified in state law. The housing policies included in the City of Fresno’s Housing Element, as well as the actions (implementation programs) that the City will undertake to meet its housing needs, are informed by extensive community input and recommendations from the following reports developed by the City of Fresno and other entities: ## Published by City of Fresno * **One Fresno Fiscal Year 2023–2025 Housing Strategy** – Published in 2022, this local housing strategy includes recommendations consolidated from over 3,000 residents via meetings and other reports that include input from public, community, nonprofit, philanthropic, and corporate representatives to facilitate more housing production and maintain affordability. * **Analysis of Impediments to Fair Housing Choice and Annual Action Plan** – Every five years, the City carries out a planning process to identify the scope of housing and community development needs in its jurisdiction and to determine how available federal funding can best be used to meet those needs. As part of the plan, a community needs survey was deployed and received input from more than 500 individuals. * **Downtown Neighborhoods Community Plan** – Adopted in 2016, this Community Plan is the result of an intense public process that involved input from over 300 residents, business owners, and property owners from Fresno’s Downtown Neighborhoods in a series of public meetings and a six-day, open, participatory design workshop. ## Published by Other Entities * **Street2Home Framework to Action Report** – Prepared in 2018 by Barbara Poppe and Associates, the report outlines a strategic framework to end homelessness in the Fresno community. The process was guided by a steering committee and feedback sessions with community leaders and represents input from 36 agencies. It assesses Fresno’s overall strengths and opportunities and offers recommendations on proven practices that have been shown to reduce homelessness in other communities. * **DRIVE’s Permanent Affordable Housing Plan** – Launched in 2019, the Fresno D.R.I.V.E. Initiative (Developing the Region’s Inclusive and Vibrant Economy) is a 10-year Community Investment Plan drafted with input from a 300-person steering committee representing over 150 organizations in the Greater Fresno Region. * **Evicted in Fresno: Facts for Housing Advocates** – Published in 2019, the study by Dr. Janine Nkosi, Dr. Amber Crowell, and Karla Arana of Central California Legal Services, Leadership Counsel for Justice and Accountability, and Faith in the Valley examines the degree of eviction rates and causes across the city of Fresno. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-1-1 SECTION 1E-1: ACTION PLAN * **Here to Stay: A Policy-Based Blueprint for Displacement Avoidance in Fresno** – Published in 2021 by the Thrivance Group and funded by the California Strategic Growth Council as part of the Transformative Climate Communities work, the report represents input from more than 580 individuals who participated in City and partner-led workshops, surveys, and letter writings. * **Financing Valley Infill: How to Boost Sustainable Development in the San Joaquin Valley** – Published in 2021 by the Council of Infill Builders, the report recommends options to boost infill housing in San Joaquin Valley downtowns and major transit corridors based on expertise of various state and local officials, architects, real estate investors, developers, and advocates. # GOALS AND POLICIES The Multi-Jurisdictional Housing Element provides an opportunity for countywide housing issues and needs to be more effectively addressed at the regional level rather than just at the local level, and the 15 participating jurisdictions are committed to continuing the regional collaboration in the implementation of the Housing Element. By working together, the jurisdictions can share best practices, explore opportunities for further collaboration, and make the best use of limited resources. The regional goals and policies that will be adopted by all participating jurisdictions are contained in Chapter 5: Housing Plan. These regional goals and policies are reiterated below and supplemented with local goals and policies specific to the City of Fresno to address the unique housing needs of the Fresno community. ## 1. New Housing Development **Regional Goal 1** Facilitate and encourage the provision of a range of housing types to meet the diverse needs of residents. **Regional Policies** **Policy 1.1** Provide adequate sites for new housing development through appropriate planned land use designations, zoning, and development standards to accommodate the regional housing needs for the 2023-2031 planning period. **Policy 1.2** Facilitate development of new housing for all economic segments of the community, including extremely low, very low-, low-, moderate-, and above moderate-income households. **Policy 1.3** Continue to direct new growth to urban areas in order to protect natural resources. **Policy 1.4** Promote balanced and orderly growth to minimize unnecessary development costs adding to the cost of housing. **Policy 1.5** Encourage infill housing development on vacant, by-passed, and underutilized lots within existing developed areas where essential public infrastructure is available. Policy 1.6 Promote development of higher-density housing, mixed-use, and transit-oriented development in areas located along major transportation corridors and transit routes and served by the necessary infrastructure. Policy 1.7 Ensure the adequate provision of water, sewer, storm drainage, roads, public facilities, and other infrastructure necessary to serve new housing. Policy 1.8 Approve new housing in accordance with design standards that will ensure the safety, quality, integrity, and attractiveness of each housing unit. Policy 1.9 Encourage development around employment centers that provides the opportunity for local residents to live and work in the same community by balancing job opportunities with housing types. # 2. Affordable Housing **Regional Goal 2 Encourage and facilitate the development of affordable housing.** **Regional Policies** Policy 2.1 Support innovative public, private, and nonprofit efforts in the development of affordable housing, particularly for the special needs groups. Policy 2.2 Continue to support the efforts of the Fresno Housing Authority in its administration of Housing Choice Vouchers certificates and vouchers, and the development of affordable housing throughout the County. Policy 2.3 Encourage development of affordable housing through the use of development incentives, such as the Density Bonus Ordinance, fee waivers or deferrals, and expedited processing. Policy 2.4 Provide technical and financial assistance, where feasible, to developers, nonprofit organizations, or other qualified private sector interests in the application and development of projects for federal and state financing. Policy 2.5 Pursue grant funding to subsidize the development of affordable housing for low-, very low-, and extremely low- income households through new construction, acquisition, and/or rehabilitation. Policy 2.6 Encourage the development of second dwelling units to provide additional affordable housing opportunities. Policy 2.7 Work to ensure that local policies and standards do not act to constrain the production of affordable housing units. Policy 2.8 Expand homeownership opportunities to lower- and moderate-income households through downpayment assistance and other homeownership programs. Policy 2.9 Encourage sweat equity programs as a means for increasing homeownership opportunities for lower-income residents. SECTION 1E-1: ACTION PLAN ### Local Policies **Policy 2.10** Require 55-year affordable housing covenants for all developments receiving public funds, including but not limited to CDBG, HOME, ESG, Housing Trust Fund, Land Trust Funding, Impact Fee Waivers, and General Fund Contributions. **Policy 2.11** Housing developments with at least 20 percent affordable lower-income housing units shall be permitted by-right (without discretionary action) at appropriate densities, consistent with objective development and design standards, on lower-income sites counted in previous housing element cycles, in compliance with Government Code Section 65583.2. This policy shall take effect upon adoption of the housing element and administrative procedures will be developed by March 31, 2025, as necessary. ## 3. Housing and Neighborhood Conservation **Regional Goal 3** Improve and maintain the quality of housing and residential neighborhoods in Fresno County. ### Regional Policies **Policy 3.1** Preserve the character, scale, and quality of established residential neighborhoods by protecting them from the encroachment of incompatible or potentially disruptive land uses and/or activities. **Policy 3.2** Assist low- income homeowners and owners of affordable rental properties in maintaining and improving residential properties through a variety of housing rehabilitation assistance programs. **Policy 3.3** Continue code enforcement efforts to work with property owners to preserve the existing housing stock. **Policy 3.4** Provide for the removal of all unsafe, substandard dwellings that cannot be economically repaired. **Policy 3.5** Invest in public service facilities (streets, curb, gutter, drainage, and utilities) to encourage increased private market investment in declining or deteriorating neighborhoods. **Policy 3.6** Preserve assisted rental housing for long-term occupancy by low- and moderate-income households. ## 4. Special Needs Housing **Regional Goal 4** Provide a range of housing types and services to meet the needs of individuals and households with special needs. ### Regional Policies **Policy 4.1** Encourage public and private entity involvement early and often through the design, construction, and rehabilitation of housing that incorporates facilities and services for households with special needs. APPENDIX 1E: CITY OF FRESNO **Policy 4.2** Assist in local and regional efforts to secure funding for development and maintenance of housing designed for special needs populations such as seniors and persons with disabilities. **Policy 4.3** Support the use of available federal, state, and local resources to provide and enhance housing opportunities for farm workers. **Policy 4.4** Encourage development of affordable housing units to accommodate large households (three and four bedroom). **Policy 4.5** Ensure equal access to housing by providing reasonable accommodation for individuals with disabilities. **Policy 4.6** Working in partnership with the other jurisdictions and the private/non-profit sectors in Fresno County, facilitate the provision of housing and services for persons experiencing homelessness and those at-risk of becoming homeless. ## 5. Fair and Equal Housing Opportunities **Regional Goal 5** Promote housing opportunities for all residents regardless of age (over 40), race, religion, sex/gender, gender identity/expression, sexual orientation, marital status, ancestry, national origin, color, disability, genetic information, or military or veteran status. ### Regional Policies **Policy 5.1** Support the enforcement of fair housing laws prohibiting discrimination in lending practices and in the development, financing, sale, or rental of housing. **Policy 5.2** Ensure local ordinances and development regulations provide equal housing opportunity for persons with disabilities. ### Local Policies **Policy 5.3** Amplify community voices among multi-lingual and other historically underrepresented populations by building capacity for community-based and neighborhood organizations to conduct outreach, public education, and community development activities. **Policy 5.4** Promote mixed income neighborhoods with an equitable distribution of housing types for people of all incomes throughout the city by encouraging new affordable housing in high resource areas. **Policy 5.5** Invest in historically underserved communities to transform racially and ethnically concentrated areas of poverty into areas of opportunity, while working to promote housing stability and provide new stable housing opportunities for current residents to stay and enjoy the neighborhood investments. **Policy 5.6** Encourage developers and contractors to support local labor through job fairs, training and apprenticeship programs. SECTION 1E-1: ACTION PLAN # 6. Energy Conservation and Sustainable Development **Regional Goal 6** Encourage energy efficiency in all new and existing housing. **Regional Policies** **Policy 6.1** Encourage the use of energy conserving techniques in the siting and design of new housing. **Policy 6.2** Actively implement and enforce all state energy conservation requirements for new residential construction. **Policy 6.3** Promote public awareness of the need for energy conservation. # 7. Prevent Displacement and Homelessness **Local Goal 7** Protect Fresno residents from displacement and prevent and reduce homelessness. **Local Policies** **Policy 7.1** Implement affordable housing preservation and renter protection strategies, especially in neighborhoods with racially concentrated areas of poverty and a high risk of renter vulnerability. **Policy 7.2** Protect residents from displacement and homelessness by preserving naturally occurring affordable housing and continuing to prohibit eviction without “just cause,” enforcing the adopted limitations on rent increases, and promoting agencies and service providers offering foreclosure services. **Policy 7.3** Allow tenants and qualified non-profit organizations the right of first offer and/or the refusal to purchase eligible properties on the market to prevent tenant displacement and create long-term affordability. **Policy 7.4** Support the preservation of existing mobile home parks throughout the city as an important source of affordable housing. **Policy 7.5** Work to provide solutions that are consistent with “Housing First” principles in that stable housing is the first, critical step towards addressing human needs. **Policy 7.6** Support development of accessory dwelling units (ADU) and other innovative housing types for persons at-risk of or experiencing homelessness. **Policy 7.7** Increase capacity and sustainability of emergency shelter and service providers. **Policy 7.8** Facilitate acquisition and conversion of motels and hotels for use as emergency shelters or triage shelter transition and affordable housing conversion and support neighborhood-scale planning efforts to create complete community around the converted residences. **Policy 7.9** Ensure quality of independent living facilities meets standards developed by the Independent Living Association (ILA). # IMPLEMENTATION PROGRAMS The City is committed to implementing the programs outlined below over the eight-year planning period. These implementation programs have been developed with community input and consideration for what the City could feasibly accomplish during the planning period with current staff resources. The implementation programs, which are organized by goal, are listed below: **Goal 1: New Housing Development** * Program 1– Maintain Adequate Sites * Program 2 – Variety of Housing Opportunities in High Resource Areas * Program 3 – Encourage and Facilitate Accessory Dwelling Units and Small Homes * Program 4 – Streamline Development Review Process * Program 5 – Large and Small Lot Development * Program 6 – Objective Design Standards * Program 7 – Adaptive Reuse * Program 8 – List of Local Labor Unions and Apprenticeship Programs * Program 9 – Use of Sites in Previous Housing Elements * Program 10 – Annual Reporting Program **Goal 2: Affordable Housing** * Program 11 – Incentives for Housing Development * Program 12 – Local Housing Trust Fund * Program 13 – Pursue State and Federal Funding Sources for Housing Development * Program 14 – Partnerships with Affordable Housing Developers * Program 15 – Land Bank * Program 16 – Community Land Trust * Program 17 – Surplus Public Lands * Program 18 – Mixed Income Neighborhood Trust (MINT) * Program 19 – Home Buyer Assistance * Program 20 – Housing Choice Voucher Incentive Program * Program 21 – Advocate for Repeal of Article 34 SECTION 1E-1: ACTION PLAN **Goal 3: Housing and Neighborhood Conservation** * Program 22 – Housing Rehabilitation * Program 23 – Comprehensive Code Enforcement **Goal 4: Special Needs Housing** * Program 24 – Special Needs Housing * Program 25 – Development Code Amendments for Compliance with State Law and to Reduce Barriers to Housing Development **Goal 5: Fair and Equal Housing Opportunities** * Program 26 – Fair Housing Services * Program 27 – Environmental Justice * Program 28 – Equitable Community Investments * Program 29 – Equitable Engagement * Program 30 – Workforce Development **Goal 6: Energy Conservation and Sustainable Development** * Program 31 – Reduce or Waive Fees for Vehicle Miles Traveled (VMT) **Goal 7: Prevent Displacement and Homelessness** * Program 32 – Opportunity to Purchase Act * Program 33 – Mobile Home Parks * Program 34 – Eviction Protection Program * Program 35 – Replacement Units * Program 36 – Homeless Assistance * Program 37 – At-Risk Housing # Goal 1: New Housing Development ## Program 1– Maintain Adequate Sites The City shall continue to maintain a current inventory of Housing Element sites to ensure that it can adequately accommodate the 2023-2031 RHNA. The City shall continue to update the inventory on an ongoing basis as projects are approved and new sites are rezoned. To assist developers in identifying land suitable for residential development throughout the planning period, the City shall continue to make this information available to the public and developers online via the City’s website. The City shall work with applicants of pipeline projects counted in the Housing Element sites inventory to facilitate development. The City shall coordinate with applicants to expedite remaining entitlements and support funding applications, as appropriate. The City shall monitor the rent and sale prices of pipeline projects as they are built and adjust affordability assumptions in the inventory to reflect actual rents and sale prices. If the adjustment of affordability assumptions results in a deficit in capacity to meet the RHNA, the City will take action to identify capacity to meet a shortfall in accordance with “no-net-loss” zoning requirements in Government Code Section 65863. The City shall annually monitor the progress made on the pipeline projects counted in the inventory and if entitlements expire or projects are otherwise not anticipated to be completed in the planning period, the City shall remove them from the approved project list, reclassify them as vacant/non-vacant opportunity sites as appropriate unless conditions are found that will preclude development in the planning period, and recalculate the capacity on the sites according to the methodology used in the sites inventory chapter. If entitlements expire or projects are otherwise not anticipated to be completed in the planning period and conditions are found that preclude development on identified sites in the planning period, the City will evaluate whether adequate sites are maintained to accommodate the RHNA by income group. If determined that the City no longer has sufficient capacity to meet the RHNA, the City will take action to identify additional sites within 180 days, which may require rezoning another parcel to allow for increased density. To ensure sufficient residential capacity is maintained to accommodate the RHNA need, the City shall make findings related to the potential impact on the City’s ability to meet its unmet regional housing needs allocation when approving applications to rezone sites included in the lower- and moderate-income sites inventory or when approving applications to develop a lower- or moderate-income housing element site with fewer units or at a higher income than what is assumed for the site in the Housing Element sites inventory, consistent with “no-net-loss” zoning requirements in Government Code Section 65863. If at any point it is determined that the City does not have adequate capacity to meet the unmet lower- or moderate-income RHNA, the City shall identify and make available a replacement site within 180 days. The City shall prioritize finding replacement sites in high resource areas to affirmatively further fair housing goals. The City shall work with willing property owners to rezone sites and will conduct comprehensive outreach on the process prior to making any decisions. SECTION 1E-1: ACTION PLAN | Responsibility | Planning & Development Department | | :--- | :--- | | **Funding Source** | General Fund | | **Timeframe** | Ongoing implementation. Update and assess status of housing sites inventory as projects are approved or as entitlement expire.

Monitor the rent and sale prices of pipeline projects as they are built, adjust affordability assumptions in the inventory, and take action to meet shortfalls as needed.

Monitor progress toward completion of pipeline projects and take appropriate action if entitlements expire or projects are otherwise not expected to be completed in the planning period. | | **Objective** | Maintain adequate sites to meet the lower- and moderate-income RHNA throughout the entire planning period. | **Program 2 – Variety of Housing Opportunities in High Resource Areas** Although the Housing Element demonstrates adequate capacity to meet the RHNA at all income levels, a larger portion of the lower-income housing sites are in areas considered low resource and concentrated areas of poverty compared to the above moderate-income housing sites. This is partially due to policies to encourage infill and higher density development in the Downtown Fresno and other centrally located neighborhoods with access to services and transit but is also reflective of the predominance of single-family zoning in new growth areas at the periphery. Many of these new growth areas, particularly in North Fresno, have higher median incomes, more positive educational outcomes, and rank higher on access to opportunity. To increase housing mobility opportunities for lower-income households and encourage racially and socially inclusive neighborhoods, the City shall expand opportunities for a variety of housing types in high resource neighborhoods that are currently dominated by single-family zoning. This includes the following actions: * The City will present potential sites or rezoning options for land in high and relatively higher resource and income areas, including RCAAs, for Council consideration to provide opportunities for higher density development in all areas of the city and reduce concentrations of poverty. This shall include developing zoning standards to permit residential conversions in the Office Zone District, housing as a permitted use on parcels zoned Office, allow ministerial approval of office-to-residential conversions, and allow ministerial approval of housing near bus stops, including in RM zones and in zone districts that allow mixed-use. Additionally, the City will bring forward a text amendment to the development code that would increase allowable density and permitted uses (e.g., multifamily) in single-family districts within ¼ mile of a transit stop of any type. If the objective of 2,500 units cannot be met within the Office Zone District, the City will work with willing property owners to identify additional sites. APPENDIX 1E: CITY OF FRESNO * The City will identify and pursue opportunities to promote the development of affordable and mixed-income housing in high and relatively higher resource and income, including RCAAs, areas through outreach to and engagement with affordable housing developers and by supporting the attainment of financing, such as CDBG, HOME Funds, tax credits, and state AHSC funds. * The City shall develop zoning standards to encourage missing middle and multi-unit housing types in currently single-family dominated neighborhoods. Missing middle and multi-unit housing types include accessory dwelling units, duplexes, triplexes, fourplexes, townhomes, bungalow courts, courtyard apartments, live/work units, and SB 9 lot splits. The City shall review and amend the Development Code to incorporate objective standards to encourage these housing types in Residential Single-Family (RS) Districts. Zoning modifications may include but are not limited to increasing allowable heights and densities, reducing minimum lot sizes, and/or reducing open space and setback requirements to facilitate more diverse housing types. The City will develop objective design standards to ensure that new missing middle and multi-unit housing is compatible with the scale of existing residential neighborhoods. * The City will incorporate Affirmatively Further Fair Housing analysis into decisions affecting funding and land use approvals for housing projects that require consideration by Planning Commission, City Council, or other boards and commissions as appropriate. | Responsibility | Planning & Development Department | | :--- | :--- | | **Funding Source** | General Fund | | **Timeframe** | Create capacity for 500 units for high density multi-family development in high and relatively higher resource and income areas by the end of 2025, an additional 1,000 units by December 2027, and an additional 1,000 units by December 2031

Initiate review of zoning standards for missing middle housing in January 2025 and develop and adopt objective zoning and design standards by December 2025.

Initiate a text amendment to the development code that would increase allowable density and permitted uses in single-family districts near transit by January 2026 for adoption by December 2026.

Incorporate AFFH into land use and funding decisions beginning in January 2025. | | **Objective** | Create additional capacity for 2,500 multi-unit lower-income housing units in high and relatively higher resource and income areas. | SECTION 1E-1: ACTION PLAN Support the development of 400 missing middle housing types (e.g., duplexes, triplexes, fourplexes, SB-9 lot splits) in RS zones during the planning period to increase the supply of affordable units throughout the city, thereby increasing access to resources and facilitating housing mobility opportunities for lower-income households and creating racially and socially inclusive neighborhoods. **Program 3 – Encourage and Facilitate Accessory Dwelling Units and Small Homes** The City will encourage the construction of accessory dwelling units (ADUs) and small homes (i.e., smaller than average primary residences) to bridge the gap between predominantly single-family neighborhoods with higher median incomes and multifamily neighborhoods. A primary objective of this program is to increase the supply of affordable units and small homes throughout the city, thereby increasing access to resources and facilitating housing mobility opportunities for lower-income households: * Continue to provide pre-approved ADU and small home plans on the City website to facilitate lower costs and expedited reviews for applicants. Expand marketing of these pre-approved plans such that homeowners in all areas of the city are made aware of this opportunity. * Encourage designers to create ADU ‘standard plans’ within the City’s building plan review system to allow for fast-tracking of approval. * Continue to implement the public education program advertising the opportunity for ADUs and small homes by updating informational handouts and brochures about ADUs and small homes that are available on the City’s website and at the public counter annually, or as needed to reflect changes in state law. Publish informational materials pertaining to ADUs and small homes in multiple languages and through a combination of media, including the City’s social media accounts and direct mailing. Promote public educational programs in all parts of the city. * Provide informational materials on ADU and small home opportunities to all discretionary residential land use applicants. * Develop partnerships with local builders and organizations such as California Tiny Homes, Pre-Fab Innovations, and Fresno City College’s Construction Department to facilitate opportunities for ADU and small home development, workforce development, and innovative strategies to construct units for landlords that make ADUs and small homes affordable housing for low- or very low-income households. * Promote inclusion of ADUs as multi-generational housing in new development. * Continue to work with partner agencies and funding entities to remove barriers to ADU development. * Subsidize inspections fees for landlords that make ADUs as affordable housing for low- or very low-income households. * Explore a subsidy for utility hook-ups such as water, sewer, and electricity for landlords that make ADUs affordable housing for low- or very low-income households. APPENDIX 1E: CITY OF FRESNO * Encourage the use of the City’s free ADU and small home standard plans for farmworker dwelling units and cottage communities. * Continue to provide ADU and small home resources on the City website, hotline, and email to answer questions on the program. * Monitor the production and affordability of ADUs every two years and the progress made according to the assumptions in the inventory. Take alternative actions (e.g., additional incentives) within six months of finding if not meeting the assumptions in the sites inventory. | | | | :--- | :--- | | **Responsibility** | Planning & Development Department | | **Funding Source** | General Fund or Grant Funds | | **Timeframe** | Update ADU and small home materials annually, or as needed to reflect changes in state law and identify incentives for construction by December 2024.

Report ADU production and affordability levels in the annual progress report. Every two years, determine if on track to meet sites inventory assumptions. If not, adjust assumptions or take action within six months of finding.

Update City pre-approved ADU and small home plans with Residential Building Code update cycle every three years starting in 2026.

Promote City pre-approved ADU and small home plans through public engagement activities in all areas of the city assessing outcomes of outreach annually beginning in 2025.

Subsidize inspection fees for landlords that make ADUs affordable for low- and very low-income households starting in July 2025.

Explore subsidies for utility hook-ups for landlords that make ADUs affordable by December 2025.

In coordination with the Fresno County Farm Bureau, the City will advertise the ADU and small home standard plans to farmworkers and farm owners by 2026.

Identify barriers to development of ADUs by July 2025 and work to reduce barriers by January 2026. | | **Objective** | Facilitate development of 50 ADUs or small homes for lower-income households (including extremely low-, very low-, and low-income), 24 ADUs for moderate-income households, and 20 ADUs for above moderate-income households to improve housing mobility opportunities and reduce displacement risk, with 30 percent of development for lower- and moderate-income households in relatively higher resource and income areas including RCAAs. | SECTION 1E-1: ACTION PLAN ### Program 4 – Streamline Development Review Process The City will develop a preliminary application form and procedure or will adopt the Preliminary Application Form developed by HCD, pursuant to SB 330. The City will also establish a written policy and/or procedure, and other guidance as appropriate, to specify the SB 35 streamlining approval process and standards for eligible projects under Government Code Section 65913.4. The applications and guidance documents will be available on the City’s website for developers interested in pursuing the streamlined process or vesting rights. The City shall conduct a review of local entitlement and permit processing procedures and identify ways to further streamline the development review process, including establishing a non-discretionary process to approve housing for qualifying developments based on size, type, affordability level, and location. The City will also amend the Development Code to remove appeal provisions for Development Permits or convert certain housing application types to ministerial if the project is consistent with the objective General Plan, zoning, subdivision, and design standards and criteria. Finally, the City will continue its commitment to providing navigation and concierge services to assist applicants with entitlement and permit processing for affordable housing projects. | | | | :--- | :--- | | **Responsibility** | Planning & Development Department, with support from other development services departments | | **Funding Source** | General Fund | | **Timeframe** | Develop an SB 330 preliminary application form and SB 35 streamlined approval process by July 2025.
Review local entitlement and permitting procedures by December 2025 and make further modifications within 6 months to streamline development of housing throughout the city. | | **Objective** | Shorten average entitlement processing times | ### Program 5 – Large and Small Lot Development Small sites present the opportunity for development on existing sites or lot consolidation into larger projects. There are many opportunities for lot consolidation surrounding identified sites, given the underutilized nature of surrounding properties. The Voluntary Parcel Merger program, in effect since 2016, permits the combining of parcels without going through the Parcel Map or Lot Line Adjustment process. The City adopted a reduced application fee, currently (2023) $696. APPENDIX 1E: CITY OF FRESNO The Sites Inventory includes vacant and underutilized lower-income sites that are over 10 acres in size. To encourage a strategic approach to the development of large sites and to facilitate the development of housing, the City will encourage the development of large sites through an allowance of phasing of development and off-site improvements as allowed pursuant to Section 66456.1 of the Subdivision Map Act, and, where applicable, through a Master Plan. In addition, the City will provide incentives for the development of large sites with a variety of housing types, including affordable housing, such as site planning and design, including preliminary feasibility analysis, and providing funding through the annual Notice of Funding Availability (NOFA). The City will provide the site planning and feasibility analysis and partner with the property owners to market the large sites to the developers, including developers of affordable housing. The City will routinely coordinate with interested developers/property owners in identifying opportunities for lot consolidation or lot splitting. The City will continue to streamline the processing of requests for lot consolidation and lot splitting concurrent with other development reviews, and subdivision maps that include affordable housing units. Currently, the City utilizes tools such as ministerial processing and other streamlining tools, as appropriate, to facilitate lot merging and parcelization. Additionally, the City will consider incentives for development of low-income high-density residential on large sites, such as concessions to development standards beyond state density bonus law, assistance with on and off-site improvement, parking reductions, funding, and fee deferrals or reductions. The City will conduct a biennial review of the development on large and small lots, and seek input from developers and property owners on the regulatory barriers to lower-income residential development of these lots. | Responsibility | Planning & Development Department | | :--- | :--- | | **Funding Source** | General Fund | | **Timeframe** | Continue to implement the Voluntary Parcel Merger Program and fee reduction program.

Conduct a biennial review of development on large and small lots, include an annual review process for monitoring the percentage of affordable units developed on large lots.

As projects are processed throughout the planning period, make changes as appropriate based on review and input.

Review and establish incentives by Winter 2026.

Provide site planning and feasibility analysis on at least one large site every two years during the housing element period, i.e., 2025, 2027, 2029, and 2031

Issue NOFA annually to provide funding for affordable housing. | | **Objective** | Facilitate development of 600 lower-income units on large and small lots to promote the efficient use of land for residential development, with 30 percent of development in relatively higher resource and income areas including RCAAs. | SECTION 1E-1: ACTION PLAN ### Program 6 – Objective Design Standards The City will review and amend site development standards and façade design standards in the Development Code for residential and mixed use zones to ensure standards are clear and objective. | Responsibility | Planning & Development Department | | :--- | :--- | | **Funding Source** | General Fund | | **Timeframe** | Initiate review of zoning standards for site development and façade design in January 2025 and develop and adopt objective zoning and design standards by December 2025. | | **Objective** | Accelerate housing production by ensuring development standards are clear and objective | ### Program 7 – Adaptive Reuse The City shall encourage adaptive reuse of commercial and office buildings to housing. The City shall evaluate, and if appropriate, amend the Development Code to remove potential constraints for adaptive reuse, including review or approval processes. The City shall consider regulatory incentives or waivers related to parking, open space, trash, and landscaping requirements and standards. | Responsibility | Planning & Development Department | | :--- | :--- | | **Funding Source** | General Fund | | **Timeframe** | Evaluate whether review or approval processes and development standards are a constraint on adaptive reuse or interim reuse. If barriers to adaptive reuse or interim use are identified, modify processes and/or adopt incentives as appropriate. Establish regulatory modifications no later than 2026.

Evaluate the California Building Code to determine if there are alternate means and methods which if applied could reduce the construction costs related to adaptive reuse. Evaluate with the next Ca BC cycle effective January 2026. | | **Objective** | Facilitate adaptive reuse of existing buildings into housing to increase the city’s housing supply. | ### Program 8 – List of Local Labor Unions and Apprenticeship Programs Provide a list of local labor unions and apprenticeship programs to developers, contractors, and community members to use and to encourage developers and contractors to hire local labor. | Responsibility | Planning & Development Department | | :--- | :--- | | **Funding Source** | General Fund | | **Timeframe** | By December 2024, the City will provide the list on the City’s website and update annually thereafter or upon request from local unions to be added to the list. | | **Objective** | To encourage developers and contractors to hire local labor. | ### Program 9 – Use of Sites in Previous Housing Elements Pursuant to Government Code Section 65583.2(c), any vacant sites included in the prior two Housing Elements (4th and 5th Cycle RHNA planning periods) and any non-vacant sites included in at least one prior Housing Element shall be provided by-right development when at least 20 percent of the units in the proposed development are affordable to lower-income households. This means that the City cannot require any form of discretionary review or approval for such projects. The City will develop an SB 330 preliminary application and SB 330 streamline approval process. The City will implement a text amendment to the Development Code to permit developments with at least 20 percent affordable lower-income units without appeal on any vacant and non-vacant sites identified in the lower-income inventory of the 5th Cycle Housing Element. A proposed project would also not be subject to CEQA and would not be appealable. See Policy 2.11. | Responsibility | Planning & Development Department | | :--- | :--- | | **Funding Source** | General Fund | | **Timeframe** | Develop and implement text amendment to Development Code by May 2025

Develop SB 330 preliminary application and SB 35 streamline approval process in 2025. | | **Objective** | Streamline development on vacant and non-vacant sites identified in previous Housing Element planning periods. | SECTION 1E-1: ACTION PLAN # Program 10 – Annual Reporting Program The City shall actively work toward Housing Element implementation, and reach out to the community including housing advocates, organizations, and developers annually to assess progress as part of a Housing Element Annual Report. The City shall provide multiple avenues for residents and stakeholders to provide input on the implementation of the Housing Element and submit feedback to staff. Every year, the City shall invite interested community members to discuss housing production progress at an annual public hearing. The City will provide annual information to the community on housing density and affordable housing and will develop a metric on displacement to include in the Annual Progress Report. The City will seek input on the effectiveness of housing and fair housing-related programs and policies maintained by the City. The City shall utilize multiple methods of outreach to engage all members of the Fresno community, including multilingual notices and media outlets. The City shall track and report on the location of new housing development, including affordability levels and geographic distribution in relation to areas of affluence and poverty (i.e., RE/CAPs and RCAAs). The City will consider establishing a Housing Element Public Engagement Committee that meets semiannually to garner feedback on housing conditions and housing element implementation. | Responsibility | Planning & Development Department | | :--- | :--- | | Funding Source | General Fund | | Timeframe | Conduct public outreach on a draft Housing Element Annual Progress Report prior to the annual public hearing. Hold public hearing prior to submittal to HCD. | | Objective | Engage a broad spectrum of the community ongoing, and often, on the progress and effectiveness of Housing Element implementation, and make changes as appropriate based on review and input. | # Goal 2: Affordable Housing ## Program 11 – Incentives for Housing Development The City will continue to work with housing developers to expand affordable housing opportunities by doing the following: * Work with developers of multifamily and affordable housing projects to identify site opportunities in high and relatively higher resource and income areas, including RCAAs, to reduce concentrations of poverty, improve access to resources for lower-income residents, and promote racially and socially inclusive neighborhoods. * Continue to provide priority processing for the construction of new housing in the Downtown Planning Area by processing completed plans, consistent rezoning, and Development Permit review and Conditional Use Permit applications for permitting within an average of 75 working days. APPENDIX 1E: CITY OF FRESNO * Continue to provide reduced application fees and priority processing for single-family and multi-family projects within the Inner City Fee Program area, as referenced in the Municipal Code, to create housing units in infill areas. * Continue to offer impact fee waivers for qualifying infill projects in priority areas of the city pursuant to Ordinances 2013-21 (The Build Act), and Fresno Municipal Code Article 4.14 (Fee Waivers for Certain Projects in Economically Disadvantaged Areas). * Provide flexibility in meeting off-site infrastructure requirements for affordable housing projects. * Encourage developers to use the State Affordable Housing Density Bonus and City of Fresno Transit-Oriented Development (TOD) Height and Density Bonus provisions through technical assistance and information dissemination. * Consider and establish additional incentives for the provision of affordable housing. * Incorporate the location of affordable housing in high and relatively higher resource and income areas, including RCAAs, as an additional priority that would qualify for incentives. * Post and maintain a list of incentives available to developers, including density bonus and impact fee waivers, on the City’s website. | Responsibility | Planning & Development Department | | :--- | :--- | | **Funding Source** | General Fund | | **Timeframe** | Provide ongoing assistance and incentives to support development during the 2023-2031 planning period. Establish and post the list of available incentives on the City’s website by December 2026. Update the list, as needed. | | **Objective** | Provide incentives for 1,200 extremely low-income, 1,750 very low-income, and 1,500 low-income units, at least 40 percent of which are in moderate, high, or highest resource areas to facilitate housing mobility for lower-income households and special-needs groups. | ### Program 12 – Local Housing Trust Fund In 2021, the City established a Local Housing Trust Fund (LHTF) to address the need for decent, safe, and affordable housing within the city. The City shall leverage the LHTF to direct funds toward eligible projects that are informed by a community input process. In 2022, the City was awarded a State of California Local Housing Trust Fund matching grant to support projects involving new construction of affordable rental housing for lower-income households [i.e., households earning below 60 percent of the Area Median Income (AMI)]. The City shall publish a Notice of Funding Availability (NOFA) to solicit applications for the distribution of funding from the LHTF as funds are available. SECTION 1E-1: ACTION PLAN The City shall review and update the current list of priorities for use of the funds through a community-driven process at least once during the Housing Element planning period. | | | | :--- | :--- | | **Responsibility** | Planning & Development Department | | **Funding Source** | Local Real Estate Transfer Tax, General Fund, and State of California Local Housing Trust Fund Program. | | **Timeframe** | Annually publish a NOFA to solicit applications for funding.

Review and update community priorities for the distribution by July 2028. | | **Objective** | Utilize LHTF to leverage up to $24 million of additional investment in affordable housing development during the planning period to support 320 extremely low-, very low-, or low-income housing units, with 30 percent of development in relatively higher resource and income areas including RCAAs. | **Program 13 – Pursue State and Federal Funding Sources for Housing Development** The City will actively pursue funding to assist in the development, preservation, and rehabilitation of housing with a particular emphasis on the development of mixed-income neighborhoods. The City will identify these funding opportunities to both for-profit and non-profit developers by deploying multiple rounds of funding availability notices. The City will also continue to provide technical assistance regarding state and federal financing and grant applications including but not limited to Low-Income Housing Tax Credit (LIHTC) and Affordable Housing and Sustainable Communities (AHSC) applications. The actions that the City will take specifically include, but are not necessarily limited to: * Identifying potential funding assistance and support applications for current state and federal assistance. * Identifying sites available for development and infill opportunities. * Pursuing funding to assist in the development, preservation, and rehabilitation of housing, with a particular emphasis on the development of mixed-income residential neighborhoods and the expansion of affordable housing opportunities outside of the city’s low- and moderate-income areas. * Partnering with non-profit entities to acquire properties for rehabilitation and/or development of affordable and mixed-income housing. * Supporting state and federal legislation that increases financial support for affordable housing. * Strive to maintain Prohousing Designation status to increase competitiveness for state funding opportunities. * Assessment and exploration of the potential for new funding programs to create additional local sources of funding for affordable housing. | Responsibility | Planning & Development Department, nonprofit and for profit developers | | :--- | :--- | | Funding Source | CDBG, HOME, LIHTC, AHSC, PLHA | | Timeframe | Annual assessment of funding opportunities and status of housing sites inventory as part of the annual reporting process; Ongoing implementation and annual reporting throughout the planning period. | | Objective | Pursue $15 million in funding annually to assist in the development, preservation, and rehabilitation of affordable housing, with 30 percent of investment targeting relatively higher resource and income areas including RCAAs. | ### Program 14 – Partnerships with Affordable Housing Developers The City will continue to strengthen partnerships and relationships with affordable housing developers by doing the following: * Identifying site opportunities for affordable housing in higher-resource areas and areas with higher median incomes to reduce concentrations of poverty and improve access to resources. * Encouraging and assisting in funding applications to applicable federal, state, and local funding sources. * Working with affordable housing developers to structure annual funding commitments to support multiple rounds of tax credit applications. * Identifying opportunities to align entitlement and permit approvals for affordable housing projects with funding deadlines e.g., HOME), including post-entitlement processes like encroachment permits. * Supporting local capacity building efforts around affordable housing finance, including convening affordable housing developers, community development leaders, lenders, advocates, lower-income and special needs households, and households and individuals in protected classes to identify housing needs as well as ongoing regulatory and funding barriers to affordable and mixed-income development. * Attracting large investors to facilitate the construction of new affordable housing units * Assisting nonprofits who develop self-help type single-family housing construction for extremely low-income households. * Joint advocacy for CEQA streamlining of single-unit affordable housing. * Supporting training programs for small-scale affordable housing developers. * Publishing notices for funding availability for various City housing programs, projects, and activities. SECTION 1E-1: ACTION PLAN * Administering Community Housing Development Organization (CHDO) funds for affordable housing projects with certified CHDOs. * Encouraging non-profit organizations to seek funding for development of new farmworker housing projects, as well as local affordable housing and mixed-income projects in transit-oriented developments along transit corridors throughout the city. * Pursue partnerships with developers and businesses which build and produce affordable pre-fabricated housing to facilitate the increased production of these cost efficient alternative housing types. | | | | :--- | :--- | | **Responsibility** | Planning & Development Department | | **Funding Source** | HOME & CDBG Programs, PLHA, LHTF | | **Timeframe** | Ongoing implementation and annual reporting throughout the planning period; annual review and assessment of potential funding opportunities; convene annual meetings with housing stakeholders starting in January 2025.

Identify opportunity sites for affordable housing including in high resource areas by 2027. | | **Objective** | Partner with affordable housing developers and stakeholders to facilitate the development of 1,200 extremely low-income, 1,750 very low-income, and 1,500 low-income units, at least 40 percent of which are in high or highest resource areas to facilitate housing mobility for lower-income households and special-needs groups. | ### Program 15 – Land Bank The City shall research viable land banking models with the goal of establishing a local land bank that could acquire parcels of land for the development of affordable housing. Once established, the City shall identify and maintain an inventory of underutilized land and vacant properties and work to acquire properties and remove blight while returning them to productive use. | | | | :--- | :--- | | **Responsibility** | Planning & Development Department | | **Funding Source** | General Fund; ARPA | | **Timeframe** | Research viable land banking models with the goal of establishing a local land bank by 2029. | | **Objective** | Accumulate underutilized land and/or vacant properties that could be used to support construction of affordable housing. | # Program 16 – Community Land Trust The City shall support the establishment of local Community Land Trusts to acquire and/or build affordable housing that remains so in perpetuity within the city of Fresno. The City shall support the Community Land Trusts in acquiring affordable housing units in areas at risk of displacement and acquiring land in high resource areas for the construction of new affordable housing, as well as collaborating to maintain vacant sites once acquired. Additionally, the City will provide support to land trusts for staff, stakeholder and community education on the land trust model. | | | | :--- | :--- | | **Responsibility** | Planning & Development Department with support from Code Enforcement, Public Works | | **Funding Source** | General Fund; ARPA | | **Timeframe** | By 2027, identify opportunity sites in areas at risk of displacement and in high resource areas and provide to the local Community Land Trusts for their consideration. | | **Objective** | Build capacity of local Community Land Trusts to acquire and/or build affordable housing that remains so in perpetuity within the city, with 30 percent of land acquisitions and new construction targeting relatively higher resource and income areas including RCAAs. | # Program 17 - Surplus Public Lands The City will continue to release land designated as surplus for development of affordable housing and other uses consistent with the California Surplus Lands Act (SLA). The City will continue to release sites as available for affordable housing development projects. All surplus sites disposed of pursuant to the SLA will include a minimum of 15 percent affordable units and in many cases will include up to 100 percent affordable units. Current City policy directs that property sale receipts are to be credited to originating funding sources utilized for purchase of property. The City will consider depositing a portion up to 100 percent of net proceeds from such sales or leases to the Local Housing Trust Fund. Prior to disposition under the SLA, the City will identify opportunities to use surplus sites – as well as other City-owned or City-leased properties – for emergency housing programs and other community-serving uses. Several City-owned sites are included in the Housing Element sites inventory, but others are not included because they are not currently zoned for residential. Some of the included sites are currently zoned for lower-density single-family development. The City will review all City-owned sites by June 2025 to determine appropriateness for affordable housing and identify if a zone change would be needed to facilitate affordable housing. If zoning amendments are needed, the City will complete rezoning of the sites within one year (June 2026). Some of the sites owned by the City and Successor Agency are small lots within existing neighborhoods that might be appropriate sites for missing middle or affordable homeownership opportunities for lower-income households. The City will review the list of publicly-owned sites and work with the Successor Agency and local non-profits and other organizations to develop a strategy for facilitating affordable housing on small, scattered sites. SECTION 1E-1: ACTION PLAN | Responsibility | Planning & Development Department | | :--- | :--- | | **Funding Source** | General Fund | | **Timeframe** | Complete a list of potential City surplus sites by June 2025.

Develop list of small publicly-owned sites by December 2025 and coordinate with the Successor Agency and local organizations to develop a strategy for facilitating missing middle and affordable housing opportunities on these sites by December 2027.

Develop disposition and disposal strategy in 2026. Initiate rezoning of City-owned sites in 2026 and complete rezoning in 2027.

Publish a Notice of Availability for at least 15 percent of City surplus sites annually and complete disposition within one year of publication.

Complete entitlements and issue building permits within one year of disposition.

Evaluate progress in 2029 toward achieving the objective and if necessary to maintain adequate sites to accommodate the RHNA, identify and/or rezone additional sites by 2030. | | **Objective** | Based on marketability and demand, release sites when available for affordable housing development projects. Facilitate development of 2,000 units, including 1,250 lower-income units. | ### Program 18 - Mixed Income Neighborhood Trust (MINT) The City shall partner with and build capacity of the Central Fresno Neighborhood Trust (CFNT), a Mixed Income Neighborhood Trust (MINT) model, which has been identified as a tool for accelerating the development of affordable rental housing. Established in 2023, CFNT will develop, own, and manage a scattered site income-restricted rental portfolio, governed by community stakeholders, and legally mandated to preserve affordability and belonging for today's renters. The CFNT and Central California Land Trust would complement one another in purpose. | Responsibility | Planning & Development Department and CFNT | | :--- | :--- | | **Funding Source** | General Fund; ARPA | | **Timeframe** | Complete initial contract by end of 2026 | | **Objective** | Support CFNT to develop a scattered site rental portfolio of a minimum of 50 new affordable rental housing units. | # Program 19 – Home Buyer Assistance In order to expand housing opportunities across Fresno, the City will commit to offering financial and technical assistance, as well as encourage counseling services to assist low-income residents in purchasing a home. The City will continue to pursue state and federal funds annually to support local first-time homebuyer programs to assist low-income first-time homebuyers to purchase a home in the city of Fresno. The City shall also maintain a partnership with NAHREP (National Association of Hispanic Real Estate Professionals) Fresno, Federal Home Loan Bank (FHLBank) of San Francisco’s WISH Program, Self-Help Enterprises, and Union Bank to administer the Llaves de tu Casa Iniciativa to provide down payment and closing cost assistance, home buyer grants, comprehensive home buyer education and counseling including first-time home buyer workshops and flexible mortgage products and programs available to all residents, with a focus on increasing Latino homeownership rates. The City’s Housing and Community Development Division will offer the following support and assistance in the variety of languages representative of Fresno including, but not limited to, Spanish, Hmong, and Punjabi: * **Technical assistance** - Guide applicants through the application process, offer technical support throughout the length of the program * **Financial assistance** - Offer up to $100,000 in loans, cover down payments and closing costs, zero interest fees, loan fees, or monthly payment fees, loan forgiveness after 15 years, and flexible payment plans calculated according to income at the time of application and adjusted based on changes in grantees income. Applicants will be required to participate in financial counseling services for support in becoming strong financial candidates, adapting to the challenges of becoming homeowners, and increase the beneficial impact of the program. * **Financial counseling services** - Intended to increase the beneficial impact of the program by preparing applicants to become strong financial candidates and offer support as grantees to help them adapt to the financial challenges of becoming homeowners. The City will promote all available homebuyer resources on the City’s website, at public counters, viand through City media outlets, community outreach, informative workshops, partnerships with local media outlets, neighborhood/homeowners’ associations, realtors’ associations, homebuilders, lenders, Rotary, and Community Based Organizations. Targeted outreach and promotional efforts will occur in R/ECAP and extremely low and very low-income households, prioritizing individuals and households with special needs. | | | | :--- | :--- | | **Responsibility** | Planning & Development Department and nonprofit community development corporations | | **Funding Source** | Permanent Local Housing Allocation (PLHA), NAHREP (National Association of Hispanic Real Estate Professionals) Fresno, Federal Home Loan Bank (FHLBank) of San Francisco, Self-Help Enterprises, and Union Bank | SECTION 1E-1: ACTION PLAN | | | | :--- | :--- | | **Timeframe** | Apply annually for state funding to support local first-time homebuyer programs starting in 2024, including the state’s CalHome Program and the Jose Serna, Jr. Farmworker Housing Grant, as funding is available.

Beginning June 2025, provide quarterly reports describing how many applicants were assisted, and a description of outreach efforts and the location of where grantees were able to find housing.

Beginning January 2025, the City will host two informative workshops every quarter and emphasize accessibility to extremely low-income and very low-income residents.

Beginning in January 2025, develop and implement a strong community outreach program to notify residents of the availability of the program targeting extremely low-income and very low-income residents. Marketing and outreach shall occur on an ongoing basis and updated at least annually from receipt of funds.

Beginning January 2025 or within 4 months of receipt of funds, the City will begin accepting applications for the program.

Review City website annually. | | **Objective** | If the City receives PLHA or other homeownership funding, the City will strive to support a total of 40 low- and moderate-income households with home purchases during the planning period, with 30 percent of purchases targeting relatively higher resource and income areas including RCAAs. | **Program 20 – Housing Choice Voucher Incentive Program** The Housing Choice Voucher (HCV) program is the federal government's major program for assisting very low-income families, the elderly, and the disabled to afford decent, safe, and sanitary housing in the private market. Since housing assistance is provided on behalf of the family or individual, participants are able to find their own housing, including single-family homes, townhouses and apartments. The participant is free to choose any housing that meets the requirements of the program and is not limited to units located in subsidized housing projects. Housing choice vouchers are administered locally by Public Housing Agencies (PHAs). The PHAs receive federal funds from the U.S. Department of Housing and Urban Development (HUD) to administer the voucher program. A family that is issued a housing voucher is responsible for finding a suitable housing unit of the family's choice where the owner agrees to rent under the program. This unit may include the family's present residence. Rental units must meet minimum standards of health and safety, as determined by the PHA. A housing subsidy is paid to the landlord directly by the PHA on behalf of the participating family. The family then pays the difference between the actual rent charged by the landlord and the amount subsidized by the program. Fresno Housing is the PHA for the county of Fresno. The City shall collaborate with and support Fresno Housing’s administration of the Housing Choice Voucher (HCV) program on an ongoing basis by: * Providing information about HCVs at the planning counter, on the City website, and in other public places to increase awareness. * Enforcing source of income protection and providing education to property owners on laws prohibiting the ability to refuse to rent to an applicant based on their source of income (e.g., Section 8 and other HCV programs, social security, disability). * Assisting Fresno Housing in holding regular informational meetings and discussions with multifamily property owners and potential new landlords to expand the number of developments that accept HCV tenants. Collaborating with Fresno Housing to conduct outreach to developments in high and relatively higher resource and income areas, including RCAAs, about participation in the HCV program by exploring best practices to target areas for voucher education, such as areas with high-performing schools or areas with high area median income, as well as areas near jobs and transit. The City’s role will be to assist in the geographic analysis necessary to target the outreach. The outreach will be performed on an annual and ongoing basis. | Responsibility | Planning & Development Department and Fresno Housing | | :--- | :--- | | Funding Source | HUD funding | | Timeframe | Support Fresno Housing’s outreach to households in high need areas as often as needed. Support Fresno Housing to conduct two to four workshops annually at varying locations throughout the city to provide mobility counseling and recruit landlords to help voucher holders find housing options in resource-rich neighborhoods. | | Objective | Work with Fresno Housing to enforce source of income laws that prohibit owners from refusing to rent to HCV holders and increase landlord participation by at least 250 new units in high and relatively higher resource and income areas, including RCAAs, to support housing mobility for low-income families and special needs households. | SECTION 1E-1: ACTION PLAN ### Program 21 – Advocate for Repeal of Article 34 Article XXXIV of the State of California Constitution (Article 34) prohibits the development of low-income affordable housing with state or local public financing or assistance unless there has been local voter approval. Article 34 dampens the capacity of public housing authorities to develop affordable housing locally and statewide. The City should continue to advocate for the repeal of Article 34. The City currently has sufficient voter approval for up to 1,800 units, the most recent vote being March 6, 1979. Cumulatively, up to 1,800 units have been authorized by voters. Should Article 34 not be repealed, the City may soon be required to place a measure on the ballot to seek voter approval that would grant the City general authority to support the development of additional affordable housing units which, at a minimum, would meet the lower-income RHNA. This program would request voter approval should the balance of voter authorized units be exceeded. | Responsibility | City of Fresno; State of California | | :--- | :--- | | Funding Source | General Fund | | Timeframe | Monitor annually to determine if Article 34 ballot measure is needed | | Objective | Remove regulatory barrier associated with receiving voter approval for affordable housing development. | ### Goal 3: Housing and Neighborhood Conservation ### Program 22 – Housing Rehabilitation With the goal of conserving affordable housing, preventing displacement, and cultivating thriving communities, the City of Fresno will assist households who on average have below-moderate incomes by connecting them to resources and services specialized in the rehabilitation of their homes. The City shall connect homeowners with resources for eligible improvements including health and safety, hazard corrections, and accessibility modifications to reduce displacement risk and facilitate place-based revitalization. The City offers programs that provide exterior repair to seniors and provides funds to non-profits for home rehabilitation programs for lower-income households. These activities have been funded with CDBG program funds. The Senior Exterior Repair Program provides a grant to low-income seniors (62 years and older) who own and occupy their homes to make needed exterior repairs and improvements to their homes. The maximum allowable amount for a rehabilitation grant is $20,000 in 2023. The City will: * Promote available housing rehabilitation resources, including the Fresno Economic Opportunities Commission’s (EOC’s) Energy Services Program that includes weatherization, on the City’s website, at public counters, and in libraries. The program will also be promoted through City media outlets, community outreach, informative workshops, and partnerships with local media outlets, neighborhood associations, and community benefit organizations. APPENDIX 1E: CITY OF FRESNO * Outreach and promotional efforts will occur in R/ECAPs, targeting households who on average have extremely low to very low incomes, households of undocumented residents, homes with substandard living conditions, and households with special needs. All materials will be made available in a variety of languages representative of Fresno including, but not limited to, Spanish, Hmong, and Punjabi. * Offer the following assistance to homeowners in a variety of languages representative of Fresno: * **Technical assistance** - Guide applicants through the application process and offer technical support throughout the length of the program. * **Referral assistance** - Connect applicants to resources and services based on the level of repair needed. * **Financial assistance** - Offer rehabilitation grants to homeowners. * Prioritize rehabilitation for households with special needs, homes with damages that pose a serious health risk, and homes with damages that are likely to be exacerbated by weather and climate change. * Employ local licensed general and paint contractors and prioritize partnerships with contractors who predominantly employ or will employ local residents including part-time jobs for youth for the duration of their participation in the program * Engage and consider community feedback when setting future program priorities for housing rehabilitation as part of the next Consolidated Plan update cycle. | Responsibility | Planning & Development Department | | :--- | :--- | | **Funding Source** | CDBG program funds | | **Timeframe** | Beginning in January 2025, host two quarterly informative workshops. Half of the workshops will occur in an area accessible to residents residing in R/ECAPs.

Begin outreach one month before every informative workshop by notifying Community Based Organizations and posting on social media.

By March 2025, notify the community via city media outlet and community benefit organizations, and update its website to promote the development of the Program.

By August 2025, begin offering rehabilitation services.

By February 2026, provide annual and quarterly reports describing how many homeowners were assisted with revitalization, how many local residents were employed, a description of outreach efforts including the location where they took place.

Complete 15 Senior Exterior Repair projects annually.

Seek input from the community and begin setting program priorities for the Consolidated Plan in 2024. | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-1-29 SECTION 1E-1: ACTION PLAN | | | | :--- | :--- | | **Objective** | Aim to connect at least 80-120 lower-income households with rehabilitation resources during the planning period and complete a third of these in areas of concentrated poverty with older housing stock to facilitate place-based revitalization. | **Program 23 – Comprehensive Code Enforcement** The City of Fresno, in conjunction with private businesses, developers, and community-based non-profit organizations, will continue to collectively increase neighborhood revitalization activities as follows: * The Community Compliance Unit will continue to assertively conduct targeted neighborhood inspections of housing units for potential health and safety issues. All Area Teams, as needed, will continue to improve neighborhoods throughout Fresno and increase livability by creating safe and healthy conditions, removing blight, educating citizens and connecting residents to housing rehabilitation programs and services, promoting pride of ownership, and building collaborative relationships with the community. * The Rental Housing Unit shall continue to operate the Rental Housing Improvement Program to address the issue of substandard rental properties, promote greater compliance with health and safety standards, and to preserve the quality of Fresno’s neighborhoods and available housing opportunities. The goal is to work with property owners to achieve compliance of health and safety code violations that are a threat to the occupant’s safety, structural integrity of the building, and have a negative impact on the surrounding neighborhoods. The City will pursue resolution of cases identified through the inspection process, including through enforcement actions against landlords if necessary, including Administrative Citations, Penalties, Abatement by Contractor, Court Appointed Receivership, Property Liens, Judicial Remedies, Referrals, etc. The City shall work to expand awareness of the Lien Waiver Program in which the City Manager may enter into an agreement to waive fines or citations if properties are brought into compliance. * The Special Teams Unit will continue to maintain its School Area Team, designed to conduct proactive inspections in neighborhoods surrounding schools; Waste Tire Team to remove waste tires from the city, including hosting Tire Amnesty days; the Demolition Team to ensure dangerous buildings are being demolished or fully rehabilitated; the Vacant Lots team, to ensure properties are clear of tall grass and weeds; the Illegal Dumping Team, to investigate and hold accountable those who unlawfully dump garbage in neighborhoods, streets, and alleys; and the Abatement Team to remove significant health and safety hazards and other violations pursuant to warrants. The Legal Team will continue to seek inspection/abatement warrants and petition the court for receivership of properties unable to be brought into compliance. | Responsibility | City Attorney’s Office, Code Enforcement | | :--- | :--- | | Funding Source | General Fund and CalRecycle Grant (for Waste Tire & Illegal Dumping Team) | | Timeframe | Complete 10,000 inspections annually, pursue resolution of cases identified through the inspection process.

Work with the Mayor’s Office on developing an outreach strategy for the Lien Waiver Program in 2027. Ensure marketing is directed to older and disadvantaged neighborhoods. | | Objective | Continue code enforcement efforts to improve and preserve the quality of housing and residential neighborhoods in Fresno. Conduct focused outreach and programming in older and disadvantaged neighborhoods in central and south Fresno, including but not limited to Downtown Fresno, Lowell/Jefferson Neighborhood, Edison Neighborhood, Southeast neighborhood, Southwest Neighborhood, Central Southeast Neighborhoods, Mclane Neighborhood, Fresno High-Roeding Neighborhood, El Dorado Park Neighborhood, and the Shaw/Marks Neighborhood. Determine any additional neighborhoods that should be identified for outreach and programming. Connect residents to available housing rehabilitation programs and services. | ## Goal 4: Special Needs Housing ### Program 24 – Special Needs Housing The City shall advocate for the provision of special needs housing, including disabled-accessible units and housing for persons with mental and physical disabilities. The City will provide technical support and offer incentives to housing developers, such as Fresno Housing and Self-Help Enterprises, in the application of funds for housing, including HCD (e.g., the Joe Serna grant program) and USDA Rural Development loans and grants, other programs administered by California’s Office of Migrant Service (OMS) and other funding sources that may become available to meet the needs of persons with special needs (such as seniors, farmworkers, survivors of domestic violence, and people with disabilities, including persons with developmental disabilities), including the following efforts: * Continue to implement the Universal Design Ordinance for new construction or modification of City-subsidized housing. * The City will support and work actively to meet the housing needs of permanent and migrant farmworkers in Fresno. The City will cooperate with public and private agencies to seek funding to identify and implement strategies leading to the rehabilitation of existing and provision of new housing for farmworkers. SECTION 1E-1: ACTION PLAN * The City will target code enforcement and other resources to the existing housing stock with the most need for rehabilitation and sanitary conditions that could be more likely to house farmworkers and work with regional or other organizations to improve living conditions for farmworkers. * For new affordable housing projects developed with City assistance, incentives, and/or subject to City requirements, the City will require that the developer give qualified farmworker households a preference for at least 5 percent of the new units. Should demand from farmworker households be insufficient to fill the set-aside units, then the units will be made available to other qualified households. The City will annually reach out to affordable housing developers to gather interest and input on how to best implement this program and will provide information on available funding. * The City will offer incentives such as density bonuses, streamlined processing, and the minor deviation process to facilitate development of farmworker housing. The City will identify development opportunities for farmworker housing at least every other year during the planning period. * Meet with farmworker housing developers and advocates on a biannual basis to discuss their needs and offer assistance in the form of letters of recommendation for grant applications, assistance with site identification and grant opportunities, and discuss incentives for constructing farmworker housing. * The City will annually monitor the status of farmworker housing as part of their annual report to HCD on Housing Element progress and evaluate if City efforts are effective in facilitating the provision of farmworker housing. If appropriate, the City will make necessary changes to enhance opportunities and incentives for farmworker housing development. * Seek and apply to funding sources and partner with local and statewide organizations to facilitate the construction of units for extremely low-, very low-, and low-income income seniors (typically age 65 years and over; may vary by funding source or program). * Use funding programs such as the Emergency Solutions Grant (ESG), and Housing Opportunities for Persons with HIV/AIDS (HOPWA) to provide financial support to organizations that provide counseling, information, education, support, housing services/referrals, and/or legal advice to extremely low-income households, to mitigate risk of displacement and support housing stability for extremely low-income households, persons with disabilities, farmworkers, and persons experiencing homelessness. * Support needed social services and review applications annually. * Continue to utilize available funds and/or seek funding to support the Fresno-Madera Continuum of Care, a local collaborative of homeless service providers, to construct transitional and supportive housing units. APPENDIX 1E: CITY OF FRESNO * Provide technical assistance to developers with proposed Single Room Occupancy (SRO) facilities, transitional and supportive housing, and other special housing types to create units during the planning period. * Provide incentives to builders to provide housing with multiple bedrooms affordable to lower- and moderate-income households to meet the needs of female-headed, single-parent, and large-family households of all income levels (possible incentives will include reduced setbacks, reduced parking requirements, and technical assistance with applications for funding). * Encourage the provision of affordable housing for young adults, particularly former foster youth and young mothers, through planning consultations, streamlined permit processing, and funding assistance. * The Mayor’s Office of Community Affairs will assist in engaging all residents of the community including youth, Black, Indigenous, People of Color (BIPOC), Latino, Asian/Pacific Islander, Indian, and LGBTQ on their housing needs. | Responsibility | Planning & Development Department, Mayor’s Office of Community Affairs | | :--- | :--- | | **Funding Source** | HUD Funds (ESG), Other Grants | | **Timeframe** | Ongoing, as projects are processed by the Planning & Development Department.

By December 2024, initiate outreach, and in 2025 conduct outreach to organizations that support extremely low-income residents and residents with special needs housing to understand funding needs.

Support expediting applications on an ongoing basis.

Contact nonprofit developers at least every other year to identify opportunities for the development or improvement of housing for farmworkers

Monitor status of farmworker housing and evaluate effectiveness of efforts annually as part of the annual report process. Annually review the availability of funding opportunities to provide housing vouchers or other forms of rental assistance for farmworkers, and apply for funding as opportunities arise. Identify farmworker housing development opportunities throughout the city at least twice in the planning period. | | **Objective** | Facilitate development of special needs housing, including 1,200 units for extremely low-income households and development of 100 units for farmworkers and their families. Pursue funding in collaboration with agencies serving farmworkers to support the rehabilitation and conserve an estimated 140 units serving farmworkers annually through code enforcement. | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-1-33 SECTION 1E-1: ACTION PLAN # Program 25 – Development Code Amendments for Compliance with State Law and to Reduce Barriers to Housing Development The City will amend the Development Code to address the following development standards and barriers to housing opportunities: * **Density Bonus:** Amend the Development Code to include provisions allowing 80 percent density bonus and up to four concessions for 100 percent affordable developments consistent with the current requirements of State Density Bonus Law outlined in Government Code Section 65915. Monitor State Density Bonus Law annually for legislative changes and modify ordinance as needed during the planning period. * **Accessory Dwelling Units:** Amend the Development Code to be consistent with the latest state legislation related to development standards for ADUs and ensuring that the construction of a junior accessory dwelling unit (JADU) on each lot is clearly permitted in addition to an ADU, in accordance with California Government Code Section 65852.2. * **Parking Requirements:** Amend parking requirements for ADUs and supportive housing units within a half mile of transit and amend the development code to remove parking minimums within a half mile of transit consistent with AB 2097, outlined in Government Code Section 65863.2. * **Emergency Shelters:** Adopt the updated State definition of emergency shelters and modify the parking requirement for emergency shelters to require sufficient parking to accommodate all staff working in the emergency shelter, provided that the standards do not require more parking for emergency shelters than other residential or commercial uses within the same zone, in compliance with Government Code Section 65583(a)(4). Amend the hours of operation to cover nighttime hours, and review and confirm the standards for toilets is not excessive relative to similar other uses, and overall ensure that standards for emergency shelters comply with state law (Government Code Section 65583(a)(4). * **Low-Barrier Navigation Centers:** Permit low-barrier navigation centers, defined as low-barrier, temporary service-enriched shelters to help homeless individuals and families to quickly obtain permanent housing as a permitted use subject only to ministerial approval in zones where mixed uses are allowed or in nonresidential zones that permit multifamily housing (Government Code Section 65662; AB 101). * **Residential Care Facilities:** Review requirements for unlicensed and licensed group homes and larger group homes and permit them in all residential zones in a similar manner to other residential uses to comply with the City’s obligation to affirmatively further fair housing pursuant to Government Code Section 8899.50 (b)(1) and Government Code Section 65583 (c )(10). The City will also review CUP findings for residential care facilities to ensure they are objective and do not serve as a barrier to development. If determined to be a barrier or subjective then the City will amend CUP findings for residential care facilities. APPENDIX 1E: CITY OF FRESNO * **Single-Room Occupancy Units:** Amend the Development Code to comply with Government Code Section 65583 (c)(1) and remove the current limit of 15 guests in SRO units, change SRO to permitted use in RM-1, RM-2, RM-3, NMX, CMX, and RMX, and evaluate objective design standards for SROs to ensure that units are maintained and safe for all residents long term. * **Farmworker and Employee Housing:** Amend the Development Code to comply with Government Code Section 65583 (c)(1) and permit employee housing for six or fewer as a residential use and permit agricultural labor housing in all zoning districts where agricultural uses are permitted. * **Supportive Housing:** Allow for the approval of 100 percent affordable developments that include a percentage of supportive housing units, either 25 percent or 12 units, whichever is greater, to be allowed without a conditional use permit or other discretionary review in all zoning districts where multifamily and mixed-use development is permitted, consistent with Government Code Section 65651(a). * **Definition of “Family”:** Amend the Development Code to add an inclusive definition of family and consistently replace the terms “single family” and multi-family” with “single-unit” and multi-unit” to ensure internal consistency. * **Definition of “Tiny Home”:** Amend the Development Code to expand the definition of tiny homes to allow for modular homeownership on leased parcels. The City will consider amending the Development Code to address the following development standards and barriers to housing opportunities: * **Overlay Zone in Transit Rich and Urban Infill Sites:** Assess benefits of implementing SB 10 (2021) and if it is found to be beneficial then amend the Development Code to add an overlay zone which would allow up to 10 residential units in certain “transit rich” and “urban infill sites.” * **Overlay Zone for Workforce Housing:** Assess benefits of implementing workforce housing and if it is found to be beneficial then amend the Development Code to add an overlay zone which would allow workforce housing in certain Commercial, Business Park, and Public Facilities zone districts. * **Reduce Parking Requirements for Residential Care, General:** Amend the Development Code to reduce parking requirements to 1 space per employee and 1 space for every 7 residents. Parking stalls within residential garages count towards required parking spaces. | Responsibility | Planning & Development Department | | :--- | :--- | | **Funding Source** | General Fund | | **Timeframe** | The City will initiate Development Code amendments by December 2025.

In 2025, the City will assess the potential benefits of SB10 and Workforce Housing overlay zones to Fresno and if determined to be beneficial then the City will initiate a Development Code Amendment by 2026. | SECTION 1E-1: ACTION PLAN | | | | :--- | :--- | | **Objective** | Annually review the effectiveness and appropriateness of the Development Code and process any necessary amendments to remove or mitigate potential constraints to the development of housing. | ## Goal 5: Fair and Equal Housing Opportunities ### Program 26 – Fair Housing Services The City will continue to contract with a fair housing service provider to support enforcement of state and federal Fair Housing Laws and provide fair housing services that include, but are not limited to, the following with an emphasis on providing targeted outreach and support to disproportionately burdened groups and areas of the city: * Continue analyzing and addressing fair housing issues through the five-year review and update of the regional Analysis of Impediments to Fair Housing Choice, in alignment with HUD's updated guidelines. The City shall take meaningful actions to overcome patterns of segregation, promote fair housing choice, eliminate disparities in opportunities, and foster inclusive communities free from discrimination throughout the city by implementing the solutions developed in the Regional Analysis of Impediments to Fair Housing Choice (AI). * Referring inquiries and landlord/tenant complaints concerning housing discrimination to the applicable regulatory body (State Department of Fair Employment and Housing, HUD, or private counsel) for processing. * Disseminating fair housing information citywide by sponsoring workshops, housing information fairs, monitoring of affirmative marketing, and working closely with fair housing service providers to target outreach and programming to Black, Latino, and other disproportionately impacted groups, as well as neighborhoods experiencing high levels of housing issues. * Disseminating fair housing information through radio, television, and other media in multiple languages and targeted neighborhoods to reach disproportionately impacted residents. * Geographic coverage of the outreach should be targeted to the most vulnerable populations as depicted in Figure 1E-3.3 – Racial Segregation by Census Tract, Figure 1E-3.7-Distribution of Poverty, and Figure 1E-3.10 – Percentage of Population with a Disability. * Advertising fair housing laws and complaint procedures through literature displays at the City. The City will provide displays to non-profit organizations such as Central California Legal Services, Lao Family Organization, Fresno Interdenominational Refugee Ministries, Fresno Center for New Americans, property management organizations, lenders, and other such organizations to help reach disproportionately impacted populations. Literature will be provided in English, Spanish, Hmong, and Punjabi. * Improve Fair Housing complaint tracking and response; allow trusted nonprofit counselors to be added to tracking systems to aid their clients in receiving and understanding notifications on the complaint process. As most housing discrimination complaints in Fresno are related to a disability bias, the City will work with fair housing providers to provide additional educational resources in a variety of languages to both tenants and landlords related to disability rights in housing. The City will publicize fair housing services on its website, in City Hall, and in all housing-related programming. | Responsibility | Planning & Development Department, fair housing service provider | | :--- | :--- | | Funding Source | CDBG | | Timeframe | Update the City of Fresno Analysis of Impediments to Fair Housing Choice by 2025.

Provide funding, as available, to local fair housing service providers and provide services to 1,500 persons annually consistent with the Consolidated Plan and Action Plans.

Complete ongoing implementation and annual reporting throughout the planning period. | | Objective | Ensure compliance with fair housing laws. Refer discrimination to appropriate State and Federal enforcement agencies. Mitigate impediments to fair housing opportunities throughout the city, with an emphasis on supporting the needs of populations and neighborhoods most impacted by fair housing issues, including but not limited to Lowell/Jefferson Neighborhood, Edison Neighborhood, Southeast neighborhood, Southwest Neighborhood, Central Southeast Neighborhoods, Mclane Neighborhood, Fresno High-Roeding Neighborhood, El Dorado Park Neighborhood, and the Shaw/Marks Neighborhood. | ### Program 27 – Environmental Justice The City has initiated the preparation of an Environmental Justice (EJ) Element that will include policies and actions to lessen pollution burden on disproportionately-impacted neighborhoods through urban greening, lessening impacts of industrial uses on residential areas, reducing impacts of extreme heat, and other actions to reduce pollution exposure, and promote equitable access to public facilities, healthy food, safe and sanitary homes, and recreation and physical activity. The EJ Element will include: 1. Objectives, policies, and implementation strategies to reduce the unique or compounded health risks in disadvantaged communities by means that include but are not limited to: a. Reducing pollution exposure, including improving air quality b. Promoting public facilities access SECTION 1E-1: ACTION PLAN c. Promoting food access d. Promoting safe and sanitary homes e. Promoting physical activity 2. Objectives, policies, and implementation strategies to promote civic engagement in the public decision making process 3. Objectives, policies, and implementation strategies that prioritize improvements and programs that address the needs of disadvantaged communities The EJ Element is expected to be complete and incorporated into the General Plan by June of 2026. The City will monitor the impact of the EJ Element policies in the General Plan by developing a data tracking program to assess program outcomes in disadvantaged communities. Every five years, the City will collect data to assess its performance against a minimum of five of the following types of measures using 2024 as the base year. The City will adjust policies, actions, or the approach to improve performance as needed: * Health outcomes of residents in disadvantaged communities * Number and percentage of homes that are within a half-mile of a grocery store of other entity that offers fresh food * Number of homes that are within a half-mile of a park or open space as defined in the Parks Master Plan * Tree canopy within disadvantaged areas * Number of homes that are within a half-mile of community facilities such as community centers, libraries, and hospitals or clinics * Number of homes that are within a half mile of high quality transit routes * Number of jobs created or people employed in disadvantaged communities * Amount of support (defined as technical assistance or financial support) for small businesses in disadvantaged communities through the City’s and County’s economic development departments. * Number of residents that participated in a city outreach event, City Council, Commission or City meeting, or completed a City-sponsored survey. | | | | :--- | :--- | | **Responsibility** | Planning & Development Department in coordination with Department of Public Works, PARCS Department, Department of Public Utilities, Capital Projects Department, and Mayor’s Office of Community Affairs | | **Funding Source** | General Fund | | **Timeframe** | Update General Plan to incorporate Environmental Justice policies by June 2026. Define metrics for tracking program and establish baseline by December of 2025. Complete first tracking report by December of 2027. Implement the EJ Element at least annually and ongoing, including applying for funding annually or as available. | | **Objective** | Prepare an EJ Element with actions to improve public health and quality of life in disproportionately-impacted neighborhoods, including racially and ethnically concentrated areas of poverty (R/ECAPs). The City will target a 15 percent improvement in the metrics described above, once baselines are established. | **Program 28 – Equitable Community Investments** The City will continue to prioritize investment in underserved neighborhoods, which includes racially and concentrated areas of poverty, with strategic projects in the areas of parks and community centers, water and sewer infrastructure, pedestrian and bicycle safety, road improvements, transit electrification, youth programs, public safety, small business investment, and urban greening and beautification. In order to build upon past work and expand future investment for equitable community investments, the City will pursue a variety of activities including increasing investment, partnership, outreach, and transparency, which will include but not be limited to the following: * New and improved community centers in West and Central Fresno. *(Timeframe/Objective: 5 new/improved community centers during 2023-2031 planning period)* * Transform Fresno Greening Projects, which includes investment in new and improved parks, plazas and open space in Southwest Fresno, Chinatown, and Downtown. *(Timeframe/Objective: 7-8 improvements during 2023-2031 planning period)* * Pedestrian, bicycle, and streetscape improvements, including streetlights, planting trees, new and improved crosswalks, filling sidewalk gaps, pedestrian and bicycle bridges. *(Timeframe/Objective: 5-6 projects during 2023-2031 planning period)* * Purchase of over $68 million in new zero-emission buses and expansion of transit service, including paratransit for persons with disabilities. *(Timeframe/Objective: Over 130 new vehicles by 2031)* * Water, sewer, stormwater, and other infrastructure improvements to accelerate mixed-income infill housing development Downtown, Chinatown, and Southwest Fresno. *(Timeframe/Objective: $293 million by 2031)* SECTION 1E-1: ACTION PLAN * The investments listed above facilitate ongoing implementation and investment in the Southwest Fresno Specific Plan (SWFSP) area, including bicycle, pedestrian and trail facilities, Fresno Greening Projects, and construction of new parks. Specifically, the Southwest Fresno Trail, the Southwest Urban Forest Project, and the MLK Park are all under construction and expected to be completed during the 2023-2031 planning period. At least annually and on an ongoing basis implement and monitor the Southwest Specific Plan and make adjustments as appropriate to ensure meeting objectives. * The investments listed above facilitate ongoing implementation and investment in the Downtown Neighborhoods Community Plan area, including Chinatown and Downtown urban greening, pedestrian, bicycle and streetscape improvements and infrastructure improvements. Specifically, the Chinatown Urban Greening project, Chinatown Streetscape Improvements and water and sewer main replacements are expected to be completed during the 2023 – 2031 planning period. Progress the Downtown Neighborhoods Community Plan implementation will be monitored on an annual basis and adjustments made as appropriate to ensure meeting objectives. In addition to General Funds, major sources of funding for these programs include but are not limited to: * An estimated $40 million per year through Measure P to build new parks and improve existing parks and expand cultural programming opportunities prioritizing areas of greatest need. * Measure C funds for bicycle, pedestrian, and other road infrastructure projects. * $293 million from the State of California for infrastructure improvements in Downtown Fresno. This includes the Downtown Fresno Capital Improvement Project (CIP), supported by $47 million from the Infill Infrastructure Grant (IIG) program, which will include sewer main replacements across multiple streets, a water project, site preparations, surface improvements, urban greening, installation of pedestrian lighting and push buttons, and ancillary works, and construction of a centralized off-site parking structure. * An estimated $23 million in remaining Transformative Climate Communities grant funding, which will fund investments in trails, parks, sidewalks, educational facilities, and other infrastructure improvements. City Departments are working to transparently track investment for the public to see what and where investment is taking place and to conduct outreach and partner with the community through actions that include but are not limited to: * Developing an online tool accessible to the public to view the location, type, value, and status of public infrastructure projects. * Publishing a quarterly report on the planned, obligated, underway, and completed infrastructure projects as they correspond to areas of greatest need. APPENDIX 1E: CITY OF FRESNO * Evaluating annually the distribution of infrastructure funds from all funding sources corresponding to areas of greatest need. * Continuing to partner with local community-based organizations (CBOs) and local affordable housing developers, with a focus on building local capacity, to seek funding and implement programs in the areas of highest need in the city. | Responsibility | All City Departments | | :--- | :--- | | **Funding Source** | General Fund; Capital Improvement Funds; state and federal funding as available including HUD Funds (CDBG). | | **Timeframe** | Annually prioritize investments and annually seek grant funding targeting areas of greatest need, including racially and ethnically concentrated areas of poverty

Continue to implement place-based improvements throughout the 2023-2031 planning period in areas of greatest need, including racially and ethnically concentrated areas of poverty.

Develop an online tool accessible to the public to view projects by July 2025.

Once the tool is created, track infrastructure projects by opportunity area classification (e.g., low resource areas vs high resource areas) and report quarterly online and annually through the Annual Progress Report.

As individual planning efforts are completed, implement the plans and evaluate their effectiveness annually, making adjustments as appropriate to ensure their objectives are achieved, such as compatibility between residential and industrial uses.

If land use is changed from an adopted use in a specific plan, the City will evaluate impacts and create new targets to better balance for residential-industrial compatibility. | | **Objective** | Prioritize investment in underserved neighborhoods, which includes racially and concentrated areas of poverty, including but not limited to Downtown, Edison Neighborhood, Southeast Neighborhood, Jane Addams Neighborhood, Southwest Neighborhoods, Central Southeast Neighborhoods, McLane Neighborhood, Fresno High-Roeding Neighborhood, El Dorado Park Neighborhood, and Shaw/Marks Neighborhood.

See individual objectives above related to targeted investments. | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-1-41 SECTION 1E-1: ACTION PLAN # Program 29 – Equitable Engagement The Office of Community Affairs was created within the Mayor’s Office to provide greater access to historically underrepresented communities. The OCA offers services and resources for Fresno residents. It engages all members of the Fresno community by serving as the City government’s liaison to key constituent groups, associations, multicultural and immigrant populations, faith-based, civic and human service, and others including community benefit organizations. The OCA connects marginalized communities with City services and resources; these communities include the Asian/Pacific Islander community, Black Indigenous and People of Color community, Indian community, Latino community, and LGBTQ community with representation through community coordinators. The goal of the OCA is to bring underserved communities a voice and create a network for community organizations, community members, and community businesses to feel represented, heard, and connected to city government. The OCA serves as a welcoming presence to make residents comfortable bringing questions, concerns, and comments to city hall, providing a connection with someone who can speak their language and understand their needs, and building trust. The City of Fresno leadership is committed to providing resources for underserved communities and the OCA is intended to bridge the gaps between City Hall and the residents of Fresno. | Responsibility | Office of Community Affairs | | :--- | :--- | | **Funding Source** | General Fund | | **Timeframe** | At least annually and ongoing | | **Objective** | Expand outreach and public education strategies to increase engagement amongst historically underrepresented populations and residents with the greatest need, including within the context of the City’s long range and community planning functions as well as the land use entitlement process. | # Program 30 – Workforce Development The City will work collaboratively with regional partners to improve job opportunities for residents in sectors that provide not only entry level employment opportunities, but paths that lead to higher paying jobs and better housing. This will include continuation of the following programs and expanding targeted job training as possible: * Through the One Fresno Youth Jobs Corps Program, the City hires youth ages 16-30 years old, pays them a livable wage, provides training and wrap-around services and puts them on a career pathway for future City or outside organization employment in that field. The program focuses on hiring youth that face barriers, including but not limited to youth who are low-income, justice-involved, transitioning from foster care, and/or unhoused or at-risk of becoming unhoused. * **Local Conservation Corps (LCC) LCC provides young adults (ages 18-26) with paid job training and educational opportunities. Corps members (participants) provide service to the community through paid vocational training while advancing their education.** * **Valley Apprenticeship Connections (VAC) Construction Pre-Apprenticeship Program** Fresno EOC VAC program provides a 12-week pre-apprenticeship training to prepare individuals for the construction industry. * **Workforce Connection Young Adult Program** is an Academic Tutorial and Career Readiness Program providing a comprehensive array of services that focus on assisting young adults with one or more barriers to employment to prepare for post-secondary education and employment opportunities, attain educational and/or skills training credentials, and secure employment with career or promotional employment opportunities. Workforce Connection focuses primarily on serving youth who live south of Shields Ave. in the Fresno metropolitan area. Additionally, the program also serves Urban East, which encompasses Urban Fresno and Clovis to the east of Highway 41. | | | | :--- | :--- | | **Responsibility** | Office of the Mayor; Fresno Regional Workforce Development Board; Economic Opportunities Commission | | **Funding Source** | State and federal grant funding | | **Timeframe** | Ongoing, continue to implement | | **Objective** | Provide job training programs to improve economic opportunities | ## Goal 6: Energy Conservation and Sustainable Development ### Program 31 – Reduce or Waive Fees for Vehicle Miles Traveled (VMT) New CEQA rules on Vehicle Miles Traveled (VMT) require projects to mitigate the number of VMTs generated above the adopted threshold. Projects within 1/2 mile of high quality transit corridors are mostly exempt, as are projects that include a "high" amount of affordable housing. The City will determine what that percentage will be. The City is developing a VMT program which includes a VMT mitigation fee that would pay for active transportation capital improvements which reduce vehicle miles traveled. | | | | :--- | :--- | | **Responsibility** | Planning & Development Department | | **Funding Source** | General Fund | | **Timeframe** | Establish an affordable housing threshold by 2026

Establish VMT Mitigation Fee by 2026 | | **Objective** | Reduce costs and application processing times associated with VMT analysis for new developments that include affordable housing and support improvements for active transportation infrastructure | SECTION 1E-1: ACTION PLAN # Goal 7: Prevent Displacement and Homelessness ## Program 32 – Opportunity to Purchase Act The City shall research best practices related to Right of First Refusal and Opportunity to Purchase Act (OPA) programs in California, and based on the findings of the research, consider establishing an OPA ordinance or similar policy that would give tenants and qualifying non-profits priority to purchase a building that has entered pre-receivership with the Anti-Slum Enforcement Team (ASET) Division. The City shall seek public input, coordinate with non-profits, and collaborate with the California Apartment Association (CAA) and Community Based Organizations (CBOs) that work closely with low-income communities in racially and ethnically concentrated areas, on the potential adoption of an OPA ordinance, including targeted outreach to stakeholders such as Central California Legal Services (CCLS) and organizations representing lower-income households and special needs groups. | Responsibility | Planning & Development Department, CBOs, and CAA | | :--- | :--- | | **Funding Source** | Private funding | | **Timeframe** | Work with CBOs and CAA to collaborate on review of OPA programs and policies throughout 2025.

Provide recommendations to the City in the form of a report by the end of 2026. | | **Objective** | Allow qualifying tenants and local non-profits the opportunity to purchase existing buildings to be used and/or maintained for affordable housing, with 30 percent of purchases targeting relatively higher resource and income areas including RCAAs.

Upon OPA Ordinance adoption, provide opportunity to purchase for 10% of buildings that enter pre-receivership. | ## Program 33 – Mobile Home Parks The City shall maintain the responsibility for enforcement of the California Mobilehome Parks Act at all mobile home parks located within the city limits. Almost 4,000 mobile home units exist in Fresno in 27 mobile home parks. Mobile home parks represent one of the few remaining sources of unsubsidized affordable housing in the city, and they also provide opportunities for homeownership to individuals and households who might not be able to afford other housing purchase options. As real estate prices rise, mobile home park owners may seek to close parks so that the land can be sold and converted to other uses. Deferred maintenance of a mobile home park can lead to substandard conditions that can also eventually lead to park closures. In an effort to preserve the city’s mobile home parks, the City shall implement the following: * Enforce the California Mobilehome Parks Act throughout the City. APPENDIX 1E: CITY OF FRESNO * Evaluate the effectiveness of the existing Mobilehome Park Rent Review & Stabilization Ordinance and engage residents and commissioners in consideration of policy changes, including the rent review process. * Establish regulations to protect affordable housing on property currently occupied by mobile home parks. If the property is proposed for conversion from a mobile home park, it will be required to redevelop with a number of covenanted affordable units equal to the number of mobile home units lost in the conversion, or 10 percent of new units, whichever is higher. If the underlying zone district does not allow for housing, the City shall require the project proponent of a non-residential project to find a replacement site in an area where housing is an allowed use, and provide relocation benefits to any mobile home park residents displaced by the proposed project. * Continue to support the Mobile Home Rent Review & Stabilization Commission which serves the purpose of protecting mobile home park residents from excessive rent increases. * Provide reactive and proactive inspections of the conditions of mobile home parks. Hold meetings at mobile home parks to explain the enforcement process. * Provide annual notification to park owners about rent increase applications. * Maintain a list and map of mobile home parks in Fresno. * Compile a list of resources and provide technical assistance to mobile home residents and park owners to facilitate the maintenance and preservation of mobile home parks. Provide relevant information to interested mobile home park residents, owners, and non-profit organizations. * Make funding available for home repairs, including weatherization, to owner-occupied mobile homes of low-income homeowners. * Promote available housing rehabilitation and weatherization resources on the City’s website, at public counters, and in libraries. Provide relevant information to interested mobile home park residents, owners, and non-profit organizations. Offer assistance to homeowners in a variety of languages representative of Fresno including, but not limited to, Spanish, Hmong, and Punjabi. * Conduct targeted outreach to inform park owners, mobile home owners, and other eligible applicants of rehabilitation assistance in local mobile home parks through the Mobile Home Park Repair Program, and the State’s Manufactured Housing Opportunity & Revitalization Program (MORE). * Provide assistance with funding applications to mobile home park owners, residents, and non-profit organizations to assist in mobile home park preservation and improvement. * Work with HCD to approve using PLHA funds to establish a mobile home repair program to provide critical repairs to owner-occupied mobile homes, including weatherization and improvements for indoor air quality. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-1-45 SECTION 1E-1: ACTION PLAN | | | | :--- | :--- | | **Responsibility** | City Attorney’s Office, Code Enforcement Division; Planning & Development Department | | **Funding Source** | General Fund; Permanent Local Housing Allocation (PLHA) | | **Timeframe** | Work with HCD to approve use of PLHA funds for a mobile home repair program in 2024.

Compile a list of mobile home preservation experts and non-profits by the end of 2024 and maintain existing list of mobile home parks annually.

Compile and distribute a list of financial resources for residents and park owners for maintenance and preservation biennially starting in 2025.Conduct biennial outreach to and engagement with mobile home park residents, park owners, preservation experts, and non-profit organizations interested in preservation of mobile home units, starting in 2025. Begin outreach one month before every informative workshop by notifying community benefit organizations and posting on social media.

Annually, report on the number of homeowners assisted, the type and volume outreach including meeting locations, number of proactive maintenance inspections conducted, and number of rent increases evaluated. | | **Objective** | Preserve mobile homes as opportunities for homeownership to individuals and households who might not be able to afford other housing purchase options through code enforcement, funding opportunities, prevention of excessive rent increases, and resident engagement.

Conduct proactive maintenance inspections of 13% of mobile home parks annually, exceeding the 5 percent required by HSC §18400.1.

Conduct outreach meetings at 13 percent of mobile home parks annually.

As rent increases are proposed, protect mobile home park residents from excessive rent increases.

Connect a minimum of 58 lower-income families with rehabilitation, home repair, and weatherization grant assistance to preserve affordable ownership housing. | APPENDIX 1E: CITY OF FRESNO ### Program 34 – Eviction Protection Program The City shall continue to seek funding for the Eviction Protection Program to fight potentially unlawful evictions in accordance with the California Tenant Protection Act. The Eviction Protection Program (EPP) defends tenants renting an apartment or house in the city of Fresno from unlawful eviction in support of enforcement of the California Tenant Protection Act. If the City determines a tenant is potentially facing unlawful eviction, the tenant may be eligible to receive a City-appointed attorney or legal services to assist in the judicial process at no charge. This program is open to any city of Fresno resident who is facing an unlawful eviction regardless of financial or documented status. Common reasons for unlawful evictions include retaliation for reporting code enforcement violations, discrimination, unlawful rent increases, and many more. | | | | :--- | :--- | | **Responsibility** | City Attorney; Finance Department, Local Housing Trust Fund– Grants Management Unit | | **Funding Source** | General Fund; US Treasury and CA Department of Housing and Community Development (ARPA), HUD Eviction Protection Grant Program | | **Timeframe** | Funding will be expended by the end of fiscal year 2025. The City will seek additional funding to support the Eviction Protection Program, an original element of the Emergency Rental Assistance Program. Marketing and outreach shall occur on an ongoing basis as funds are available. | | **Objective** | Assist 500 tenants annually with eviction defense ranging from legal advice through representation in court. | ### Program 35 – Replacement Units To reduce displacement risk, the City will require replacement housing units subject to the requirements of California Government Code Sections 65915 and Housing Crisis Act (66300 et. seq.) on sites identified in the sites inventory or other areas as appropriate when any new development (residential, mixed-use, or nonresidential) occurs on a site that has been occupied by or restricted for the use of lower-income households at any time during the previous five years. This requirement applies to non-vacant sites and vacant sites with previous residential uses that have been vacated or demolished. | | | | :--- | :--- | | **Responsibility** | Planning & Development Department | | **Funding Source** | General Fund; Developer Fees | | **Timeframe** | Ongoing, the replacement requirement will be implemented immediately and applied as applications on identified sites are received and processed.

Administrative processes and project application forms will be updated to reflect Housing Crisis Act requirements by June 2025. | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-1-47 SECTION 1E-1: ACTION PLAN | | | | :--- | :--- | | **Objective** | Prevent displacement and enforce the provision of replacement housing units subject to the requirements of California Government Code Section 65915 and Housing Crisis Act (66300 et. seq.). | **Program 36 – Homeless Assistance** The City is committed to addressing homelessness and is working on a variety of actions in collaboration with service agencies and providers to provide shelter, housing, and case management services to those in need. The City will apply or support applications for funding for emergency shelters, transitional or supportive housing. The City will continue to use Emergency Solutions Grant (ESG) Program funds to support needed social services and review applications annually. The City is also utilizing the HOME Investment Partnerships (HOME) Program and is contracted with Fresno Housing to implement a tenant-based rental assistance program for persons that are homeless, threatened with homelessness, or in need of housing assistance after completing a transitional living program. The City will take the following actions to provide assistance and resources to those experiencing unsheltered homelessness: * Cooperate with neighboring cities, the County, and other agencies in completing the Point-in-Time count every other year. Reach out to local colleges and universities and local and regional homeless service providers by July 2024 to identify partnership opportunities to conduct Point-in-Time counts. * Establish a pilot program funded by Encampment Resolution Funding (ERF) to resolve the experience of unsheltered homelessness for people residing in encampments in the Downtown and Southern Blackstone Corridor areas (see Figure 1E-3.33 in Chapter 3) by establishing a Rapid Rehousing and Case Management Program for 100 persons for up to 24 months at certified Independent Living Homes (ILH) throughout the City. * Provide available funding for emergency shelter types to accommodate the unhoused, including shelter for victims of domestic violence, facilities for LGBTQ+ community members, and facilities that serve families and households with dependent minors which may include but are not limited to pregnant parents, parenting youth, households engaged in reunification and/or child welfare services in need of funding to render said services with the goal of supporting a minimum of 500 shelter beds. * Establish a reserve fund for operations, support services, maintenance, and repair for various types of shelters and activities (e.g., case management provided at shelters and triage centers, including sleeping cabins, and Project Homekey-funded shelters/triage centers). * Support the temporary transition of former motels into emergency shelter and permanent supportive housing through private partnerships and the use of Low-Income Housing Tax Credits (LIHTC). * Leverage the Homeless Assistance Response Team (H.A.R.T.) to provide direct services, street outreach, and case management services, including outreach to link unhoused residents with mental health and substance treatment services. APPENDIX 1E: CITY OF FRESNO * Support the Voucher Incentive Program (established in 2023) which recruits landlords to house families experiencing homelessness or who are at risk of homelessness. The Voucher Incentive Program provides financial compensation to landlords that, for the first time, rent units to Housing Choice Voucher holders who otherwise would not be able to identify a leasable unit. * Work with local service providers to explore the feasibility of a safe parking program which would designate parking lots for people living out of their vehicles to safely stay overnight and provide services to help navigate them toward permanent housing. * Provide mobile showers and restrooms for unhoused individuals through the Homeless Services Division. * Provide crisis intervention training to City staff that work with the unhoused community. * Assess how many youth are at risk of homelessness (couch surfing, aging out of foster care) and partner with local school districts and colleges to develop targeted strategies to address the needs of at risk youth. The City has committed to the following 7 principles, developed by the United States Interagency Council on Homelessness, for developing and implementing responses to encampments: * Principle 1: Establish a Cross-Agency, Multi-Sector Response. * Principle 2: Engage Encampment Residents to Develop Solutions. * Principle 3: Conduct Comprehensive and Coordinated Outreach. * Principle 4: Address Basic Needs and Provide Storage. * Principle 5: Ensure Access to Shelter or Housing Options. * Principle 6: Develop Pathways to Permanent Housing and Supports. * Principle 7: Create a Plan for What Will Happen to Encampment Sites After Closure. | Responsibility | Planning & Development Department | | :--- | :--- | | **Funding Source** | HUD Funds - ESG, HOME,
State Funds - Project Homekey, Homeless Housing Assistance Prevention (HHAP) | | **Timeframe** | Identify partnership opportunities to conduct Point-in-Time counts and surveys by December 2024.
Annual implementation as part of the Emergency Shelter Grant and Continuum of Care funding process and complete annual reporting for HUD entitlement funds throughout the planning period. | SECTION 1E-1: ACTION PLAN | | | | :--- | :--- | | **Objective** | Invest in various housing and emergency shelter types to serve people experiencing homelessness with the goal of sustaining an inventory of at least 500 shelter beds and creating 400 new units of permanent supportive housing. Target investments in areas where the homeless population can more easily access services and public transportation in the central core of the city, including Downtown and along commercial corridors such as Blackstone Avenue. | **Program 37 – At-Risk Housing** The City will continue to undertake the following activities during the Housing Element planning period to guard against the loss of covenanted affordable housing units available to lower-income households. The efforts listed below represent a varied strategy to mitigate potential loss of at-risk units due to conversion to market-rate units. These local efforts use existing City and local resources and include efforts to secure additional resources from the public and private sector should they become available. * Contact property owners of units at risk of converting to market-rate housing within three years of affordability expiration to discuss the opportunity to preserve complexes as affordable housing. * Provide ongoing preservation technical assistance and education to affected tenants and the community at-large on the need to preserve the existing affordable housing stock. * Monitor covenanted affordable housing projects reaching the end of their covenant timeframes on an ongoing basis, at least annually, in coordination with other public and private entities to determine their interest in selling, prepaying, terminating, or continuing participation in a subsidy program. * Monitor at-risk projects through the use of existing databases (e.g., HUD, State HCD and California Tax Credit Allocation Committee). * Respond to any federal and/or state notices, including Notice of Intent to Pre-Pay, owner Plans of Action, or Opt-Out Notices filed on local projects, by contacting property owners upon receipt of notices. * Work with Fresno Housing to determine the availability of tenant-based vouchers for tenants who choose to move from at-risk units or are displaced by conversion. * Establish contact with public and non-profit agencies interested in purchasing and/or managing units at-risk to inform them of the status of such projects. Where feasible, provide technical assistance and support to these organizations with respect to financing. The City will actively pursue affordable housing opportunities and maintain a list of interested and qualified affordable housing developers. APPENDIX 1E: CITY OF FRESNO In the event at-risk units are not preserved, the City shall require projects that received government funding and/or were granted a density bonus to comply with the required noticing procedures under state law, including providing at least three years notice prior to the conversion of any deed-restricted affordable rental units to market rate and providing additional notice at 12 and 6 months. The City shall also minimize displacement of current tenants by negotiating an anti-displacement policy or relocation mitigation with the owner, whenever possible, and providing support and education to tenants at least 6 months prior to conversion. | Responsibility | Planning & Development Department; affordable housing developers | | :--- | :--- | | **Funding Source** | HOME Program funds, LIHTC, Cap & Trade, other available funding sources | | **Timeframe** | The City will monitor, every six months, the status of any HUD receipt/approval of Notices of Intent and Plans of Action filed by property owners to convert to market-rate units. The City will annually explore funding sources available to purchase affordability covenants on at-risk projects, transfer ownership of at-risk projects to public or non-profit agencies, purchase existing buildings to replace at-risk units, or construct replacement units. When covenants are expiring, contact property owners to gauge interest in continuing project affordability and pursue funding and preservation strategy on a project basis. Upon receipt of opt-out notices, the City will work with tenants of at-risk units and provide them with education regarding tenant rights and conversion procedures. | | **Objective** | Preserve 313 at-risk units from converting to market rate housing. *(Planning Period 2021-2031)* | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-1-51 SECTION 1E-1: ACTION PLAN # QUANTIFIED OBJECTIVES Table 1E-1.1 summarizes the City's quantified objectives for the 2023-2031 planning period by income group. Table 1E-1.1: Summary of Quantified Objectives, 2023-2031 | Program Types | Extremely Low-Income | Very Low-Income | Low-Income | Moderate-Income | Above Moderate-Income | Total | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | **New Construction** | | | | | | | | 2023-2031 RHNA | 4,720 | 4,720 | 5,884 | 5,638 | 15,904 | 36,866 | | **Rehabilitation** | | | | | | | | Housing Rehabilitation (Program 22) | 20 | 20 | 80 | | | 120 | | **Conservation/Preservation** | | | | | | | | Homebuyer Assistance (Program 19) | | | 20 | 20 | | 40 | | Housing Choice Vouchers (Program 20) | 60 | 65 | 125 | | | 250 | | Homeless Assistance (Program 37) | 500 | 400 | | | | 900 | | At-Risk Housing (Program 38) | | | 313 | | | 313 | Source: City of Fresno, 2024. APPENDIX 1E: CITY OF FRESNO # SECTION 1E-2: SITES INVENTORY ## Introduction Government Code Section 65583(a) requires local governments to prepare an inventory of land suitable for residential development, including vacant sites and sites having the potential for redevelopment. The inventory of land suitable for residential development shall be used to identify sites that can be developed for housing within the planning period. Government Code Section 65583(a) also requires an analysis of the relationship between zoning and public facilities and services to those sites. ## Regional Housing Needs Allocation California General Plan law requires each city and county to have land zoned to accommodate its fair share of the regional housing need. HCD allocates a numeric regional housing goal to the Fresno Council of Governments (FCOG). FCOG is then mandated to distribute the numerical goal among the 15 cities in the region and the County. This share for the FCOG region is known as the Regional Housing Needs Allocation (RHNA). The major goal of the RHNA process is to ensure a fair distribution of new housing construction among cities in the region and the County so that every community may plan for a mix of housing types for all economic segments. The housing allocation targets are not building requirements; rather, they are planning goals for each community to accommodate through appropriate planning policies and land use regulations. Allocation targets are intended to ensure that adequate sites and zoning are made available to address anticipated housing demand during the Housing Element planning period. The RHNA for the FCOG region covers an 8.5-year projection period (June 30, 2023, to December 31, 2031)[^p67-1] and is divided into four income categories: very low, low, moderate, and above moderate. As determined by FCOG, the City of Fresno’s allocation is a total of 36,866 new housing units, divided among the four income categories as shown in Table 1E-2.1. ### Table 1E-2.1: Regional Housing Needs Allocation (June 30, 2023, to December 31, 2031) | | Very Low Income (<50% of AMI) | Low Income (50% to 80% of AMI) | Moderate-Income (80% to 120% of AMI) | Above Moderate-Income (>120% of AMI) | Total | | :--- | :--- | :--- | :--- | :--- | :--- | | Housing Units | 9,440[^p67-1] | 5,884 | 5,638 | 15,904 | 36,866 | *AMI = Area Median Income* [^p67-1] *Extremely low-income allocation is equal to 50 percent of very-low income allocation (4,720 units).* *Source: FCOG Sixth Cycle RHNA Final Methodology, July 2022.* State law also requires the City to identify the projected need for extremely low-income housing. The City assumes that 50 percent of the very low-income housing need is equal to the extremely low-income housing need. As such, there is a projected need for 4,720 extremely low-income housing units. [^p67-1]: The Housing Element planning period differs slightly from the RHNA projection period. The Housing Element covers the planning period of December 31, 2023, through December 31, 2031. SECTION 1E-2: SITES INVENTORY # Approved Residential Projects Jurisdictions may count toward the RHNA any housing units in residential development projects that are approved but have not yet been issued building permits or were issued permits after the start of the RHNA projection period (June 30, 2023). Table 1E-2.3 includes approved residential development projects that are credited toward the RHNA. Only deed-restricted affordable units are counted toward the lower-income RHNA. Market rate multi-family rental units are counted as 50 percent moderate- and 50 percent above moderate-income based on market rents of recently built multifamily housing, which tends to be affordable to moderate income households (see Table 1E.2.2 and associated analysis below). Where projects are described as luxury duplexes or gated communities, the units are all counted as above moderate-income rather than the 50/50 split. Market rate rental or ownership townhomes and other ownership housing is counted as above moderate-income housing. The Housing Element includes an implementation program to monitor the affordability of projects as they come to fruition to ensure that these assumptions remain valid. The City will adjust affordability assumptions in the inventory if rent and sale prices differ. If the adjustment of affordability assumptions results in a deficit in capacity to meet the RHNA, the City will take action to identify capacity to meet a shortfall in accordance with “no-net-loss” zoning requirements in Government Code Section 65863. Approved residential projects also include single family residential subdivisions that are under construction. Table 1E-2.4 lists these subdivisions with the number of unbuilt lots counted toward the RHNA. These single-family lots are counted as above moderate-income housing. In total, there are 2,757 units in approved developments counted toward the RHNA. This includes 152 extremely low-, 140 very low-, and 317 low-income deed-restricted affordable units. It also includes 1,041 market rate apartment units inventoried as moderate-income and 1,107 above-moderate-income units. These approved residential developments and subdivisions are shown on Figure 1E-2.7. # Affordability of Market Rate Multi-family Based on a review of rental listings at recently built apartments, it was determined that new market-rate apartments in Fresno are generally affordable to moderate-income households. Table 1E-2.2 below compares affordable monthly rents for moderate-income households earning 100 percent and 120 percent of the area median income (AMI) with 2024 listed rents for recently built market-rate complexes in the city. One-bedroom units are generally affordable to one- and two-person moderate income households earning 120 percent AMI. Two- and three-bedroom units are generally affordable to 2- and 3- person moderate-income households earning around 120 percent AMI. Three apartment complexes, Avalon Apartments, The Orchards Apartments at New Fig Garden, and The Villas at Fancher Creek, offer 1-bedroom units that are within reach for 2-person moderate income households earning between 100 percent and 120 percent AMI. The Villas at Fancher Creek also offer 1-bedroom, 2-bedroom, and 3-bedroom units that are within reach for moderate income households earning 100 percent AMI. Only a couple of the recent developments have listed rents that slightly exceed the affordable monthly rents for moderate-income households. Based on this analysis, market rate multifamily housing in the pipeline projects (Table 1E-2.3) are assumed to be 50 percent moderate-income and 50 percent above moderate-income. Table 1E-2.2: Analysis of Market-Rate Rental Affordability | Income Level (2023) | Affordable Monthly Rent[^p69-1] | | | | | :--- | :--- | :--- | :--- | :--- | | | 1-Person | 2-Person | 3-Person | 4-Person | | Moderate Income at 100% AMI | $1,466 | $1,676 | $1,885 | $2,095 | | Moderate Income at 120% AMI | $1,760 | $2,011 | $2,263 | $2,514 | | **Apartment Complex (Year Built)** | **1-bedroom** | **2-bedroom** | **3-bedroom** | | | 525 San Jose Apartments (2020) | | $1,850 | $1,950-$2,095 | $2,350 | | Avalon Apartments (2022) | | $1,595 - $1,665 | $1,950 - $2,040 | $2,225 - $2245 | | B Street Apartments (2022) | | N/A | $1,650.00 | $1,850.00 | | Brookside Villas (2019) | | $1,745.00 | $1,925 - $2,000 | N/A | | Casa di Fortuna Luxury Townhomes (leased) (2022) | | N/A | $1,995 - $2,150 | $2,395.00 | | Coronado Luxury Apartments (2023) | | $1950-$2050 | $2,020-$2,600 | $2,375 | | Drew Court (2019) | | N/A | $2,090 - $2,100 | N/A | | The Orchards Apartments at New Fig Garden (2022) | | $1,595-$1,645 | $1,850-$1,895 | $1,995-$2,195 | | Rock Ranch Apartments (2021) | | $1,882 - $1,964 | $1,945 - $2,090 | $2,371.00 | | Tempranillo Apartment Homes (2019) | | $1,975.00 | $2,163.00 | $2,369.00 | | The District (condominiums) (2022) | | $1,690.00 | N/A | N/A | | The Lark at Copper River (2020) | | $2,056 - $2,136 | $2,067 - $2,759 | $2,607 - $3,157 | | The Rousseau Luxury Apartments (2023) | | $1,850.00 | $1,995 - $2,100 | $2,290 - $2,400 | | The Row (2019) | | $2,056 - $2,137 | $2,200 - $2,725 | $2,508 - $2,736 | | The Villas on Fancher Creek (2023) | | $1,175 - $1,295 | $1,175 - $1,525 | $1,395 - $2475 | | Vintage Park (2018) | | $1,725 - $1,805 | $1,975 - $2,005 | $2,275 - $2,355 | AMI = Area Median Income [^p69-1]: Affordable monthly rents based on 2023 HCD Income Limits. Sources: City of Fresno and Ascent, April 2024. https://rentgranville.com/estate_property/525-san-jose/; https://www.avalonfresno.com/floorplans; www.bstreetapts.com; https://rentgranville.com/estate_property/brookside-villas/; www.cdfhomes.com; https://www.coronadofresno.com/floorplans; www.drewcourt.com; https://www.theorchardshomes.com/; www.rockranchapts.com; www.liveattempranillo.com; www.rentgranville.com/estate_property/the-district/; www.liveatthelark.com/the-lark-at-copper-river-fresno-ca/; www.rousseauapts.com; www.therowresidences.com; www.affordablehousing.com/fresno-ca/the-villas-on-fancher-creek-578211/; www.vintageparkfresno.com SECTION 1E-2: SITES INVENTORY This page intentionally left blank. APPENDIX 1E: CITY OF FRESNO Table 1E-2.3: Planned or Approved Projects, City of Fresno, February 2024 | ID | Project Name | APN(s) | Census Tract | Address | Tracking ID | Project Status | Units by Income Level | Total Units | Project Description | Phasing, Anticipated Build-out, and Known Barriers to Development | Projected Rents for Market Rate Projects | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | | | | | | ELI | VLI | LI | M | AM | | | | | | | P-1 | Village at West Creek North | 47906013 | 9.01 | 571 E Jensen Ave | P23-04115 | This project was approved and receive entitlement on December 22, 2023. | 64 | 13 | 43 | 0 | 1 | 121 | Development of 121 affordable rental housing units as Phase 1 of the West Creek Village master planned community by Self Help Enterprises. Funded by LIHTC, NTHF, HOME, and CA Housing Accelerator with 55-year Declaration of Restrictions. It is a mixture of two and three-story buildings with 38 one-bedroom units, 51 two-bedroom units, and 32 three-bedroom units. Residential Multi-family, Medium High Density (RM-1) Zone District at 25 dwelling units/acre. | 3 phases – expect to start phase 1 by January 2025 but challenge is getting funded because it’s oversubscribed. | Will be dictated by funding source but in phase one 30 units will be for very low income. | | P-2 | Step Up on 99 | 44923201 | 20 | 1240 N Crystal Ave 102 | P21-02291, B23-05208, B23-05213, and B23-07481 | This project was entitled in June 2021 and submitted for building permits in May 2023. Building permits were issued (at risk) on June 30, 2023. Construction is underway as of February 2024. | 21 | 28 | 13 | 0 | 1 | 63 | Hotel conversion to deed-restricted affordable units and one manager’s unit and construction of one new building on APN 44923201. Fresno Housing Authority. Homekey and LIHTC funded FHA project; 21 units at 30% AMI, 8 units at 40% AMI, 20 units at 50% AMI, and 13 units at 60% AMI, and 1 manager’s unit at market rate. Neighborhood Mixed Use (NMX) Zone District at 29 dwelling units/acre. | Phasing: 1) demolition of current lobby/on-site manager building; 2) adaptive reuse of existing motel rooms; 3) additional landscaping and outdoor community spaces. Anticipated completion by Dec 2024. | N/A | | P-3 | 44923202 | | | | | | | | | | | | | | | | | | Peach-Tulare Apartments | 46309011 | 29.03 | N/A | P19-06061 | This project was approved and received entitlements on August 28, 2020 and June 6, 2021. Entitlements extended through August 27, 2025. | 0 | 0 | 0 | 65 | 64 | 129 | 129 units of market rate rental two- and three-bedroom apartment units. House demolished on APN 46309057 under demolition permit B21-04991. Residential Multi-family, Urban Neighborhood (RM-2) Zone District at 30 dwelling units/acre. | Unknown | Unknown | | | 46309028 | | | | | | | | | | | | | | | | | | | 46309057 | | | | | | | | | | | | | | | | | | | 46309059 | | | | | | | | | | | | | | | | | | P-4 | Maple Luxury Living Duplexes | 47130228 | 13.04 | 2056 S Maple Ave | P20-01643 B21-02221 to B21-02232 | This project was approved and received entitlements on 10/29/2021. The entitlement will expire on 10/21/2024 unless it receives an extension. Submitted for building permits on 3/17/2021 but building permits have not yet been pulled. | 0 | 0 | 0 | 0 | 23 | 23 | 23 units of luxury market rate duplexes. Residential Single-family, Medium Density (RS-5) Zone District at 12 dwelling units/acre. | Barriers identified by applicant: price of lumber and interest rates | Unknown | | P-5 | Jensen-Maple Mix of uses on one parcel (RM-3, CC, and IL) | 48003060 | 12.02 | 4645 E Jensen Ave | P20-00636, P24-01220, P24-01186, AD23-03130, BG23-00006 | This project was approved and received entitlements on March 5, 2021. Site grading and utility improvements are underway but building permits have not yet been issued. | 0 | 0 | 0 | 75 | 75 | 150 | Mixed-use commercial, light industrial, and 150 market rate multi-family. Four-story rental residential units and a day care center. Rental studio, one-, and two-bedroom apartment units. Residential Multi-family, High Density (RM-3) Zone District at 13 dwelling units/acre (43 du/acre for RM-3 part of the parcel). Approximately 31,000 sq ft of commercial proposed on Community Commercial (CC) and Light Industrial (IL) zoned part of the parcel. | Unknown | Unknown | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-2-5 SECTION 1E-2: SITES INVENTORY | ID | Project Name | APN(s) | Census Tract | Address | Tracking ID | Project Status | Units by Income Level | Total Units | Project Description | Phasing, Anticipated Build-out, and Known Barriers to Development | Projected Rents for Market Rate Projects | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | | | | | | ELI | VLI | LI | M | AM | | | | | | | P-6 | The Park | 46828205T

468282022T

468282023T | 1 | 829 Fulton St | P21-04764 | This project was approved and received entitlements on December 27, 2021. | 0 | 0 | 0 | 81 | 80 | 161 | Mixed-use with ground floor commercial and five floors of 161 rental one-bedroom apartment units. Downtown Core (DTC) Zone District at 206 dwelling units/acre. Parcels 4688205t and 22T are owned by the Redevelopment Agency of Fresno and APN 468282023T is a City-owned parking lot | Unknown | Unknown | | P-7 | Villa Di Abaldo | 40353228 | 1 | 8715 N Chestnut Ave | P21-06232, P23-01723 | This project was approved and received entitlements on May 11, 2023. | 0 | 0 | 0 | 16 | 16 | 32 | 32 unit multi-family apartment complex with two-bedroom apartment units. House demolished under demolition permit B22-00480. Residential Multi-family, Medium High Density (RM-1) Zone District at 15 dwelling units/acre. | Unknown | Unknown | | P-8 | The Palms at Alluvial | 40450029 | 55.08 | 2806 E Alluvial Ave | P2200795, B22-18089, B22-18926 to B22-189239 | This project was approved and received entitlements on December 2, 2022. Building permits were issued on September 26, 2023. Construction is underway as of February 2024. | 0 | 0 | 0 | 0 | 28 | 28 | Gated duplex community - 13 duplexes with two- and three-bedroom units and 2 single family residential detached units (T-6402), Residential Single-family, Medium Density (RS-5) Zone District at 10 dwelling units/acre. | Anticipated completion in Fall 2024 | Not sure of rents, but will be market rate – will depend on construction costs and more | | P-9 | Bath Apartments | 46202009 | 55.09 | 255 N Clovis Ave | P20-04549, B23-11359, B23-11808 to B23-11812, P22-03017 | This project was submitted for entitlement review on March 5, 2021, and approved on August 8, 2022. Then the project was submitted for building permit review on July 31, 2023. | 0 | 0 | 0 | 54 | 54 | 108 | 108 market rate rental one-, two- and three-bedroom apartment units in 6 apartment buildings. Commercial Mixed Use (CMX) Zone District at 22 dwelling units/acre. | Barrier: owner is delayed in taking the next steps. | Unknown | | P-10 | DADA Lofts | 46620528 | 30.04 | 1433 Broadway | P21-05557, B22-19096, B22-18971, P22-04143, P22-03142 | This project was approved for entitlement on August 16, 2022 and an appeal request was made on October 24, 2022. The appeal was denied on October 5, 2023, and the project was entitled on October 31, 2023. The two buildings (Front and Rear) were submitted for building permits review on December 28 and 29, 2022 respectively and as of February 2024, the application is still being processed. | 0 | 0 | 0 | 19 | 18 | 37 | Downtown apartment units with 31 studio flats, 3 lofts, and 3 two-story townhome rental units in two buildings. Downtown Core (DTC) Zone District at 82 dwelling units/acre. | No completion date set yet because more funding is needed. Barriers identified by applicant: construction costs are high; bank did not appraise high enough; grants sometimes trigger prevailing wage which can actually increase the funding gap. | No projected rents yet, but want a mix with affordable | | ID | Project Name | APN(s) | Census Tract | Address | Tracking ID | Project Status | Units by Income Level | Total Units | Project Description | Phasing, Anticipated Build-out, and Known Barriers to Development | Projected Rents for Market Rate Projects | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | | | | | | **ELI** | **VLI** | **LI** | **M** | **AM** | | | | | | | P-11 | Kings Canyon-Backer Mixed-Use | 47008103 47008104 47008105 | 13.01 | 4648 E Kings Canyon Rd | P21-05694, AD23-05726, AD23-04481, B22-18546, P22-02542, P21-05694 | This project was approved and received entitlements on July 1, 2022. Phase 1 Office building is under construction but building permit application for Phase 2 has not yet been submitted. | 0 | 0 | 0 | 12 | 12 | 24 | Phase 2 Mixed-use retail/commercial and multi-family. Mixed-use with commercial/retail and 4 rental apartment units on the ground floor and 20 rental apartment units on three floors above. Commercial Mixed Use (CMX) Zone District at 38 dwelling units/acre. | Unknown | Unknown | | P-12 | Mander Villa Apartment Complex | 50504018 | 42.18 | 7018 W Barstow Ave | P21-04839 | This project was submitted for entitlement on September 2, 2021, and approved on April 17, 2023. | 0 | 0 | 0 | 16 | 16 | 32 | 32 market rate rental two-bedroom apartment units | Estimated construction in 2026. | Unknown | | P-13 | Fresno Rescue Mission - RTC 2 | 44209058T | 20 | 2341 N Parkway Dr | P23-03411 | This project was approved and receive entitlement on November 3, 2023 | 0 | 0 | 49 | 0 | 0 | 49 | This Rescue the Children facility by Fresno Mission is a phased community of 49 multi-family factory-built modular homes to offer supportive affordable housing for graduates of the Rescue the Children programs and other displaced low-income individuals. Phase 1 is land, site and infrastructure development, Phase 2 is the installation of 20 modular homes, and Phase 3 is the installation of 39 modular homes and a community center. The homes vary in size from 288 square feet to 912 square feet fabricated in one, two or three unit sections and some stacked in two-floor configuration. Upon building permits being issued, it will take approximately six months for Phase 1 infrastructure to prepare the site and another six months for the completion of Phase 2. Phase 3 installation will be completed upon the funding availability for them or within one year after the completion of Phases 1 & 2, whichever is first. This is an all residential project in a Neighborhood Mixed Use (NMX) Zone District at 37 dwelling units/acre. | No planned phasing No expected start date Barriers to development identified by applicant: having difficulties with affordable housing contracts with the City | N/A | | P-14 | One Fresno at Manchester Center Mall | 43718120 | 51 | 1901 E Shields Ave Building 101 | P23-00890 | This project was approved and entitled on August 4, 2023. | 0 | 0 | 0 | 305 | 305 | 610 | Conversion of existing commercial/office space to rental dwelling units within the Manchester Mall. The project is planned for construction in three (3) phases (unit counts approximate): Phase 1 includes 165 studios and 56 one-bedroom units, totaling 221 units; Phase 2 includes 63 studios and 15 one-bedroom units, totaling 78 units; Phase 3 includes 211 studios and 71 one-bedroom units, totaling 282 units. This is adding residential to an existing mall that currently has no residential and is zoned Commercial Regional (CR) Zone District at 22 dwelling units/acre. | Unknown | Unknown | SECTION 1E-2: SITES INVENTORY | ID | Project Name | APN(s) | Census Tract | Address | Tracking ID | Project Status | Units by Income Level | Total Units | Project Description | Phasing, Anticipated Build-out, and Known Barriers to Development | Projected Rents for Market Rate Projects | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | | | | | | ELI | VLI | LI | M | AM | | | | | | | P-15 | Latitudes at Armstrong | 31025013 | 58.05 | 2594 N Armstrong Ave | P22-02376 and B22-19031 to B22-19091, AD24-00894, AD24-02822 | This project was submitted for entitlement on June 20, 2022, and received approval on August 15, 2023. Applicant submitted construction drawings to City for building plan check review on December 23, 2022, and is making corrections in preparation to resubmit to City. | 0 | 0 | 0 | 32 | 32 | 64 | 64 market rate rental one-, two- and three-bedroom apartment units. Residential Multi-family, Medium High Density (RM-1) Zone District at 15 dwelling units/acre. | Under construction with anticipated completion of Fall 2025 | Unknown | | P-16 | Helm Tower Office and Lofts | 46621204 | 1 | 1105 Fulton St | P22-01922 | This project was submitted for entitlement on May 16, 2022, and approved for entitlement on January 8, 2024. | 0 | 0 | 0 | 50 | 49 | 99 | Conversion of an existing vacant 10-story retail building into mixed-use retail and 99 units of market rate multi-unit residential. Mixed-use with retail on ground floor and floors 2 through 10 converted into rental studio apartment units. Downtown Core (DTC) Zone District at 341 dwelling units/acre. | Unknown | Unknown | | P-17 | Green Valley Apartments | 47216201 | 14.07 | 717 S Adler Ave | P22-02697 | This project was submitted for entitlement review on July 15, 2022, and approved on April 12, 2023. | 0 | 0 | 0 | 4 | 4 | 8 | 8 units market rate multi-family rental three-bedroom apartment units. Commercial Mixed Use (CMX) Zone District at 31 dwelling units/acre. | Anticipate building permits may take 2 months, but no other issues at this time | Unknown | | P-18 | Ashlan Inn | 51010047S | 38.09 | 4278 W Ashlan Ave | P22-00797 and B22-12673 | This project was approved and entitled on August 15, 2022. Then received building permits on August 15, 2023, and construction is underway as of February 2024. | 0 | 0 | 0 | 62 | 63 | 125 | Hotel to dwelling unit conversion to 125 housing units. This is an all-residential project and the development will occur within one two-story building and all of the units are studios including 7 units that are accessible to persons with disabilities. Commercial General (CG) Zone District at 32 dwelling units/acre. | Unknown | Unknown | | P-19 | Majestic Palms Apartments | 51203108 | 42.18 | 4879 N Bryan Ave | P22-03852 B23-09554, B23-09692 to B23-09702, B23-10443, and B23-09554 | This project was submitted for entitlement review on October 4, 2022, and received approval on January 8, 2024. The project was submitted for building plan check review on August 7, 2023, and as of June 2024, is still under review. | 0 | 0 | 0 | 71 | 70 | 141 | 141 market rate rental one-, two- and three-bedroom apartment units and one manager’s unit. Regional Mixed Use (RMX) Zone District at 18 dwelling units/acre. | Completion: Summer 2026 Barriers identified by applicant: Accela more challenging than previous in-person processing | $2,000-$3,500 | | P-20 | Avalon Commons Buildings 1 thru 5 | 40407150T | 55.09 | 7521 N Chestnut Ave | P21-02506, B22-18206, B22-18342 to B22-18345 | This project was approved and entitled on June 25, 2022. Then received building permits on October 18, 2023, and construction is underway as of February 2024. | 0 | 34 | 25 | 46 | 0 | 105 | This is an affordable multi-family housing project by Fresno Housing utilizing LIHTC and NPLH funding and exercising an affordable density bonus to get a 33% increase in total allowable unit. This project includes twelve one- and two-story buildings with 105 total units and a unit breakdown of 16 one-bedroom, 53 two-bedroom, and 36 three-bedroom units. This project was entitled in June 2021 under application P21-02506 and 60 of the units are currently under construction. The other 45 units have not been submitted for building permit plan review yet. Residential Single-family, Medium Density (RS-5) Zone District at 15 dwelling units/acre. | Completion: Fall 2024 | 7521 N Chestnut Ave | APPENDIX 1E: CITY OF FRESNO | ID | Project Name | APN(s) | Census Tract | Address | Tracking ID | Project Status | Units by Income Level | Total Units | Project Description | Phasing, Anticipated Build-out, and Known Barriers to Development | Projected Rents for Market Rate Projects | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :---: | :---: | :---: | :---: | :---: | :---: | :---: | :---: | :--- | :--- | :--- | | | | | | | | | **ELI** | **VLI** | **LI** | **M** | **AM** | | | | | | P-21 | Parkside Inn | 44927056T | 20 | 1429 W Olive Ave | P22-04444 | This project was submitted for entitlement review on November 17, 2022, and approved on June 7, 2023. | 15 | 6 | 17 | 1 | 0 | 39 | Deed-restricted lower -income housing development by the Fresno Housing Authority. Hotel Conversion (27 units) and 12 new multi-family units. Specific levels of affordability are undetermined at the moment but will be affordable to lower-income. Rental studio, one-, two-, three-bedroom, and special needs apartment units and one manager's unit. Neighborhood Mixed Use (NMX) Zone District at 22 dwelling units/acre. | Completion: Spring 2026 Phase 1: 27 units, hope to start next spring Phase 2 16+units, hope to apply next year Barriers identified by applicant: Competitive funding; Accela more challenging than previous in-person processing | N/A | | P-22 | Self-Help Enterprises 6 SFRs | 47716201T | 9.02 | 2304 S Walnut Ave | P22-00670, B24-01581, B24-01583, B24-01584, B24-01586, B24-01590, and B24-01591 | This project was approved and received entitlements on July 8, 2022. Then submitted for building plan check review on February 8, 2024, and is still under review. | 0 | 0 | 6 | 0 | 0 | 6 | Custom affordable deed-restricted single family residential (6 units) by Self Help Enterprises. Deed-restricted at 50% to 80% AMI, HOME and PLHA 30-year Declaration of Restrictions. Residential Single-family, Medium Density (RS-5) Zone District at 8 dwelling units/acre. | No planned phasing Expected completion date mid Jan 2025 Barriers, coordination with utilities, and some problems with private owner | This property will not have rents, it will be homeownership | | P-23 | San Joaquin Hotel | 42504139 | 46.02 | 1309 W Shaw Ave | N/A | This project was submitted for entitlement review on December 20, 2022. | 0 | 59 | 0 | 0 | 0 | 59 | Hotel conversion to dwelling units (69 units total, 24 units for chronic homelessness and 35 for youth). Funded by Project Homekey. Phase 1 - 10 ground floor units have been entitled and completed. Remaining 59 units have not yet been completed. Commercial Mixed Use (CMX) Zone District at 40 dwelling units/acre. | Unknown | N/A | | P-24 | Self-Help Enterprises 11 SFRs | 47714530T 47714531T 47714532T 47714533T 47714542T 47714544T 47714545T | 9.02 | 84 E Geary St | P22-00671, B23-13767, B23-13774, B23-13775, B23-13777, B23-13779 to B23-13781, and B23-13783 to B23-13786 | This project was approved and received entitlements on June 20, 2022. Then submitted for building plan check review on September 7, 2023.. | 0 | 0 | 11 | 0 | 0 | 11 | Custom affordable deed-restricted single family residential (11 units) by Self Help Enterprises. Deed-restricted at 50% to 80% AMI, HOME and PLHA 30-year Declaration of Restrictions. Residential Single-family, Medium Density (RS-5) Zone District at 2.5 dwelling units/acre. | No phasing Expected completion date is Sept 2024 Barriers, coordination with utilities, and some problems with private owner | This property will not have rents, it will be homeownership | | P-25 | Audubon Park Apartments | 40257008 40257009 | 44.11 | 555 W Audubon Dr | P19-04137 | This project was approved and received entitlements on February 12, 2020. | 0 | 0 | 0 | 0 | 63 | 63 | Expansion of existing Audubon Park Apartments to add an additional 63 units of market rate rental studio, one-, two-bedroom apartment units with underground parking garage. Residential Multi-family, High Density (RM-3) Zone District at 19 dwelling units/acre. | Completion: Summer 2026 Barriers identified by applicant: Accela more challenging than previous in-person processing | $2,500-3,500; luxury multifamily, above moderate-income | | P-26 | Sarah's Court | 31310124 | 14.11 | 200 N Salma Ave | B22-09529 P21-00561 | This two-phase 240 affordable unit project was approved and received entitlements on August 30, 2022. Building Permits were issued on January 5, 2023, for 120 units under Phase 1 and construction is underway. The 120 units for Phase 2 have not been submitted for building permit plan check review. | 0 | 0 | 120 | 0 | 0 | 120 | Part of Fancher Creek Town Center. 240 multi-family deed-restricted affordable units, with Phase 1 (120 units being built by June 2024) and Phase 2 (120 units). Funded by LIHTC and HOME funds. Commercial Regional (CR) Zone District at 46 dwelling units/acre. | Phase 1 anticipated opening in Fall 2024 Phase 2: potential barrier is being able to receive LIHTC | N/A | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 | 1E-2-9 SECTION 1E-2: SITES INVENTORY | ID | Project Name | APN(s) | Census Tract | Address | Tracking ID | Project Status | Units by Income Level | Total Units | Project Description | Phasing, Anticipated Build-out, and Known Barriers to Development | Projected Rents for Market Rate Projects | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | | | | | | ELI | VLI | LI | M | AM | | | | | | | P-27 | Ambassador Hotel | 44923111 | 20 | 1804 W Olive Ave | B22-12938 | Under the Emergency Housing Program this project was not required to be entitled. This project did receive building permits on August 16, 2023, and completed construction on October 12, 2023. | 52 | 0 | 0 | 0 | 0 | 52 | Conversion of two-story hotel into 52 affordable housing units including 8 accessible to persons with disabilities. All the units are studios. The project is Homekey funded with a 55-year Declaration of Restrictions. Neighborhood Mixed Use (NMX) Zone District at 50 dwelling units/acre. | Project is completed and occupied | N/A | | P-28 | Willow Apartments | 40409046 and 40409047 | 55.09 | 7345 and 7355 N Willow Ave | B20-01446 to B20-01461 | This three-phase multi-family residential project was approved for entitlement on May 19, 2008. The first two phases of this project received building permits on August 3, 2023, and construction is underway. | 0 | 0 | 0 | 132 | 133 | 265 | This is a 265 unit multi-family residential apartment complex with 24 two-story apartment buildings consisting of a mix of one-, two-, and three-bedroom. The three-story community center includes one manager's unit. This is a three phase project and the 176 units currently under construction represent 16 buildings and a clubhouse in the first two phases. Phase 3 has not been issued building permits. Residential Multi-family, Medium High Density (RM-1) zoning at 16 du/acre. | Multiple phases with phase 1 under construction and estimated to be complete in 14 months; phase 2 estimated to be complete in about 3 years; third phase is unknown at this time. | Unknown | | P-29 | Heritage Estates | 47706004T | 9.02 | 123 -139 E Pitt Ave, 122 - 141 E Belgravia, 121 - 148 E Tower Ave, 2305 - 2389 S Modoc St | P23-02692 | All residential building templates were approved in May 2024. All 33 SFRs have been submitted for plan check in June 2024. All 33 SFRs have received at-risk foundation only permits in July 2024, which means they can begin laying underground utilities and concrete foundations prior to receiving building permits. | 0 | 0 | 33 | 0 | 0 | 33 | This is an affordable homeownership development project by Fresno Housing. The project will consist of 33 single family homes, with the first homes estimated to be available by August 2025. | Groundbreaking happened September 2024. | This property will not have rents, it will be homeownership | | **Total** | | | | | | | **152** | **140** | **317** | **1,041** | **1,107** | **2,757** | | | | | APN = Assessor's Parcel Number, N/A = Not Available, DU = Dwelling Units, ELI = Extremely-low Income, VLI = Very-low Income, LI = Low-income, M = Moderate-income, AM = Above-moderate Income Source: City of Fresno and Ascent, September 2024. APPENDIX 1E: CITY OF FRESNO ### Table 1E-2.4: Vacant Land with Final Subdivision Maps Under Construction, City of Fresno, June 2023 | Map Number | Recorded Year | Number of Single-Family Lots | Number of Permits Issued Prior to June 18, 2023 | Number of Unbuilt Single Family Lots Counted in 6th Cycle | Income Category | | :--- | :--- | :--- | :--- | :--- | :--- | | 5388 | 2023 | 42 | 16 | 26 | Above Moderate | | 6139 | 2017 | 102 | 92 | 10 | Above Moderate | | 6162 | 2021 | 83 | 26 | 57 | Above Moderate | | 6201 | 2022 | 97 | 0 | 97 | Above Moderate | | 6224 | 2021 | 349 | 86 | 263 | Above Moderate | | 6238 | 2023 | 47 | 34 | 13 | Above Moderate | | 6258 | 2021 | 98 | 87 | 11 | Above Moderate | | 6285 | 2021 | 181 | 165 | 16 | Above Moderate | | 6295 | 2021 | 110 | 71 | 39 | Above Moderate | | 6299 | 2023 | 218 | 56 | 162 | Above Moderate | | 6308 | 2023 | 209 | 34 | 175 | Above Moderate | | 6336 | 2022 | 72 | 26 | 46 | Above Moderate | | 6400 | 2023 | 72 | 20 | 52 | Above Moderate | | **Total** | | **1,680** | **713** | **967** | | Source: City of Fresno, June 2023. ## Sites Inventory State law requires that jurisdictions demonstrate in the Housing Element that the land inventory is adequate to accommodate that jurisdiction’s share of the region’s projected growth (RHNA). Fresno has many vacant residential development opportunities along with underutilized non-vacant sites with redevelopment potential with sufficient capacity to meet and exceed the identified housing need for 2023-2031. The detailed sites inventory is contained in Section 1E-7 (Detailed Sites Inventory Tables), Table 1E-7.1 and Table 1E-7.2. The opportunities shown in this inventory consist of vacant and non-vacant land in residential, mixed-use sites, and commercial districts that allow residential development. No identified constraints on these sites would prevent development or reuse during the Housing Element period. ## Methodology The following is a description of the methodology used to estimate housing unit capacity on vacant and non-vacant sites within Fresno and to classify sites by income level. SECTION 1E-2: SITES INVENTORY ## Income Assumptions Density can be a critical factor in the development of affordable lower-income housing. Higher density development can lower per-unit land cost and facilitate construction in an economy of scale. The following describes the assumptions used to determine the inventoried income categories and the realistic buildout capacity for each site. ## Lower-Income Sites State law (Government Code Section 65583.2(c)(3)) establishes a “default density standard” of 30 units per acre for Fresno, which is categorized as a metropolitan jurisdiction because the population exceeds 100,000. This is the density that is “deemed appropriate” in State law to accommodate the City’s lower-income RHNA. Most zoning districts in Fresno allow for this density; however, many of these zones use height to regulate the maximum building envelope rather than a residential density standard. To accelerate housing production in infill areas the City adopted amendments to remove maximum density limitations in the Mixed Use Districts, to modify the restriction that prohibits ground floor residential uses in mixed-use, and to allow ministerial approval of multi-family residential uses within the Priority Areas for Development. The City performed an analysis to determine the following maximum achievable densities under the height, setback, and other development standards for the mixed use zoning districts: * CMS (Commercial Main Street): 48 units per acre * CMX (Corridor/Center Mixed Use): 75 units per acre * CR (Commercial – Regional): 80 units per acre * NMX (Neighborhood Mixed Use): 64 units per acre * RMX (Regional Mixed Use): 90 units per acre The Downtown Development Code establishes unlimited densities for the three Downtown Districts (Downtown Core (DTC), Downtown General (DTG), and Downtown Neighborhood (DTN)) as well as the Apartment House (AH) Overlay zone. To determine achievable densities in the Downtown, the City analyzed development trends of residential projects since 2008. The average number of units per floor for projects in Downtown Fresno was 18.9 units per floor. Multiplying that average by the allowed number of stories for Downtown Districts and the AH overlay, the City determined the following potential densities for these zones: * DTC (Downtown Core): 283 units per acre (15 stories) * DTG (Downtown General): 189 units per acre (10 stories) * DTN (Downtown Neighborhood): 113 units per acre (6 stories) * DTN-AH (Apartment House) Overlay: 57 units per acre (3 stories) Based on the density analysis of mixed use and Downtown Districts, it was determined that the following zoning districts in Fresno allow at least 30 units per acre: * RM-2 (Residential Multi-Family, Urban Neighborhood): 16-30 units per acre * RM-3 (Residential Multi-Family, High Density): 30-45 units per acre * DTC (Downtown Core): No density or Floor Area Ratio (FAR) limits, 190 foot height limit * DTG (Downtown General): No density or FAR limits, 140 foot height limit * DTN (Downtown Neighborhood): No density or FAR limits, 90 foot height limit * AH (Apartment House) Overlay: No density or FAR limits, 35 foot height limit * NMX (Neighborhood Mixed Use): min. density 12 units/acre, no max. density * CMX (Corridor/Center Mixed Use): min. density 16 units/acre, no max. density (note: General Plan requires a minimum 40 percent residential use) * RMX (Regional Mixed Use): min. density 30 units/acre, no max. density (note: General Plan requires a minimum 30 percent residential use) * CMS (Commercial - Main Street): no density limit * CR (Commercial – Regional): no density limit Sites larger than 0.5 acres and within a zoning district listed above were included in the inventory as meeting the lower-income RHNA, except as described below. ### Moderate-Income Sites Zoning districts that allow multi-family residential at densities less than 30 units per acre are assumed to accommodate the moderate-income RHNA. In Fresno, this includes two zoning districts: * RM-1 (Residential Multi-family, Medium High Density), which allows for multi-family at a density of 12-16 units per acre; and * RM-MH (Mobile Home Park), which allows for the development of mobile home parks at a density of 12-16 units per acre. ### Above Moderate-Income Sites Zoning districts that allow primarily single-family housing are counted in the above moderate-income inventory. This includes the following zoning districts: * RE (Residential Estate): up to 0.15 units/acre * RS-1 (Residential Single-family, Extremely Low Density): up to 1.0 unit/acre * RS-2 (Residential Single-family, Very Low Density): up to 2.5 units/acre SECTION 1E-2: SITES INVENTORY * RS-3 (Residential Single-family, Low Density): up to 3.5 units/acre * RS-4 (Residential Single-family, Medium Low Density): 3.5-6.0 units/acre * RS-5 (Residential Single-family, Medium Density): 5.0-12.0 units/acre In addition, sites smaller than 0.5 acres with the zoning districts listed above as meeting the “default density” for lower-income sites are counted in the above moderate-income sites inventory, assuming that these sites are too small to accommodate subsidized lower-income developments. While the inventory assumes single family homes on these sites, it is important to note that many of these zones allow a broader variety of housing types including duplexes, Senate Bill (SB) 9 lot splits, and Accessory Dwelling Units (ADUs). ### Realistic Capacity Government Code Section 65583.2(c) requires, as part of the analysis of available sites, a local government to calculate the projected residential development capacity of the sites identified in the housing element that can realistically be achieved. The housing element must describe the methodology used to make this calculation. Jurisdictions have two options to make this calculation: 1) use the minimum densities, or 2) use a realistic density based on typical densities of other residential developments at similar affordability levels and other adjustment factors to account for land use controls and infrastructure availability. ### Capacity Assumptions on Residential Districts In order to develop assumptions of realistic density for each of the zones where housing is an allowed use, City staff reviewed the density of recently approved and built residential projects from 2018 to 2023. Table 1E-2.5 outlines density assumptions by zone. A separate methodology, which is described below, was used to determine realistic density assumptions for the mixed use zones to reflect the recent (2022) amendments to remove maximum density limitations. The realistic residential development potential of vacant and non-vacant sites has been assumed to be between 60 to 95 percent of the maximum permitted density, depending on the zone, for Residential Single Family (RS) and Residential Multi Family (RM) Districts. As shown below in Table 1E-2.5, project examples from 2018-2023 in the RS and RM Districts varied in range, sometimes exceeding the maximum allowed densities and other times not meeting the minimum. There is one site in the vacant inventory that is zoned Mobile Home Park (RM-MH). Because there are not any recent examples of mobile home park developments, the realistic density of 8.5 units per acre was set based on the average density of surrounding mobile home parks. APPENDIX 1E: CITY OF FRESNO Table 1E-2.5: Density Assumptions for Residential Districts | Zone District | Min. Density DU/ Acre | Max Density DU/ Acre | Project Examples (2018-2023) | Density Assumptions | | | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | | Number | DU/Acre Average | Actual Percent of Max | DU/Acre Range | Assumed Percent of Max | Realistic Density DU/Acre | Affordability Level | | **Residential Single Family (RS) Districts** | | | | | | | | | | | RE | N/A | 0.2 | N/A | N/A | N/A | N/A | 80% | 0.1 | Above Moderate | | RS-1 | N/A | 1.0 | N/A | N/A | N/A | N/A | 80% | 0.8 | Above Moderate | | RS-2 | N/A | 2.5 | N/A | N/A | N/A | N/A | 80% | 2 | Above Moderate | | RS-3 | N/A | 3.5 | 16 | 3.3 | 95% | 2-7 | 95% | 3.3 | Above Moderate | | RS-4 | N/A | 6.0 | 39 | 5.0 | 80% | 3-9 | 80% | 4.8 | Above Moderate | | RS-5 | N/A | 12.0 | 99 | 8.3 | 68% | 3-26 | 70% | 8.4 | Above Moderate | | **Residential Multi-Family (RM) Districts** | | | | | | | | | | | RM-1 | 12 | 16.0 | 25 | 13.9 | 87% | 4-21 | 85% | 13.6 | Moderate | | RM-2 | 16 | 30.0 | 16 | 17.8 | 59% | 14-30 | 60% | 18 | Very Low/Low (> 0.5 acre), Moderate (< 0.5 acre) | | RM-3 | 30 | 45.0 | 2 | 34.5 | 77% | 25-44 | 75% | 33.8 | Very Low/Low (> 0.5 acre), Moderate (< 0.5 acre) | | **Other** | | | | | | | | | | | RM-MH | 12 | 16.0 | 0 | N/A | N/A | N/A | N/A | 8.5 | Moderate | N/A = Not Applicable, RE = Residential Estate, RS-1 = Residential Single-Family, Extremely Low Density, RS-2 = Residential Single-family, Very Low Density, RS-3 = Residential Single-family, Low Density, RS-4 = Residential Single-family, Medium Low Density, RS-5 = Residential Single-family, Medium Density, RM-1 = Residential Multi-family, Medium High Density, RM-2 = Residential Multi-Family, Urban Neighborhood, RM-3 = Residential Multi-Family, High Density, RM-MH = Mobile Home Park Source: City of Fresno and Ascent, June 2023. SECTION 1E-2: SITES INVENTORY ## Capacity Assumptions on Mixed Use Sites To accelerate housing production in infill areas, the City adopted zoning amendments to remove maximum density limitations in the Mixed Use Districts, modify the restriction that prohibits ground floor residential uses in mixed-use, and allow ministerial approval of multi-family residential uses within the Priority Areas for Development. The City performed an analysis to determine the following maximum achievable densities under the height, setback, and other development standards for the mixed use zoning districts. ## Commercial and Mixed Use Zones Table 1E-2.6 identifies the five mixed-use and commercial zones included in the inventory that allow residential development. The three mixed use zones (NMX, CMX, RMX) require residential development and do not allow 100 percent non-residential developments except on lots smaller than 20,000 square feet or more than 1,000 feet from a planned or existing bus rapid transit (BRT) route. The CMS and CR zones allow but do not require residential to be included in all developments. These zones allow both standalone residential and standalone commercial developments. However, all five zones have some level of restrictions on ground floor residential uses in order to activate the sidewalk. In the MX zones, residential is not allowed on the ground floor within 200 feet of an intersection of two or more major streets with the exception of main building entrances and active community spaces. In the CMS and CR zones, ground floor residential is not permitted along arterials or collectors. In addition, there are requirements for active ground floor uses for developments close to transit stations in all five zones. Within 100 feet in each direction of an existing or planned BRT station, no less than 60 percent of the building frontage along public streets must be occupied by food and beverage sales, entertainment and recreation, general personal services, artist's studios, eating and drinking establishments, personal services, general retail, or convenience retail uses. Other high-activity uses that typically operate at night and on weekends may be approved at the discretion of the Review Authority. As described above, in 2022 the City modified standards in the commercial and mixed use zones to facilitate higher residential densities. One of the key changes was to remove the maximum residential density and instead rely on height. As part of this effort, the City created conceptual sites plans to determine reasonable densities under the Citywide Development Code. The Citywide Development Code Section 15-309 defines FAR as the measure of intensity of non-residential development, so it was not applied to Mixed Use Development. The conceptual plans reflected required commercial components. The anticipated densities were significantly higher than what had been previously allowed in the commercial and mixed use zones. Because the zoning amendment is so recent, there are only a few projects that have been submitted or approved under the new standards. However, given the significant increase in allowed density and the minimum residential requirements for several of the mixed use zones (described above), it is realistic to assume development in these mixed use zones will be at much higher densities. APPENDIX 1E: CITY OF FRESNO Looking at development trends on mixed use zoned sites over the past five years (i.e., since 2018), 48 percent of developments have been commercial (including 100 percent commercial developments and commercial that is part of a mixed use project) and 52 percent have been residential. The sites inventory applies an assumption of 50 percent of the identified reasonable density in commercial and mixed use zones to account for commercial development in mixed use zones, as shown in Table 1E-2.6. Mixed-use sites account for 29 percent of all residential capacity identified, including 52 percent of lower-income housing capacity. ### Table 1E-2.6: Density Assumptions for Mixed Use Zones | Zone District | Zone District Name | Min. Density (DU/ Acre) | Calculated “Reasonable” Density (DU/ Acre) | Density Assumptions | | Allowed Land Uses | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | | | Assumed Percent Residential | Realistic Density (DU/Acre) | | | NMX | Neighborhood Mixed Use | 12 | 64 | 50% | 32.0 | Horizontal or vertical mixed use, standalone residential, standalone non-residential is only permitted on lots smaller than 20,000 square feet or further than 1,000 feet from a planned or existing BRT route | | CMX | Corridor/Center Mixed Use | 16 | 75 | 50% | 37.5 | | | RMX | Regional Mixed Use | 30 | 90 | 50% | 45.0 | | | CMS | Commercial – Main Street | N/A | 48 | 50% | 24.0 | Vertical or horizontal mixed use, standalone residential, standalone commercial | | CR | Commercial – Regional | N/A | 80 | 50% | 40.0 | | *Source: City of Fresno and Ascent, June 2023.* ### Recent Project Examples in Mixed Use Zones Recent development trends in Fresno reflect a high demand for residential development, which has resulted in developments that emphasize residential development over exclusively non-residential developments. Most mixed-use projects that have been approved or are in the development process are primarily residential, with just enough ground-floor retail to occupy the ground floor. Even with the provision of ground-floor commercial space, most of these developments were able to achieve or exceed the previously established maximum allowable residential densities, further demonstrating the strength of residential development over commercial development in Fresno. Staff anticipates that this trend will continue, and land zoned for mixed use will achieve residential densities at or above the previously maximum allowed. SECTION 1E-2: SITES INVENTORY The following are examples of recent projects in mixed use zones that are at various stages. **Hageman Apartments** The Hageman Apartments is zoned CMS with a density of 42 dwelling units per acre. This project is located at 1010 E Home Avenue (APN 451-122-24), which is a 0.24 acre site in the Tower District near Fresno City College. It will be a three-story vertical mixed-use development with 10 units of affordable housing; 91 percent residential and 6 percent retail/office. The project received approval for entitlement in 2018 and is in building permit review as of September 2024. <
> **The Hardison** The Hardison is zoned NMX with a density of 106 dwelling units per acre. It is located at 2049 Broadway Street (APN 459-296-03), which is 0.17 acres and located in Downtown Fresno. It will be a four-story vertical mixed-use site with 26 units of market-rate housing; 75 percent residential and 25 percent retail/office. The project received entitlement approval in 2020 and is in building permit review as of September 2024. <
> APPENDIX 1E: CITY OF FRESNO **Brandhaven Senior Apartments** The Brandhaven Hageman Apartments are zoned CR with a density of 118 dwelling units per acre. They are located at 150 N Salma Avenue (APNs 313-920-03, 05, 06, and 07), which is a 1.52-acre site in southeast Fresno. It is a three story 100 percent residential development with 178 affordable units and two manager units. The project received approval for entitlement in 2020 and completed construction in 2023. <
> FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-2-19 SECTION 1E-2: SITES INVENTORY # Downtown Zoning Districts Downtown sites account for 11 percent of all residential capacity identified, including 16 percent of the lower-income housing capacity. As described above, the Zoning Code establishes unlimited densities for the three Downtown Districts (Downtown Core (DTC), Downtown General (DTG), and Downtown Neighborhood (DTN)) as well as the Apartment House (-AH) Overlay zone. To determine achievable densities in the Downtown, the City analyzed development trends of residential projects since 2008. The average number of units per floor for projects in Downtown Fresno was 18.9 units per floor. Multiplying that average by the allowed number of stories for Downtown Districts, the City determined the following potential densities for these zones: * DTC (Downtown Core): 283 units per acre (Maximum 15 stories) * DTG (Downtown General): 189 units per acre (Maximum 10 stories) * DTN (Downtown Neighborhood): 113 units per acre (Maximum 6 stories) * DTN-AH (Apartment House) Overlay: 57 units per acre (Maximum 3 stories) However, recent development projects have not been built at the maximum heights allowed in the downtown zones. Instead, developments in the DTC zone ranged from 4-11 stories; developments in the DTN zone ranged from 2-4 stories; and developments in the DTN-AH zone were typically 2 stories. Looking at actual built and approved projects in the downtown zones during the 2018-2023 timeframe shows densities within the range of 65-247 units per acre, depending on the zone. The realistic densities used in the sites inventory analysis are based on median densities for projects approved in 2018-2023 unless otherwise noted in Table 1E-2.7. ### Table 1E-2.7: Density Assumptions for Downtown Districts | Zone District | Zone District Name | Maximum Number of Stories | Project Examples (2018-2023) | Realistic Density DU/Acre | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | | Number | DU/Acre Average | DU/Acre Median | DU/Acre Range | | | **Downtown Districts** | | | | | | | | | DTC | Downtown Core | 15 | 5 | 136 | 90 | 81-247 | 90 | | DTG* | Downtown General | 10 | N/A | N/A | N/A | N/A | 83 | | DTN | Downtown Neighborhood | 6 | 6 | 72 | 76 | 36-94 | 76 | | DTN-AH** | Apartment House Overlay | 3 | 3 | 32 | N/A | 17-47 | 32 | *There were no projects in the DTG zone. The realistic density is calculated as an average between the DTC and DTN realistic densities since the DTG zone allows 10 stories of development, which is halfway between the 15 allowed in the DTC and the 6 allowed in the DNT zone. **There were no projects in the DTN-AH zone during the 2018-2020 timeframe. The density analysis is based on development projects from 2008-2013 as described in the previous housing element. Source: City of Fresno and Ascent, June 2024. APPENDIX 1E: CITY OF FRESNO # Recent Project Examples in Downtown Zones The following are examples of recent developments in the Downtown zones. Both of these projects are at densities that greatly exceed the realistic densities used in the sites inventory calculations. ### The Monarch @ Chinatown The Monarch @ Chinatown is zoned DTN with a density of 106 dwelling units per acre. It is located at 1101 F Street (APN 467-065-15), which is 0.60 acres. It is a four-story vertical mixed-use project with 52 affordable housing units; 93 percent residential and 7 percent retail. The project received approval for entitlement in 2020 and completed construction in 2023. <
> SECTION 1E-2: SITES INVENTORY ### The Park The Park is zoned DTC with a density of 206 dwelling units to the acre. It is located at 829 Fulton Street, APN 468-282-05T, which is 0.78 acres and located in Downtown Fresno. It will be a six-story vertical mixed-use project with 161 housing units; 83% residential and 17% retail/office. The project received approval for entitlement in August 2024 and has not submitted for building permits yet. <
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> APPENDIX 1E: CITY OF FRESNO # Non-Vacant Sites State law allows jurisdictions to rely on non-vacant and underutilized sites to accommodate the RHNA. However, non-vacant sites can present challenges for residential redevelopment and must therefore be analyzed closely to determine suitability. Jurisdictions must consider the extent to which existing uses may constitute an impediment to additional residential development, past experiences converting existing uses to higher density residential development, lease or contract requirements limiting residential redevelopment, development trends, market conditions, and regulatory or other incentives. Jurisdictions that rely on non-vacant sites to accommodate more than 50 percent of the lower-income RHNA must include substantial evidence that the existing use on each non-vacant site in the inventory will not create an impediment to development during the planning period (Government Code Section 65583.2(g)(2)). After accounting for capacity in approved projects, on vacant sites, and projected accessory dwelling units (ADUs), the sites inventory relies on non-vacant sites to meet only 22 percent of the lower-income RHNA. The non-vacant sites included in this Housing Element sites inventory have been vetted through a site-by-site analysis to only include sites deemed to have a great potential for redevelopment during the planning period. The sites generally fall into five categories, which are described in more detail below. ## A. Agricultural Uses Planned for Residential There are several hundred acres of agricultural land, mostly on the periphery of city limits, that have been annexed into the city and zoned for residential development. Many of these sites have approved tentative subdivision maps and are planned for residential development in the short-term. Several of the sites are fallowed farm fields that are no longer actively farmed, and several are immediately adjacent to recently built residential subdivisions. The City reviewed the initial list of non-vacant sites with agricultural uses and removed sites with active agricultural uses, such as vineyards or orchards, or farms owned and operated by active farmers that seemed likely to continue operations during the planning period. Examples of non-vacant sites with agricultural uses are shown below (see Site Examples A1 and A2). ### Site Example A1: Agricultural use with residential subdivision map <
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> SECTION 1E-2: SITES INVENTORY ### Site Example A2: Fallowed agricultural field <
> The following are five examples of residential development projects built in recent years on agricultural sites that are similar to the types of sites included in the sites inventory. Project Example A1 is a 240-unit affordable housing development called Sarah’s Court that is being built as part of a multi-phase residential and commercial mixed use development, Fancher Creek Town Center. Project Example A2, The Row, is a market rate apartment project within a residential and commercial mixed use development built on agricultural land. Project Examples A3-A5 are examples of single family residential subdivisions built on agricultural land. ### Project Example A1: Sarah’s Court Affordable Housing on Agricultural Land | Project Description | Before | After | | :--- | :--- | :--- | | Affordable Apartments | Pipeline Project (under construction). Sarah’s Court, APN 462420001 – 05 & 00F at 200 N Salma Ave. Phase I - 120 low income apartment units (under construction) and Phase II – 120 low income units in building permit review | <
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> | APPENDIX 1E: CITY OF FRESNO ### Project Example A2: Market Rate Apartments on Agricultural Land | Project Description | Before | After | | :--- | :--- | :--- | | Market Rate Apartments | The Row apartments and commercial, horizontal mixed use, 56801022 -30. | <
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> | ### Project Example A3: Single Family Residential on Agricultural Land | Project Description | Before | After | | :--- | :--- | :--- | | Market Rate Single Family Residential | Single Family Residential subdivisions at northwest corner of Kings Canyon Rd and Fowler Ave (FM 5232, 5913, 6103, 6104, and 6291) | <
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> | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-2-25 SECTION 1E-2: SITES INVENTORY ### Project Example A4: Single Family Residential on Agricultural Land | Project Description | Before | After | | :--- | :--- | :--- | | Market Rate Single Family Residential | Single Family Residential subdivisions at northwest corner of Kings Canyon Rd and Fowler Ave (FM 4380, 4582, 4737, and 4831) | <
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> | ### Project Example A5: Single Family Residential on Agricultural Land | Project Description | Before | After | | :--- | :--- | :--- | | Market Rate Single Family Residential | Single Family Residential subdivisions at southwest corner of Grantland Ave and Barstow Ave (FM 5600) | <
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> | APPENDIX 1E: CITY OF FRESNO ## B. Largely Vacant Residential Land A few of the non-vacant sites are large and mostly vacant parcels with a single house that are planned for development at much higher densities. Many of these sites have a tentative subdivision map and are adjacent to other existing subdivisions. It is common in Fresno for the existing home to be demolished to make way for new residential subdivision development. The City estimated that about 25 percent of the time an existing home will remain and be identified as a remainder lot in the tract map. Examples of non-vacant sites in this category are shown below (see Site Examples B1 and B2). ### Site Example B1: Largely vacant residential land with tentative subdivision map <
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> ### Site Example B2: Largely vacant residential land adjacent to other residential <
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> SECTION 1E-2: SITES INVENTORY The following are three examples of residential development projects built in recent years on rural residential sites that are similar to the types of sites included in the sites inventory. Project Example B1 is a 66-lot single family residential tentative subdivision map approved on a 15.60-acre rural residential parcel. Project Example B2, Avalon Commons, is a 105-unit mixed-income apartment project currently (2024) under construction on a 7.11-acre parcel that was previously used as a rural residence with a landscaping business. Project Example B3 is a 28-unit market rate apartment project called the Palms at Alluvial built on a 4.67-acre rural residential site. In all these examples the original residence was demolished (or will be demolished) and replaced by new single family or multifamily development. ### Project Example B1: Single Family Residential Tentative Map | Project Description | Before | After | | :--- | :--- | :--- | | Market Rate Single Family Residential | APN 31602201, 2149 S Clovis Ave, Approved Tentative Tract Map 5672 | <
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> | ### Project Example B2: Avalon Commons Mixed Income Housing | Project Description | Before | After | | :--- | :--- | :--- | | Affordable and Market Rate Apartments | Pipeline Project (under construction). Avalon Commons, APN 40407150T at 7521 N Chestnut Ave. Phase I – 34 units very low income, 25 units low income, and 46 above moderate apartment units (under construction). Was a landscaping business. | <
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> | APPENDIX 1E: CITY OF FRESNO **Project Example B3: The Palms at Alluvial Market Rate Apartments** | Project Description | Before | After | | :--- | :--- | :--- | | Market Rate Apartments: Pipeline Project (under construction). The Palms at Alluvial, 28 market ate apartment units, APN 40450028 and 29 at 2806 E Alluvial Ave. | <
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> | ### C. Mostly Vacant Land With Paving or Minor Improvements Several sites would be considered vacant land by most standards, but because there are minor improvements or remnant paving from prior uses, they are considered non-vacant by HCD standards. Examples of non-vacant sites in this category are shown below (see Site Examples C1 and C2). **Site Example C1: Mostly vacant land with paving and vehicle access** <
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> SECTION 1E-2: SITES INVENTORY ### Site Example C2: Mostly vacant City-owned land with minor improvements <
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> The following are three examples of residential development projects built in recent years on sites that were mostly vacant but had paving or other minor site improvements. Project Example C1, Iron Bird Lofts, is a 80-unit market rate apartment project built on a 2.17-acre site that had previously been two retail buildings which were demolished around 1994. Project Example C2, Las Palmas de Sal Gonzales is a 135-unit affordable housing development built on a 4.50-acre site that used to have an office facility that was demolished around 1997. Project Example C3 is a 5-unit single family project built on a 0.60-acre site that had previously been an office building. ### Project Example C1: Iron Bird Lofts | Project Description | Before | After | | :--- | :--- | :--- | | Market Rate Apartments | Iron Bird Lofts (constructed) APN 46618245S, 101 Fulton St, | <
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> | ### Project Example C2: Las Palmas de Sal Gonzales | Project Description | Before | After | | :--- | :--- | :--- | | Affordable Apartments | Las Palmas De Sal Gonzales, APN 47216008, 5070 E Kings Canyon Rd, affordable housing | <
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> | ### Project Example C3: Single Family Infill Development | Project Description | Before | After | | :--- | :--- | :--- | | Market Rate Apartments | Single family homes, APN 46822320, 450 to 496 M St | <
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> | ## D. Existing Non-Residential Uses on Large Lots With Infill Potential There are several non-vacant sites with existing non-residential uses that only cover a small portion of the site. In many cases the parcels are large enough for the existing uses to remain and the undeveloped portion of the site to be developed with housing at high densities allowed under the mixed use or downtown zoning districts (see Site Example D1 below). In other cases, the existing non-residential use is marginal and would likely be demolished and replaced with residential or mixed use (see Site Example D2 below). SECTION 1E-2: SITES INVENTORY ### Site Example D1: Commercial strip center on large lot with infill potential <
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> ### Site Example D2: Commercial building on corner lot with infill potential <
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> The following are four examples of affordable housing developments built in recent years on underutilized infill sites. All of these developments are on sites that had existing commercial uses with large surface parking lots, similar to many of the nonvacant sites in the sites inventory. Project Example D1 is a planned senior affordable housing development that is proposed on a 6.22-acre City-owned site that used to be occupied by a commercial building. The existing building has been demolished to make way for the new housing development. Project Example D2, Clinton Family Apartments, is a 77-unit affordable housing development within a horizonal mixed use project that is currently (2024) under construction. The mixed-use project will replace an existing commercial strip center and several adjacent residences. The parcels were consolidated and the existing buildings were demolished. Project Example D3, The Link, is an 88-unit vertical mixed use affordable housing development constructed on a 2.91-acre site that had previously been occupied by a commercial business. The existing buildings were demolished. Project Example D4, The Arthur at Blackstone, is an also an affordable housing development that replaced an existing commercial building and surface parking lot on five adjacent parcels with 41 units of affordable housing and new commercial in a mixed-use development. APPENDIX 1E: CITY OF FRESNO ### Project Example D1: Planned Senior Affordable Housing | Project Description | Before | Now | Planned | | :--- | :--- | :--- | :--- | | Affordable Senior Apartments | Proposed affordable senior housing and senior center. APN 42625317, 4343 N Blackstone Ave. Horizontal mixed/use. Mostly Vacant City-Owned Property (Commercial Bldg/Parking Lot not in use, demolished) | <
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> | ### Project Example D2: Clinton Family Affordable Apartments | Project Description | Before | After | | :--- | :--- | :--- | | Affordable Apartments | Clinton Family Apartments (under construction), APN 44409220, 22, 26, 27 and 28, 1538 E Clinton Ave, 77 affordable units, horizontal mixed-use | <
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> | SECTION 1E-2: SITES INVENTORY ### Project Example D3: The Link Affordable Apartments | Project Description | Before | After | | :--- | :--- | :--- | | The Link (constructed), APN 45106416, 1661 E Home Ave, vertical mixed use with 88 affordable housing units on the upper floors and commercial/office uses on the first floor, and located on a corner with an existing commercial building. | <
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> | ### Project Example D4: The Arthur at Blackstone Affordable Housing | Project Description | Before | After | | :--- | :--- | :--- | | The Arthur at Blackstone (under construction), APN 44310408T, 09T, 10, and 23, 3039 N Blackstone Ave, 41 affordable units/mixed use on a corner lot with an existing commercial building. | <
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> | ### E. Parking lots The initial list of non-vacant sites included several dozen parking lots, mostly in the downtown area that were associated with existing commercial or office uses, places of assembly, or were standalone paid parking areas. While all of these parking lots provide opportunity for infill development downtown, the City was selective with which parking lots were included in the Housing Element inventory given the continued reliance on parking in the short-term. Only about half of the initial list of parking lots are included in the inventory. Parking lots that were significantly underutilized, deteriorating, or abandoned were included, as well as parking lots owned or leased by state or local jurisdictions that were not in heavy use. The City reviewed the publicly owned parking lots carefully for appropriateness and removed those not deemed available during the housing element planning period. Site Examples E1 and E2 below demonstrate typical sites that fit within this category. APPENDIX 1E: CITY OF FRESNO **Site Example E1: Overflow parking lot for adjacent church** <
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> **Site Example E2: Parking lot, not in use** <
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> The following are three examples of affordable and market rate housing developments built in recent years on parking lots. Project Example E1, Brio on Broadway, is a vertical mixed use, market rate housing development built on a 1.34 acre commercial site that was mostly used as surface parking. Project Example E2, Renaissance at Santa Clara, is a 70-unit affordable housing development built on two adjacent parcels totaling 0.74 acres, one of which was an overflow parking lot for an adjacent commercial use. Project Example E3 is a 30-unit market rate apartment development on a 1.01 acre parking lot that was regularly used for a farmers market. Similar to most of the parking lot sites included in the sites inventory, all of these project examples are in Downtown Fresno. The sites are similar in size and location to the other parking lot sites included in the inventory. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-2-35 SECTION 1E-2: SITES INVENTORY ### Project Example E1: Brio on Broadway | Project Description | Before | After | | :--- | :--- | :--- | | Brio on Broadway, APN 46619328, 1636 Broadway Avenue, vertical mixed-use. Parking lot, not in use and commercial building on corner lot with infill potential. | <
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> | ### Project Example E2: Renaissance at Santa Clara | Project Description | Before | After | | :--- | :--- | :--- | | Renaissance at Santa Clara, affordable apartment units, APN 46708231 and 32, 1505 Santa Clara Street. | <
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> | APPENDIX 1E: CITY OF FRESNO ### Project Example E3: 2: 1612 Fulton Street | Project Description | Before | After | | :--- | :--- | :--- | | Market Rate Apartments | 1612 Fulton Street was a parking lot (with regular farmers market) and now market rate apartments. APN 46614416 Fulton Street. | <
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> | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-2-37 SECTION 1E-2: SITES INVENTORY ### Summary of Non-Vacant Site Categories Figure 1E-2.1 shows unit capacity by income level by type of site, including vacant and the five types of non-vacant sites: A) agricultural uses planned for residential, B) largely vacant residential land, C) mostly vacant land with paving or minor improvements, D) existing non-residential uses on large lots with infill potential, and E) parking lots. In all income levels, a majority of the housing capacity on sites in the inventory (not including pipeline project or ADUs) is on vacant sites (51 percent). **Figure 1E-2.1: Housing Capacity on Vacant and Non-Vacant Sites by Category, All Income Levels** <
> *Source: Ascent, September 2024.* Figure 1E-2.2 shows unit capacity of lower-income sites by type of site. A majority of the lower-income capacity is on vacant sites (59 percent). Of the non-vacant site categories, sites categorized as existing agriculture have the highest capacity of 2,234 lower-income units, and sites categorized as parking lots have the second highest capacity at 2,017 lower-income units. APPENDIX 1E: CITY OF FRESNO ### Figure 1E-2.2: Lower-Income Site Capacity by Category <
> *Source: Ascent, September 2024.* ## Publicly Owned Sites There are about 50 sites in the sites inventory that are owned by various public agencies, including the City of Fresno, Fresno Housing Authority, Redevelopment Agency (now the Successor Agency), and the State of California. City staff has reviewed the list of publicly-owned sites carefully to understand ownership, whether the sites are already planned for housing development, any known barriers to development, and whether or not existing uses would need to be relocated. City staff removed more than 100 sites that are unlikely to develop for a variety of reasons, including site location within airport safety zones; sites planned for local or state infrastructure; sites with existing uses; awkwardly shaped and landlocked sites; and sites located adjacent to industrial uses. The remaining sites included in Table 1E-2.9 represent publicly-owned and generally barrier-free sites with information about ownership and steps to development. This includes 8 sites that are non-vacant, including 3 lower-income sites located in the Downtown with total capacity for 1,146 units; and 3 above moderate income sites, also mostly smaller high-density zoned sites in the Downtown with total capacity for 72 units. All sites in the inventory are zoned to allow for residential development, and most are vacant, including 9 vacant lower-income sites with capacity for 896 units, 2 moderate-income sites with capacity for 59 units, and 31 above moderate-income sites with capacity for 267 units. This is in addition to the public sites identified in Table 1E-2.8 that will be supported by improvements through the Downtown Fresno CIP. SECTION 1E-2: SITES INVENTORY ## Downtown Fresno Housing Projects Supported by Infill Infrastructure Grant Several sites in the inventory have been identified as catalyst infill sites through the Infill Infrastructure Grant program. The City of Fresno was awarded $49 million through the State’s Infill Infrastructure Grant Program – Catalytic Qualifying Infill Area (IIGC) in the 2022-2023 fiscal year. The primary goal of IIGC is to promote infill housing development by providing financial assistance for Capital Improvement Projects (CIPs) that are an integral part of, or necessary to facilitate the development of, Catalytic Qualifying Infill Areas. Under the program, grants are available as gap funding for infrastructure and other capital improvements necessary for specific residential or mixed-use infill development proposals. The Downtown Fresno CIP supported by the IIGC grant includes sewer main replacements across multiple streets, a water project, site preparations, surface improvements, urban greening, installation of pedestrian lighting and push buttons, and ancillary works, and construction of a centralized off-site parking structure. These improvements will allow for development of nine housing projects in Downtown Fresno, shown in Table 1E-2.8 and Figures 1E-2.3-1E-2.5. These projects encompass multiple sites that are under the ownership of the City of Fresno, the Fresno Housing Authority, and private entities. Of 863 total units anticipated to be developed, 457 are planned to be restricted to lower-income households, including 86 units for extremely low-income households, and the remaining 405 units are anticipated to be market rate, which are assumed to provide a 50/50 mix of moderate- and above moderate-income housing. The grant does not provide funding for the housing developments themselves. However, each planned housing development has a plan to assure financial feasibility in time to meet required IIGC program milestones. These projects are currently in the design phase, and entitlements are expected to be requested by May 2025. APPENDIX 1E: CITY OF FRESNO ### Table 1E-2.8: Downtown Fresno Infill Infrastructure Grant Sites | City Project ID | Site ID | APN | Ownership | Calculated Project Acres | Units by Income Level | Total Units | Site Description | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | | | | **ELI** | **VLI** | **LI** | **M** | **AM** | | | | HD1 | 1617 | 46615314 | Private Owner | 0.55 | | 75 | | | | 75 | The Business Journal parking lot and right of way. HD1 is planned for student housing. | | HD2 | 2473 | 46620656T | Housing Authority (HACF) | 0.47 | | 62 | | | | 62 | Parking lot for IRS building. Housing Authority owned site. Assumed that IRS building will remain. HD2 is planned for student housing. | | HD3 | 1617 | 46615318 | Private Owner | 0.85 | 16 | 48 | | | | 64 | The Business Journal parking lot and right of way. HD3 is planned to receive Low Income Housing Tax Credits. | | | | ROW | City of Fresno | | | | | | | | | | HD4 | 2473 | 46620656T | Housing Authority (HACF) | 0.47 | 15 | 40 | | | | 55 | Parking lot for IRS building. Housing Authority owned site. Assumed that IRS building will remain. HD4 is planned to receive Low Income Housing Tax Credits. | | HD 5 | 1615 | 46620650T | City of Fresno | 0.95 | | | | 56 | 56 | 112 | Parking lot across from IRS building in Downtown Fresno. On this site is proposed Market 1 by Fresno Housing with 112 market rate units. No development project submitted in Accela. There is currently a lease agreement in place for Fresno County. The most recent extension dated September 16, 2022 allowed a five-year extension expires December 31, 2027 | | | | 46620651T | | | | | | | | | | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-2-41 SECTION 1E-2: SITES INVENTORY | City Project ID | Site ID | APN | Ownership | Calculated Project Acres | Units by Income Level | Total Units | Site Description | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | | | | ELI | VLI | LI | M | AM | | | | HD 6 | 1618 | 46615315 | Private Owner | 0.91 | | | | 50 | 50 | 100 | Closed CVS parking lot and right of way. On this site is proposed Market 2. | | | | ROW | City of Fresno | | | | | | | | | | HD 7 | 2484 | 46704023ST | City of Fresno | 2.32 | 26 | 74 | | 97 | 97 | 294 | Recently demolished building on the parcel owned by the City. The other parcel is privately-owned owned by Fresno Sports and Events Partners Inc | | | | 46704020S | Private Owner | | | | | | | | | | HD 8 | 1525 | 46707115 | Private Owner | 0.78 | 21 | 50 | | | | 71 | Abandoned building | | | | 46707120 | Private Owner | | | | | | | | | | HD 9 | 2485 | 46707402 | Private Owner | 0.33 | 8 | 22 | | | | 30 | Existing commercial buildings | | **TOTAL** | | | | **7.63** | **86** | **371** | **0** | **203** | **203** | **863** | | *Source: City of Fresno, September 2024.* APPENDIX 1E: CITY OF FRESNO Figure 1E-2.3: IIGC Sites HD1 - HD6 (Fulton Street) <
> Figure 1E-2.4: IIGC Site HD7 (H Street Site in the South Stadium District) <
> FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-2-43 SECTION 1E-2: SITES INVENTORY Figure 1E-2.5: IIGC Sites HD8 - HD9 (Bing Kong and Peacock Sites in Chinatown) <
> APPENDIX 1E: CITY OF FRESNO Table 1E-2.9: Publicly-Owned Sites | Site ID | APN | Address | Zoning Code | Acres | Capacity (Units) | Ownership | Existing Use | Status and Remaining Steps | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | | | | Lower | Moderate | Above Moderate | | | | | 287 | 45603034T | 5471 E Belmont Ave | RM-1 | 4.17 | | 57 | | City of Fresno | Vacant; potential brownfield remediation | In September 2024, the City of Fresno will release a Request for Proposal (RFP) for the development of a vibrant community featuring 24 ARPA funded tiny homes on wheels and 26 ERF funded prefabricated micro homes, totaling 50 homes, all provided by the City. The development will include a community center, trail, or park. The submission deadline will be November 2024. Construction is anticipated to start in October 2025 and be completed in August 2026 | | 304 | 31332107T | | RS-4 | 0.45 | | | 2 | City of Fresno | Vacant; near future retail center and BRT | | | 535 | 47005201T | 3702 E Ventura St | NMX | 3.40 | 109 | | | City of Fresno | Vacant | | | 47005202T | 3754 E Ventura St | NMX | | | | | | | | | 47005203T | 3745 E El Monte Way | RS-5 | | | | | | | | | 660 | 45205308 | 1556 E Olive Ave | CMS | 0.17 | | | 4 | Fresno Irrigation District | Vacant | | | 708 | 45021106T | 929 N Fruit Ave | RS-5 | 0.21 | | | 2 | City of Fresno | Vacant | As of September 2024, this property has not been declared a surplus site. | | 714 | 45015401T | 761 W Hammond Ave | RM-1 | 0.16 | | 2 | | State of California | Vacant | | | 987 | 51135201ST | | RS-4 | 0.26 | | | 1 | City of Fresno | Vacant | As of September 2024, this property has not been declared a surplus site. | | 1096 | 46404059T | | RS-4 | 0.98 | | | 5 | State of California | Vacant | City surplus site | | 1097 | 46404073T | | RS-4 | 2.32 | | | 11 | State of California | Vacant | City surplus site | | 1098 | 46431210T | 1108 S Roeding Dr | RS-4 | 0.18 | | | 1 | State of California | Vacant | City surplus site | | 1099 | 46431211T | 1122 S Roeding Dr | RS-4 | 0.23 | | | 1 | City of Fresno | Vacant | City surplus site | | 1100 | 46431212T | 1136 S Roeding Dr | RS-4 | 0.24 | | | 1 | City of Fresno | Vacant | City surplus site | | 1101 | 46431213T | 1150 S West Ave | RS-4 | 0.46 | | | 2 | City of Fresno | Vacant | City surplus site | | 1102 | 46431214T | 1164 S West Ave | RS-4 | 0.39 | | | 2 | City of Fresno | Vacant | City surplus site | | 1103 | 46427237T | 1212 S West Ave | RS-4 | 1.05 | | | 5 | City of Fresno | Vacant | City surplus site | | 1124 | 46410208T | 2022 S West Ave | CMX | 0.27 | | | 10 | City of Fresno | Vacant | No known barriers to development. As of September 2024, this property has not been declared a surplus site. | | 1129 | 47704075ST | 901 W Atchison Ct | RM-2 | 1.19 | 21 | | | Housing Authority (HACF) | Vacant | Though the Housing Authority does not have development plans in place for these properties at this time. Lot acres have been reduced to usable portion of the site. | | 1130 | 47704075ST | 901 W Atchison Ct | RM-2 | 4.91 | 88 | | | Housing Authority (HACF) | Mostly vacant. Community garden on portion of site. | | | 1131 | 47704073T | 555 W California Ave | CMX | 8.06 | 302 | | | Housing Authority (HACF) | Vacant | | | 1151 | 47712113T | 33 E Atchison St | RS-5 | 0.21 | | | 2 | Redevelopment Agency (RACF) | Vacant | | | 1153 | 47712105T | | NMX | 0.37 | | | 12 | Redevelopment Agency (RACF) | Vacant; adjacent sites. | City surplus site adjacent to privately owned site 1152. Could be consolidated with nearby parcels to become a larger development opportunity. | | 47712106T | | | | | | | | | | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 | 1E-2-45 SECTION 1E-2: SITES INVENTORY | Site ID | APN | Address | Zoning Code | Acres | Capacity (Units) | | | Ownership | Existing Use | Status and Remaining Steps | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | | | | Lower | Moderate | Above Moderate | | | | | 1365 | 46724601T | 731 E California Ave | NMX | 2.92 | 93 | | | Housing Authority (HACF) Redevelopment Agency (RACF) | Vacant | Site within the West Fresno CAN! Choice Neighborhood Initiative planned for new housing. Phase 1: 60 new affordable units in vertical mixed-use development slated for planning application submittal in Q4 of 2025; entitlement approval in Q2 of 2026, construction drawings in Q3 of 2027; and building permit issuance in Q2 of 2028. | | | 46724506T | 537 Inyo St | | | | | | | | | | | 46724505T | 811 Waterman Ave | | | | | | | | | | | 46724504T | 813 Waterman Ave | | | | | | | | | | | 46724503T | | | | | | | | | | | | 46724507T | 661 E California Ave | | | | | | | | | | | 46724511T | 854 Klette Ave | | | | | | | | | | | 46724509T | | | | | | | | | | | | 46724512T | 864 Klette Ave | | | | | | | | | | | 46724508T | | | | | | | | | | | | 46724510T | 842 Klette Ave | | | | | | | | | | | 46726201T | | | | | | | | | | | | 46726202T | 851 Klette Ave | | | | | | | | | | | 46726203T | | | | | | | | | | | | 46726204T | 601 E California Ave | | | | | | | | | | 1386 | 46718609T | 1128 Collins Ave | RS-5 | 0.34 | | | 3 | City of Fresno | Vacant | As of September 2024, this property has not been declared a surplus site. | | 1391 | 46715507T | 1107 B St | RS-5 | 0.15 | | | 1 | Redevelopment Agency (RACF) | Vacant parcel adjacent to 4 other vacant parcels. | City surplus site | | 1418 | 46517421T | 1511 B St | RS-5 | 0.13 | | | 1 | Redevelopment Agency (RACF) | Vacant | City surplus site | | 1419 | 46517422T | 1515 B St | RS-5 | 0.13 | | | 1 | Redevelopment Agency (RACF) | Vacant | City surplus site | | 1436 | 46411313T | 130 W Lemon Ave | RS-5 | 0.14 | | | 1 | Redevelopment Agency (RACF) | Vacant | City surplus site | | 1489 | 46706124T | 1535 Fresno St | DTN | 0.34 | | | 25 | State of California | Vacant | Site is planned for transit-oriented development according to the High Speed Rail Station Master Plan. Status of State’s plan for this site is unknown. | | 1490 | 46706123T | | DTN | 0.12 | | | 9 | State of California | Vacant | | | 1492 | 46706211T | 1526 Fresno St | DTN | 0.26 | | | 20 | State of California | Vacant | | | 1493 | 46706203T | 1141 G St | DTN | 0.26 | | | 20 | State of California | Parking | | | 1523 | 46707410T | 930 E St | DTN | 0.35 | | | 26 | City of Fresno | Parking Lot adjacent to privately-owned site 1522. Potential lot consolidation for a larger development opportunity | As of September 2024, this property has not been declared a surplus site. | | 1529 | 46707316T | 730 F St | DTN | 0.60 | 46 | | | Redevelopment Agency (RACF) | Vacant | These properties were declared surplus in 2024 and RACF will follow the SLA guideline. | | 1530 | 46707305T | 723 G St | DTN | 0.09 | | | 7 | Redevelopment Agency (RACF) | Vacant | These properties were declared surplus in 2024 and RACF will follow the SLA guideline. | | 1531 | 46707306T | | DTN | 0.18 | | | 13 | Redevelopment Agency (RACF) | Vacant | These properties were declared surplus in 2024 and RACF will follow the SLA guideline. | | 1532 | 46708116T | 655 G St | DTN | 0.35 | | | 26 | City of Fresno | Paved | In June 2024, this project was declared surplus. | APPENDIX 1E: CITY OF FRESNO | Site ID | APN | Address | Zoning Code | Acres | Capacity (Units) | Ownership | Existing Use | Status and Remaining Steps | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | | | | Lower | Moderate | Above Moderate | | | | | 1562 | 46705013ST | 555 H St | DTN | 1.41 | 107 | | | State of California | Vacant | Part of the property is abandoned for widening of Caesar Chavez underpass. | | 1573 | 46822212T | 550 M St | DTG | 0.30 | | | 25 | Redevelopment Agency (RACF) | Vacant | As of September 2024, this property has not been declared a surplus site. The RACF is preparing to take this to the Fresno City Council for surplus site declaration consideration in 2025. | | 1574 | 46822215T | 525 N St | DTG | 0.60 | 50 | | | Redevelopment Agency (RACF) | Vacant | As of September 2024, this property has not been declared a surplus site. The RACF is preparing to take this to the Fresno City Council for surplus site declaration consideration in 2025. | | | 46822216T | 505 N St | | | | | | | | | | 1576 | 46822301T | 461 N St | DTG | 0.43 | | | 36 | Redevelopment Agency (RACF) | Vacant | As of September 2024, this property has not been declared a surplus site. The RACF is preparing to take this to the Fresno City Council for surplus site declaration consideration in 2025. | | | 46822302T | 453 N St | | | | | | | | | | | 46822319T | 461 N St | | | | | | | | | | 1579 | 46819534T | 2402 Ventura St | DTG | 0.73 | 61 | | | Redevelopment Agency (RACF) | Only counting vacant part of parcel | As of September 2024, this property has not been declared a surplus site. The RACF is preparing to take this to the Fresno City Council for surplus site declaration consideration in 2025. | | 1580 | 46819213T | 2504 Ventura St | DTG | 0.95 | 79 | | | Redevelopment Agency (RACF) owns two parcels four parcels are privately-owned as of September 2024 | Vacant | As of September 2024, this property has not been declared a surplus site. The RACF is preparing to take this to the Fresno City Council for surplus site declaration consideration in 2025. | | | 46819214T | 2518 Ventura St | | | | | | | | | | | 46819236 | 530 O St | | | | | | | | | | | 46819237 | 534 O St | | | | | | | | | | | 46819222 | 2526 Ventura St | | | | | | | | | | | 46819227 | 2534 Ventura St | | | | | | | | | | 1606 | 46621522T | 1822 Fresno St | DTC | 2.78 | 250 | | | State of California | Parking lot | State-owned site within the Station Master Plan Area (“Merchant’s Lot). City will work with State to pursue development. | | 1607 | 46621426T | | DTC | 0.78 | 70 | | | City of Fresno | Parking lot | Will serve as temporary parking until parking garage behind Hotel Fresno is built. Hotel Fresno has recently been converted to affordable housing. Permits are not being sold for this lot and parking is being deferred to this lot. As of September 2024, this property has not been declared a surplus site. These parcels are RDAF parcels to be disposed of going to the Hotel Fresno group | | | 46621427T | | | | | | | | | | | 1610 | 46703039ST | 1705 Fresno St | DTC | 2.25 | 202 | | | State of California | Dairy Semi-truck parking | Will serve as temporary parking until parking garage behind Hotel Fresno is built. Hotel Fresno has recently been converted to affordable housing. Permits are not being sold for this lot and parking is being deferred to this lot. | | 1612 | 46504038ST | 1301 H St | DTC | 2.98 | 268 | | | City of Fresno | Small building on site | This is a brownfield site acquired by the City in 2002. In 2023, the City was awarded $3,122,648 in ECRG grant funding from DTSC to remediate the hazardous site for future Affordable housing. Our team is currently working with DTSC to complete the remediation by 2026. The proposed reuse consists of developing a micro home community of 26 prefabricated units of 100% Affordable rental housing. The units will be reserved for households at or below 30% AMI and will see unhoused individuals transition to permanent housing. | | 1613 | 46620518T | 1408 H St | DTC | 0.29 | | | 26 | State of California | Vacant | | | 1811 | 44405116T | | RS-5 | 0.12 | | | 1 | City of Fresno | Vacant | As of September 2024, this property has not been declared a surplus site. | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-47 SECTION 1E-2: SITES INVENTORY | Site ID | APN | Address | Zoning Code | Acres | Capacity (Units) | | | Ownership | Existing Use | Status and Remaining Steps | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | | | | Lower | Moderate | Above Moderate | | | | | 1891 | 50409212T | | RS-5 | 1.74 | | | 15 | City of Fresno | Vacant | As of September 2024, this property has not been declared a surplus site. It is proposed to be disposed of to a developer for a mixed-housing project. | | 2396 | 46707307T | | DTN | 0.28 | | | 21 | City of Fresno | Vacant | City surplus site | | 2486 | 44502013T | 3374 E Shields | O | 2.8 | 224 | | | State of California | Vacant Building: Dept of Water Resources | This project is on state surplus land (per State Executive Order N-06-19), and the State is partnering with the City to develop the site as multi-unit housing. The state completed its RFP process at the end of 2023 and selected Alexis Laing as the Developer. Project is now in predevelopment. Development of the 2.8 acre site with multi-unit housing including 50% 3-bedroom units and with a range of affordability in two phases: Ph. 1 includes 84 units and deeper affordability with a special needs set-aside. Ph 2 is anticipated at 140 units with higher AMI unit mix. Development will include energy efficient plumbing and lighting fixtures, as well as drought tolerant landscaping and hydrozones to maximize water efficiency on site. Each building will achieve a minimum silver LEED or GreenPoint rating. Solar PW panels will be installed on both projects. Phases 1 and 2: Due Diligence, Community Outreach, Entitlement, Financing 11/23 – 5/25; Construction 11/25 | | **TOTAL** | | | | **55.24** | **2,042** | **59** | **339** | | | | Source: City of Fresno, September 2024. # Suitability of Large Sites There are 10 vacant sites and 12 non-vacant sites included in the lower-income inventory that are larger than 10 acres. While the allowable density on these sites exceeds the default density of 30 units per acre, qualifying them as lower-income sites, the size and sheer number of units allowed make it more likely that they would be further subdivided and/or built with a mix of housing types at various income levels. Several assumptions are applied to large sites to reflect more realistic assumptions for the mix of incomes that could be accommodated on the sites. Most of these large sites are in the West Area Neighborhood Specific Plan (WANSP) boundary, west of Highway 99. The City is in the process of developing a Specific Plan for the future growth and development in this area. The Specific Plan is scheduled to be considered for adoption in the first quarter of 2025. The Draft Specific Plan calls for land use changes; however, because it is not yet adopted, the Draft Housing Element reflects the currently adopted land use designations. Once the Specific Plan has been adopted, the Draft Housing Element will be updated to reflect the new designations. There is a significant amount of developable land in the area, so many of the sites in the inventory are within the plan area boundary. Because the area has been and continues to transition from agriculture to urban development, many of the sites are larger in size than sites in other parts of the city. Most of the large sites in the WANSP area are located along the Shaw Avenue Corridor, in an area referred to as the West Shaw Avenue Town Center. Assumptions for the Town Center parcels are described in more detail in the following section below. Based on recent examples of large site developments (refer to Table 1E-2.12), large scale 100 percent affordable projects with more than 150 units have successfully been built in Fresno. For example, Parc Grove Commons is an affordable development with 215 units. Given this trend, the Housing Element assumes that if a site’s total capacity is 250 units or fewer, it is feasible to develop the site as 100 percent affordable housing. For larger sites where the total capacity exceeds 250 units, it is assumed that the project would be subdivided to create a mixed-income development, with 20 percent lower-income units, 60 percent moderate-income units, and 20 percent above moderate-income units. This is similar to how Fancher Creek and West Creek Village were developed (see Table 1E-2.11). Two of the four large vacant sites outside of the West Shaw Avenue Town Center boundary are owned by the Fresno Housing Authority (Sites 988 and 1129/1130). Site 988 is a 14.57-acre parcel zoned RM-2, while Site 1129/1130 is an 11.3-acre split zoned parcel, with a 6.10-acre portion of the site zoned RM-2. It is realistic to assume that these RM-2 sites will be developed with 100 percent affordable housing given ownership by the Housing Authority (see Table 1E-2.10 below). SECTION 1E-2: SITES INVENTORY Of the non-vacant sites, there are four large RM-2 sites outside of the Town Center (Sites 808, 979, 1076, and 1223). The non-vacant RM-2 sites include an 18.8-acre parcel currently in agricultural use on South Walnut Avenue (Site 1223), an 18.4-acre parcel on West Whites Bridge Avenue also currently in agricultural use (Site 1076), and a 28.37-acre parcel split-zoned parcel of which 22.57 acres is zoned RM-2 (Site 979). There is also one large non-vacant site zoned RM-3 (Site 853) at 6277 W Shaw Ave that is currently in agricultural use. The sites inventory applies an assumption of 20 percent lower-income, 60 percent moderate-income, and 20 percent above moderate-income housing on these parcels (see Table 1E-2.10 below). The last parcel in Table 1E.2-10 is a 10.6-acre parcel zoned RMX (APN 417-34-223) on the corner of West Shaw Avenue and Blackstone Avenue. There are two small retail uses on the site, including a restaurant and an eyeglass store, as well as a residence that collectively cover about half of the site. The sites inventory assumes only 60 percent of the site is developed with residential infill housing and the remaining 40 percent remains occupied by existing uses. In total, the inventory assumes 3,279 units on the eleven large sites shown in Table 1E-2.10, including 1,480 lower-income units, 1,329 moderate income-units, and 470 above moderate-income units. ### West Shaw Avenue Town Center One of the areas with the greatest amount of future housing potential is the West Shaw Avenue Town Center, which is envisioned in the General Plan to be developed as a high-density, urban mixed-use corridor supported by enhanced transit service. There are 29 sites in the West Shaw Avenue Town Center mostly designated for mixed use development; 11 sites are larger than 10 acres and are considered “large sites.” Because all of the sites are concentrated in one area, the assumptions described below are applied to all sites within the Town Center, not just large sites. While the Draft Specific Plan does not call for any specific phasing of the Town Center, given the scale of the Town Center, it is expected that it will develop over a longer timeframe than the 8-year housing element planning period. Also, given the large size of the mixed use sites and the lack of existing retail in the area, it is anticipated that there will be a greater percentage of commercial uses compared to the smaller, infill parcels located on mixed use corridors where there is already a significant amount of existing retail. To reflect this, the sites inventory applies the following assumptions to both small and large sites in the West Shaw Avenue Town Center: * **Mix of uses.** Sites designated mixed-use in the Town Center are assumed to have 60 percent residential and 40 percent commercial. This is slightly higher than the 30-40 percent residential that is required in the mixed use designations. This assumption for the mix of uses is layered on top of the 50 percent likelihood assumptions applied to the site, which already accounted for a portion of the site developing as commercial. APPENDIX 1E: CITY OF FRESNO * **Mix of incomes.** Sites in the Town Center that allow 30 units per acre, qualify as “lower-income,” and have a capacity of 250 units or fewer are counted as 100 percent affordable. The remaining sites are counted as 20 percent lower-income, 60 percent moderate-income, and 20 percent above moderate-income to reflect a vision of a variety of housing types and to avoid a concentration of lower-income units on large sites. This applies to sites designated CMX, RMX, and RM-2. The parcel designated RM-1 is assumed to be moderate-income. * **Development phasing.** Only 50 percent of the capacity of the sites in the Town Center is counted in the sites inventory to reflect an assumption that about half of the area could build out during the Housing Element planning period. Rather than selecting which parcels to include and which to exclude, the 50 percent capacity assumption is applied to all sites in the Town Center. This is shown in the table as “50% Likelihood.” This means that what is shown as the total capacity for each individual site is significantly less than the actual realistic capacity for the site. **Figure 1E-2.6** shows the sites within the West Shaw Avenue Town Center and **Table 1E-2.11** summarizes the inventoried capacity by land use designation. In total, there are 3,227 units counted in the sites inventory in this area, including 1,177 lower-income, 1,585 moderate-income, and 395 above moderate-income units. To help achieve the assumptions used in the sites inventory, the Housing Element includes an implementation program to help facilitate the subdivision of large sites into parcels that are more appropriately sized for affordable housing. SECTION 1E-2: SITES INVENTORY Table 1E-2.10: Large Sites (Excluding West Shaw Avenue Town Center) | Site ID | APN | Parcel Size (Acres) | Zone | Location/ Site Description | Lower-Income Units | Moderate- Income Units | Above-Moderate Units | Total Inventoried Units | Assumptions | Existing Use | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | **Vacant Large Sites** | | | | | | | | | | | | 768 | 506-13-039 | 10.48 | RM-2 | Near W Sierra Ave & N Vista Ave | 189 | 0 | 0 | 189 | 100% Lower | Vacant | | 780 | 504-09-209 | 13.1 | RM-2 | N Hayes Ave near W Herndon Ave | 236 | 0 | 0 | 236 | 100% Lower | Vacant | | 988 | 511-02-301 | 14.57 | RM-2 | 5677 W Dakota Ave (Housing Authority site) | 262 | 0 | 0 | 262 | 100% Lower | Vacant | | 1129/ 1130 | 477-04-075ST | 11.30 (split-zoned); 6.10-acres zoned RM-2 | RM-2 | 901 W Atchison Ct. (Housing Authority site) | 109 | - | - | 109 | 100% Lower | Vacant | | **Non-Vacant Large Sites** | | | | | | | | | | | | 127 | 417-34-223 | 10.65 | RMX | Corner of Blackstone and Shaw (20 W Shaw Ave) | 57 | 172 | 57 | 286 | 60% Res, 40% Com 20% Lower, 60% Mod, 20% Above-Mod | Assortment of uses, portion of site is vacant | | 808 | 505-08-042S | 11.92 | RM-2 | N Bryan Ave at Bullard Ave | 214 | 0 | 0 | 214 | 100% Lower | Agriculture | | 853 | 512-03-203 | 19.23 | RM-3 | 6277 W Shaw Ave | 130 | 389 | 130 | 649 | 20% Lower, 60% Mod, 20% Above-Mod | Agriculture, canal through middle of parcel | APPENDIX 1E: CITY OF FRESNO | Site ID | APN | Parcel Size (Acres) | Zone | Location/ Site Description | Lower-Income Units | Moderate-Income Units | Above-Moderate Units | Total Inventoried Units | Assumptions | Existing Use | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 979 | 512-04-317S (28.37-acre parcel with split zoning) | 22.57-acre portion | RM-2 | Corner of W Ashlan Ave & N Grantland Ave | 81 | 244 | 81 | 406 | 20% Lower, 60% Mod, 20% Above-Mod | Agriculture | | 1076 | 326-10-076 | 18.38 | RM-2 | 3555 W Whites Bridge Ave | 66 | 199 | 66 | 331 | 20% Lower, 60% Mod, 20% Above-Mod | Agriculture | | 1223 | 328-08-001S | 18.80 | RM-2 | 2867 S Walnut Ave | 68 | 203 | 68 | 339 | 20% Lower, 60% Mod, 20% Above-Mod | Agriculture | | 2478 | 310-20-103 | 58.05 | RM-2 | 3518 N Fowler | 68 | 122 | 68 | 258 | 20% Lower, 60% Mod, 20% Above-Mod | Residential/ Agriculture | | **TOTAL** | | | | | **1,480** | **1,329** | **470** | **3,279** | | | *Source: City of Fresno and Ascent, September 2024.* SECTION 1E-2: SITES INVENTORY This page intentionally left blank. APPENDIX 1E: CITY OF FRESNO Table 1E-2.11: West Shaw Avenue Town Center Sites | Site ID | APN | Total Parcel Size (Acres) | Zoning | Location/Site Description | Max Density | Total Capacity at Max Density | Inventoried Capacity | Assumptions | Existing Use | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | | | | | | Lower-Income Units | Moderate-Income Units | Above-Moderate Units | Total Units | | | | **Vacant Sites** | | | | | | | | | | | | | | 816 | 505-06-008 (38.33 acre parcel, split zoning) | 13.26 portion | RM-1 | 6785 W Barstow Ave | 16 | 212 | 0 | 90 | 0 | 90 | 50% Likelihood 100% Mod | Vacant | | 817 | 16.98 portion | CMX | 75 | 1,274 | 38 | 115 | 38 | 191 | 50% Likelihood 60% Res, 40% Com 20% Lower, 60% Mod, 20% Above-Mod | Vacant | | 818 | 7.80 portion | CMX | 75 | 585 | 18 | 53 | 18 | 89 | | Vacant | | 819 | 505-06-074 | 24.05 | RM-2 | W Scott Ave near W Barstow Ave and End of N Ensenada Ave (consolidated sites) | 30 | 735 | 44 | 132 | 44 | 220 | 50% Likelihood 20% Lower, 60% Mod, 20% Above-Mod | Vacant | | 820 | 505-06-066 | 1.33 | | | | | | | | | | | | 505-06-070 | 0.45 | | | | | | | | | | | | | 826 | 505-06-024 | 3.30 | CMX | 6130 W Shaw Ave | 75 | 248 | 37 | 0 | 0 | 37 | 50% Likelihood 60% Res, 40% Com 100% Lower | Vacant | | 827 | 505-06-068 | 5.15 | CMX | 6010 W Shaw Ave | 75 | 387 | 58 | 0 | 0 | 58 | 50% Likelihood 60% Res, 40% Com 100% Lower | Vacant | | 828 | 505-06-067 | 9.20 | CMX | End of W Keats Ave | 75 | 690 | 103 | 0 | 0 | 103 | 50% Likelihood 60% Res, 40% Com 100% Lower | Vacant | | 830 | 508-03-025 | 13.27 | RMX | N Island Waterpark Dr at canal | 90 | 1,194 | 36 | 107 | 36 | 179 | 50% Likelihood 60% Res, 40% Com 20% Lower, 60% Mod, 20% Above-Mod | Vacant | | 831 | 508-03-004 | 5.56 | RMX | 5708 W Shaw Ave | 90 | 500 | 75 | 0 | 0 | 75 | 50% Likelihood 60% Res, 40% Com 100% Lower | Vacant | | 2315 | 508-03-014 | 22.38 | CMX | North of W Shaw Ave, south of Island Waterpark | 75 | 1,678 | 50 | 151 | 50 | 251 | 50% Likelihood 60% Res, 40% Com 20% Lower, 60% Mod, 20% Above-Mod | Vacant | | 2316 | 508-03-026 | 7.23 | RMX | North of W Shaw Ave, south of Island Waterpark | 90 | 651 | 0 | 98 | 0 | 98 | 50% Likelihood 60% Res, 40% Com 100% Lower | Vacant | | 2317 | 508-03-005 | 11.16 | RMX | N Lola Ave at W Shaw Ave | 90 | 1,005 | 30 | 90 | 30 | 150 | 50% Likelihood 60% Res, 40% Com 20% Lower, 60% Mod, 20% Above-Mod | Vacant | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 | 1E-2-55 SECTION 1E-2: SITES INVENTORY | Site ID | APN | Total Parcel Size (Acres) | Zoning | Location/Site Description | Max Density | Total Capacity at Max Density | Inventoried Capacity | | | | Assumptions | Existing Use | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | | | | | | Lower-Income Units | Moderate-Income Units | Above-Moderate Units | Total Units | | | | **Non-Vacant Sites** | | | | | | | | | | | | | | 821 | 505-06-007 | 28.65 | RMX | 5326 N Grantland Ave | 90 | 2,578 | 77 | 232 | 7 | 386 | 50% Likelihood 60% Res, 40% Com 20% Lower, 60% Mod, 20% Above-Mod | Agriculture | | 822 | 505-06-033 | 2.30 | CMX | North of W Shaw Ave and N Bryan Ave intersection | 75 | 173 | 26 | 0 | 0 | 26 | 50% Likelihood 60% Res, 40% Com 100% Lower | Agriculture | | 823 | 505-06-020 | 2.84 | RMX | 6824 W Shaw Ave | 90 | 255 | 38 | 0 | 0 | 38 | 50% Likelihood 60% Res, 40% Com 100% Lower | Residence and trucking | | 824 | 505-06-076 | 16.52 | RMX | 6730 W Shaw Ave | 90 | 1,486 | 45 | 134 | 45 | 224 | 50% Likelihood 60% Res, 40% Com 20% Lower, 60% Mod, 20% Above-Mod | Agriculture and residence | | 825 | 50-506-016S (19.09 acre parcel, split zoning) | 14.93 portion | RMX | W Shaw Ave east of N Grantland Ave | 90 | 1,343 | 40 | 121 | 40 | 201 | 50% Likelihood 60% Res, 40% Com 20% Lower, 60% Mod, 20% Above-Mod | Agriculture | | 2440 | | 4.20 portion | CMX | | 75 | 315 | 9 | 28 | 9 | 46 | | | | 829 | 508-03-027 | 3.62 | RMX | N Island Waterpark Dr | 90 | 325 | 49 | 0 | 0 | 49 | 50% Likelihood 60% Res, 40% Com 100% Lower | Part of parcel vacant | | 2430 | 505-06-041 | 2.31 | CMX | 6556 W Shaw Ave | 75 | 173 | 26 | 0 | 0 | 26 | 50% Likelihood 60% Res, 40% Com 100% Lower | Agriculture | | 2431 | 505-06-042 | 2.12 | CMX | W Shaw Ave north of intersection with N Bryan Ave | 75 | 159 | 24 | 0 | 0 | 24 | 50% Likelihood 60% Res, 40% Com 100% Lower | Agriculture | | 2432 | 505-06-034 | 11.00 | CMX | 6518 W Shaw Ave | 75 | 825 | 124 | 0 | 0 | 124 | 50% Likelihood 60% Res, 40% Com 100% Lower | Agriculture and residence | | 2433 | 505-06-036 | 2.34 | RMX | North of W Shaw Ave & N Grantland Ave intersection | 90 | 210 | 32 | 0 | 0 | 32 | 50% Likelihood 60% Res, 40% Com 100% Lower | Agriculture | | 2434 | 505-06-037 | 3.93 | RMX | 6972 W Shaw Ave | 90 | 353 | 53 | 0 | 0 | 53 | 50% Likelihood 60% Res, 40% Com 100% Lower | Agriculture and farmstand | APPENDIX 1E: CITY OF FRESNO | Site ID | APN | Total Parcel Size (Acres) | Zoning | Location/Site Description | Max Density | Total Capacity at Max Density | Inventoried Capacity | Assumptions | Existing Use | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | | | | | | Lower-Income Units | Moderate-Income Units | Above-Moderate Units | Total Units | | | | 2435 | 505-06-038 | 2.30 | RMX | East of 6972 W Shaw Ave | 90 | 207 | 31 | 0 | 0 | 31 | 50% Likelihood 60% Res, 40% Com 100% Lower | Agriculture | | 2436 | 505-06-034 | 2.30 | CMX | North of W Shaw Ave & N Bryan Ave intersection | 75 | 173 | 26 | 0 | 0 | 26 | 50% Likelihood 60% Res, 40% Com 100% Lower | Agriculture | | 2437 | 505-06-017 | 20.31 | CMX | 6392 W Shaw Ave | 75 | 1,523 | 46 | 137 | 46 | 229 | 50% Likelihood 60% Res, 40% Com 20% Lower, 60% Mod, 20% Above-Mod | Agriculture | | 2438 | 505-06-039 | 0.85 | CMX | West of 6150 W Shaw Ave | 75 | 64 | 10 | 0 | 0 | 10 | 50% Likelihood 60% Res, 40% Com 100% Lower | Agriculture | | 2439 | 505-06-040 | 14.31 | CMX | 6150 W Shaw Ave | 75 | 1,073 | 32 | 97 | 32 | 161 | 50% Likelihood 60% Res, 40% Com 20% Lower, 60% Mod, 20% Above-Mod | Agriculture | | **TOTAL** | | | | | | | **1,177** | **1,585** | **395** | **3,227** | | | *Source: City of Fresno and Ascent, September 2024.* FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-2-57 SECTION 1E-2: SITES INVENTORY Figure 1E-2.6: West Shaw Avenue Town Center Sites, Fresno 2023 <
> Source: City of Fresno and Ascent, June 2023 FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 # Large Site Examples The sites inventory assumes that larger parcels could be further subdivided to create smaller developable sites for housing at a range of income levels. There are several recent developments that serve as examples that this is possible. Table 1E-2.12 depicts recent examples which include below market rate units and the following section provides more detail for each project. ### Table 1E-2.12: Summary of Recent Developments on Large Sites | Project | Total Size (acres) | Deed-Restricted Affordable | Market Rate | Total Units | | :--- | :--- | :--- | :--- | :--- | | Fancher Creek Town Center | 91 acres | 420 | 240 | 660 | | The Vineyards | 38.92 acres | 158 | 0 | 158 | | West Creek Village | 120 acres | 120 | 135 | 255 | | Parc Grove Commons | 24 acres | 213 | 2 | 215 | | Campus Pointe | 27.45 acres | 0 | 550 | 550 | | Avalon Commons | 7.1 acres (total site: 17.8 acres) | 104 | 1 | 105 | *Source: City of Fresno and Ascent, July 2024.* ### Fancher Creek Town Center The Fancher Creek Town Center is a recent example of a large-scale, mixed-use project that provides a mix of affordable and market rate housing integrated into a shopping and employment district, with well over one million square feet of commercial, office, civic, hotel, theater, plaza, recreation, and park uses. The Fancher Creek Town Center encompasses three 2015-2023 Fresno Housing Element Sites (APNs 31302101 at 46.84 acres, 31310124 at 40.08 acres, and 31310122 at 4.14 acres) for a total of 91 acres. The project includes 660 multi-family residential units across three projects: the constructed Brandhaven Senior Affordable Housing with 180 units, the Sarah’s Court Family Affordable Housing with 120 units in Phase 1 (under construction) and an additional 120 units planned, and a planned four-story 240-unit market rate multifamily residential building. This project is an example of a large site that was developed with 63 percent lower-income housing (i.e., 420 affordable units) and 36 percent market rate (240 units). SECTION 1E-2: SITES INVENTORY <
> **Fancher Creek Town Center Site Plan** *Source: City of Fresno, 2024.* ### The Vineyards California Armenian Home Community – Senior Housing California Armenian Home, a not-for-profit corporation, donated 40-acres of land to develop The Vineyards, a continuing care retirement community. The Vineyards opened for residency in January 2018 and includes a total of 158 units featuring 12 resort-style independent living villas with two car garages, 60 independent living apartments, and 50 assisted living and 36 memory care apartments. The Vineyards was developed on a prior 2015-2023 Fresno Housing Element Site (APN 31328043) at 22.22 acres. The Vineyards also offers outdoor amenities such as gardens, courtyards, patios, sheltered walkways, open park space, fountains, and large outdoor pavilions. APPENDIX 1E: CITY OF FRESNO <
> **Image of The Vineyard** *Source: Life at the Vineyards.* ### West Creek Village The West Creek Village Project is a 120-acre multi-phase mixed-use project consisting of single-family homes, multi-family mixed-income housing, a new community park and approximately 323,000 square feet of medical, business, and retail. All three phases of the West Creek Villages are planned on an 18-acre site. All properties were annexed into the city after the 2015-2023 Housing Element. The overall project was conceived from the Southwest Fresno Specific Plan adopted in 2017. The West Creek Village project includes the built West Fresno Center – Fresno City College (600 E Church Avenue), entitled/permits issued City of Fresno community park, proposed commercial, approved tract map for Emerald Creek single family residential (134 units) subdivision, and entitled Phase 1 of the Villages at West Creek by Self Help Enterprises with 121 supportive multi-family housing units (120 affordable units and 1 market rate manager’s unit) consisting of 38 one bedroom, 51 two bedrooms and 32 three bedrooms. The Villages at West Creek assumes 53 percent of the restricted units will serve households with incomes less than 30 percent of AMI; 11 percent for households with incomes less than 50 percent of AMI; and 36 percent for households earning less than 60 percent of AMI; and 1 percent will be a manager’s unit. Additionally, the project will set aside a minimum number of units for farmworkers and those impacted by homelessness. SECTION 1E-2: SITES INVENTORY <
> West Creek Village Site Plan Source: City of Fresno, 2024. Blue Ocean Development, 2021. APPENDIX 1E: CITY OF FRESNO # Parc Grove Commons Parc Grove Commons, a two- and three-story affordable housing community consisting of 215 units in 32 buildings, was developed in two-phases in 2011 and 2014 by the Fresno Housing Authority. This development is all residential on a 24-acre site made up of four parcels (10.63, 7.73, 4.51, and 1.74 acres respectively). Parc Grove Commons has 67 extremely and very low-income units, 146 low-income units, and 2 manager’s units. <
> **Parc Grove Commons Site Plan** *Source: City of Fresno, 2024.* FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-2-63 SECTION 1E-2: SITES INVENTORY # Campus Pointe Campus Pointe is a 48.18-acre horizontal mixed-use development containing senior and student housing owned by Fresno State University and a local developer. The 550 units of residential was built in four phases. Phase one residential was the Palazzo at Campus Pointe apartments built in 2009 on 11.18 acres (244 units). Phase two residential was the Palmilla at Campus Pointe apartments built in 2012 is on 5.74 acres (144 units). Phase three residential was the Maravillosa-Luxury Senior Living apartments built in 2021 on a 3.66-acre site (142 units). Phase 4 residential, on a 6.56-acre site, is under construction is an extended stay Hyatt House with 138 rooms offering condo-like living and is scheduled for completion in 2025. The retail portion of the development was built in 2015 and includes 20.73 acres plus parking. <
> | PRELIMINARY PROJECT STATISTICS: | | | | :--- | :--- | :--- | | | **SQ. FOOTAGE** | **PARKING** | | **RETAIL** | | | | RETAIL | 150,000 sf | | | THEATER | 50,000 sf (14 screens) | | | OFFICE / LOFTS | 30,000 sf | | | PARKING | | | | REQUIRED | | 1,500 cars | | PROVIDED | | 1,546 cars | | **HOTEL** | | | | MEETING FAC. | 10,000 sf (200 keys) | | | RESTAURANT | 6,500 sf | | | PARKING | | 371 cars | | **HOUSING** | | | | STANDARD | 309,000 sf (216 units) | | | REC. LEASING | 9,000 sf | | | PARKING | | 573 cars | | WORK FORCE | 130,000 sf (144 units) | | | REC. LEASING | 5,000 sf | | | PARKING | | 226 cars | | SENIOR | 200,000 sf (190 units) | | | PARKING | | 480 cars | **Campus Pointe Site Plan** *Source: City of Fresno, 2024.* APPENDIX 1E: CITY OF FRESNO # Avalon Commons Avalon Commons is a 105-unit affordable multi-family housing project by Fresno Housing utilizing Low Income Housing Tax Credits (LIHTC) and No Place Like Home (NPLH) funding. The project is located at Chestnut and Alluvial Avenue in northeast Fresno. The original site was approximately 18 acres and was subdivided into two parcels, an 11.5-acre parcel for Rocky Ranch luxury apartments and a 7.1-acre site for Avalon Commons. Avalon Commons was approved and entitled on June 25, 2022. Construction is underway with a slated completion date of July 1, 2025. There will be two phases of this development. Phase I contains 60 units, including 59 affordable units. Phase II will include 45 affordable units. # AB 725 Compliance Assembly Bill 725 (2021) – which requires that at least 25 percent of the remaining above moderate-income RHNA be accommodated on sites that have a density standard that allows at least four units of housing, and that at least 25 percent of the remaining moderate-income RHNA be accommodated on sites that allow at least four units of housing but a density of no more than 100 units per acre. After counting the units in planned and approved projects and final subdivision maps, the remaining RHNA is 13,830 above moderate-income units and 4,597 moderate-income units. In order to comply with AB 725, the sites inventory must include 3,458 above moderate-income units and 1,149 moderate-income units on sites meeting the above mentioned criteria. The Housing Element sites inventory meets the requirements of AB 725 through the following: * Sites smaller than 0.5 acres that are zoned as high density residential (RM-2, RM-3), mixed use and commercial (NMX, CMX, RMX, CR, CMS), and Downtown districts (DTN, DTC, DTG, DTG-AH) are counted toward the above moderate-income inventory. All of these sites have zoning that allows at least four units of housing. * Sites larger than 10 acres and all sites within the West Shaw Avenue Town Center that meet the default density standard for lower-income RHNA (i.e., 30 units per acre) are counted in the sites inventory with a mix of incomes, generally 20 percent lower-income, 60 percent moderate-income, and 20 percent above moderate-income. This assumption helps to ensure the inventory complies with AB 725. * The moderate-income RHNA is met on sites within the RM-2 and RM-MH zones, both of which allow at least four units of housing per site but are well below the 100 units per acre maximum identified in AB 725. Table 1E-2.12 below summarizes how the Housing Element complies with AB 725. The sites inventory includes capacity for 3,483 above moderate-income units on sites complying with AB 725 criteria, which exceeds the target of 3,458 above moderate-income units; and the inventory includes capacity for 4,756 moderate-income units on sites complying with AB 725 criteria, which also exceeds the target of 1,149 moderate-income units. SECTION 1E-2: SITES INVENTORY Table 1E-2.13: AB 725 Compliance | Capacity (Units) | Above Moderate Income | Moderate Income | | :--- | :--- | :--- | | **RHNA** | **15,904** | **5,638** | | Approved Projects | 1,107 | 1,041 | | Final Subdivision Maps | 967 | - | | Remaining RHNA | *13,830* | *4,597* | | **25% of Remaining RHNA (AB 725 Target)** | **3,458** | **1,149** | | **Capacity on Qualifying Sites** | **3,483** | **4,756** | *Source: City of Fresno and Ascent, 2024.* APPENDIX 1E: CITY OF FRESNO Figure 1E-2.7: Sites Inventory, City of Fresno, 2024 <
> Source: City of Fresno and Ascent, September 2024. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-67 SECTION 1E-2: SITES INVENTORY This page intentionally left blank. # Sites Identified in Previous Housing Elements Per statute (Government Code Section 65583.2I), a non-vacant site identified in the previous planning period and a vacant site that has been included in two or more previous consecutive planning periods can only be used to accommodate the lower income RHNA if the site is subject to a program in the housing element allowing residential development by right for housing developments in which at least 20 percent of the units are affordable to lower-income households. Several sites included in the inventory for lower-income housing have been included in previous housing element planning periods. However, the City cannot easily distinguish which vacant sites were included in the Fourth Cycle Housing Element lower-income sites inventory. The sites inventory identifies all sites – vacant and non-vacant – that were included in the Fifth Cycle Housing Element and applies the by-right policy to all the identified lower-income sites. These sites are identified in Table 1E-7.1 and Table 1E-7.2 in Section 1E-7 (Detailed Sites Inventory Tables). The Housing Element includes a policy that commits the City to allowing residential use by right on these sites when at least 20 percent of the units are affordable to lower income households. # Accessory Dwelling Units Per state law, a projection of the number of ADUs expected to be built within the eight-year planning period can also be considered as part of the inventory. The City has seen an increase in ADU production in recent years, particularly since 2018 when the state passed several bills to facilitate ADUs statewide. Table 1E-2.14 shows the total number of ADU building permits issued by year since 2018, which equates to an average of 11 ADUs per year. For the purpose of the Housing Element, it is assumed that ADU production will continue at the same pace experienced since 2018, resulting in 94 ADUs counted toward the 2023-2031 RHNA (8.5 year planning period). The City has included a program to monitor compliance with State law and facilitate construction of ADUs. Table 1E-2.14: ADU Building Permits, 2018-2023 | Year | ADU Permits Issued | | :--- | :--- | | 2018 | 2 | | 2019 | 4 | | 2020 | 6 | | 2021 | 19 | | 2022 | 22 | | Average | 11 | | Projected ADUs | 94 | *Source: City of Fresno and Ascent, 2023.* SECTION 1E-2: SITES INVENTORY Because regional affordability analysis of ADUs was not available for Fresno County, the City applied rental rates for one- and two-bedroom units as a proxy for ADU rental rate. According to 2017-2021 ACS 5-year estimates, the median gross rent for one-bedroom units in Fresno is $873 per month, and $941 per month for two-bedroom units. Low-income households in Fresno County can afford between $1,091 (one-person households) and $1,558 (four-person households) in monthly housing costs without being cost burdened (see Table 2-24). Comparing rental rates with the affordability of low-income households demonstrates that ADUs are appropriate to credit toward the City’s lower-income RHNA, based on the median price of one- and two-bedroom units. However, the City has decided to take a conservative approach and assume that 30 percent of ADUs will be affordable to lower-income households, 40 percent affordable to moderate-income households, and 30 percent affordable to above moderate-income households. Based on this methodology, the sites inventory includes a projection of 94 ADUs, including 28 affordable to lower-income households, 38 affordable to moderate-income households, and 28 affordable to above moderate-income households. ## RHNA Summary Table 1E-2.15 provides a summary of Fresno’s ability to meet the 2023-2031 RHNA of 36,866 housing units. Within the city limits, available vacant and underutilized sites are adequate to accommodate the RHNA for all income categories. The city has capacity for 18,783 lower-income units, which is 3,459 lower-income units in excess of the lower-income RHNA. Table 1E-2.15: RHNA Summary, Fresno, September 2024 | Project | Units by Income Level | | | | Total Units | | :--- | :--- | :--- | :--- | :--- | :--- | | | **VLI** | **LI** | **MI** | **AMI** | | | 2023-2031 RHNA | 9,440 | 5,884 | 5,638 | 15,904 | 36,866 | | Planned or Approved Projects (Table 1E-2.3) | 292[^p136-1] | 317 | 1,041 | 1,107 | 2,757 | | Vacant Land with Final Subdivision Maps Under Construction (Table 1E-2.4) | 0 | 0 | 0 | 967 | 967 | | Capacity on Vacant Sites (Table 1E-7.1) | | 11,111 | 3,096 | 8,025 | 22,232 | | Capacity on Underutilized Non-vacant Sites (Table 1E-7.2) | | 7,035 | 2,488 | 8,127 | 17,650 | | Accessory Dwelling Units (Table 1E-2.13) | | 28 | 38 | 28 | 94 | | Total Capacity | | 18,783 | 6,664 | 18,254 | 43,700 | | Surplus/Shortfall | | 3,459 | 1,026 | 2,350 | 6,834 | VLI = Very-low Income, LI = Low-income, M = Moderate-income, AM = Above-moderate Income [^p136-1]: Includes Extremely-low Income and VLI units Source: City of Fresno and Ascent, 2024. APPENDIX 1E: CITY OF FRESNO # Availability of Infrastructure and Services Realistic site development potential indicated in the sites inventory is consistent with the development capacity reported in the Fresno General Plan Urban Form, Land Use, and Design Element. Full urban-level services are available throughout the city and specifically to each site in the inventory. Such services are more than adequate for the potential unit yield on each site. Specifically, water and sewer services are available or are programmed to be made available for all the sites included in the inventory, indicating the capacity to accommodate the City’s total share of the RHNA. ## Infrastructure Current Availability The City of Fresno Department of Public Utilities (DPU) provides potable water to the majority of the city and non-potable water to a small portion of the city for irrigation. The city currently receives water from four water supply sources: 1. Surface water that is delivered to the city by two separate sources: a. Fresno Irrigation District (FID) Agreement for Kings River water. b. United States Bureau of Reclamation (USBR) Central Valley Project (CVP) Friant Division Contract for San Joaquin River water. 2. Groundwater that is pumped from wells located within the city. 3. Recycled water that is treated at the Fresno-Clovis Regional Wastewater Reclamation Facility (RWRF) and North Fresno Wastewater Reclamation Facility (NFWRF). This water may be used for non-potable uses. The City’s 2020 Urban Water Management Plan (UWMP) demonstrates that under normal water year, single dry water year, and five-year consecutive drought, the City’s water supplies are adequate to meet projected demands. The UWMP analysis includes current water demands within the city as well as anticipated water demands associated with future development projects and planning areas within the Fresno General Plan Sphere of Influence (SOI) through 2045. The City has always met system water demand and regardless of regional hydrology is projected to meet existing and future water demands. The City has adopted long-range capital and strategic programs through the City of Fresno Metro Plan, City of Fresno Recycled Water Master Plan, and City of Fresno Wastewater Master Plan. The City has also adopted the State’s 2013 CalGreen Building Code, Model Water Efficient Landscape Ordinance, and Graywater Standards, which combine for a 10- to 20-percent reduction in water use in most new construction. General Plan Policy RC-6-b directs the City to adopt and implement ordinances, standards, and policies to achieve the intent of the City of Fresno Urban Water Management Plan, Fresno-Area Regional Groundwater Management Plan, and City of Fresno Metropolitan Water Resources Management Plan to ensure a dependable supply of water. General Plan Policy RC-6-c directs land use and development projects to adhere to the objective of the Fresno Metropolitan Water Resources Management Plan to provide sustainable and reliable water supplies to meet the demand of existing and future customers through 2045. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-2-71 SECTION 1E-2: SITES INVENTORY The City completed construction on the 80-mgd Southeast Surface Water Treatment Facility (SESWTF) in 2018, while the City’s Northeast Surface Water Treatment Facility (NESWTF) currently has a 30-mgd capacity and the capability to expand up to 60 mgd. The City is also planning to develop additional groundwater recharge facilities that would optimize use of available surface water supplies in normal and wet years. The timing for the NESWTF expansion and the development of additional groundwater recharge facilities will be examined as part of the City’s future Metro Plan update and determined based on need as the city grows and demands increase. The City also plans to continue expanding its recycled water distribution system to offset potable water demands. A substantial reduction in water demand followed the completion of residential meter installation in 2013 combined with drought restrictions and water conservation messaging. As a result, demand has averaged roughly 120,000 acre-feet per year (afy) for 2018 to 2020 instead of growing to roughly 170,000 afy by 2020 as projected in the 2014 Metro Plan. The increase in use of surface water supplies combined with decrease in demands through conservation is allowing the groundwater basin to recover. These developments positioned the City to participate in development of the North Kings Groundwater Sustainability Plan (GSP) and to meet the requirements of the 2014 Sustainable Groundwater Management Act (SGMA). The City of Fresno is the regional sewer agency for the Fresno-Clovis Metropolitan Area. The City owns and maintains the wastewater collection system that serves the city and the other participating agencies. The City also owns and operates the Fresno-Clovis Regional Wastewater Reclamation Facility (RWRF), located southwest of the city, and the North Fresno Water Reclamation Facility. The City of Fresno Department of Public Utilities (DPU) manages the sewer system through the implementation of the sewer maintenance program provided in its Sewer System Management Plan and the construction of sewer development projects recommended in its Wastewater Collection System Master Plan (Master Plan). The Master Plan evaluates sewer system capacity under existing and anticipated future conditions based on the buildout of development to the City’s SOI as represented in the Fresno General Plan. The 2015 Master Plan incorporated all of the recommended sewer projects into a Capital Improvement Program for implementation to 2025. The City of Fresno has been regularly implementing various elements of the Capital Improvement Program since the adoption of the Master Plan. The capacity analysis conducted in the 2015 Master Plan determined that the collection system has sufficient capacity to convey Base Water Flow, Peak Dry Weather Flow, and Peak Wet Weather Flow. However, there were a few areas where deficiencies were found in the existing and future sewer collection system capacity and improvement projects were recommended. Most improvements identified were driven by future development, which consist of new sewers that serve future growth or improvements to existing facilities that are needed to serve future growth. The City’s first priority is to upgrade existing facilities and then build new trunks to serve future users. Improvement projects in the Master Plan were organized into four phases spanning from 2014 through 2030. General Plan Objective PU-4 directs the City to ensure provision of adequate trunk sewer and collector main capacities to serve existing and planned urban development, consistent with the Wastewater Master Plan. Supporting polices include continued coordination and consultation with the City of Clovis, to plan and construct sewer collection facilities, pursuing construction of new or replacement sewer trunk facilities or other alternatives consistent with the Wastewater Master Plan, and pursuing enlargement or extension of the sewage collection system to serve planned urban development. The permitted wastewater treatment capacity of the RWRF is currently 91.5 million gallons per day (mgd) as an annual monthly average flow, and 101 mgd as a maximum monthly average flow. The 2015 Master Plan determined the existing annual monthly average flow at the RWRF to be about 64.7 mgd. Therefore, the RWRF has sufficient capacity for existing influent flows and to accommodate growth for several years to come. Nonetheless, the City is required by State statutes to begin planning for increased capacity when flows reach 75 percent of the current design capacity. Additionally, in 2017, Phase I of a tertiary treatment system was completed at the RWRF. The current design flow for the tertiary treatment system is 5.0 mgd but can be expanded in two subsequent phases to 15 mgd (Phase II) and ultimately 30 mgd (Phase III). The City of Clovis maintains the rights and capacity to discharge 9.3 mgd to the facility. The City of Fresno maintains the rights to the remaining capacity. ### Infrastructure Future Availability The Fresno General Plan Program Environmental Impact Report (PEIR), adopted July 2021, identified the need for the expansion of existing and development of new water supply and wastewater collection infrastructure and treatment facilities. These improvements are based on build out of the General Plan. While the sites inventory represents a fraction of General Plan build out, infrastructure improvements will ensure adequate level of water and wastewater services to future development on identified sites. To address water supply capacity for the General Plan 2035 horizon, the City, by approximately 2025, will construct an approximately 30-mgd expansion of the existing northeast surface water treatment facility, an approximately 20-mgd surface water treatment facility in the southwest portion of the city, a 25,000 acre-feet/year tertiary recycled water expansion to the RWRF, 65 new groundwater wells, a 2.0 million gallon potable water reservoir (Water Storage Tank T2) near the intersection of Clovis and California Avenues, a 4.0 million gallon potable water reservoir (Water Storage Tank T5) near the intersection of Ashlan and Chestnut Avenues, a 4.0 million gallon potable water reservoir (Water Storage Tank T6) near the intersection of Ashlan Avenue and Highway 99, 50.3 miles of regional water transmission mains ranging in size from 24-inch to 48-inch, and 95.9 miles of 16-inch transmission grid mains. To address wastewater capacity, for the General Plan 2035 horizon, the City, by approximately 2025, will construct an approximately 70 million gallons per day (mgd) expansion of the RWRF and approximately 0.49-mgd expansion of the North Facility and a 24 mgd wastewater treatment facility within the Southeast Development Area, and a 9.6 mgd expansion at the RWRF. By approximately after the year 2025, the City will construct a 24 mgd wastewater treatment facility within the Southeast Development Area, and a 9.6 mgd expansion at the RWRF. The City will also construct capacity improvements along sewer trunk lines. SECTION 1E-2: SITES INVENTORY The Housing Element is consistent with adopted General Plan land use policy. As determined in the PEIR for the General Plan, planned infrastructure improvements will ensure sufficient future water and sewer capacity to accommodate the planned development, including the identified housing need (RHNA). ## Environmental Constraints and Hazards Below is a description of potential environmental constraints and hazards pertinent to the city of Fresno and how they relate to the sites in the inventory. ### Flooding The Federal Emergency Management Agency (FEMA) develops flood maps that identify areas with the highest risk of flooding. Figure 1E-2.8 shows the locations of the existing FEMA 100-year flood zones in the city of Fresno with the Housing Element sites. While the majority of the sites in the inventory are not within a 100-year flood zone, 28 sites are within this zone (see Table 1E-7.1 and Table 1E-7.2). Siting a development in a 100-year flood zone is not an impediment to construction because a minimal amount of fill can be added to the site to mitigate the potential flood risk. Construction can occur as long as the completed floor level is one foot above flood elevation. These sites must also comply with the City’s Flood Plain Ordinance, which protects against risk to new and existing development by requiring any building proposed within a special flood hazard area to obtain a building permit and provide information specifically related to flood risk. The permit is reviewed by the Building Official, who has been designated as the Flood Plain Administrator, to ensure that the project will be reasonably safe from flooding and will not adversely increase flood risk elsewhere. Therefore, the presence of a 100-year flood zone will not preclude development on any of the sites in the inventory or expose future residents to potential harm. ### Airport Safety Zones There are two public airports in the city, Fresno-Yosemite International Airport and Fresno Chandler Executive Airport, and one private airport open to public use, Sierra Sky Park. The Fresno County Airport Land Use Commission (ALUC) provides guidance to local jurisdictions on determining appropriate and compatible adjacent land uses through an Airport Land Use Compatibility Plan (ALUCP). The ALUCP establishes six airport safety zones to identify the areas surrounding an airport that could be impacted by an airport accident (see Figure 1E-2.9). Each of the six zones have land use compatibility standards that restrict the development of land uses that could pose particular hazards to the public or to vulnerable populations in case of an aircraft accident. The accident risk level is highest within Zone 1 (Runway Protection Zone) and diminishes with each subsequent zone, with Zone 6 (Traffic Pattern Zone) having the lowest accident risk level. Structures of any kind (except for ones set by aeronautical function) are prohibited in Zone 1. Residential development is limited to very low density residential in Zones 2, 3, 4 and 5. There are no limits on residential in Zone 6 areas. APPENDIX 1E: CITY OF FRESNO There are a number of sites in the inventory that are within zones that prohibit or severely limit residential development (i.e., Zones 1, 2, 3. and 4), making development on these sites infeasible or not possible and should be removed from the inventory (see Figure 1E-2.9). The ALUC recently (October 2, 2023) approved the adoption of an amended Airport Influence Area (AIA) for the Fresno-Chandler Executive Airport that changed the boundaries of the airport safety zones. Upon receiving this new data, the sites inventory was updated to remove sites within Zones 1-4 of the new AIA for Fresno-Chandler Executive Airport. ## Other Constraints and Hazards In terms of other potential constraints, a small portion of the city north of Cooper Avenue is within a Military Training Flight Route, where there are a few above moderate and lower-income sites in the inventory. The City is required to send development applications under training routes to the military for review and comment. The military then reviews the development application for compatibility with surrounding military activities and submits any comments to the City. This process would not preclude development on these sites and the referral process has not resulted in delays or other barriers to development. Wildfire threats are minimal in the city, as the city lacks steep topographies and is largely urbanized or made up of working agricultural land. The city is not located within a very high fire hazard severity zone and therefore no sites in the Housing Element are at risk. Williamson Act contracts, which allow local governments to enter into contracts with private landowners for the purpose of restricting specific parcels of land to agricultural or related open space use is another potential constraint to residential development. However, none of the sites in the inventory have Williamson Act contracts. There are no other known environmental constraints or conditions within the city that could preclude development on identified sites within the planning period, including hazards, and related land use controls, shape, access, property conditions, contamination, easements, or overlays. However, there are some areas with existing industrial uses, specifically in Southwest Fresno, that are transitioning to facilitate more residential and mixed use development. Based on public comments, the City closely reviewed sites in this area and removed sites that would be most impacted by existing industrial uses during the Housing Element planning period. SECTION 1E-2: SITES INVENTORY ## Figure 1E-2.8: Environmental Constraints and Hazards, 100-year Flood Zones, Fresno 2023 <
> *Source: City of Fresno and Ascent, October 2023. APPENDIX 1E: CITY OF FRESNO Figure 1E-2.9: Environmental Constraints and Hazards, Airport Safety Zones, Fresno 2023 <
> Source: City of Fresno and Ascent, October 2023. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-2-77 SECTION 1E-2: SITES INVENTORY # Financial Resources The City utilizes several sources of funding to assist in the provision of quality housing to lower-income residents (see Table 1E-2.16 and Table 1E-2.17 for a list of available funding mechanisms in Fresno). Several funding programs from the U.S. Department of Housing and Urban Development (HUD) allow the City to fund community development and housing activities. The City of Fresno receives federal funding as an entitlement jurisdiction for the Community Development Block Grant (CDBG), HOME Investment Partnerships (HOME) program, Emergency Solutions Grant (ESG), and Housing for Persons with HIV/AIDS (HOPWA) funds from HUD. Table 1E-2.16 shows funds received through these programs for the years 2019 through 2022. On average the City received about $7 million in CDBG, $3.3 million in HOME, $600,000 in ESG, and nearly $700,000 in HOPWA funds during this timeframe. The City also received Permanent Local Housing Allocation (PLHA) in 2020 and 2021 and Homeless Housing Assistance and Prevention (HHAP) in 2020 through 2022. Other one-time sources of funding in recent years included CARES Act, American Rescue Plan funds, and Encampment Resolution funds to prevent, prepare for, and respond to the spread of COVID-19 during the pandemic; prevent eviction; and address homeless encampments and emergency shelter. Affordable housing developers are eligible for several federal and state funding programs. Three of the most significant programs include the Low-Income Housing Tax Credit (LIHTC) program, Affordable Housing and Sustainable Communities (AHSC) program, and Project Homekey. Created by the 1986 Tax Reform Act, the LIHTC program has been used in combination with City and other resources to encourage new construction and rehabilitation of rental housing for lower-income households. The program provides investors an annual tax credit over a 10-year period, provided that the housing meets the following minimum low-income occupancy requirements: 20 percent of the units must be affordable to households at 50 percent of AMI or 40 percent of the units must be affordable to those at 60 percent of AMI. The total credit over the 10-year period has a present value equal to 70 percent of the qualified construction and rehabilitation expenditure. The tax credit is typically sold to large investors at a syndication value. The AHSC program, funded through the State’s Cap and Trade program, provides an additional source of funding for affordable housing. This program awards funding to both public and private entities to build transit-oriented affordable housing and supporting transportation infrastructure, such as pedestrian improvements and bike lanes. The program awards are determined with a points formula; 0.25 points are awarded to projects which directly implement a policy in a long-range planning document (e.g., General Plan, Specific Plan), including new development on sites contained within the housing element’s sites inventory. Project Homekey leverages a combination of federal and state funding streams to provide grant funding to projects that will provide interim or permanent housing options for people experiencing homelessness or who are at risk of severe illness from COVID-19. This program awards funding to public entities for the acquisition and rehabilitation of a variety of housing types – including hotels, motels, vacant apartment buildings, and residential care facilities. Funding is allocated by region based on the region’s proportionate shares of people experiencing homelessness (indicated by 2021 Homeless Point-in-Time Counts) and severely cost-burdened extremely low-income households. APPENDIX 1E: CITY OF FRESNO Table 1E-2.16: Housing Funding Resources, City of Fresno, 2019-2022 | Funding Program | 2019 | 2020 | 2021 | 2022 | Average | Description | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | Community Development Block Grant (CDBG) | $6,942,458 | $7,112,639 | $7,184,218 | $6,839,072 | $7,019,597 | Fair housing, public services, senior paint program, owner-occupied rehab, park improvements, neighborhood street improvements, micro enterprise, section 108 loan repayment | | HOME Investment Partnerships (HOME) | $3,037,353 | $3,255,075 | $3,289,681 | $3,625,073 | $3,301,796 | Affordable housing development, CHDO, TBRA | | Emergency Solutions Grant (ESG) | $585,863 | $610,018 | $606,586 | $603,908 | $601,594 | Outreach/emergency shelter, homeless prevention, rapid rehousing, HMIS | | Housing for Persons with HIV/AIDS (HOPWA) | $564,747 | $636,124 | $714,258 | $875,943 | $697,768 | Services for low-income persons living with HIV/AIDS and their families | | Permanent Local Housing Allocation (PLHA) | - | $3,407,603 | $5,296,470 | - | $4,352,037 | Affordable housing development, first time homebuyer assistance, home repair (mobile homes) | | Homeless Housing Assistance and Prevention (HHAP) | - | $6,158,246 | $2,911,171 | $7,524,257 | $5,531,225 | Shelter services and street outreach | | Community Development Block Grant CARES Act (CDBG-CV) | - | $7,980,086 | - | - | N/A | Shelter operations, medical clinic investments, medical clinic operations, tenant/landlord counseling, shelter acquisition/conversion/rehab | | Emergency Solutions Grant CARES Act (ESG-CV) | - | $10,948,953 | - | - | N/A | Deposit assistance, shelter operations, street outreach, HMIS | | HOME American Rescue Plan (HOME-ARP) | - | - | $11,922,873 | - | N/A | Affordable housing development, supportive services, acquisition, and development of non-congregate shelters | | Low Income Housing Trust Fund (LHTF) | - | - | $5,000,000 | - | N/A | Affordable housing development | | American Rescue Plan Act (ARPA) | - | - | $14,200,000 | - | N/A | Affordable housing development and landlord incentives | | Encampment Resolution Funding (ERF) | - | - | - | $5,070,058 | N/A | Encampment resolution and shelter | Source: City of Fresno and Ascent, 2022 SECTION 1E-2: SITES INVENTORY ### Table 1E-2.17: Other Financial Resources and Programs | Program Name | Description | Eligible Activities | | :--- | :--- | :--- | | **Federal Programs** | | | | Community Development Block Grant (CDBG) | Grants administered and awarded by the state on behalf of the United States Department of Housing and Urban Development (HUD) to cities through an annual competitive process. | Acquisition Rehabilitation
Homebuyer Assistance
Economic Development
Infrastructure Improvements
Homeless Assistance
Public Services | | HOME Investment Partnership Act Funds | Flexible grant program for affordable housing activities awarded by the state on behalf of HUD to individual cities through an annual competitive process. | Acquisition
Rehabilitation
Homebuyer Assistance
New Construction | | Section 8 Rental Assistance Program | Rental assistance payments to owners of private market-rate units on behalf of very low-income families. | Rental Assistance | | Section 203(k) | Single-family home mortgage program allowing acquisition and rehabilitation loans to be combined into a single mortgage. | Land Acquisition
Rehabilitation
Relocation of Unit
Refinancing of Existing Indebtedness | | **State Programs** | | | | Emergency Shelter Grant Program | Program funds to rehabilitate and operate emergency shelters and transitional shelters, provide essential social services, and prevent homelessness | Support Services
Rehabilitation
Transitional Housing
Supportive Housing | | Rural Development Loans and Grants | Capital financing for farmworker housing. Loans are for 33 years at 1 percent interest. Housing grants may cover up to 90 percent of the development costs of housing. Funds are available under the Section 515 (Rental Housing), Section 502 (Homeownership Loan Guarantee), Section 514/516 (Farm Labor Housing), and Section 523 (Mutual Self-Help Housing) programs. | Purchase
Development/Construction
Improvement
Rehabilitation | | Multifamily Housing Program (MHP) | Deferred payment loans for new construction, rehabilitation, acquisition, and preservation of permanent and transitional rental housing. | New Construction
Rehabilitation
Acquisition
Preservation | | Program Name | Description | Eligible Activities | | :--- | :--- | :--- | | California Housing Finance Agency (Cal HFA) Residential Development Loan Program | Low interest, short-term loans to local governments for affordable infill, owner-occupied housing developments. Links with CalHFA’s Down Payment Assistance Program to provide subordinate loans to first-time buyers. Two funding rounds per year | New Construction
Rehabilitation
Acquisition | | California Housing Finance Agency (Cal HFA) Homebuyer’s Down Payment Assistance Program | The Forgivable Equity Builder Loan gives first-time homebuyers a head start with immediate equity in their homes via a loan of up to 10% of the purchase price of the home. The loan is forgivable if the borrower continuously occupies the home as their primary residence for five years. | Homeowner Assistance | | Low-Income Housing Tax Credit (LIHTC) | Tax credits are available to persons and corporations that invest in low-income rental housing. Proceeds from the sale are typically used to create housing. | New Construction
Rehabilitation | | California Self-Help Housing Program | Grants to cities and nonprofit developers to offer homebuyer assistance, including down payment assistance, rehabilitation, acquisition/rehabilitation, and homebuyer counseling. Loans to developers for property acquisition, site development, predevelopment, and construction period expenses for homeownership projects | Predevelopment, Site Development, Site Acquisition
Rehabilitation
Acquisition/rehab
Down Payment Assistance
Mortgage Financing
Homebuyer Counseling | | Tax Exempt Housing Revenue Bond | Supports low-income housing development by issuing housing tax-exempt bonds requiring the developer to lease a fixed percentage of the units to low-income families at specified rental rates. | New Construction
Rehabilitation
Acquisition | | Affordable Housing Sustainable Communities Program (AHSC) | This program provides grants and/or loans, or any combination, that will achieve GHG emissions reductions and benefit Disadvantaged Communities through increasing accessibility of affordable housing, employment centers, and key destinations via low-carbon transportation. | New Construction | | **Local Programs** | | | | Habitat for Humanity Greater Fresno Area | Homeownership through sweat equity. Homeowners also receive counseling and training on homeownership and maintenance. Homeowners buy their completed homes from Habitat for Humanity and repay them over 30 years through an affordable mortgage. | Homebuyer Assistance
Homebuyer Counseling | SECTION 1E-2: SITES INVENTORY | Program Name | Description | Eligible Activities | | :--- | :--- | :--- | | Fresno County Housing Assistance Rehabilitation Program (HARP) | Provides loans to eligible low and moderate income homeowners to rehabilitate their affordable homes in the unincorporated area and partner cities to bring the homes up to current building code health and safety standards. Loans are currently zero interest with affordable monthly payments based on the family's income. | Rehabilitation | | Fresno County Rental Rehabilitation Program (RRP) | Provides loans to eligible rental housing owners with low-/mod-income tenants, to rehabilitate affordable rental units in the unincorporated area and partner cities, to bring the rental units up to current building code health and safety standards. Loans are zero interest and amortized over 20 to 30 years (with a balloon payment at 20 years), based upon the income of the rental-housing owner and the case flow of the rental project | Rehabilitation | | Fresno County Homebuyer Assistance Program (HAP) | Provides homebuyer down payment and mortgage assistance loans to enable eligible low- and moderate-income families to purchase their first home in the unincorporated area and partner cities. Homes to be purchased must meet current building code health and safety standards. Loans are zero interest with payments deferred for 30 years or until the primary mortgage is fully paid, whichever occurs first. | Homebuyer Assistance | | Fresno County Affordable Housing Development Program (AHDP) | Provides gap-financing loans to nonprofit organizations and other eligible developers to construct new affordable housing, including multi-family rental housing projects and single-family owner-occupied housing projects. May also be used to substantially rehabilitate existing affordable housing projects. | New Construction
Rehabilitation | | Fresno County Mobilehome Park Program (MPP) | Provides zero-interest loans to help finance the preservation of affordable mobile home parks and development of new affordable mobile home parks. | New Construction
Acquisition and Preservation | | | **Private Resources/Lender/Bank Financing Programs** | | | Federal National Mortgage Association (Fannie Mae) Community Homebuyers Program | Fixed rate mortgages issued by private mortgage insurers. | Homebuyer Assistance | | | Mortgages that fund the purchase and rehabilitation of a home. | Homebuyer Assistance
Rehabilitation | | | Low down payment mortgages for single-family homes in underserved low-income and minority cities. | Homebuyer Assistance | APPENDIX 1E: CITY OF FRESNO | Program Name | Description | Eligible Activities | | :--- | :--- | :--- | | California Community Reinvestment Corporation (CCRC) | Nonprofit mortgage banking consortium designed to provide long-term debt financing for affordable rental housing. Nonprofit and for-profit developers contact member banks. | New Construction
Rehabilitation
Acquisition | | Federal Home Loan Bank Affordable Housing Program | Direct subsidies to nonprofit and for-profit developers and public agencies for affordable low-income ownership and rental projects. | New Construction | | Freddie Mac | Home Works: Provides first and second mortgages that include rehabilitation loan. County provides gap financing for rehabilitation component. Households earning up to 80% MFI qualify | Homebuyer Assistance combined with rehabilitation | | Northern California Community Loan Fund (NCCLF) | Offers low-interest loans for the revitalization of low-income communities and affordable housing development | Acquisition
Rehabilitation
New Construction | | Low-Income Investment Fund (LIHF) | Provides below-market loan financing for all phases of affordable housing development and/or rehabilitation. | Acquisition
Rehabilitation
New Construction | *Source: City of Fresno and Ascent, June 2023.* SECTION 1E-2: SITES INVENTORY This page is intentionally left blank. APPENDIX 1E: CITY OF FRESNO # SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ## Introduction Land use policies and planning directly impact the ability of individuals and families to live in neighborhoods that offer high levels of opportunity. This includes access to high-performing schools, availability of jobs, and safe convenient access to transit and services. Despite the long-standing federal mandate established by the Fair Housing Act (FHA)[^p151-1] – which prohibits discrimination concerning the sale, rental, and financing of housing based on race, color, religion, national origin, sex, familial status, and disability status – people within protected classes continue to encounter limits in housing choice and mobility. ## Background Government Code Chapter 15 Section 8899.50, signed into law in 2018 under Assembly Bill (AB) 686, requires all public agencies in California to “administer its programs and activities relating to housing and community development in a manner to affirmatively further fair housing (AFFH), and take no action that is materially inconsistent with its obligation to affirmatively further fair housing.” Under California law, AFFH means “taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics.”[^p151-2] This means cities and counties are required to take deliberate actions to address disparities in housing needs, access to opportunity, and settlement patterns for protected populations. Consistent with Government Code Section 65583, housing elements are required to address the following components: * **Inclusive and Equitable Outreach:** Local jurisdictions must make a diligent effort to equitably include all community stakeholders in the housing element participation process. * **Assessment of Fair Housing:** All housing elements must include an assessment of integration and segregation patterns and trends, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, and disproportionate housing needs, including displacement risk. * **Analysis of Sites Inventory:** Local jurisdictions must evaluate and address how particular sites available for housing development will meet the needs of households at all income levels. The housing element must analyze and conclude whether the identified sites improve or exacerbate conditions for fair housing. [^p151-1]: 42 U.S.C. §§ 3601-3631 [^p151-2]: California Department of Housing and Community Development, *Affirmatively Furthering Fair Housing: Guidance for All Public Entities and for Housing Elements (April 2021 Update)*, April 27, 2021, preface page, https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27-2021.pdf. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-1 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING * **Identification of Contributing Factors:** Based on findings from the previous steps, housing elements must identify, evaluate, and prioritize the contributing factors related to fair housing issues. * **Policies and Actions to Affirmatively Further Fair Housing:** Local jurisdictions must adopt fair housing goals and actions that are significant, meaningful, and sufficient to overcome identified patterns of segregation and affirmatively further fair housing. The housing element should include metrics and milestones for evaluating progress and fair housing results. ## Outreach As part of the Multi-Jurisdictional Housing Element update process, the City hosted and participated in a variety of outreach efforts. The purpose of outreach was to solicit feedback from local stakeholders and members of the community to inform the assessment of housing needs and program development. This Assessment of Fair Housing includes a summary of outreach activities conducted through the process. A full summary of outreach efforts for the Multi-Jurisdictional Housing Element update can be found in Chapter 2, Public Outreach and Engagement. ## Study Sessions A study session was held with the City Council on September 15, 2022, to discuss the Housing Element Update and process. The study session was open to the public and held in person, with a livestream option to reach members of the public who could not attend in person. Commentary was limited and no public comment related to fair housing was received at the meeting; instead, commissioners and council members expressed concern regarding the implications of new and changing housing legislation on small cities with limited financial resources. ## Community Workshops and Meetings The City held a number of community workshops and meetings to solicit feedback from the community and stakeholders on the Housing Element update. In addition to the workshops and consultations facilitated with California Coalition of Rural Housing (CCRH) and Fresno Council of Governments (FCOG), the City worked with a local nonprofit with roots in the community, Every Neighborhood Partnership (ENP), to conduct supplemental outreach to solicit as much input as feasible to inform the update to the Housing Element. Workshops and meetings were conducted throughout the span of the project, starting in August of 2022. A series of joint community meetings were then held by the City of Fresno Long Range Planning and Housing Divisions between October 27 and November 28, 2022. Several additional meetings were held in February and March of 2023. More information about the City’s diligent efforts to engage with the public, and summaries of the feedback received, are described in more detail in Section 1E-6: Public Outreach and Engagement. The City notified the community with flyers distributed in English, Spanish, Hmong, and Punjabi through the FCOG listserv of regional stakeholders and community based organizations (CBOs) and through Fresno Housing. Linguistica interpreters were available for Spanish, Hmong, and Punjabi monolingual speakers. Materials in Spanish, Hmong and Punjabi were available in-person at several workshops and then online at the project website, accessible via link or QR code. More than 250 community participants attended the City’s workshops and meetings for the Housing Element update. The following describes some of the most relevant themes and feedback received. * **Critical Housing Issues.** Community members expressed that some of the most critical issues in Fresno are related to lack of affordability and frequently changing housing costs, infrastructure needs, lack of information and education, and lack of community amenities. * **Most Impacted Groups.** Participants identified a number of special needs groups that are most impacted by housing needs such as residents with low- and extremely low- incomes, undocumented residents, people experiencing homelessness, seniors, single-parent households, people with disabilities and mental disabilities, and college students/youth. * **Fair Housing Needs.** When asked about Fresno’s most significant fair housing issues, participants noted historical disinvestment in southwest and west Fresno, inability to access credit, housing costs, and access to opportunities. Some of the suggestions for programs to include in the Housing Element include: more landlord education and incentives for Housing Choice Vouchers (HCVs), regular roundtable meeting with community leaders, and better promotion of ongoing/current information via social media. * **Suggestions and Solutions.** Participants expressed support for building more affordable housing and suggested the City develop more programs to provide financial assistance to low-income families, funding to rehabilitate homes, rent control, and more housing near amenities like grocery stores. Participants also made suggestions for increasing community involvement in the Housing Element update. Following the workshops, the City posted copies of the workshop presentations on the Fresno County Multijurisdictional Housing Element Update website in multiple languages for residents to access at their convenience. Feedback received during the workshops was used to inform this assessment as well as associated programs. For a full summary of the workshops, see Section 1E-6, Public Outreach and Engagement. ## Regional Focus Groups As described in Chapter 2 of the Multi-Jurisdictional Housing Element, two regional focus groups were held as part of the Housing Element development process. Stakeholders included representatives from FCOG member jurisdictions including County of Fresno, City of Fresno, City of Clovis, City of Fowler, City of Parlier, City of Sanger, and City of Selma. Other organizations and stakeholder represented at the focus groups include California Apartment Association (CAA), California Rural Legal Assistance (CRLA), Envision Realty, Northern California Carpenters Council (NCCRC), Building Industry Association (BIA), Fresno Housing, The Fresno Center, and We Plan Cities. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Participant groups were presented with information about the Housing Element process, particularly sections regarding community needs and fair housing, and were given the opportunity to weigh in on community needs. Some key topics that came up as regional housing issues include: corporate acquisition of mobile home parks, lack of reliable access to water and other infrastructure such as internet access and cell phone reception, over-reliance on commercially zoned property to accommodate RHNA (not much higher density zoning in the County relative to commercial), outdated community plans hindering development, and difficulties securing funding for new housing in low resource areas. There was also a fair amount of discussion on the need for more outreach and education to increase awareness/accessibility of existing assistance programs, and financial literacy to help low-income residents better compete for affordable housing/home ownership opportunities. Attendees highlighted the gap between program eligibility and the ability to afford available housing, as some applicants to affordable housing programs make too much money to qualify but still can’t afford housing without the program’s assistance. At a recent workshop for community members interested in participating in a down payment assistance program, none of the attendees qualified because their incomes were higher than 80 percent of the area median income. For other community members, being able to show an income level of at least twice the rent of an apartment in the area is impossible. During one of the focus group meetings, a participant referenced the Llaves de tu Casa Inciativa which is a financial education program open to all County of Fresno residents but with a focus on increasing Latino homeownership rates. The partners driving the initiative are NAHREP (National Association of Hispanic Real Estate Professionals) Fresno, the City of Fresno, Federal Home Loan Bank (FHLBank) of San Francisco, Self-Help Enterprises, and Union Bank. The Llaves De Tu Casa Iniciativa program consists of down payment and closing cost assistance, home buyer grants, comprehensive home buyer education and counseling including first-time home buyer workshops and flexible mortgage products and programs for Fresno neighborhoods. As a follow-up to the regionwide stakeholder focus groups, a group of initiative members representing various organizations and companies met to discuss housing needs and programs for the regional Housing Element effort. ## Regional and Local Stakeholder Consultations To ensure that the City solicits feedback from all segments of the community, consultations were conducted with service providers and other stakeholders who represent different socioeconomic groups. Throughout the summer and fall of 2022, several interviews were conducted with stakeholders who work in areas such as housing, homelessness, and other social services in Fresno and throughout the Fresno County area. The following organizations and stakeholders provided one-on-one input or written feedback on housing needs and programs in Fresno. Note, this is not an extensive list of all of the organizations and stakeholders that participated in the process of the Housing Element update. * Leadership Counsel for Justice and Accountability * Central Valley Urban Institute * Resources for Independence Central Valley * Law Office of Patience Milrod – Civil Rights Attorney * BIA of Fresno/Madera Counties * Fair Housing Council of Central California (FHCCC) * Fresno Housing * Fresno-Madera Continuum of Care * Llaves De Tu Casa Inciativa * Nor Cal Carpenter’s Union In each consultation, stakeholders were asked about: opportunities and concerns for housing in the region, housing needs by type, barriers and unmet needs, constraints, and housing conditions. Stakeholders were also asked about equity and fair housing such as “What factors limit or deny civil rights, fair housing choice, or equitable access to opportunity? What actions can be taken to transform racially and ethnically concentrated areas of poverty into areas of opportunity (without displacement)? What actions can be taken to make living patterns more integrated and balanced?” Common themes in stakeholder responses were concerns about affordability, including the location of affordable housing in undesirable areas and the gap between housing affordability and program income limits. Limited capacity and resources include funding, time, staff, infrastructure, labor supply etc. The opportunities and suggestions for future housing in the region that stakeholders proposed are local rent controls to manage affordability and reduce displacement risk, code enforcement to ensure a safe and habitable housing stock, taking advantage of State incentives to build more housing in high opportunity areas, funding fair housing groups such as FHCC to enforce fair housing laws, establishing a land trust, acknowledging a labor shortage in residential construction, and adjusting regulations or encouraging development of a variety of unit types and sizes throughout the jurisdiction to promote mobility and integration. Stakeholders also highlighted the unique needs of community members who are undocumented including how it is impossible to achieve homeownership and challenging to have the required proof of income for rental housing. Several stakeholders identified lack of credit and low incomes as a barrier to many residents in accessing stable housing. The following describes some of the themes and feedback from the consultations. * **Opportunities and Concerns.** Stakeholders described the rising cost of housing, the shortage of affordable housing available in the city, increasing rates of homelessness, sprawl in the city, infrastructure, the need for multifamily or single-family unit types, not enough accessible units for people with disabilities, substandard housing conditions, and insufficient code enforcement as concerns. Stakeholders noted that some opportunities include: availability of vacant land, repurposing old buildings into housing, tools for process streamlining, more incentives, proactive code enforcement, and requirements for inclusionary development. * **Housing Barriers/Needs.** Stakeholders described housing costs, inaccessibility of listings, and credit checks as barriers for residents to get into housing. Stakeholders also expressed that there has been insufficient progress toward meeting the lower-income Regional Housing Needs Allocation (RHNA) referring to units for low-, very low-, and extremely low-income households (i.e., not enough affordable housing being built). Most of the stakeholders encouraged the City to provide more funding for home repairs and maintenance. Stakeholders noted the economic disadvantages to market rate developers to build affordable housing and identified processing times and general costs as significant constraints. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING * **Equity and Fair Housing.** Stakeholders encouraged the City to proactively AFFH and incorporate fair housing into Housing Element programs. In terms of factors that limit or deny civil rights, fair housing choice, and/or equitable access to opportunities, stakeholders noted access to credit, deposit and income requirements, language barriers, lack of inclusionary housing requirements, and poor financial education. Someone also noted that previous evictions and criminal records create barriers to equity. Lastly, stakeholders described how fringe/sprawl development patterns have resulted in disproportionate resources and opportunities. * **Other Topics and Suggestions.** Some of the other key topics that came up were the increased costs and competition for housing due to COVID, the need for long term rental assistance in Fresno, infrastructure costs and water accessibility, inclusionary housing, code enforcement, community land trusts, mobile home park protections, and capacity building for lower income residents and nonprofits/community-based organizations. Stakeholders encouraged the City to include specific programs and timelines with designated responsible parties. ## Fair Housing Assessment This section serves as an assessment of fair housing practices in the city of Fresno and has been prepared pursuant to Government Code Section 65583 (c)(10). It examines existing conditions and demographic patterns including patterns of integration and segregation within the city, concentrated areas of low- and moderate-income housing, and areas of low and high opportunity. Information on Fresno is also compared to regional trends, describing settlement patterns across the Central Valley. The analysis is primarily based on data from the U.S. Census American Community Survey (ACS), the HCD AFFH Tool, and the City’s Analysis of Impediments to Fair Housing Choice (Draft – February 2020). A regional assessment of Fair Housing in Fresno County is provided in Chapter 3: Regional Assessment of Fair Housing. This section is organized by fair housing topics. For each topic, the regional assessment is first, followed by the local assessment. Strategies to address the identified issues are included throughout the section. This section also includes an analysis of the Housing Element sites inventory as compared with fair housing factors. Through discussions with housing service providers, fair housing advocates, and this assessment of fair housing issues, the City of Fresno identified factors that contribute to fair housing issues. These contributing factors along with associated actions are included in Table 1E-3.28, Summary of Fair Housing Issues, Contributing Factors, and Meaningful Actions to AFFH. Additional programs to affirmatively further fair housing are included in Section 1E-1: Action Plan. APPENDIX 1E: CITY OF FRESNO # Notes on Geospatial Analysis In this report, “neighborhoods” are approximated by an aggregation of census tracts. Census tracts are statistical geographic units defined by the U.S. Census Bureau for the purposes of disseminating data. Throughout this report, neighborhood level segregation measures are calculated using census tract data. However, some data is reported at the census block or census block group (block groups) level. Fresno County is used as the primary point of comparison for regional trends. References to the “Central Valley” refer to the San Joaquin basin within Fresno County. Figure 1E-3.1 displays a neighborhood map for the city of Fresno. Throughout this document, the following neighborhood names will be used to generally categorize census tract or block group data. This report uses an expansive definition of Downtown. The General Plan directed that the Downtown Planning Area be further refined through specific and community plans which include the plan areas for the Downtown Neighborhood Community Plan and the Southwest Fresno Specific Plan. While these areas are functionally similar, these neighborhoods vary culturally, rich with strong communities such as the city’s historic Chinatown. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-7 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Figure 1E-3.1: Neighborhood Map, City of Fresno <
> Source: City of Fresno, 2022. APPENDIX 1E: CITY OF FRESNO # Patterns of Integration and Segregation ## Race and Ethnicity As described in the Regional Multi-Jurisdictional Housing Element (Chapter 3), the racial and ethnic representation of residents in the County set the baseline, and closely correspond to those in the city of Fresno. Countywide, the majority of the population in most jurisdictions is Hispanic (of any race). Similarly, the city of Fresno’s Hispanic population constitutes nearly half of all residents (49.7 percent). Countywide and within the city, Hispanic representation has grown significantly since the 2000 Census. In real numbers, the Hispanic population increased from 170,520 people to 261,751 over the 20-year timeframe, a 53.5 percent increase (see Table 1E-3.1). ### Table 1E-3.1: Population by Race and Hispanic Origin, Fresno, 2000-2020 | | 2000 | | 2010 | | 2020 | | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | **Number of People** | **Percent** | **Number of People** | **Percent** | **Number of People** | **Percent** | | White | 159,473 | 37.3% | 148,598 | 30.0% | 137,216 | 26.1% | | Black or African American | 34,357 | 8.0% | 37,885 | 7.7% | 36,089 | 6.9% | | American Indian and Alaska Native | 3,259 | 0.8% | 3,127 | 0.6% | 2,445 | 0.5% | | Asian | 47,136 | 11.0% | 60,939 | 12.3% | 73,892 | 14.0% | | Native Hawaiian and Other Pacific Islander | 427 | 0.1% | 663 | 0.1% | 726 | 0.1% | | Some Other Race | 728 | 0.2% | 984 | 0.2% | 1,026 | 0.2% | | Two or More Races | 11,752 | 2.7% | 10,414 | 2.1% | 13,002 | 2.5% | | Hispanic or Latino | 170,520 | 39.9% | 232,055 | 46.9% | 261,751 | 49.7% | | **Total** | **427,652** | | **494,665** | | **526,147** | | *Source: U.S. Census Bureau, ACS16-20 and ACS05-10 (5-year Estimates), Table B03002. U.S. Census Bureau, 2000 Decennial Census Table H007.* Residents identifying as White are the second largest population segment in the city of Fresno, comprising a quarter of the city’s total population. Since 2000, the percentage of the city’s White population has decreased, from 159,473 people (37.3 percent of the city) in 2000 to 137,216 (26.1 percent) in 2020. Asian or Pacific Islanders comprise Fresno’s third largest population segment, making up 14.0 percent of the city, roughly similar to their 2000 population share of 11.0 percent. From 2000 to 2020, Fresno gained an additional 26,700 Asian or Pacific Islander residents. During this 20-year timeframe, the city also experienced a decrease in Black or African American residents and Native American residents. Figure 1E-3.2 displays the distribution of households in Fresno by race and Hispanic origin. While Fresno’s population is relatively evenly distributed throughout the city, the spatial distribution of the population indicates considerable levels of segregation by race and ethnicity. As shown in the figure, Hispanic residents are more concentrated in the southern half of the city, specifically in the Downtown, while neighborhoods in the northern half of the city have a greater predominance of White residents. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Figure 1E-3.2: Population by Race and Hispanic Origin, Fresno, 2019 <
> Source: Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on 2015-2019 American Community Survey data. 1E-3-10 FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 APPENDIX 1E: CITY OF FRESNO The dissimilarity index provides another measure of the magnitude of segregation within a city or county. The dissimilarity index measures the degree to which two specific groups are distributed across a geographic area. The score varies between 0 and 100 and measures the percentage of one group that would have to move across neighborhoods to be distributed the same way as the second group. A dissimilarity index of 0 indicates conditions of total integration under which both groups are distributed in the same proportions across all neighborhoods. A dissimilarity index of 100 indicates conditions of total segregation such that the members of one group are located in completely different neighborhoods than the second group. For example, if an index score is above 60, more than 60 percent of people in the specified area would need to move to eliminate segregation. The following can be used to interpret the index: * Less than 40: Low Segregation * Between 40 and 54: Moderate Segregation * Greater than 55: High Segregation Table 1E-3.2 displays the dissimilarity index scores in the city compared to the county. It is important to note that the dissimilarity index uses White residents as the primary comparison group. That is, all dissimilarity index values compare racial and ethnic groups against the distribution of White residents and do not directly measure segregation between two minority groups (e.g., Black or African American, and Hispanic/Latino segregation). The dissimilarity index scores are intended to contextualize the level of segregation between racial and ethnic groups city- and countywide. As shown below, the dissimilarity index for Black or African American residents is 0.49 in this city. This would mean that nearly half of Black or African American (or White) residents would need to move to a different neighborhood to achieve balance in the demographics. Table 1E-3.2: Dissimilarity Index Scores for City of Fresno and Fresno County, 2020 | Race/Ethnicity | City of Fresno | Fresno County | | :--- | :--- | :--- | | American Indian/Alaska Native | 0.66 | 0.66 | | Asian | 0.39 | 0.41 | | Pacific Islander | 0.79 | 0.82 | | Black or African American | 0.49 | 0.54 | | Hispanic/Latino | 0.39 | 0.45 | | Other | 0.73 | 0.72 | | Multiracial/ Two or More Races | 0.33 | 0.31 | | Total Non-White Population vs. White | 0.36 | 0.40 | Source: U.S Census ACS 5-Year Estimates, 2020, Table B03002. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING As discussed previously, White, and Hispanic/Latino groups comprise the majority of the population in the city (77.2 percent). The dissimilarity index shows that there is a low magnitude of segregation between these respective groups (0.39). This is comparable, but lower, than patterns countywide (0.45). The dissimilarity index also shows that the highest levels of segregation within the city are between Pacific Islander (0.79), American Indian/Alaska Native (0.66) and other racial/ethnic groups not listed (0.73). However, when calculating and analyzing the dissimilarity index, it is important to note that dissimilarity index values are less reliable for a population group if that group represents less than 5 percent of the jurisdiction’s total population, approximately. Scores are innately higher because there is a smaller population size relative to the total. Asian residents on the other hand account for 14 percent of the city’s total population and the dissimilarity index score between Asian and White residents is 0.39 which is the same as the score between White and Hispanic/Latino groups. These scores are below the threshold of 0.40 which would indicate lower levels of segregation amongst the city’s census tracts based on numerical statistics. The dissimilarity index scores for the total Non-White population indicate that the county as a whole has moderate and higher levels of racial/ethnic segregation, with dissimilarity index scores of 0.36 and 0.40, in the city and county respectively. **Figure 1E-3.3** below visualizes racial segregation/integration measures based on methodology from the Othering & Belonging Institute (OBI) and 2021 census tract boundaries. OBI’s data compares integrated neighborhoods to highly segregated White neighborhoods and highly segregated neighborhoods that are predominantly populations of color (POC). In the figure below, South Fresno stands out with the highest POC segregation. While there are more tracts in northern Fresno with highly segregated White neighborhoods (shown in green below), there are two census tracts in the Woodward Park area that are classified with high POC segregation. The central core of established neighborhoods surrounding the Shaw Avenue corridor are more racially integrated with most neighborhoods on the outskirts of those neighborhoods experiencing low to medium segregation (as indicated by the yellow cluster in the central core and lighter red color surrounding those tracts in **Figure 1E-3.3**). It is worth noting that several census tracts throughout the city do not have data assigned to them. This includes tracts in the Woodward Park, West, Downtown, and Roosevelt areas. <
> APPENDIX 1E: CITY OF FRESNO Figure 1E-3.3: Racial Segregation/Integration by Census Tract, City of Fresno <
> Source: Data downloaded from HCD AFFH Data and Mapping Tool 2.0 in 2023, based on 2021 census tract boundaries and data from the Othering & Belonging Institute 2020. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-13 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ## Income Distribution In 2020, Fresno’s citywide median household income was $53,368 which was below the Fresno County median income of $57,109 and the statewide median income of $78,672. Median incomes by racial group, shown below in Figure 1E-3.4, vary greatly. White and Asian households had median incomes that are very close at $63,517 and $63,460 respectively. Hispanic households had a median income that was approximately $17,500 less than White and Asian households at $45,984 while Black or African American households had the lowest median household income at $34,361. These trends are also displayed for the whole of Fresno County where Hispanic households had a median income of $47,141 compared to $70,763 for White households and $68,274 for Asian households while Black or African American households had a median income of $39,621. Figure 1E-3.5 displays the distribution of households in the city by median household incomes. North, northwest, west, and east neighborhoods of the city, including portions of the Woodward Park, Bullard, West, and Roosevelt community areas, have the highest median incomes relative to the rest of the city. Census block groups that most closely match the city’s median incomes ($50,000-$87,100) and are generally in line with the statewide average median income of $78,672, are located in between the highest and lowest median income neighborhoods. While the city’s average annual median income was $53,368, most of the city has incomes that are less than $50,000. Compared to the trends in residential integration and segregation shown in Figure 1E-3.3 above, incomes tend to be lowest where there is “low to medium segregation” and “high POC segregation,” particularly in Downtown and inner core neighborhoods, such as west Fresno adjacent to SR 99, south Fresno, Jane Addams and Jefferson. Residents in high poverty areas tend to have lower levels of access to opportunity due to the absence of critical resources and disinvestment in their communities. As poverty increases, disparities in access to opportunities often increase among population groups and disadvantaged communities become even more isolated. APPENDIX 1E: CITY OF FRESNO ### Figure 1E-3.4: Median Household Income by Race, Fresno, 2020 <
> Source: U.S. Census Bureau, ACS16-20 (5-year Estimates), Table B19013. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-15 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Figure 1E-3.5: Median Household Income, Fresno, 2019 <
> *Source: Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on 2015-2019 American Community Survey data.* APPENDIX 1E: CITY OF FRESNO The Area Median Income (AMI) for Fresno County is $80,300 in 2022. In 2022, a family of four making $27,750 or less would be classified as extremely low income in Fresno. In the city of Fresno, 15.8 percent of households make less than 30 percent of the AMI, which is considered extremely low income. This income equates to a wage of $14.76 per hour for a single wage-earner, which is below the minimum wage in Fresno ($15.50 per hour). An extremely low-income family of four described above could afford a monthly housing cost of approximately $694. As reported in the regional assessment of fair housing, only 7.0 percent of units in the city of Fresno rent for less than $1,000 monthly, while 54.0 percent rent for $1,001 to $1,500 monthly, 30.0 percent rent for $1,501 to $2,000 monthly, and 10.0 percent rent for above $2,000 monthly, making it very hard for extremely low-income families to afford housing and support themselves. As such, most block groups in the city have high levels of poverty on average than other cities in the state, and the overall poverty rate in Fresno is 19.2 percent. Despite Fresno being the country’s most agriculturally productive region, it has become known for its high levels of poverty and unemployment.[^p167-3] There are large disparities among racial and ethnic groups with regard to poverty (see Figure 1E-3.6). Black or African American, “Other Race,” and Hispanic populations experience the greatest rates of poverty in Fresno, while the White population has the least amount of poverty (less than 10 percent) among all population groups. Exposure to poverty varies by location in the city, with some areas of the city experiencing higher rates of poverty than others. Specifically, block groups in south and west Fresno tend to have higher exposure to poverty, while the city’s northernmost block groups have relatively low levels of poverty (see Figure 1E-3.7). ### Figure 1E-3.6: Percent of Households in Poverty by Race or Hispanic Origin, Fresno, 2020 <
> Source: U.S. Census Bureau, ACS16-20 (5-year Estimates), Table B17010A. [^p167-3]: Benner, C. and Pastor, M. 2015. Equity, Growth, and Community: What the Nation Can Learn from America's Metro Areas. “Struggle and the City: Conflict-Informed Collaboration.” University California Press. Pp. 130-160. Accessed via: https://www.jstor.org/stable/10.1525/j.ctt1ffjnd4.9. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING # Figure 1E-3.7: Distribution of Poverty, Fresno, 2019 <
> Source: Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on 2015-2019 American Community Survey data. APPENDIX 1E: CITY OF FRESNO ### Familial Status The FHA also bans discrimination based on "familial status," which refers to the presence of at least one child under 18 years old. Housing discrimination based on familial status can occur when a landlord, property manager, real estate agent, or property owner treats someone or a group of people differently because they have a family with children under the age of 18. In Fresno County, the majority of households are family households (72.3 percent). Family households are defined by California law as a household of two or more people, regardless of relationship status. Approximately 67.8 percent of households in the city of Fresno are family households including 40.7 percent married couple households, 9.4 percent of households that are unmarried cohabitating couples, and an additional 17 percent of households with alternative compositions such as single-parent households. As shown in Table 1E-3.3, 34.3 percent of households in the city had a child under the age of 18 according to ACS. Since 2000, the overall share of families with children in the city of Fresno has declined by 22.1 percentage points despite an increase in the number of families overall. A similar decline occurred at the regional level, where families with children decreased from 55.8 percent of all households in 2000 to 35.4 percent in 2020, despite gaining over 30,000 additional families with children. Table 1E-3.3: Families with Children, Fresno, 1990-2020 | | Number of Families | Percent of all Households | Number of Families | Percent of all Households | Number of Families | Percent of all Households | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | **2000** | | **2010** | | **2020** | | | City of Fresno | 44,690 | 56.4% | 59,626 | 53.0% | 58,288 | 34.3% | | Fresno Region | 79,423 | 55.8% | 112,139 | 52.3% | 109,759 | 35.4% | *Source: Decennial Census, ACS. 2020 Analysis of Impediments to Fair Housing Choice. U.S. Census Bureau, ACS16-20 (5-year Estimates), Table B11012.* Figure 1E-3.8 shows the distribution of children in married couple households, while Figure 1E-3.9 shows the distribution of children in female-headed households with no partner or spouse present. Most of Fresno County has moderate to high rates of children in married-couple households especially in the unincorporated county areas. Generally, throughout the San Joaquin Valley, areas where residences are typically more dispersed and uses are more agricultural or limited by topography have higher rates of families with children than is found in the central and southern neighborhoods of the city of Fresno. Within the city, there is a greater presence of children living in married couple households in the west and northwest neighborhoods. The inner city near Downtown has smaller populations of children living in married couple households. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Figure 1E-3.8: Percent of Children in Married Couple Households, Fresno, 2019 <
> *Source: Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on 2015-2019 American Community Survey data.* APPENDIX 1E: CITY OF FRESNO # Figure 1E-3.9: Percent of Children in Single-Female Headed Households, Fresno, 2019 <
> *Source: Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on 2015-2019 American Community Survey data.* FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-21 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING As described in the Regional Assessment of Fair Housing (Chapter 3 of the Multi-Jurisdictional Housing Element), female-headed households tend to live in and around the cities of Fresno and Clovis. This could be due to the proximity of schools, transit, services, and jobs in an incorporated city; however, the urban areas of the county also have a greater range of housing types that single-female headed households can afford. While female-headed households compose 30.7 percent of households in the city overall, there are several neighborhoods where they are the predominant household type. As shown in Figure 1E-3.9, there are several tracts in Fresno, predominantly along State Route 41, State Route 99 and State Route 180, with proportions of female-headed households that comprise 40 to 80 percent of the total households. Female-headed households are also predominant in the Woodward Park area in northern Fresno, the neighborhood areas in the east bordering old town Clovis (generally surrounding Clovis Avenue), and the Roosevelt community area in southern Fresno surrounding Kings Canyon Road and California Avenue. Female-headed households have special housing needs because they tend to be either single-parents or single-elderly adults that are living on low- or poverty-level incomes. In 2021, According to the U.S. Department of Justice, Office of Juvenile Justice, 9.5 percent of children living with two parents lived below the poverty level, compared to 31.7 percent of children living with a single parent. Children living with only their mothers in 2021 were more than twice as likely to live in poverty than those living with only their fathers (35.0 percent vs. 17.4 percent)[^p172-4]. Comparing Figures 1E-3.8 and 1E-3.9 with Figures 1E-3.5 and 1E-3.7, a connection can be made to higher concentrations of single parent households and higher poverty levels and lower median incomes in Fresno. Single-parent households with children often require special consideration and assistance as a result of their greater need for affordable housing, accessible day care, health care, and a variety of other supportive services. Because of their relatively lower household incomes, single-parent households are more likely to experience difficulties in finding affordable, decent, and safe housing and the presence of a child in the household tends to receive unequal treatment in the rental housing market. Fresno ranks fourth worst among the 50 most populous U.S. cities for the percentage of single mothers with an income below the poverty line (63.1 percent). Single mothers in this city can expect to spend 31.8 percent of their income on rent annually.[^p172-5] ### Population with Disabilities The U.S. Census Bureau defines disability as one of the following: hearing difficulty, vision difficulty, cognitive difficulty, ambulatory difficulty, self-care difficulty, and independent living difficulty. Persons with disabilities tend to have lower fixed-incomes, higher health care costs, and special housing needs. Persons with disabilities typically have special housing needs because their physical and/or developmental capabilities, fixed or limited incomes, and higher health costs associated with their disabilities. [^p172-4]: Office of Juvenile Justice and Delinquency Prevention. 2022. “Poverty status of children by family structure.” Accessed via: https://ojjdp.ojp.gov/statistical-briefing-book/population/faqs/qa01203#:~:text=In%202021%209.5%2020of%20children,17.4%25 [^p172-5]: Solum, A. 2022. “Where Single Mothers Fare Worse Economically – 2022 Study.” Accessed via: https://smartasset.com/data-studies/where-single-mothers-fare-worse-economically-2022 APPENDIX 1E: CITY OF FRESNO According to 2016-2020 ACS 5-Year Estimates, 14.3 percent of Fresno’s population has a disability, which is slightly higher than the county rate of 13.0 percent. By disability type, the city is similar to the region, with ambulatory difficulties being the most prevalent disability type (affecting 50.1 percent of the city of Fresno population and 49.7 percent of the regional population with one or more types of disability). Cognitive and independent living difficulties are the next most prevalent, affecting 44.0 percent and 39.5 percent of the disabled population. Smaller percentages of the population are affected by hearing difficulties, vision difficulties, and self-care difficulties. Figure 1E-3.10 shows the population of persons with a disability by census tract in the city using ACS data from 2015-2019. As stated in the Regional Assessment of Fair Housing (Section 3 of the Multi-Jurisdictional Housing Element), the only areas in Fresno County having a concentration of persons with a disability over 20 percent are in the cities of Fresno and Clovis, suggesting a correlation between housing opportunities for seniors in more urbanized areas with access to public transportation, services, and amenities. The other jurisdictions in Fresno County either contain a population of which less than 10 percent of the population reports a disability, or the jurisdiction is split between areas of less than 10 percent, and 10 to 20 percent of the households experiencing one or more disabilities. Within Fresno, households with a disability have higher concentrations in southwest Fresno, the Fresno High-Roeding neighborhood in central Fresno, the McLane neighborhood west of the airport, and a small tract of the Bullard neighborhood. These areas correlate with the neighborhoods with supportive housing and assisted care facilities for seniors and others that may require supportive housing. <
> Fresno residents with disabilities are served by the Fresno County Senior Resource Center, which operates an Adult Protective Services program, assisting both disabled adults and seniors with all requests for assistance. The Fresno County Human Services System Department of Adult Services also provides housing and basic needs assistance to elderly persons. The Fresno/Madera Area Agency on Aging (FMAAA) provides connections to programs, services, and resources elderly residents can use to maintain and improve their quality of life as they age. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Figure 1E-3.10: Percentage of the Population with a Disability in City of Fresno <
> Source: Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on 2010-2014 and 2015-2019 American Community Survey data. # Concentrated Areas of Race and Income ## Areas of Poverty One indicator of segregation is the presence of racially concentrated areas of poverty. Racially or Ethnically Concentrated Areas of Poverty (R/ECAP) are neighborhoods in which there are both racial concentrations and high poverty rates. The Department of Housing and Urban Development’s (HUD’s) definition of a R/ECAP is: * A census tract that has a Non-White population of 50 percent or more (majority-minority) or, for non-urban areas, 20 percent, AND a poverty rate of 40 percent or more; OR * A census tract that has a Non-White population of 50 percent or more (majority-minority) AND the poverty rate is three times the average tract poverty rate for the county, whichever is lower. Households within R/ECAP tracts frequently represent the most disadvantaged households within a community and often face a multitude of housing challenges. Overrepresentation of Black and Hispanic populations in areas of concentrated poverty can exacerbate racial disparities related to safety, employment, access to jobs and quality education, and conditions that lead to poor health. Areas of concentrated poverty generally have less private investment from financial institutions, grocery stores, and other retail outlets. R/ECAPs are meant to identify where residents may have historically faced discrimination and continue to be challenged by limited economic opportunity. As will be discussed later in the section on Fresno’s local history, concentrated areas of poverty today were shaped by various land use practices that were historically used in communities across the nation to spatially segregate neighborhoods, including redlining and racially restrictive covenants. Figure 3-15 of the regional assessment displays R/ECAPs in the Fresno County region, based on ACS data from 2009-2013. While the region as a whole appears to be fairly integrated economically and racially, concentrated poverty and racial segregation remains a major concern in several communities throughout the San Joaquin Valley. As the largest city in the region, Fresno has the highest number of R/ECAPs. Based on this data, there were 39 census tracts designated as R/ECAPs in the city of Fresno. Approximately 40 percent of Fresno residents live in R/ECAP census tracts. Hispanic residents make up the majority of the population living in R/ECAP tracts. Recalling Figure 1E-3.2 which shows where predominant concentrations of various racial/ethnic groups live in Fresno and Figure 1E-3.3 which shows racial segregation/integration, individual R/ECAPS can be linked to census tracts with predominant Hispanic populations where there are high concentrations of POC segregation. Looking at familial status, recalling Figure 1E-3.9, more than half of the families living in Fresno’s R/ECAP tracts have children. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Figure 1E-3.11 displays R/ECAPs in the city of Fresno, based on ACS data from 2009-2013. R/ECAP census tracts cover all Downtown neighborhoods, such as Jane Addams, Edison, Lowell, and Jefferson, as well as west and south Fresno. There are also two R/ECAP census tracts in the Bullard neighborhood of northern Fresno, in or near the campus of Fresno State University. A third isolated R/ECAP in the Bullard neighborhood is located around State Route 41. It is important to note that no newer analysis currently exists that specifically identifies R/ECAPs. For a better understanding of the current landscape, refer to Figure 1E-3.14, which displays the composite analysis of TCAC Opportunity Areas, including areas of “high segregation and poverty.” These maps provide more recent insights into areas of concentrated segregation and poverty and are useful for understanding the current landscape. As will be discussed in more detail in a later section, several policies and historical forces[^p176-6] have contributed to the formation of R/ECAPs in Fresno and other communities across the country, including: * Redlining: The discriminatory practice of denying loans and other financial services to residents of certain areas based on racial or ethnic composition has left lasting impacts on community development and wealth accumulation.[^p176-7] * Discriminatory Housing Practices: Including restrictive covenants, racial steering, and unequal lending practices, which limited where minority populations could live and invest.[^p176-8] * Urban Renewal: Policies aimed at redeveloping urban areas often displaced minority communities, further entrenching segregation and poverty.[^p176-9] * Economic Disparities: Structural economic inequalities, including low engagement in the labor market and wage gaps, have exacerbated poverty levels in these communities.[^p176-10] * Education Inequality: Income disparities and unequal educational resources have perpetuated limited social mobility for residents of R/ECAPs.[^p176-11] [^p176-6]: San Joaquin Valley Fair Housing and Equity Assessment, 2014. Available via: https://academics.fresnostate.edu/oced/documents/SJV_Fair-Housing-and-Equity-Assessment_April-2014.pdf [^p176-7]: Aguilera, D. October 2015. “Rare Maps Reveal Fresno’s Overlooked History of Segregation.” Accessed via: https://www.kvpr.org/community/2015-10-27/rare-maps-reveal-fresnos-overlooked-history-of-segregation [^p176-8]: Ramon D. Chacon, “A Case Study of Ghettoization and Segregation: West Fresno’s Black and Chicano Community During the 1970s,” Standford Center for Chicano Research. Working Paper Series No. 12 (Jan 1986). [^p176-9]: San Joaquin Valley Fair Housing and Equity Assessment, 2014. Available via: https://academics.fresnostate.edu/oced/documents/SJV_Fair-Housing-and-Equity-Assessment_April-2014.pdf [^p176-10]: Montalvo, M. December 2022. “Labor leaders sound the alarm about low-wage job growth in California’s Central Valley.” Accessed via: https://fresnoland.org/2022/12/09/labor-leaders-sound-the-alarm-about-low-wage-job-growth-in-californias-central-valley/ [^p176-11]: Californians for Justice. APPENDIX 1E: CITY OF FRESNO ### Figure 1E-3.11: Racially/Ethnically Concentrated Areas of Poverty, Fresno, 2013 <
> Source: Data download from the HCD AFFH Mapping tool in 2021. Based on R/ECAP data from HUD and 2009-2013 ACS. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-27 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Moreover, there are systemic and structural issues which have contributed to the perpetuation of concentrated poverty including but not limited to: high unemployment rates and low engagement in the labor market, wage gaps, limited social safety nets, and disparities in access to educational resources. Relative to other areas in the city, R/ECAPs in Fresno tend to exhibit the following characteristics: * Higher percentages of non-White populations (Figure 1E-3.2) and medium to high rates of segregation for populations of color (Figure 1E-3.3) * Median incomes less than $50,000 per year (Figure 1E-3.5) * Higher poverty rates (Figure 1E-3.7) * Higher rates of children in single-family households (Figure 1E-3.9) * Lower academic performance and fewer educational resources based on the 2021 TCAC Opportunity Index (Figure 1E-3.15) * Low engagement with the labor market (Figure 1E-3.17) * Poor environmental conditions (Figure 1E-3.23 through Figure 1E-3.25) * Higher percentages of Housing Choice Voucher usage (Figure 1E-3.29) * Higher rates of overcrowding (Figure 1E-3.30) and housing cost burden (Figure 1E-3.31 and Figure 1E-3.32) In contrast, the communities north of Shaw including Woodward Park, Bullard, and also the McLane community are not characterized as racially or ethnically concentrated areas of poverty. These communities developed in the 1980s amidst construction of the State Route 99, 41, and 180 freeway loops around Downtown. As shown in the demographic analysis above, there is less racial and ethnic diversity in these communities. Figure 1E-3.3 indicates that these neighborhoods have higher rates of integration as compared to central core neighborhoods. Regarding income distribution, household incomes are generally higher around the northern fringes of the city. In fact, these communities are characterized as racially concentrated areas of affluence. This is described in more detail in the following section. Furthermore, the built environment, or the physical resources built for the residents of Fresno, can have a significant impact on quality of life. Some ways the built environment can affect quality of life positively include physical activity, good housing conditions, and access to healthy food and healthcare. Physical activity includes walkability, bikeability, park access, and in Fresno’s hot summers, tree canopy coverage. Housing conditions can be measured by the level of repair and maintenance needed. Access to healthy foods can include the number of and distance to grocery stores. Healthcare access can include the number of and distance to hospitals, clinics, and doctor’s offices. When comparing Fresno’s R/ECAPs to Fresno’s Racially or Ethnically Concentrated Areas of Affluence (RCAAs – see next section for definition and location) in terms of the built environment the following is known about the quality of life: APPENDIX 1E: CITY OF FRESNO * **Walkability:** Based on data from the 2017 Fresno Active Transportation Plan (ATP) there is a much higher percentage of sidewalk gaps in R/ECAPs compared to RCAAs. The gaps in the R/ECAPs occur within existing neighborhoods, in neighborhoods adjacent to freeways, and along major roadways in Southwest Fresno. * **Bikeability:** Based on data from the ATP, there is a much higher percentage of bikepath gaps in R/ECAPs compared to RCAAs. The gaps in the R/ECAPs occur throughout and are most notable in Downtown Fresno, Southwest Fresno, and the eastern portion of the Fresno High-Roeding. * **Walkability and Bikeability:** Based on data from the 2017 Fresno Active Transportation Plan there is a much higher percentage of trails in the RCAAs compared to the R/ECAPs. In 2019, the RCAAs had 18 miles of trails and one of those trails, the Fresno Sugar Pine Trail, connects to miles of Clovis trails. * **Walkability and Bikeability:** In the 2019 Fresno Network Expansion Feasibility Plan, the City evaluated all proposed unfunded trails identified in the ATP based on the Active Transportation Prioritization Tool adopted with the ATP. The criterion included access and equity, connectivity, traffic control, mode shift, and user comfort. The R/ECAPs have 30 segments of needed trails totaling 16.5 miles whereas the RCAAs areas have 10 segments totaling 3.16 miles. Twenty-eight of the trails in the R/ECAP scored a higher priority than all the trail needs in the RCAAs. * **Park Access:** In 2024, there are two regional, three community, and 13 neighborhood parks for a total of 18 City parks in R/ECAPs and one regional, three community, and six neighborhood parks for a total of 10 City parks in RCAAs areas. The RCAAs areas have 15 Clovis or Central Unified School District campuses with open campus policies, which allow residences to use outdoor courts and playfields and structures after school and on weekends. These school campuses have similar amenities to neighborhood and community parks. * **Park Access:** The parks in the R/ECAPs were built between 1903 and 2014 with the median year being 1968 and the parks in the RCAAs areas were built between 1988 and 2006 with the median year being 1994. In 2016, during the Parks Master Plan process the park consultants evaluated 50 percent of the parks in the R/ECAPs to be in poor condition and 50 percent in fair condition. Whereas, in the RCAAs areas, the parks were considered fair to good condition. * **Park Access:** The Measure P tax initiative went into effect in 2020 and required at least 50 percent of the funds be allocated to the highest need neighborhoods in Fresno. Through analysis, the Fresno PARCS Department determined the highest need neighborhoods by census tract. There are no highest need neighborhood census tracts in the RCAAs areas while there are 21 in the R/ECAPs. * **Tree Canopy Coverage:** In 2024, the City completed an Urban Forest Management Plan. The Plan conducted an analysis to determine a planting priority score for all census tracts in the city. Among all census tracts the lowest score was zero, the highest 78, and the median 22. The R/ECAPs had 20 census tracks above the median and the RCAAs areas had two. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING * **Housing Conditions:** In 2010, the City did a windshield neighborhood condition survey as part of the General Plan update. The study concluded that the housing was in good condition in the RCAAs areas and in fair to poor condition in the R/ECAPs. * **Healthy Food:** According to the USDA Economic Research Service, in 2019, there were 12 census tracts with low income and low access to food and most were in Southwest Fresno. * **Healthcare:** According to FELT there are eight hospitals and clinics within or near the RCAAs areas and eleven in the R/ECAPs. There is a large network of doctor’s offices along Herndon Avenue between Highways 99 and 41 near the RCAAs areas and in Downtown Fresno within the R/ECAPs. To improve the quality of life and access to opportunities in R/ECAPs, the Housing Element includes several key programs and initiatives, summarized below (see Section 1E-1 Action Plan for more details on each of these programs). * **Program 2 – Variety of Housing Opportunities in High Resource Areas.** Increase the availability of affordable housing units in higher resource areas to alleviate pressure in R/ECAP areas, reduce housing cost burdens, and improve living conditions. * **Program 11 – Incentives for Housing Development.** Provide incentives to encourage private developers to include affordable housing in their projects. * **Program 19 – Home Buyer Assistance.** Promote homeownership programs that provide down payment assistance and affordable mortgage options for low-income families. * **Program 22 – Housing Rehabilitation.** Launch a housing rehabilitation program that offers grants or low-interest loans to homeowners for repairs and maintenance. Provide resources and support for weatherization and energy efficiency upgrades. * **Program 23 – Comprehensive Code Enforcement.** Implement code enforcement initiatives to ensure landlords maintain rental properties to health and safety standards. * **Program 27 – Environmental Justice.** Prepare an Environmental Justice Element with actions to improve public health and quality of life in disproportionately impacted neighborhoods focusing on: equitable distribution of parks, recreation facilities, and other beneficial civic and cultural facilities; planting native trees and vegetation in neighborhoods with less tree canopy coverage; access to multi-modal transportation opportunities; and healthy food access. * **Program 28 – Equitable Community Investments.** Develop publicly accessible tools for the evaluation and tracking of infrastructure projects in areas of greatest need (high segregation & poverty, low resource, and moderate resource). * **Program 29 – Equitable Engagement.** Expand outreach and public education strategies to increase engagement amongst historically underrepresented populations and residents with the greatest need. * **Program 30 – Workforce Development.** Provide job training programs to improve economic opportunities, reduce poverty, and increase financial stability. * **Program 33 – Mobile Home Parks.** Protect mobile home park residents from excessive rent increases and preserve mobile homes as opportunities for homeownership to individuals and households who might not be able to afford other housing purchase options. * **Program 34 – Eviction Protection Program.** Defend tenants renting an apartment or house in the city of Fresno from unlawful eviction. * **Program 36 – Homeless Assistance.** Invest in various initiatives to provide housing, emergency shelter, and essential services to people experiencing homelessness. ### Description of R/ECAP Areas The Downtown neighborhoods are some of the oldest in Fresno, as the city began as a railroad town around the Central Pacific Railroad Depot in 1872. Spurred by the railroads and expanding agricultural opportunities, the town grew quickly and in 1885 was incorporated into a city. Many of the immigrants that first arrived were ethnic minorities, who settled in downtown neighborhoods such as Chinatown, Armenian Town, German Town and Italian Town. The town expanded rapidly and between 1913 and 1929, eleven high-rise buildings rose to create a distinct Fresno skyline. However, the Great Depression, redlining practices, and the construction of freeways that cut through these neighborhoods left their mark and contributed to the decline of these neighborhoods over time. However, over the last decade, residents and community leaders have worked together to reinvest in Downtown neighborhoods. A new Development Code was put in place to streamline development, the Southwest Fresno Specific Plan was adopted, and the Transform Fresno Program resulted in over $120M in investment in Southwest Fresno, Downtown and Chinatown, and a new community college opened its doors in the neighborhood in 2024. There are several R/ECAPS in the Downtown Neighborhoods Community Plan area and these are discussed below. **Lowell / Jefferson Neighborhood:** This R/ECAP consists of 515 acres just north of Downtown, between Divisadero and State Route 180. The neighborhood began developing in 1884. It has a mix of single family and multifamily housing, and strong historic character. Over time, with construction of the freeways, and migration to the suburbs, it became a mostly rental neighborhood, with many low-quality post WWII apartment buildings constructed as a result of past zoning policies that were not place-based. The neighborhood was also redlined. Current statistics show that over 40% of the population is living below the poverty level and 80% of the households are renters, 20-40% of which are cost-burdened. The neighborhood is also pollution burdened due to proximity to freeways, and has lower access to cars, healthy food, parks, and community facilities. Finally, the low-income population in the area has a high level of displacement risk. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING To address concerns related to incompatible development and quality of life, the Fulton-Lowell Specific Plan was adopted in 1996, and a Design Review Committee was created to ensure new development was compatible with the neighborhood. Subsequently, the City adopted the Downtown Neighborhoods Community Plan and Fulton Corridor Specific Plan, with an accompanying new Development Code that incorporated all applicable provisions of the original specific plan and design guidelines. At the same time, this neighborhood was part of a focused effort to revitalize disadvantaged neighborhoods in and around the Downtown called Restore Fresno. This effort focused on developing leadership capacity among the residents and addressing grassroots issues. The Lowell Community Development Corporation (CDC) was part of these efforts and continues work in the neighborhood today, and was consulted during development of the Housing Element. These new planning efforts helped to conserve the historic character of the neighborhood and build capacity among the residents to effectuate positive change. Housing Element workshops were conducted in or near this neighborhood on November 16, 2022, March 1, 2023 and August 9, 2023. Community feedback from the workshops was carefully considered and incorporated into the housing element Action Plan. To further support this neighborhood and promote equitable quality of life, the following Housing Element programs would be most applicable: * **Program 18** – Mixed Income Neighborhood Trust (the first trust of this kind has been established in the neighborhood and is being administered by the Lowell CDC). * **Program 19** – Home Buyer Assistance * **Program 22** – Housing Rehabilitation * **Program 23** – Comprehensive Code Enforcement * **Program 32** – Opportunity to Purchase Act * **Program 34** – Eviction Protection Program, and * **Program 36** – Homeless Assistance. **Downtown:** The 1,000-acre Downtown Neighborhood is located south of Divisadero and bounded by State Routes 41 and 99. Downtown is the oldest part of Fresno and was long the retail, entertainment, and cultural center for not only Fresno, but the surrounding region. Redlining relegated Chinese and other ethnicities, and their businesses, to the west side of the railroad tracks. As the City grew and freeway construction enabled new suburbs and suburban malls, commercial activity in Downtown began to decline. State routes 180, 41, and 99 further isolated downtown from the surrounding neighborhoods upon which it depended for its economic well-being. In the 1960s, the best thinking was to replicate suburban conditions in downtown, resulting in the conversion of Fulton Street to a pedestrian mall. Unfortunately, this and the continuing outward suburbanization continued to negatively impact commerce and quality of life in downtown. Many large department stores relocated to the suburban malls where commercial activity continues to be focused today. APPENDIX 1E: CITY OF FRESNO Downtown Fresno is now in transition, with new priorities established in the Downtown Neighborhoods Community Plan and Fulton Corridor Specific Plan adopted in 2016. While it still has challenges around underperforming retail and lack of round the clock activity, it is the city's largest job center, with over 30,000 jobs, and has the highest concentration of historic resources within the City of Fresno. It is slated to be the location of the nation's first High Speed Rail Station at Mariposa and G Streets. In the last decade, several blocks of new multi-unit and mixed-use development have occurred, mostly in the northern subarea, called the Cultural Arts District or the Mural District. Several projects called out in the plans have been or are being implemented, including the removal of the Fulton Mall and reconstruction of Fulton Street, Chinatown Urban Greening, enhancement of Mariposa Plaza, street upgrades, and sewer and water upgrades. Disparities in access to opportunity that still exist in the Downtown include average median incomes less than city average of $53,368, poor access to neighborhood serving retail and commercial uses, insufficient access to parks and open space, and aging infrastructure. Downtown has a higher pollution burden due to proximity to three freeways: SRs, 99, 180, and 41. In addition the amount of impervious surfaces results in higher levels of extreme heat. There is a high concentration of individuals experiencing homelessness and individuals with disabilities in the Downtown area; however, government services and high-quality transit opportunities are also concentrated Downtown. Housing Element workshops were conducted in or near this neighborhood on November 16, 2022, March 1, 2023 and August 9, 2023. Community feedback from the workshops was carefully considered and incorporated into the housing element Action Plan. Opportunities to promote equitable quality of life in Downtown Fresno include the following Housing Element Programs: * Program 7 – Adaptive Reuse * Program 24 – Special Needs Housing * Program 25 – Development Code Amendments for Compliance with State Law and to Reduce Barriers to Housing Development, and * Program 28 – Equitable Community Investments. Edison Neighborhood: This area consists of 1,560 acres located adjacent to and west of Downtown, bounded on the east by State Route (SR) 99, on the west by Thorne and West Avenues, and on the south by Church Avenue. This area is a multi-ethnic community that was the center of Fresno’s Black community. It includes older residential neighborhoods that are aligned on the original street grid, oriented to the UP railroad tracks; a testament to its original connection to Downtown. Key features of the built environment include Chandler Executive Airport (1929), a designated historic resource, Edison High School, and more churches per capita than any other neighborhood in Fresno. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING The area was redlined, graded as C and D on the Home Owners’ Loan Corporation (HOLC) Residential Security Map. Construction of SR 99 bifurcated vibrant neighborhoods and cut off this area from Downtown and Chinatown, which was its commercial center. The walkable historic pre-WWII neighborhood fabric was also disrupted by Urban Renewal policies and projects of the 1960s and 1970s, resulting in long-standing cleared vacant lots, public housing, and other developments on “superblocks” with buildings not oriented to the street. Subdivision infill occurred in the 1980s, resulting in patchwork development. School desegregation was implemented in the 1970s. In 1977, the Edison Community Plan was adopted, covering this neighborhood as part of a much larger area west of Downtown. Indicators of disparities include high segregation of people of color; over 40% of households living under the poverty level; 20-30% of households include individuals with disabilities; and high displacement risk. Housing stock is older and in need of repairs and/or weatherization. Additional environmental factors include lack of neighborhood retail access and high pollution burden due to freeway proximity. The neighborhood is in transition today, with a focus on revitalization as part of the Downtown Neighborhoods Community Plan. In 2018, the City was awarded $65 million in Transformative Climate Community funds, enabling investments of over $100 million to occur in the Edison Neighborhoods, Southwest Fresno, Downtown, and Chinatown. Investments underway include public transit (new routes provided with enhanced 15-minute frequency) and improvements being made to Frank H. Ball, Sunset, Maxie L Parks, and Neilsen Park. Pedestrian improvements are being made on Cesar Chavez (previously California) Blvd and Church Avenue. A new Community College was recently constructed on Church Avenue just south of the Edison neighborhood. Housing Element workshops were conducted in or near this neighborhood on November 28, 2022, March 14, 2023 and July 20, 2023. On June 18, 2024, a Climate Adaptation-Environmental Justice Workshop was held in the neighborhood that included fair housing concepts. Community feedback from the workshops was carefully considered and incorporated into the housing element Action Plan. Opportunities to promote equitable quality of life in the Edison neighborhood include the following Housing Element Programs: * **Program 19** – Homebuyer Assistance * **Program 22** – Housing Rehabilitation * **Program 23** – Comprehensive Code Enforcement * **Program 24** – Special Needs Housing * **Program 27** – Environmental Justice; Program, and * **Program 28** – Equitable Community Investments. APPENDIX 1E: CITY OF FRESNO **Southeast Neighborhood:** This primarily residential neighborhood consists of a 2,400-acre area to the east of Downtown, bounded by SR 41 on the west, SR 180 on the north, Chestnut on the east, and the railroad tracks, Butler, and Cesar Chavez on the south. The western portion of this neighborhood is the oldest, developed in the early 1900s. The area east of Orange and Cedar Avenues developed from the 1930s through the 1950s. Huntington Boulevard was the first subdivision on the eastern edge of Fresno's parent grid (and western edge of this neighborhood) and was platted in 1911 as a streetcar suburb as part of the Alta Vista Tract. Huntington Boulevard is an eclectic mix of architectural styles that were popular from 1911 through the 1960s, including Craftsman bungalows and period revival buildings. Of interest is the economic mix of buildings from upscale mansions to more modest residences for the middle class and working class. This early neighborhood influenced the surrounding neighborhoods, which were mostly working-class bungalow-style homes. Roosevelt High School was constructed in 1928 and there are six more elementary schools in the neighborhood. Like other neighborhoods within the Downtown Neighborhoods Community Plan area, this neighborhood was redlined. Abandonment of the streetcar in 1929 and the typical early zoning codes were factors that lead to the strip commercial development along the corridors seen today. This neighborhood was also influenced by freeways on its western and northern boundaries, and SR 41 facilitated the City's expansion to the north. When the Roosevelt Community Plan, which covered this area, was initially adopted in 1978, the need for updated infrastructure to facilitate orderly development did not happen in this neighborhood, leaving this area vulnerable to piecemeal rezoning of strip commercial and high-density residential uses. School and park development was unable to keep up with the rapid population growth. Recent investments in building neighborhood capacity (Restore Fresno), rezoning of corridors to mixed use development, designation of the Huntington Blvd neighborhood as a historic district, adoption of the DNCP and investment in high quality transit (BRT "lite") along Cesar Chavez Blvd are leading to neighborhood transformation. Indicators of disparities in access to opportunities include high segregation of people of color (primarily Hispanic), in southern half of neighborhood; 30-40% of households with incomes below the poverty level in the western portion of the neighborhood; and 40-60% of renter households cost burdened. Over 20% of households are experiencing overcrowding in the southern half of the neighborhood, and the neighborhood is categorized as having moderate displacement risk. The population is this area has lower access to cars, healthy food, and community facilities such as parks and libraries. It also has higher extreme heat risk due to low tree canopy coverage. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Today, the Southeast neighborhood is still predominantly residential. Strip commercial development still lines the major east-west corridors of Butler, Cesar Chavez (previously Kings Canyon), and Tulare Avenues. However, due to its inclusion in the DNCP, and also due to earlier planning efforts related to the Roosevelt Community Plan, the area is in transition, with a major investment in BRT made along the Cesar Chavez corridor in 2018 (the city's highest ridership corridor) connecting residents in this area to Downtown to the west and shopping and schools to the east. Holmes and Romain parks serve the west side of the project area, and these have both had recent investments in amenities, play equipment, and restrooms. Street improvement projects are underway on First Street and Chestnut Avenue that include new bicycle facilities. Investments in leadership capacity have been made through Restore Fresno and the Hidalgo Community Development Corporation now operates in the neighborhood, helping to connect residents to resources. Housing Element workshops were conducted in or near this neighborhood on October 27, 2022, July 28, 2023, and March 11, 2023. On June 29, 2024, a Climate Adaptation-Environmental Justice Workshop was held in the neighborhood that included fair housing concepts. Community feedback from the workshops was carefully considered and incorporated into the housing element Action Plan. Opportunities to promote equitable quality of life in the Southeast neighborhood include the following Housing Element Programs: * **Program 3** – Encourage and Facilitate Accessory Dwelling Units and Small Homes * **Program 22** – Housing Rehabilitation * **Program 23** – Comprehensive Code Enforcement * **Program 24** – Special Needs Housing * **Program 26** – Fair Housing Services * **Program 27** – Environmental Justice * **Program 28** – Equitable Community Investments * **Program 29** – Equitable Engagement * **Program 30** – Workforce Housing, and * **Program 34** – Eviction Protection. **Jane Addams Neighborhood:** This neighborhood consists of 1,155 acres located between the Golden State/Union Pacific Railroad alignment on the east and Marks, Hughes and West Avenues on the west. The area is physically isolated from its surroundings by the railroad and has poor internal connectivity as it is bifurcated by SR 99. Key features of the built environment include Roeding Park and Fresno Chaffee Zoo in the southern half and several mobile home parks. APPENDIX 1E: CITY OF FRESNO The Jane Addams community was originally rural in nature and consists of small homes on large lots. Tielman Elementary school was constructed in 1911. The Golden State Highway was expanded and redesignated as State Route 99 in 1964, which exacerbated the north/south barrier through the neighborhood. Hotels and motels were constructed along the freeway in the 1950s and 60s, which became blighted and magnets for criminal activity. Because the area was mostly developed while in the County, the roads did not meet City standards, lacking curb, gutter, sidewalks, and street trees. Past policies (or lack thereof) related to freeway construction and City-County coordination of growth and development resulted in negative impacts to this neighborhood. Today the Jane Addams neighborhood is still largely rural in nature. It is home to several mobile home parks and Jane Addams Elementary School, as well as a patchwork of heavy commercial uses. The area lacks neighborhood-scale open space and commercial amenities. An estimated 30-40% of the residents have incomes below the poverty level. Renter households comprise 40-60% of the neighborhood and 15-30% of the residents are recipients of Housing Choice Vouchers. Disparities that exist in the neighborhood include poor connectivity within and with surrounding areas, lacking pedestrian and bicycle infrastructure, poor open space access (although Roeding Park is part of this neighborhood, it is difficult to access), and high pollution burden due to freeway proximity. The neighborhood is in transition today, as public investments are being made in housing, transportation, sewer and water infrastructure, and parks. Among these are conversion of the hotels and motels on Parkway Drive in the project area to Project Homekey transitional housing, and a Parkway Drive Plan to improve the environment and provide freeway buffering and beautification along that corridor. In addition, McKinley Blvd is being widened and enhanced with pedestrian improvements; a pedestrian overcrossing connecting Parkway Drive and Roeding Park is in the early planning stages. The Jane Addams Community Development Corporation has been operating in this area since the Restore Fresno initiative in 2015, helping to build resident leadership capacity. Opportunities to promote equitable quality of life in the Jane Addams neighborhood include the following Housing Element Programs: * Program 3 – Encourage and Facilitate Accessory Dwelling Units and Small Homes * Program 27 – Environmental Justice * Program 28 – Equitable Investments, and * Program 33 – Mobile Home Parks. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING The R/ECAPS that are southwest, southeast, and north of Downtown, in Central Fresno, including the outer portions of Southwest Fresno, and portions of the Roosevelt ,McLane and Fresno High-Roeding Communities were affected by these same factors. While redlining did not occur south of Church Avenue, State Routes 41, 99, and 168 traverse those neighborhoods. In addition, poor coordination between City and County planning resulted in the County allowing residential development to occur in these areas in spite of the fact that the City had planned industrial development in the areas south of Downtown from as early as 1918 due to the abundance of transportation options available, including freeways and rail. The City is investing in these neighborhoods as well, with several specific planning efforts complete or underway, including the Southwest Specific Plan and the Central Southeast Specific Plan. These areas are further described below. Southwest Neighborhood: This 3,255-acre area is the southwestern continuation of the Edison Neighborhood, bounded by SR 180 to the north, North Avenue on the south, Valentine, Marks, Hughes and Walnut on the West, and West and Thorne on the east. Even as an area that developed post WWII, it has experienced many of the same influences as the Edison neighborhood. Initially agricultural land, the area developed as a patchwork of agricultural, residential, and industrial uses, with some commercial sprinkled throughout, resulting in land use incompatibilities. Urban Renewal policies resulted in clearing land for redevelopment that sometimes was left vacant for long periods of time. In addition, much of the transportation network developed in the County, lacking bicycle and pedestrian facilities. The construction of SR 99 cut this area off from its commercial center in Chinatown/Downtown and very little neighborhood serving commercial uses were developed to serve the neighborhoods, leaving residents to travel to other neighborhoods for daily shopping needs, banking, and other services. The following indicators point to disparities in access to opportunity: 30-40% of the population lives below the poverty line; individuals with disabilities comprise 20-30% of neighborhood residents; and data shows high segregation of people of color. About half of the households are renter households, and rental housing along the Church, Jensen, and North corridors has the highest cost burden. Overcrowding is occurring in over 20% of households between Cesar Chavez Blvd and Church Avenue and in the area between Elm Avenue and SR 41. The area has moderate displacement risk and high pollution burden due to freeway proximity and legacy land uses. It is also at risk for extreme heat due to low tree canopy of 8%, compared to the citywide average of 15%. Other environmental justice concerns include access to public facilities, safe and sanitary housing, and healthy food. Today, the Southwest Neighborhood is in transition pursuant to the adoption of the Southwest Fresno Specific Plan in 2017, which sought to enhance the plan area by incentivizing housing and commercial development, prioritizing parks and public facilities, and rezoning industrial land to other uses. A brownfields program was started in 2018 and an areawide plan to remediate and catalyze brownfields development was adopted for Elm Avenue in 2019. APPENDIX 1E: CITY OF FRESNO Implementation of the Southwest Specific Plan began in 2018 through the Transform Fresno program, which resulted in over $100 million in investment in the plan area, financing a portion of a new community college and the surrounding complete streets, a new park, a shared mobility program, planting of street trees, and more. At least 600 dwelling units of various types, including market-rate single family, are currently in the entitlement process and expected to begin construction in 2025. Southwest Fresno Development Corporation initiated a Homebuyer Education Program to prepare Southwest Fresno residents to purchase the new homes. Housing Element workshops were conducted in or near this neighborhood on November 28, 2022, March 14, 2023 and July 20, 2023. On June 18, 2024, a Climate Adaptation-Environmental Justice Workshop was held in the neighborhood that included fair housing concepts. Community feedback from the workshops was carefully considered and incorporated into the housing element Action Plan. Opportunities to promote equitable quality of life in Southwest Fresno include targeting the following Housing Element Programs: * **Program 3** – Encourage and Facilitate Accessory Dwelling Units and Small Homes * **Program 19** – Homebuyer Assistance * **Program 22** – Housing Rehabilitation * **Program 23** – Comprehensive Code Enforcement * **Program 24** – Special Needs Housing * **Program 27** – Environmental Justice * **Program 28** – Equitable Community Investments, and * **Program 30** – Workforce Development. Central Southeast Neighborhoods: This area consists of 2,200 acres adjacent to the eastern boundary of the DNCP, bounded by Belmont Avenue to the north, East Avenue to the west, Church Avenue to the south, and Peach Avenue to the east. Today the plan area includes approximately 30,624 people and 9,150 homes, and is characterized by a blend of older single-family and multi-family housing developments, industrial facilities, public facilities, vacant land, and commercial areas. This area developed post WWII, from the 1950s to the 1980s and includes both higher density single family neighborhoods laid out on small blocks within a gridded street system and later subdivisions with curved streets and cul-de-sacs. Early development in the area consisted of the Fresno County Fairgrounds, established in 1884. Other key elements of the neighborhood include Fresno Pacific University (1964), and the Fresno IRS processing center (now vacant) which was approved in the early 1970s to provide jobs for 4,000 employees. As noted in the Roosevelt Community Plan, the area was often passed over for new investment due to lack of adequate infrastructure and the predominant direction of growth to the north of the city. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING The City's facilitation of growth to the north had a negative impact on this area. When the Roosevelt Community Plan, which covered this area, was initially adopted in 1978, the need for updated infrastructure to facilitate orderly development was not prioritized in this neighborhood, leaving this area vulnerable to piecemeal rezoning of strip commercial and high-density residential uses. School and park development was unable to keep up with the rapid population growth. As of 2018, this neighborhood was more ethnically diverse and with a higher percentage of children than the City as a whole, and consisted of 71% renter households. An estimated 47% of the adult population has not graduated high school and 53% of the neighborhood’s households had incomes below the poverty level. The neighborhood includes a high percentage of population that does not own a car, low healthy food access, higher risk of extreme heat, high levels of cost burdened renters, and overcrowding, as well as low access to community facilities such as parks and libraries. Today the area is in transition, with investments in neighborhood capacity (Restore Fresno), rezoning of corridors to mixed use development, and investment in high quality transit (BRT) along Cesar Chavez Blvd. The IRS site is now vacant and could be available for housing. Sidewalks are being constructed in the neighborhood on the southeast corner of Tulare and Chestnut, near Burroughs Elementary School, and ITS technology is being installed along the Cesar Chavez corridor, all of which are contributing to neighborhood transformation. A Housing Element workshop was conducted in this neighborhood on November 1, 2022. On June 29, 2024, a Climate Adaptation-Environmental Justice Workshop was held in the neighborhood that included fair housing concepts. Community feedback from the workshops was carefully considered and incorporated into the housing element Action Plan. Opportunities to promote equitable quality of life in Southeast Fresno include targeting the following Housing Element Programs: * **Program 3** – Encourage and Facilitate Accessory Dwelling Units and Small Homes * **Program 22** – Housing Rehabilitation * **Program 23** – Comprehensive Code Enforcement * **Program 24** – Special Needs Housing * **Program 26** – Fair Housing Services * **Program 27** – Environmental Justice * **Program 28** – Equitable Community Investments * **Program 29** – Equitable Engagement * **Program 30** – Workforce Development, and * **Program 34** – Eviction Protection. **McLane Neighborhood:** This large area, the subject of a Community Plan, consists of 16 square miles, bounded on the north by Ashlan Avenue, the south by McKinley and Belmont Avenues, the east by Locan Avenue, and the west by Blackstone. Key features include the Fresno Yosemite Airport and Manchester Mall. According to the McLane Community Plan, adopted in 1976, the Plan area was fairly orderly and balanced. The area began to develop in the 1940s with the anticipation of Fresno State College locating at Blackstone and Shields, the current location of Manchester Mall. The area primarily developed during post WWII, between the 1950s and the 1980s. The plan notes that multi-unit development had increased from 11% of the housing stock in 1960 to 37% in 1978. Heavy commercial uses and the then new Manchester Mall were located on Blackstone Avenue, while office uses were primarily located on Fresno, First, and Shields Avenues. The area was affected by freeways, as during the period when the community plan was written, rights of ways for SRs 41 and 168 had been cleared, but no construction had taken place for several years, causing uncertainty. Growth to the northeast caused bypassed parcels and sporadic rural residential development east of Clovis Avenue. In general, during the 1970s, the housing conditions were above average, the median income was higher than the Fresno average, and the community had above-average indicators of health. Today, the McLane area is categorized as 40-60% renter households and the area between Ashlan, McKinley and SRs 41 and 168 is the most cost burdened. Higher poverty areas are on both sides of the three freeways that bound or traverse the area: SRs 41, 180, and 168, while incomes increase east of Willow Avenue. An estimated 30-60% of households in the area between SR 41 and First Street depend on Housing Choice Vouchers, one of the highest rates in the city. The northern portion of the McLane area is racially integrated, while the southern portion is less so. The McLane community has a high pollution burden from airport emissions and well as two freeways, as well as low tree canopy and high urban heat. The McLane area has developed according to the community plan. The airport expanded and an airport environs plan was adopted to protect the surrounding area from airport noise. Land use and street circulation was adjusted around the airport to include compatible uses such as industrial. The freeways were constructed. Manchester Mall developed, peaked, and is now being repurposed into educational, office, and residential uses. Blackstone has become the city's first BRT corridor. Current investments include construction of the Midtown Trail which traverses the area, a terminal expansion at the airport, numerous traffic improvements including pedestrian amenities, and a new park is being designed at Dakota and Barton. Fresno Interdenominational Refugee Ministries is located in this neighborhood and serves the needs of over 10,000 refugees in the Fresno area, primarily refugees of Southeast Asian, Slavic and African origin. Housing Element workshops were conducted in or near this neighborhood on August 31, 2022, November 16, 2022, and August 9, 2023. On April 23, 2024, a Climate Adaptation-Environmental Justice Workshop was held in the neighborhood that included fair housing concepts. Community feedback from the workshops was carefully considered and incorporated into the housing element Action Plan. Opportunities to promote equitable quality of life include targeting the following Housing Element Programs to the McLane neighborhood: SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING * **Program 3** – Encourage and Facilitate Accessory Dwelling Units and Small Homes * **Program 19** – Homebuyer Assistance * **Program 22** – Housing Rehabilitation * **Program 23** – Comprehensive Code Enforcement * **Program 27** – Environmental Justice * **Program 28** – Equitable Community Investments * **Program 30** – Workforce Development, and * **Program 34** – Eviction Protection Program. **Fresno High-Roeding Neighborhood.** This neighborhood is located in the northern portion of the Fresno High/Roeding Community Plan area and consists of approximately 950 acres bounded by Dakota on the north, Palm on the east, Clinton on the south, and SR 99 on the west. This area developed between the 1950s and 1980s and is within the environs of SR 99. This neighborhood has low food access and very low parks access. Over 40% of all households in this neighborhood live below the poverty level, are renter households, and 60-80% of the households are cost-burdened. Overcrowding is high, with over 20% of households overcrowded. Displacement risk is moderate. Current investments in this area include a road and sidewalk improvement project in the area bounded by Clinton/Hughes/Shields/West. Housing Element workshops were conducted near this neighborhood on November 16, 2022, and August 9, 2023. On June 1, 2024, a Climate Adaptation-Environmental Justice Workshop that included fair housing concepts was attended by residents from this neighborhood. Community feedback from the workshops was carefully considered and incorporated into the housing element Action Plan. Opportunities to promote equitable quality of life in the Fresno High-Roeding Park Neighborhood include targeting the following Housing Element Programs: * **Program 3** – Encourage and Facilitate Accessory Dwelling Units and Small Homes * **Program 19** – Homebuyer Assistance * **Program 22** – Housing Rehabilitation * **Program 23** – Comprehensive Code Enforcement * **Program 27** – Environmental Justice * **Program 28** – Equitable Community Investments, and * **Program 30** – Workforce Development. The R/ECAPS in north Fresno developed in the 1950s and the 1980s and have unique factors contributing to their current condition. APPENDIX 1E: CITY OF FRESNO **El Dorado Park Neighborhood.** Located in the Hoover Community west of Fresno State, this neighborhood is occupied by a mix of low income residents and families. Much of the housing stock was cheaply built in the 1960s for students by absentee landlords and has not been well maintained. In recent years, newer student housing has been constructed, accommodating students, while some of the older off-campus student housing has turned over and is being rented to low-income non-student residents. The El Dorado Park Neighborhood Plan, incorporated into the Hoover Community Plan in 2009, was an effort to revitalize this near-campus neighborhood. After the plan was adopted, Fresno Housing revitalized two aging apartment buildings and provided upgraded deed restricted housing for this neighborhood. This inspired neighboring property owners to make improvements to their properties as well, and the PARCs Department now runs programs from a church property in the neighborhood. The momentum generated by the planning and revitalization efforts resulted in the construction of a new community center, which opened after the pandemic. The center has a gym, educational programs, after-school programs, and activities for seniors. Even after adoption of the El Dorado Park Neighborhood Plan, the neighborhood is still in transition, with high levels of poverty, renter households, and cost burden. A 15-30% utilization of Housing Choice Vouchers exists in this neighborhood. Significant social disparities exist in the community and are most prevalent between the Fresno State area and El Dorado Park. Fresno State owns many of the adjacent parcels surrounding the campus and provides amenities such as libraries, athletic and recreational facilities, and dining facilities that are intended to serve its student population. By contrast, El Dorado Park has aging infrastructure and experiences higher levels of crime. Both Fresno State and El Dorado Park have high pollution exposure due to proximity to freeways and the Fresno Yosemite Airport. Recent investments include a new Class IV bike path along Barstow Avenue, the northern boundary of the neighborhood. Housing Element workshops were conducted in or near this neighborhood on February 25, 2023 and July 22, 2023. On June 1, 2024, a Climate Adaptation-Environmental Justice Workshop was held in the neighborhood that included fair housing concepts. Community feedback from the workshops was carefully considered and incorporated into the housing element Action Plan. Opportunities to promote equitable quality of life in the El Dorado Park neighborhood include targeting the following Housing Element Programs: * **Program 19** – Homebuyer Assistance * **Program 22** – Housing Rehabilitation * **Program 23** – Comprehensive Code Enforcement * **Program 27** – Environmental Justice, and * **Program 28** – Equitable Community Investments. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING **Shaw/Marks Neighborhood.** Located in the southwest corner of the Bullard Community Plan, this 785-acre R/ECAP is located in the southwest quadrant of the intersection of Shaw and Marks Avenues, bounded by Shaw Ave on the north, Marks Avenue on the east, and bounded by the SR 99 corridor and the UP railroad tracks on the west. While the Bullard Community Plan area generally scores high on measures related to income, socio-economic conditions, and environmental conditions, this particular area is subject to pollution burden. Compared to the rest of the Bullard Community Plan area, this neighborhood has lower incomes, a higher proportion of renter households (40-60% compared to under 20% for much of the plan area), and higher utilization of Housing Choice Vouchers (5-15% compared to less than 5% for most of the plan area). Housing Element workshops were conducted near this neighborhood on November 9, 2022 and March 1, 2023. Community feedback from the workshops was carefully considered and incorporated into the housing element Action Plan. Opportunities to promote equitable quality of life in the Shaw/Marks Neighborhood include targeting the following Housing Element Programs: * **Program 19** – Homebuyer Assistance * **Program 22** – Housing Rehabilitation * **Program 23** – Comprehensive Code Enforcement * **Program 27** – Environmental Justice * **Program 28** – Equitable Community Investments, and * **Program 30** – Workforce Development. ### Areas of Affluence Racially or Ethnically Concentrated Areas of Affluence (RCAAs) are neighborhoods in which there are both high concentrations of White households and high household income rates. Using HCD’s methodology for identifying RCAAs in California, RCAAs in Fresno County are census tracts with: 1) an average total White population that is 1.25 times higher than the average total White population in the Fresno County region and 2) a median household income that is 1.5 times higher than the Fresno County AMI in 2019. Based on this methodology, there are several RCAAs in Fresno County (see Figure 3-16, Regional RCAAs) including in the cities of Fresno and Clovis. As shown in the figure, RCAAs are present in unincorporated islands including additional unincorporated areas east of Clovis and Fresno. Figure 1E-3.12 displays a closer look at RCAAs in the city of Fresno. There are 18 RCAA tracts within the city limits. Several of the RCAA tracts overlap with areas that are not incorporated into Fresno city limits as of 2022. Within Fresno City, RCAAs are generally found in the North and Northeast Fresno neighborhoods, often characterized by high property values, excellent schools, and well-maintained infrastructure. Neighborhoods deemed as RCAAs include portions of the Woodward Park, Bullard, McLane, and Roosevelt community areas. APPENDIX 1E: CITY OF FRESNO Figure 1E-3.12: Racially/Ethnically Concentrated Areas of Affluence, Fresno, 2019 <
> Source: Data download from the HCD AFFH Mapping tool in 2021. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-45 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Several policies and historical forces have contributed to the formation of RCAAs. Areas of affluence in Fresno largely developed as a result of newly constructed freeways and new subdivision development at the outer edges of the city where land was less expensive. Historically, lending practices have favored white, affluent borrowers, facilitating easier access to home loans and homeownership in these areas while zoning regulations favored single-family homes and large lot sizes limiting the availability of affordable housing to maintain high property values. Affluent households began to purchase new single family homes on inexpensive land in north and northeast Fresno. These northern suburbs have the advantage of Clovis Unified School District’s high performing schools and a healthcare sector along Herndon Avenue . Affluent northern neighborhoods are also well served by large amounts of park land since they were developed more recently when the City established a mechanism to require land dedication and fees for park development, while many of the central neighborhoods in Fresno lack convenient access to parks and fall well below the City standard of 3.0 acres per 1,000 residents, since these neighborhoods were developed prior to having park dedication and development requirements. As will be discussed, these neighborhoods have the greatest access to resources including positive educational outcomes, high labor market engagement (despite having further proximity from major employment centers), and healthier environmental conditions relative to the region. Compared to other areas in the city, RCAAs have distinct characteristics: * Predominantly white population (Figure 1E-3.2) * Median household incomes greater than $100,000 per year (Figure 1E-3.5) * Significantly lower poverty rates (Figure 1E-3.7) * Higher percentages of children in married-couple households (Figure 1E-3.8) than single-parent households (Figure 1E-3.9) * Lower rates of people living with disabilities (Figure 1E-3.10) * Positive educational outcomes based on the 2021 TCAC Opportunity Index (Figure 1E-3.15) * Greater labor market engagement (Figure 1E-3.17) * More positive environmental conditions Index (Figure 1E-3.23 through Figure 1E-3.25) * Higher percentage of owner-occupied units (Figure 1E-3.28) * Lower rates of housing cost burden (Figure 1E-3.31 and Figure 1E-3.32) The Housing Element includes the following programs, many of which are already established and ongoing, which will help to promote inclusivity, affordability, and diversity in RCAAs (see Section 1E-1 Action Plan for more details on each of these programs): * Program 2 – Variety of Housing Opportunities in High Resource Areas. Create additional capacity for multi-unit lower-income housing units in high and highest resource areas. * Program 3 – Encourage and Facilitate Accessory Dwelling Units and Small Homes. Promote the construction of ADUs to increase affordable housing options and diversify housing types in RCAAs. * Program 11 – Incentives for Housing Development. Encourage the development of affordable housing in RCAAs by providing financial and regulatory incentives. - Program 14 – Partnerships with Affordable Housing Developers. Partner with affordable housing developers and stakeholders to facilitate the development of housing that is affordable to low- very low- and extremely low- income households, with at least 40 percent developed in high or highest resource areas to facilitate housing mobility for lower-income households and special-needs groups. - Program 20 – Housing Choice Voucher Incentive Program. Provide housing vouchers and subsidies to low-income families, allowing them to move to RCAAs. Partner with landlords and property managers in RCAAs to encourage participation in voucher programs. - Program 26 – Fair Housing Services. Provide training and resources for landlords and property managers on fair housing laws and best practices to prevent bias based on race, ethnicity, income, or family status. ### Contributing Factors to Patterns of Segregation Municipal land use policies (e.g., zoning, code enforcement, and redevelopment) are one of the focal determinants affecting race and class segregation. In most cities throughout the San Joaquin Valley, it is common for higher income areas (e.g., RCAAs) to be zoned single family or low density residential, while lower-income areas (e.g., RECAPs) contain most of the higher density residential zoning. This trend is applicable to development patterns in Fresno particularly in new growth areas, such as Northeast Fresno, which start out with predominantly single family development then fill in with higher density residential later. Regulatory constraints have perpetuated patterns of spatial inequality since middle- and lower- income households have traditionally been excluded from these high opportunity areas. ### Access to Opportunity Since 2017, the Tax Credit Allocation Committee (TCAC) and California Department of Housing and Community Development (HCD) have developed annual maps of access to resources such as high-paying job opportunities; proficient schools; safe and clean neighborhoods; and other healthy economic, social, and environmental indicators to provide evidence-based research for policy recommendations. This effort has been dubbed “opportunity mapping” and is available to all jurisdictions to assess access to opportunities within their community. HCD defines access to opportunity as a concept to approximate place-based characteristics linked to critical life outcomes.[^p197-12] Improving access to opportunity means both improving the quality of life for residents of low-income communities, as well as supporting mobility and access to “high resource” neighborhoods. This encompasses education, employment, economic development, safe and decent housing, low rates of violent crime, transportation, and other opportunities, including recreation, food, and healthy environment (air, water, safe neighborhood, safety from environmental hazards, social services, and cultural institutions). The opportunity mapping process includes three domains: economic, environmental, and education. Each domain uses a number of indicators to determine its individual score. Table 1E-3.4 shows the full list of indicators. The indicators are then averaged into a composite index score. [^p197-12]: California Department of Housing and Community Development (HCD) AFFH Guidance Memo, April 2021 update, pg. 34. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Table 1E-3.4: Domains and List of Indicators for Opportunity Maps | Domain | Indicators | | :--- | :--- | | Environmental | CalEnviroScreen 4.0 pollution indicators and processed values | | Economic | Poverty | | | Adult education | | | Employment | | | Job proximity | | | Median home value | | Education | Math proficiency | | | Reading proficiency | | | High School graduation rates | | | Student poverty rates | | Poverty and Racial Segregation | Poverty: tracts with at least 30 percent of population under federal poverty line | | | Racial Segregation: Overrepresentation of people of color relative to the county (i.e., Tracts with a racial location quotient higher than 1.25 for Black or African American, Hispanic, Asian, or all people of color in comparison to the county) | *Source: CA Fair Housing Task Force, Methodology for TCAC/HCD Opportunity Maps, December 2021.* The opportunity mapping tool maps areas of highest resource, high resource, moderate resource, moderate resource (rapidly changing), low resource, and high segregation and poverty. * **Highest Resource.** Areas designated as “highest resource” are the top 20 percent highest-scoring census tracts in the region. It is expected that residents in these census tracts have access to the best outcomes in terms of economic opportunities, health, and education attainment. * **High Resource.** Census tracts designated “high resource” score in the 21st to 40th percentile compared to the region. Residents of these census tracts have access to highly positive outcomes for health, economic, and education attainment. * **Moderate Resource.** “Moderate resource” areas are in the top 30 percent of the remaining census tracts in the region and those designated as “moderate resource (rapidly changing)” have experienced rapid increases in key indicators of opportunity, such as increasing median income, home values, and an increase in job opportunities. Residents of these census tracts have access to either somewhat positive outcomes in terms of health, economic attainment, and education; or positive outcomes in a certain area (e.g., score high for health, education) but not all areas (e.g., may score poorly for economic attainment). * **Low Resource.** Low-resource areas are those that score in the bottom 30 percent of census tracts and indicate a lack of access to positive outcomes and poor access to opportunities. * **High Segregation and Poverty.** The final designation are those areas identified as having “high segregation and poverty;” these are census tracts that have an overrepresentation of people of color compared to the county as a whole, and at least 30 percent of the population in these areas is below the federal poverty line ($27,750 annually for a family of four in 2022). APPENDIX 1E: CITY OF FRESNO Overall, in comparison to other more affluent areas of California, the San Joaquin Valley has very little access to opportunity.[^p199-13] Figure 1E-3.13 shows the composite score of the 2022 TCAC Opportunity Areas in the Fresno County region. As shown in the figure, most of Fresno County is a mix of low-resource or moderate-resource areas and areas of high segregation and poverty. There are pockets of high-resource designations throughout incorporated areas and in the northeast and eastern portions of the county. Lower resource areas of high segregation and poverty are identified in the western unincorporated areas of the county. Figure 1E-3.14 shows a closer look at the TCAC Opportunity Areas in the city of Fresno. As the largest city in the county, Fresno has the greatest variation in resource area designations among the incorporated cities of Fresno County. Growth areas on the periphery of established neighborhoods along the northern and eastern edges of the city are designated moderate and high resource designations, including an annexation area, designated as highest. The central portion of the city is designated as low resource and high segregation and poverty. Across the nation, affordable housing has been disproportionately developed in minority neighborhoods with high poverty rates, thereby reinforcing the concentration of poverty and racial segregation in low opportunity and low resource areas. Fresno is no different. While communities of color account for more than half of the population in the county, the county’s racial inequities persist across all indicators of community health and well-being. These inequities threaten future economic prosperity.[^p199-14] [^p199-13]: San Joaquin Valley Fair Housing and Equity Assessment, 2014. Available via: https://academics.fresnostate.edu/oced/documents/SJV_Fair-Housing-and-Equity-Assessment_April-2014.pdf. [^p199-14]: PolicyLink, 2017. Advancing Health Equity and Inclusive Growth in Fresno County. Accessed via: https://www.policylink.org/sites/default/files/advancing-health-equity-and-inclusive-growth-in-fresno.pdf. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Figure 1E-3.13: TCAC Opportunity Areas - Composite Score, Region, 2022 <
> Source: Data downloaded from the California State Treasurer TCAC/HCD Opportunity Area Maps in 2022. APPENDIX 1E: CITY OF FRESNO ### Figure 1E-3.14: TCAC Opportunity Areas - Composite Score, Fresno, 2022 <
> *Source: Data downloaded from the California State Treasurer TCAC/HCD Opportunity Area Maps in 2022.* SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ## Educational Opportunity School proficiency is an indication of the quality of education that is available to residents of an area. High quality education is a vital community resource that can lead to more opportunities and improve quality of life. Historically, neighborhoods or communities with higher median incomes and home values have had access to higher-performing schools than residents of lower-income neighborhoods since income distribution influences home values and property taxes, and therefore funding for public schools. Each year, the California Department of Education (DOE) publishes performance metrics for public schools in the state, including student assessment results for English Language Arts and Mathematics as they compare to the state grade-level standards and demographic characteristics of each school’s student population. Historically, school districts with higher concentrations of affordable housing typically have lower test scores in schools. The characteristics reported on include rates of chronic absenteeism and suspension, percentage of students that are socioeconomically disadvantaged, percentage of students that are in foster care, percentage of students learning the English language, and the percentage of high school students that are prepared for college. Students who are eligible for free or reduced-priced meals, or who have parents or guardians who did not receive a diploma are also considered socioeconomically disadvantaged. TCAC and HCD rely on this data from DOE to determine the expected educational outcome in each census tract and block group within the state. TCAC and HCD’s educational domain score reflects mathematics proficiency, reading proficiency, high school graduation rates, and student poverty rates of all schools for which this data is available, culminating in a score ranging from 0 to 1, with higher values being the most positive expected educational outcome. Figure 1E-3.15 shows the 2021 TCAC/HCD education domain score in Fresno. Access to proficient schools among block groups varies significantly throughout the city. Clovis Unified School District and Central Unified School District are performing best as indicated in this map. Block groups in north Fresno, which have higher proportions of white residents, have the highest school proficiency index scores (greater than .75). Despite the presence of CSU Fresno and University High School, a top 100 school by U.S. News and the highest ranked high school in Fresno, census tracts surrounding the CSU Fresno campus scored between 0.25 and 0.5 indicating less positive education outcomes. The area is classified as a racially concentrated area of poverty, and as described above and shown in Table 1E-3.4, student poverty rates are a determining variable in measuring educational opportunity and outcomes. School proficiency index scores are lowest in the southern and western portions of the city, areas in which Hispanic and Black or African American residents generally reside, and within Fresno Unified and Washington Union school districts. APPENDIX 1E: CITY OF FRESNO # Figure 1E-3.15: TCAC Opportunity Areas - Education Score, Fresno, 2021 <
> Source: Data downloaded from the HCD AFFH Data Tool in 2021. Note that this data is based on 2021 TCAC Opportunity Areas as the 2022 data by indicator is not yet available through the HCD AFFH Tool. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-53 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Results from the survey conducted for the 2020 Analysis of Impediments to Fair Housing Choice in Fresno echoed concerns surrounding disparate access to proficient schools, with approximately 40 percent of survey respondents noting that schools in the city are not equally provided for. In addition, public comments received on the Draft Housing Element expressed concerns that students in certain areas of the city, particularly in R/ECAP areas, face unsafe and challenging conditions traveling to and from school. This is due to the lack of or incomplete sidewalks, stormwater drainage, and streetlights in these areas; coupled with inefficient public transportation options in neighborhoods at the fringes of the city; and the use of local roads by heavy-duty truck traffic. These conditions also have a significant impact on the quality of the environment in which learning is taking place. The City intends to prepare an Environmental Justice element that will dive deeper into these issues to develop specific actions related to educational opportunity and equitable access. ### Employment Opportunity Although neighborhoods with jobs in close proximity are often assumed to have good access to jobs, distance alone does not capture any other factor such as transportation options, the type of jobs available in the area, or the education and training necessary to obtain them. There may be concentrations of jobs and low-income neighborhoods in urban centers, but many of the jobs may be unattainable for residents of low-income neighborhoods. This section analyzes both the labor market engagement and jobs proximity indices, developed by HUD, which together offer a better indication of job accessibility for residents of specific areas. The jobs proximity index measures the physical distance between place of residence and job locations, with employment centers weighted more heavily. It also takes into account the local labor supply (i.e., competition for jobs) near such employment centers. The Labor Market Engagement Index is based on unemployment rate, labor force participation rate, and the percentage of the population age 25 and over with a bachelor’s degree or higher. For both indices, census block group results are standardized on a scale of 0 to 100 based on relative ranking nationally. A higher score indicates stronger job proximity or labor force participation. Figure 1E-3.16 shows the Jobs Proximity Index in Fresno. Fresno generally has moderate levels of jobs proximity. Block groups with high proximity to jobs are well-distributed across the city indicating employment centers. Jobs Proximity Index scores are higher for Downtown neighborhoods as well as in north Fresno around the Hoover neighborhood and California State University (CSU) Fresno. Additionally, data shows that the majority of workers employed in the city both live and work in Fresno (56.8 percent) while a lower proportion of residents live in Fresno but commute to employment elsewhere (43.2 percent). APPENDIX 1E: CITY OF FRESNO Figure 1E-3.16: Jobs Proximity Index, Fresno, 2017 <
> Source: Data downloaded from the HCD AFFH Data Tool in 2021. Based on 2014-2017 HUD Jobs Proximity Index. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-55 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING **Figure 1E-3.17** maps Labor Market Engagement Index scores for block groups in Fresno. Despite being one the largest cities in the county, there are stark disparities in labor market engagement in that most of Fresno’s southern block groups indicate low levels of engagement with the labor market. Regionally, the highest labor force engagement scores are in the unincorporated county islands in northern Fresno and the majority of Clovis and unincorporated area immediately adjacent to Clovis on the east. While block groups in north Fresno display high levels of labor market engagement, the southern areas of the city have low levels of engagement with the labor market, which can indicate high unemployment rates and/or low educational attainment. Compared to **Figure 1E-3.7** above, Distribution of Poverty, the population living below the poverty line generally has higher levels of jobs proximity compared to the population in the city as a whole but lower levels of labor market engagement, indicating an inability to access jobs due to factors other than proximity or a choice to not engage in the labor market. Comparing **Figures 1E-3.5** and **1E-3.7**, not engaging in the labor market can be a contributing factor to lower median incomes and poverty. Interviews with stakeholders in the city conducted for the 2020 Analysis of Impediments to Fair Housing Choice indicated that contributing factors to lower labor market engagement may also be a result of lack of access to transportation and/or mismatches between available jobs and worker education and skillsets. Figure 1E-3.17: Labor Market Engagement Index, Fresno <
> Source: Data downloaded from the HCD AFFH Data Tool in 2021. Based on HUD Labor Market Engagement Index. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ## Transit Mobility Transit mobility refers to an individual’s ability to navigate the city and region on a daily basis to access services, employment, schools, and other resources. Indicators of transit mobility include the extent of transit routes, proximity of transit stops to affordable housing, and frequency of transit. The city of Fresno is generally car-dependent but there is some variation in level of transit access, walkability, and access to amenities. AllTransit is one type of transit and connectivity analytic tool developed by the Center for Neighborhood Technology for the advancement of equitable communities and urban sustainability[^p208-15]. The tool analyzes the transit frequency, routes, and access to determine an overall transit score at the city, county, and regional levels. Geographic regions (e.g., cities, counties, Metropolitan Statistical Areas (MSAs)) are scored on a scale of 0 to 10, with 10 being complete transit connectivity. The Multi-Jurisdictional Housing Element Chapter 3, Table 3-18 displays AllTransit Performance Scores for all Fresno County jurisdictions based on data from 2019. Figure 1E-3.18 below shows Fresno’s performance score representing average household transit access. Fresno’s score is 5.0, indicating a low combination of trips per week and number of jobs accessible, enabling fewer people to take transit to work. Overall, Fresno has a higher performance score than the county (3.2) however the city of Fresno represents an outlier both in terms of population size, degree of urbanization, and transit accessibility amongst jurisdictions in the county. It should be noted that since the last update of AllTransit analytics in 2019, transit routes have been added, frequencies increased, and fares reduced. ### Figure 1E-3.18: AllTransit Performance Score, Fresno, 2019 <
> Source: AllTransit.cnt.org, 2019 [^p208-15]: Center for Neighborhood Technology, 2019, AllTransit™, alltransit.cnt.org APPENDIX 1E: CITY OF FRESNO There are three major public transit operators that serve the residents in the city and county of Fresno. The City of Fresno’s Fresno Area Express (FAX) is the largest transit operator, offering high capacity fixed-route services and a demand responsive service for disabled riders (Handy Ride). The City of Clovis’ Stageline offers four fixed routes with 30-minute headways, limited weekend fixed-route service, and a demand responsive paratransit service (Round Up). In smaller cities and rural communities, the Fresno County Rural Transit Agency (FCRTA) provides limited fixed route service and demand responsive services within and between communities through several community-focused transit subsystems. FCRTA links to FAX and Stageline services in the Fresno-Clovis Metropolitan Area (FCMA). Fresno residents are primarily served by FAX, operated by the City of Fresno. FAX operates on a modified grid system and provides service on 18 transit routes on weekdays and weekends. The fixed route system consists of 10 lines that provide service in a predominantly north-south direction, seven east-west cross-town lines, and a 15.7-mile Bus Rapid Transit (BRT) line that operates on Blackstone Avenue from north Fresno to Downtown and on Ventura/Kings Canyon from Downtown to Clovis Avenue. In addition to the BRT, FAX operates 15-minute frequencies on Route 9 (Shaw Avenue), Route 34 (First Street), and Route 38 (Cedar Avenue). To better serve residents in neighborhoods on the fringe, FAX recently extended Route 45 farther into West Fresno and extended Route 34 farther into South Central Fresno. They also recently upgraded Route 34 to a 15-minute frequency route. The system is designed to facilitate bus travel by making transfers convenient between intersecting lines and between seven lines that converge Downtown at Courthouse Park. The FAX system map is shown in Figure 1E-3.19. Note that the figure does not reflect the most recent extensions of Routes 34 and 45 into West and South Central Fresno. FAX generally serves the Fresno-Clovis Metropolitan Area. Within the city of Fresno, FAX is strongly connected to the Central Business District. The Central Business District is the local and regional governmental center for federal, state, county, city, and educational offices, and contains the Community Regional Medical Center and a regional shopping center (Fulton Street). The Fresno Convention Center, two major hotels, various private office buildings, Amtrak, the regional bus station, and the future high-speed rail station, are also located in this area. Seven of FAX's 18 routes converge in the Central Business District and other routes serve several other regional centers of employment. Residents living on the fringe of the city experience barriers to public transportation as there are fewer routes available in these areas. The fringe includes both disadvantaged neighborhoods which are more strongly reliant on public transportation and high resource neighborhoods in North, Northwest, and East Fresno. FAX Handy Ride is a shared ride, curb-to-curb service, provided from any origin to any destination throughout the service area for any trip purpose. The accommodation service was designed to meet the transportation needs of eligible persons with disabilities who cannot functionally use the FAX City bus system. Service hours for Handy Ride mirror those of FAX fixed route service, and reservations are required one day in advance of the scheduled trip to comply with ADA regulations. A limited number of will calls are provided each day based on availability, with priority going to medical appointments. FAX is in full compliance with the ADA. The Handy Ride service area mirrors the FAX fixed route service area plus three-quarters of a mile. The service area for Handy Ride is shown in Figure 1E-3.20. The current service area is bounded by Copper Avenue on the north, Central Avenue on the south, Grantland/Polk Avenue on the west, and Willow/Temperance Avenue on the east. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Figure 1E-3.19: Fresno Area Express (FAX) System Map <
> *Source: City of Fresno, Department of Transportation, 2022.* APPENDIX 1E: CITY OF FRESNO # Figure 1E-3.20: Handy Ride Service Area Map, 2023 <
> Source: City of Fresno, Department of Transportation, 2023. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Figure 1E-3.21 displays HUD’s Transportation Cost Index for the region and Figure 1E-3.22 displays a closer look at index scores in the city of Fresno. While access to low-cost transportation is moderate and relatively uniform throughout most neighborhoods in the city, block groups in Downtown, proximate to the Yosemite International Airport and CSU Fresno campus, and in centrally located established neighborhoods have lower transportation cost levels with the lowest levels located at the major transportation hubs of Herndon and Blackstone Avenues and the Central Business District in Downtown. Higher transportation costs exist in neighborhoods that are on the fringe of the city. According to the 2020 Analysis of Impediments, transit usage is highest in South and West Fresno and lowest in the city’s most northern block groups. Within the region, Black or African American, Hispanic, and Asian or Pacific Islander populations below the poverty line use public transportation more than White populations. Overall low levels of transit performance in Fresno combined with moderate levels of access indicates potential challenges for residents without access to vehicles in accessing needed services and amenities. Transit fares in the city are now the lowest they have ever been, with expanded free fares to children under 12 and Veterans/Active Military. As part of the Zero Fare Clean Air Act, on May 13, 2022, Kaiser Permanente Fresno awarded grant funds to FAX to subsidize fares for Reduced Fare riders. Reduced Fare riders include seniors 65 or older with ID, Medicare card holders, and persons with disability placards. This project is supported by Kaiser Permanente Northern California Community Benefit Programs. Then in January 2023, Fresno State University, State Center Community College District, and Fresno Unified School District started subsidizing transit fares for students, faculty, and staff. Despite this, there are still barriers to mobility for residents, particularly those living on the fringe of the city. Barriers include lengthy travel times due to long bus wait times, lack of direct routes, and route limitations requiring residents to use multiple modes of transportation to reach their first and last stop. High transportation costs also contribute to overall low levels of affordability in Fresno. For a typical household in Fresno, combined housing and transportation, makes up an estimated 61 percent of household income according to the 2020 Analysis of Impediments to Fair Housing Choice. For a moderate-income household in the region, the proportion jumps to 71 percent. Notably, combined housing and transportation costs are lower closer to the city center and are generally higher further out from the city. According to comments received during the public review process for the Draft Housing Element, other issues related to transit mobility in the city are: * Inadequate and/or absent infrastructure to facilitate safe and efficient active transportation, including but not limited to sidewalks, curbs, stormwater drainage, streetlights, crosswalks, and protected bike lanes. * Inadequate and/or absent protection from extreme weather, including climate-related weather events, such as extreme heat and flooding, that impact walking, biking, and public transportation use. This includes but is not limited to the availability of shade (e.g., trees, structures), shelter, sidewalks, and stormwater drainage. * The presence of high volumes of traffic, including heavy-duty truck traffic, on roadways used by pedestrians or bicyclists, including in and near areas zoned for industrial land uses and along designated truck routes. APPENDIX 1E: CITY OF FRESNO To address these issues, the Housing Element includes a program to direct investments to address infrastructure and public service deficiencies in high-need areas including areas classified as high segregation and poverty, low resource, and moderate resource in **Figure 1E-3.14**. As funding allows, the City will prioritize neighborhood infrastructure improvements such as water, sewer, curbs, gutters, sidewalks, streets, curb ramps, driveway approaches, curb cuts, and streetlights in areas of greatest needs in coordination with new residential developments. **Figure 1E-3.21: Transportation Cost Index, Fresno County Region, 2017** <
> *Source: Data downloaded from the HCD AFFH Data Tool in 2021. Based on 2013-2017 HUD Low Cost Transportation Index.* FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-63 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Figure 1E-3.22: Transportation Cost Index, Fresno, 2017 <
> *Source: Data downloaded from the HCD AFFH Data Tool in 2021. Based on 2013-2017 HUD Low Cost Transportation Index.* APPENDIX 1E: CITY OF FRESNO # Environmental Health and Opportunity CalEnviroScreen was developed by the California Environmental Protection Agency (CalEPA) to evaluate pollution sources in a community while accounting for a community’s vulnerability to the adverse effects of pollution. Measures of pollution burden and population characteristics are combined into a single composite score that is mapped and analyzed. Higher values on the index indicate higher cumulative environmental impacts on individuals arising from these burdens and population factors. The California Office of Environmental Health Hazard Assessment (OEHHA) compiles these scores to help identify California communities disproportionately burdened by multiple sources of pollution. In addition to environmental factors (pollutant exposure, groundwater threats, toxic sites, and hazardous materials exposure) and sensitive receptors (seniors, children, persons with asthma, and low birth weight infants), CalEnviroScreen also considers socioeconomic factors such as educational attainment, linguistic isolation, poverty, and unemployment. The TCAC Environmental Health Index summarizes this into a map to identify potential exposure to harmful toxins at a neighborhood level. Index values range from 0 to 100 and the higher the index value, the less exposure to toxins harmful to human health. Therefore, the higher the value, the better the environmental quality of a neighborhood, where a neighborhood is a census block-group. Fresno has long struggled with environmental, health, and economic disparities, including high concentrations of poverty, air pollution, and toxin and pesticide exposure. In Fresno, lower-income housing and racially segregated communities are disproportionately impacted by a combination of locational factors such as proximity to landfills, freeways, industrial areas, and other toxins and pollutants. There are a number of historical disparities that exist between north and south Fresno.[^p215-16] The life expectancy of residents in south Fresno is significantly lower than that of residents living in the northern part of town. Southwest Fresno specifically has been recognized as one of the most pollution-burdened communities in the state. According to a study published in 2018 by the National Center for Health Statistics and the National Association for Public Health Statistics, the life expectancy of residents in south and central Fresno was 77 years, compared to 85 years for residents in northern Fresno. The outbreak of COVID-19 worldwide also disproportionately impacted POC in Fresno. Social determinants of health (e.g., income level, occupation, access to health care, and living conditions, which includes housing and built environment) have not only contributed to higher rates of underlying medical conditions for POC in Fresno, but also increased their risk of contracting the virus, being hospitalized, and dying from COVID-19.[^p215-17] [^p215-16]: Martinez, N. 2021. Tale of Two Cities: Environmental Injustice in Fresno. Accessed via: https://fresnoalliance.com/tale-of-two-cities-environmental-injustice-in-fresno/#:~:text=According%20to%20a%20study%20published,for%20residents%20in%20northern%20Fresno. [^p215-17]: Centers for Disease Control and Prevention (CDC), 2021. Megally, H., Pacheco-Werner, T., Mireles, D., Celedon, S., Frost, B., Sataraka, J., Williams, K., Davies-Balch, S., Mendoza, S., Banerjee, S., Chan, S., Dhaliwal, S., Ward, L., Silva-Aguilar, Y., & Gasga, L. A Neighborhood Approach to Mitigate COVID-19 Transmission in BIPOC and People with Disabilities: Benefits and Lessons Learned Using the Community Health Worker Model. (2021) Central Valley Health Policy Institute. California State University, Fresno. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Figure 1E-3.23 maps TCAC Environmental Health Index scores for Fresno. Most block groups in the city of Fresno score poorly. The highest environmental health scores in the city can be found in the city’s most northern block groups, which include high proportions of open space and residential land uses. In contrast, the lowest scoring tracts are in south Fresno that also have lower access to opportunity. Fresno County is a major agricultural producer and agricultural production processes harm water supply and quality by discharging fertilizer contaminants into the groundwater via runoff. Over time, the region’s water supply has contended with a wide range of contaminants, including nitrates, arsenic, and pesticides. Due to geographic, topographic, meteorologic, and environmental conditions, the region’s air basin has particular challenges for air quality. These factors and others contribute to the environmental problems in Fresno including its role as the region’s center for agricultural industry and its location as the intersection of several major state highways. Topographically, low elevations in the Central Valley trap emissions from commuter vehicles and logistics vehicles like semi-trucks, along with high levels of pollutants from farming and pesticide use. Until 2004, farmers in the region would routinely burn tons of debris at the end of a growing season, which generated large amounts of particulate matter in the air. While agricultural burning has decreased, it has not been phased out completely.[^p216-18] The Central Valley also experiences above average temperatures, especially in the summer, when ozone pollution becomes much worse due to the longer periods of time ozone can develop in the sunlight. Regional and state forest fires also contribute to poor air quality during the summer and fall. Smoke and particles from the fires tend to accumulate and build up along the base of the mountains to the north and east of the city severely impacting Fresno’s air quality especially for those living in north and east Fresno. As a result of these conditions, many residents suffer from respiratory illness and poor health outcomes. As described in the Regional Fair Housing Assessment, much of Fresno County, particularly the western area and the cities along the State Route 99 corridor, have high cumulative CalEnviroScreen scores, see Figure 1E-3.24. This is a result of high scores for indicators of pollution burden, primarily pesticides, drinking water contaminants, particulate matter, diesel particulate matter, toxic releases from facilities, hazardous waste, and ozone. Fresno also suffers from some of the highest asthma, low birth weight, and cardiovascular disease levels in the state. [^p216-18]: Benner, C. and Pastor, M. 2015. Equity, Growth, and Community: What the Nation Can Learn from America's Metro Areas. “Struggle and the City: Conflict-Informed Collaboration.” University California Press. Pp. 130-160. Accessed via: https://www.jstor.org/stable/10.1525/j.ctt1ffjnd4.9. APPENDIX 1E: CITY OF FRESNO # Figure 1E-3.23: TCAC Opportunity Areas – Environmental Score, Fresno, 2022 <
> Source: Data downloaded from the HCD AFFH Data Tool in 2021. Note that this data is based on 2021 TCAC Opportunity Areas as the 2022 data by indicator is not yet available through the HCD AFFH Tool. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-67 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Figure 1E-3.24: CalEnviroScreen 4.0 Scores, Fresno <
> Source: Data downloaded from the Office of Environmental Health and Hazard Assessment in 2022. APPENDIX 1E: CITY OF FRESNO Citywide, the average Fresno resident has more exposure to air pollution than nearly 70 percent of census tracts nationwide and adult asthma rates are higher in Fresno than both the state and nation overall.[^p219-19] Spatial patterns of Environmental Health Index scores and residential patterns by race/ethnicity show that there are varying levels of disparity among racial and ethnic groups with regard to environmental quality. Hispanic, Black or African American, and Asian or Pacific Islander populations that live below the poverty line in the city are exposed to the worst environmental health conditions.[^p219-20] As shown in the figure below, nearly all of the census tracts with the highest CalEnviroScreen 4.0 score results align with predominantly Hispanic neighborhoods that have high POC segregation or low-medium rates of segregation. In the established neighborhoods north and south of Shaw Avenue near the Hoover planning area, residential patterns are more balanced and integrated, but environmental health scores are still poor. Policies and land use decisions which have affected these patterns will be described in further detail later in this chapter (see “Other Relevant Factors and Local Knowledge”). ## SB 535 Disadvantaged Communities A disadvantaged community (DAC) or environmental justice community (EJ Community) is identified by the California Environmental Protection Agency (Cal EPA) as “areas that are disproportionately affected by environmental pollution and other hazards that can lead to negative health effects, exposure, or environmental degradation,” and may or may not have a concentration of low-income households, high unemployment rates, low homeownership rates, overpayment for housing, or other indicators of disproportionate housing need. Disadvantaged communities in California are specifically targeted for investment of proceeds from the state’s Cap-and-Trade Program. These investments are aimed at improving public health, quality of life and economic opportunity in California’s most burdened communities, and at the same time, reducing pollution that causes climate change. In the CalEnviroScreen tool, census tracts receiving the highest 25 percent of overall scores in CalEnviroScreen 4.0 are those that have been designated as disadvantaged communities under Senate Bill (SB) 535. The cumulative score that can result in a disadvantaged community designation is calculated based on individual scores from two groups of indicators: Pollution Burden and Population Characteristics. Pollution Burden scores exposure to negative environmental hazards, such as ozone concentrations; fine inhalable particles, with diameters that are generally 2.5 micrometers and smaller (PM2.5) concentrations; drinking water contaminants; lead risk from housing; traffic impacts; and more. Population Characteristics scores the rate of negative health conditions and access to opportunities, including asthma, cardiovascular disease, poverty, unemployment, and housing cost burden. For each indicator, as with the cumulative impact, a low score reflects positive conditions. The designation takes into account the latest and best available data and considers factors related to data unavailability. Other qualifying criteria for a disadvantaged community includes: [^p219-19]: PolicyLink, 2017. Advancing Health Equity and Inclusive Growth in Fresno County. Accessed via: https://www.policylink.org/sites/default/files/advancing-health-equity-and-inclusive-growth-in-fresno.pdf [^p219-20]: Ibid SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING * Census tracts lacking overall scores in CalEnviroScreen 4.0 due to data gaps, but receiving the highest 5 percent of CalEnviroScreen 4.0 cumulative pollution burden scores. * Census tracts identified in the 2017 DAC designation as disadvantaged, regardless of their scores in CalEnviroScreen 4.0. * Lands under the control of federally recognized Tribes. For purposes of the DAC designation, a Tribe may establish that a particular area of land is under its control even if not represented as such on CalEPA’s DAC map and therefore should be considered a DAC. The San Joaquin Valley has the most disadvantaged communities per capita statewide. As shown in Figure 1E-3.25, in the city of Fresno specifically, nearly 70 total tracts in Fresno are considered a SB 35 DAC, comprising an estimated 85 percent of the city’s land area. Fresno also has several tracts that scored in the highest 5 percent of CalEnviroScreen scores which is likely attributed to the fact that there are two National Priorities List (NPL) Superfund sites within the city of Fresno include the 145-acre Fresno Municipal Sanitary Landfill in southwest Fresno and the half-acre Industrial Waste Processing site in north Fresno. The 5-acre T.H. Agriculture & Nutrition Company site, a deleted NPL site in the city, was removed from the NPL in 2006 following cleanup. A Superfund site is any land in the United States that has been contaminated by hazardous waste and identified by the Environmental Protection Agency (EPA) as a candidate for cleanup because it poses a risk to human health and/or the environment. One NPL site exists immediately outside of the city of Fresno in the community of Malaga. The EPA also manages a Toxics Release Inventory (TRI) to track the management of certain toxic chemicals that may pose a threat to either human health or the environment. There are 18 industrial facilities in Fresno that must report annually how much of each chemical is recycled, combusted for energy recovery, treated for destruction, and disposed of or otherwise released on- and off-site. This information is collectively referred to as production-related waste managed. The facilities are clustered in south and west Fresno. APPENDIX 1E: CITY OF FRESNO # Figure 1E-3.25: SB 535 Disadvantaged Communities <
> Source: Data downloaded from the HCD AFFH Data Tool in 2021. Data is based on CalEnviroScreen 4.0 Scores from the Office of Environmental Health and Hazard Assessment in 2022. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING # Housing Mobility Housing mobility refers to an individual’s or household’s ability to secure affordable housing in areas of high opportunity, move between neighborhoods, and purchase a home if they so choose. A few indicators of housing mobility include availability of rental and ownership opportunities throughout the jurisdiction, vacancy rates, distribution of Housing Choice Vouchers (HCVs), and housing costs and affordability. ## Tenure and Rates of Homeownership One of the most prevalent consequences of residential segregation is the intergenerational inaccessibility of homeownership. Homeownership is typically the largest asset of most households in the U.S. and hugely impacts generational wealth, as it is contingent upon passing down assets. For low-income families, maintaining homeownership provides an opportunity for future generations to progress their wealth by increasing the family’s equity. Systems of institutional racism created through federal housing policies and discriminatory mortgage lending practices prior to the Fair Housing Act of 1968, along with insufficient access to credit, have had significant impacts on the homeownership rates of racial and ethnic minorities — particularly Black or African American and Hispanic populations.[^p222-21] These discriminatory practices will be described in further detail later in this section (see “Other Relevant Factors and Local Knowledge”). According to the 2016-2020 American Community Survey, there are 170,137 households in Fresno. Approximately 46.8 percent of households own their homes. Homeownership rates are highest for White (51.1 percent) and Asian households (49.6 percent). About 40.1 percent of Hispanic households in the city own their homes while Black or African American (27.8 percent), American Indian or Alaska Native (30.9 percent), and Native Hawaiian and other Pacific Islander residents (31.3 percent) have the lowest homeownership rates (see Figure 1E-3.26). [^p222-21]: Reid, C. 2021. Crisis, Response, and Recovery: The Federal Government and the Black/White Homeownership Gap. Terner Center for Housing Innovation. Available via: https://ternercenter.berkeley.edu/research-and-policy/crisis-response-and-recovery-the-federal-government-and-the-black-white-homeownership-gap/ APPENDIX 1E: CITY OF FRESNO ### Figure 1E-3.26: Housing Tenure by Race and Hispanic Origin <
> *Source: U.S. Census Bureau, ACS 16-20 (5-year Estimates), Table B25003* **Figure 1E-3.27** shows the distribution of renter-occupied households in the city and indicates that renters are more predominant in central Fresno. Areas where the percentage of renters exceeds 80 percent are near Fresno State University, Downtown, southeast Fresno, and in the Pinedale neighborhood of north Fresno. Conversely, there is low renter occupancy and homeownership is more prevalent in southeastern Fresno along north and south Fowler Avenues. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Figure 1E-3.27: Renter Households in Fresno, 2019 <
> *Source: Data downloaded from the HCD AFFH Data Tool in 2021.* APPENDIX 1E: CITY OF FRESNO # Housing Supply Summary According to the 2016-2020 American Community Survey, there are 180,020 housing units in Fresno, which represents an increase of 5.1 percent since 2010 and 20.8 percent since 2000. # Vacancy Rates Of Fresno’s total housing units, 95.5 percent are occupied, and 5.5 percent are vacant. Vacancies in Fresno County are at 7.0 percent of all housing units. The vacancy rate, calculated from ACS data, includes housing that is available for sale or rent, housing that has been rented or sold but not yet occupied, seasonal housing, and other vacant units. Figure 1E-3.28 displays the total number of vacant units in Fresno by type. Note the categories are determined by the U.S. Census Bureau. ### Figure 1E-3.28: Vacant Units by Type, City of Fresno, 2020 <
> *Source: U.S. Census Bureau, ACS 16-20 (5-year Estimates), Table B25004* Seasonal, Recreational, or Occasional Use units are typically used or intended for use only in certain seasons or for weekends or other occasional use throughout the year. Seasonal units include those used for summer or winter sports or recreation, such as beach cottages and hunting cabins. Seasonal units also may include quarters for such workers as herders and loggers. Interval ownership units, sometimes called shared-ownership or timesharing condominiums, also are included here. Migrant Worker units include vacant units intended for occupancy by migratory workers employed in farm work during the crop season. If a vacant unit does not fall into any of the categories specified above, it is classified as “Other vacant.” For example, this category includes units held for occupancy by a caretaker or janitor, and units held for personal reasons of the owner. # Unit Sizes Availability of housing in a variety of sizes is important to meet the needs of different demographic groups. Neighborhoods with multi-bedroom detached, single-family homes will typically attract larger families, whereas dense residential developments with smaller unit sizes and fewer bedrooms often accommodate single-person households or small families. But market forces and affordability impact housing choice and FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-75 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING the ability to obtain housing of a suitable size, and markets that do not offer a variety of housing sizes at different price points can lead to barriers for some groups. Rising housing costs can, for example, lead to overcrowding as large households with lower incomes are unable to afford pricier, larger homes and are forced to reside in smaller units. On the other hand, people with disabilities or seniors with fixed incomes may not require large units but can be limited by higher housing costs in densely populated areas where most studio or one-bedroom units are located. Table 1E-3.5 summarizes housing units in Fresno by size and tenure. Housing units with two- and three-bedrooms represent the largest share of renter-occupied units in Fresno (approximately 65 percent). Three- and four-bedroom units represent the largest share of owner-occupied units (approximately 80 percent). For comparison, only 5.9 percent of renters occupy four-bedroom units, which may indicate limited choice for larger renter families. Stakeholder outreach for the 2020 Analysis of Impediments to Fair Housing in Fresno noted the need for larger, affordable units to meet the needs of large families[^p226-22]. Table 1E-3.5: Housing Tenure by Number of Bedrooms (2020) | | City of Fresno | | Fresno County | | | :--- | :--- | :--- | :--- | :--- | | | **Number of Households** | **Percent** | **Number of Households** | **Percent** | | **Homeowners** | | | | | | Owner - No Bedroom | 614 | 0.8% | 1,024 | 0.6% | | Owner - 1 Bedroom | 756 | 0.9% | 1,534 | 0.9% | | Owner - 2 Bedrooms | 10,392 | 13.0% | 19,752 | 11.9% | | Owner - 3 Bedrooms | 44,342 | 55.6% | 91,033 | 54.7% | | Owner - 4 Bedrooms | 19,534 | 24.5% | 43,719 | 26.3% | | Owner - 5 or More Bedrooms | 4,059 | 5.1% | 9,358 | 5.6% | | **Owner - Subtotal** | **79,697** | **46.8%** | **166,420** | **53.7%** | | **Renters** | | | | | | Renter - No Bedroom | 10,353 | 11.4% | 12,510 | 8.7% | | Renter - 1 Bedroom | 14,720 | 16.3% | 21,532 | 15.0% | | Renter - 2 Bedrooms | 35,433 | 39.2% | 54,803 | 38.1% | | Renter - 3 Bedrooms | 23,789 | 26.3% | 42,406 | 29.5% | | Renter - 4 Bedrooms | 5,346 | 5.9% | 10,847 | 7.5% | | Renter - 5 or More Bedrooms | 799 | 0.9% | 1,579 | 1.1% | | **Renter - Subtotal** | **90,440** | **53.2%** | **143,677** | **46.3%** | | **Total Households** | **170,137** | | **310,097** | | Source: U.S. Census Bureau, ACS 16-20 (5-year Estimates), Table B25042 [^p226-22]: Draft 2020 Analysis of Impediments to Fair Housing Choice Fresno. Available via: https://www.fresno.gov/darm/wp-content/uploads/sites/10/2020/02/Draft-2020-Analysis-of-Impediments-to-Fair-Housing-Choice.pdf APPENDIX 1E: CITY OF FRESNO # Housing Choice Voucher Usage The Housing Choice Voucher Program (HCV, formerly Section 8) is a federally funded program that provides rental assistance through approximately 11,000 vouchers, to eligible low-income individuals and families in Fresno County. Eligible applicants who receive a voucher are responsible for finding an apartment or house in the private rental market. HCVs are portable and their distribution throughout the city is subject to fluctuate based on location preferences of individual voucher households and the participation of landlords in the HCV program. Approximately 3,000 owners of rental properties in Fresno County accept tenants who participate in the program, but HCV use is most concentrated within the city of Fresno, with rates up to 52.2 percent of households in tracts along State Route 41 and a concentration of areas with rates between 15.0 and 30.0 percent of households in the central portion of the city and along the State Route 99 corridor. The higher rates of HCV use also tend to correspond to, or are adjacent to, census tracts where public housing or subsidized housing is located. Figure 1E-3.29 displays the rate of HCV usage in the city. HCVs are used most across west, central, and south Fresno. Central Fresno has clusters of HCV use east of State Route 41 and south of East Ashlan Avenue. In Southeast Fresno, census tracts abutting Sequoia-Kings Canyon Freeway, and further south along East Kings Canyon Road show clustering of HCV use. HCV use is also prevalent in West Fresno, south of North Santa Fe Avenue. This area, separated by railroad tracks from northwest Fresno, indicates the stark difference between northwest and northeast Fresno and the rest of the city. Northeast Fresno has very limited HCV use, with only four census tracts north of Herndon Avenue containing any HCVs, and of those four tracts, no tract exceeds 5 percent HCV use. Northwest Fresno also has limited HCV use; the single census tract north of North Santa Fe Avenue with HCV use is composed of approximately 18 percent vouchers. A recent change to state law went into effect in January 2020 that protects HCV holders from discrimination by landlords based on their participation in the HCV program. With this new prohibition against landlords refusing HCV tenants, resources to educate northeast and northwest Fresno landlords who have traditionally not participated in the HCV program are included in the Housing Element as a way to improve and balance the distribution of HCVs in the city. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-77 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Figure 1E-3.29: Housing Choice Voucher (HCV) Usage, Fresno <
> Source: Data download from the HCD AFFH Data Tool in 2021. # Disproportionate Housing Needs and Displacement Risk In the city of Fresno and Fresno county, renter-occupied households and households of color are more likely to have a housing need than White households or owner-occupied households.[^p229-23] In fact, several demographic groups experience a disproportionately greater rate of housing need compared to White households and owner-occupied households. There are four housing problems that are typically reported on to assess affordability and other types of housing needs. These are: 1) housing units that lack complete kitchen facilities; 2) housing units that lack complete plumbing facilities; 3) households that are overcrowded (i.e., more than 1.0 people per room); and 4) households that are cost burdened (i.e., monthly housing costs exceed 30 percent of monthly income). A household is said to have a housing problem if they have one or more of these four problems. A household is said to have a severe housing problem if the housing unit lacks complete kitchen or plumbing facilities and/or includes severe cost burden (more than 50 percent of monthly income is spent on housing costs) or severe overcrowding (more than 1.5 people per room). As shown in Table 1E-3.6, more than 80,870 households have at least one housing problem in Fresno, comprising 51 percent of all households. Of these, nearly one-third (31 percent) of all households have a severe housing problem. In the region, housing problems occur at slightly lesser rates; 137,555 households (48 percent) have at least one housing problem and 83,265 households (29 percent) have a severe housing problem. ### Table 1E-3.6: Demographics of Disproportionate Housing Needs, 2017 | | City of Fresno | | Fresno County | | | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | **Total Number of Households** | **Number with Problems** | **Percent with Problems** | **Total Number of Households** | **Number with Problems** | **Percent with Problems** | | **Households Experiencing Any of the Four Housing Problems** | | | | | | | | White | 64,665 | 25,400 | 39.3% | 126,010 | 46,335 | 36.8% | | Black of African American | 13,775 | 8,140 | 59.1% | 15,785 | 9,105 | 57.7% | | Hispanic | 61,070 | 36,850 | 60.3% | 118,935 | 67,555 | 56.8% | | Asian Pacific Islander | 15,637 | 8,443 | 54.0% | 22,482 | 11,353 | 50.5% | | Native American | 684 | 445 | 65.1% | 1,522 | 764 | 50.2% | | Other | 3,338 | 1,595 | 47.8% | 5,100 | 2,455 | 48.1% | | **Total** | **159,165** | **80,870** | **50.8%** | **137,555** | **289,815** | **47.5%** | [^p229-23]: Draft 2020 Analysis of Impediments to Fair Housing Choice Fresno. Available via: https://www.fresno.gov/darm/wp-content/uploads/sites/10/2020/02/Draft-2020-Analysis-of-Impediments-to-Fair-Housing-Choice.pdf. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING | | City of Fresno | | | Fresno County | | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | **Total Number of Households** | **Number with Problems** | **Percent with Problems** | **Total Number of Households** | **Number with Problems** | **Percent with Problems** | | **Households Experiencing Any of the Four Severe Housing Problems** | | | | | | | | White | 64,665 | 13,305 | 20.6% | 126,010 | 23,600 | 18.7% | | Black or African American | 13,775 | 5,290 | 38.4% | 15,785 | 5,860 | 37.1% | | Hispanic | 61,070 | 24,615 | 40.3% | 118,935 | 44,840 | 37.7% | | Asian Pacific Islander | 15,637 | 5,402 | 34.6% | 22,482 | 7,121 | 31.7% | | Native American | 684 | 250 | 36.6% | 1,522 | 429 | 28.2% | | Other | 3,338 | 960 | 28.8% | 5,100 | 1,420 | 27.8% | | **Total** | **159,165** | **49,810** | **31.3%** | **289,815** | **83,265** | **28.7%** | *Note: All % represent a share of the total population.* *Source: Draft Assessment of Impediments to Fair Housing Choice, Fresno, 2020. CHAS, 2017.* The highest rates of housing needs are found in census tract 54.08 around Fresno State University, census tract 25.02 along parts of Sequoia Kings Canyon Freeway that are immediately east of Downtown, and census tract 47.04 in northwest Fresno bordered by West Shields Avenue to the south, North West Avenue to the east, and West Dakota Avenue to the north. Census tracts in southwest, southeast, west, and central Fresno have elevated levels of housing problems with tracts typically having at least 50 percent of all households having at least one housing problem. The following sections describe trends in households experiencing the greatest housing needs. ## Overcrowding A household is overcrowded if there is more than 1.0 people per room, not including kitchen or bathrooms. Severe overcrowding refers to households with more than 1.5 people per room. Nearly 11 percent of households in the city are considered overcrowded. Similar to trends across the state, overcrowding is more common among renters than homeowners. By tenure, approximately 15.3 percent of Fresno renter-occupied households are overcrowded compared to 4.4 percent of owner-occupied households are overcrowded (See Table 1E-3.7). This is consistent with the previously described summary of housing unit sizes which suggested that larger rental families have less housing options. APPENDIX 1E: CITY OF FRESNO Table 1E-3.7: Tenure and Occupants per Room, Fresno, 2020 | | Households | Percent | | :--- | :--- | :--- | | **Owner Occupied** | | | | 0.50 or less occupants per room | 51,937 | 65.2% | | 0.51 to 1.00 occupants per room | 23,298 | 29.2% | | 1.01 to 1.50 occupants per room | 3,215 | 4.0% | | 1.51 to 2.00 occupants per room | 807 | 1.0% | | 2.01 or more occupants per room | 440 | 0.6% | | **Total Owner Occupied Units** | **79,697** | **46.8%** | | **Renter Occupied** | | | | 0.50 or less occupants per room | 38,052 | 42.1% | | 0.51 to 1.00 occupants per room | 38,522 | 42.6% | | 1.01 to 1.50 occupants per room | 7,311 | 8.1% | | 1.51 to 2.00 occupants per room | 3,541 | 3.9% | | 2.01 or more occupants per room | 3,014 | 3.3% | | **Total Renter Occupied Units** | **90,440** | **53.2%** | | **Total** | **170,137** | **100.0%** | *Source: U.S. Census Bureau, ACS 16-20 (5-year Estimates), Table B25014.* As shown in **Figure 1E-3.30**, the ACS estimates that there is a higher rate of overcrowding in Southwest Fresno and Downtown. As shown in the racial segregation and integration trends discussed previously, these areas correlate to areas with the highest rates of POC segregation. In addition, there is a greater presence of single-parent households and low levels of labor market engagement. Data indicates that there are a few areas of more severe overcrowding conditions (more than 20 percent) in the Pinedale area, around the Fresno Yosemite International Airport, in Downtown, and south of Downtown. Overall, the neighborhoods that are most impacted by high rates of overcrowding align with racially concentrated areas of poverty in the city. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Figure 1E-3.30: Overcrowding in Fresno, 2020 <
> Source: Data downloaded from HCD AFFH Data and Mapping Tool in 2021. APPENDIX 1E: CITY OF FRESNO # Overpayment This section provides an analysis of the proportion of households overpaying for housing. Current standards measure housing cost in relation to gross household income: households spending more than 30 percent of their income, including utilities, are generally considered to be overpaying or cost burdened. Severe overpayment occurs when households pay 50 percent or more of their gross income for housing. For owners housing costs include mortgage payment, taxes, insurance, and utilities. Typically, the impact of high housing costs falls disproportionately on extremely low-, very low-, and low-income households, especially renter households. Lower-income households are defined as those that earn 80 percent or less of the area median household income (AMI). While some higher-income households may choose to spend a greater proportion of their income on housing, lower-income households may be limited by a lack of affordable housing. In Fresno, 33,460 households (19.8 percent of all households) are cost burdened and 34,945 (20.7 percent of all households) are severely cost-burdened, for a total of 68,405 households (40.6 percent) (see Table 1E-3.8, Overview of Cost Burden in Fresno, 2019). As discussed in the Overpayment section of the Housing Needs Assessment, overpayment often impacts lower-income households at a higher rate due to financial constraints. Of the cost-burdened households in Fresno, approximately 48,615 (71.0 percent) are renters and 19,790 (28.9 percent) are homeowners. ### Table 1E-3.8: Overview of Cost Burden in Fresno, 2019 | | Number of Households (Owners + Renters) | Percent of Households | | :--- | :--- | :--- | | Cost Burden <=30% | 97,620 | 57.9% | | Cost Burden >30% to <=50% | 33,460 | 19.8% | | Cost Burden >50% | 34,945 | 20.7% | | Cost Burden not available | 2,600 | 1.5% | | **Total** | **168,625** | **100.0%** | Source: CHAS (Comprehensive Housing Affordability Strategy) data 2015-2019 Since 2010, overpayment rates have decreased. As seen in Table 1E-3.9, there was a 32.0 percent decrease in overpayment for moderate-income homeowner households and a 64.5 percent decrease for above-moderate income homeowner households. Overpayment rates also decreased amongst low-income households (incomes between 50 percent and 80 percent of the AMI) since 2010. This is largely due to the fluctuation in the number of low-income homeowners experiencing cost burden. As shown in the table, severe overpayment rates decreased for low-income homeowners by 48.1 percent and 28.8 percent for low-income renters, thus influencing the percent change for all low-income households. On the other end of the income spectrum, extremely low-income households have experienced a disproportionate growth in overpayment regardless of tenure. Since 2010, overpayment rates have increased by 36.0 percent for extremely low-income households and severe overpayment rates have increased 26.9 percent. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Table 1E-3.9: Cost Burden in Fresno, 2010-2019 | Household Type by Tenure and Income Level | Cost Burdened | | | Severely Cost Burdened | | | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | **2010** | **2019** | **% Change (2010-2019)** | **2010** | **2019** | **% Change (2010-2019)** | | Total Households | 156,225 | 168,625 | - | 156,225 | 168,625 | - | | All Households | 70,700 | 68,410 | -3.2% | 36,110 | 34,945 | -3.2% | | Renters | 42,320 | 48,615 | 14.9% | 24,375 | 26,735 | 9.7% | | Homeowners | 28,380 | 19,790 | -30.3% | 11,735 | 8,210 | -30.0% | | Extremely Low-Income Households (Income is less than or equal to 30% of AMI) | 19,530 | 26,555 | 36.0% | 17,255 | 21,905 | 26.9% | | Renters | 16,965 | 22,285 | 31.4% | 15,120 | 18,555 | 22.7% | | Homeowners | 2,560 | 4,270 | 66.8% | 2,130 | 3,350 | 57.3% | | Very Low-Income Households (Income is between 30% and 50% of AMI) | 17,145 | 19,295 | 12.5% | 10,310 | 9,050 | -12.2% | | Renters | 12,310 | 14,845 | 20.6% | 6,940 | 6,640 | -4.3% | | Homeowners | 4,840 | 4,455 | -8.0% | 3,375 | 2,415 | -28.4% | | Low-Income Households (Income is between 50% and 80% of AMI) | 14,985 | 13,965 | -6.8% | 4,945 | 2,920 | -41.0% | | Renters | 8,995 | 8,650 | -3.8% | 1,840 | 1,310 | -28.8% | | Homeowners | 5,995 | 5,310 | -11.4% | 3,105 | 1,610 | -48.1% | | Moderate-Income Households (Income is between 80% and 100% of AMI) | 5,655 | 3,845 | -32.0% | 1,455 | 615 | -57.7% | | Renters | 2,300 | 1,745 | -24.1% | 350 | 130 | -62.9% | | Homeowners | 3,350 | 2,095 | -37.5% | 1,105 | 480 | -56.6% | | Above Moderate-Income Households (Income is greater than 100% of AMI) | 13,385 | 4,750 | -64.5% | 2,145 | 455 | -78.8% | | Renters | 1,750 | 1,090 | -37.7% | 125 | 100 | -20.0% | | Homeowners | 11,635 | 3,660 | -68.5% | 2,020 | 355 | -82.4% | Source: CHAS (Comprehensive Housing Affordability Strategy) data 2006-2010 and 2015-2019. APPENDIX 1E: CITY OF FRESNO Figure 1E-3.31 and Figure 1E-3.32 display the trends of overpayment for renters and homeowners in Fresno between 2014 and 2019. As described above, the rate of households experiencing overpayment significantly decreased during this time. As shown below, overpayment is most concentrated in census tract 54.08 around Fresno State University, census tract 25.02 along parts of Sequoia Kings Canyon Freeway that are immediate east of Downtown, and census tract 47.04 in northwest Fresno bordered by West Shields Avenue to the south, North West Avenue to the east and West Dakota Avenue to the north. Census tracts in south and west Fresno have the most elevated levels of overpayment with tracts having at least 40 to 60 percent of all households overpaying towards housing costs. These areas tend to align with racially concentrated areas of poverty where there is a greater presence of children in single female-headed households and low job market engagement. Downtown and the neighborhoods north and south of Shaw Avenue display lower rates of overpayment overall. In 2020, HUD released a comprehensive housing market analysis which summarizes housing market trends in Fresno between 2010 and 2020.²⁴ According to the report, after the Great Recession of 2008, home sales and prices began to stabilize again during 2010 and 2011. Home prices then increased every year between 2012 and 2018, although there were some fluctuations around 2014. The sales market began to balance out while rental market conditions began tightening. In the Fresno rental market, high levels of renter household growth and decreased rental construction contributed to a decline in vacancy rates and rising rents since 2015. Although rents rose, local economic conditions reportedly kept pace as the city experienced a net increase in jobs available. Between 2010 and 2018, the median gross rent increased by a total of 21 percent, while the median income of renter households increased by 29 percent. As shown in the figure below, overpayment amongst renters decreased throughout most of the city between 2014 and 2019. Overpayment amongst homeowners generally decreased in the existing neighborhoods north and south of Shaw Avenue during the same time period. Overpayment remained higher for both renters and homeowners closer to new growth areas and priority development areas such as neighborhoods along BRT corridors. [^p235-24]: U.S. Department of Housing and Urban Development, 2020. Comprehensive Housing Market Analysis: Fresno, California. Retrieved from: https://www.huduser.gov/portal/publications/pdf/FresnoCA-CHMA-20.pdf. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-85 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Figure 1E-3.31: Percent of Renters Overpaying, Fresno, 2014-2019 <
> *Source: Data download from the HCD AFFH Data Tool in 2021.* Figure 1E-3.32: Percent of Homeowners Overpaying, Fresno, 2014-2019 <
> Source: Data download from the HCD AFFH Data Tool in 2021. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ## Substandard Housing Conditions More than 65 percent of housing units in Fresno were built prior to 1990, making a majority of the housing stock over 30 years old, and approximately half of those are over 50 years old (Table 2-19, Age of Housing Stock (2020), in the Regional Housing Needs Assessment). Older units are generally more frequently subject to maintenance issues than newer housing stock. Even units that are not urgently in need of repair may benefit from energy-efficiency improvements to reduce energy usage and related climate impacts. In Fresno, older homes are primarily concentrated the city’s Downtown Neighborhoods historic core, including in Downtown, Chinatown, Southwest Fresno, Huntington, and Fulton-Lowell. Outside of the Downtown Neighborhoods, older homes also exist in historic communities that were annexed into the city, like Highway City and Pinedale. As the city grew outward, many commercial, office, and educational opportunities did as well, having the impact of reducing resources within these older, established neighborhoods. Homes in these neighborhoods are often in greater need of repair due to the limitation of available resources compounded with their age. Another measure of substandard housing conditions is the lack of presence of kitchen and plumbing facilities. The 2016–2020 ACS estimated that there are 1,804 renter-occupied units and 291 owner-occupied units in Fresno that lack a complete kitchen or plumbing. In total, these 2,095 units account for less than 2.0 percent of the total housing stock in Fresno. This indicates that renters are disproportionately burdened by substandard housing conditions and risk displacement if conditions deteriorate beyond the lack of a kitchen or plumbing, particularly beyond what is considered habitable. Input received during the community engagement process for the City’s 2020 Analysis of Impediments to Fair Housing Choice aligns with age trends to indicate the need for housing rehabilitation in Fresno. Residents and other stakeholders noted the need for single-family home repair and rehabilitation, rental rehabilitation, and improvements to aging mobile homes, particularly roof repair. This need was most identified in Southwest Fresno, although some participants noted homes in need of rehabilitation in other areas as well. The Housing Element includes a program to provide targeted assistance to extremely low-income homeowners and targeting marketing in mobile home parks and similar areas. In addition, a program has been added to market the availability of additional rehabilitation assistance programs in areas of greatest need, such as the Southwest Fresno neighborhoods. APPENDIX 1E: CITY OF FRESNO # Homelessness In January 2023, the Fresno-Madera Continuum of Care (FMCoC) conducted its annual Homeless Census and Survey Point-in-Time (PIT) Report, which estimated 3,207 individuals experiencing homelessness in the city of Fresno (71.4 percent) out of 4,493 persons experiencing homelessness throughout the entire Continuum of Care area (both Fresno and Madera Counties). Of that number, 1,388 persons were sheltered and 1,819 were unsheltered. Between 2022 and 2023, the total number of people experiencing homelessness in the city decreased by 5.6 percent, although the number of people unsheltered increased by 7.3 percent. Based on Fresno’s quarterly tally, those experiencing unsheltered homelessness are living in all parts of the city, with a modest concentration in downtown Fresno and Southern Blackstone Corridor areas, where approximately 175 people are living. Generally, the unhoused population tends to be more concentrated in areas where they can more easily access services and public transportation. Figure 1E-3.33 shows generally where unsheltered camping areas exist in the city, along with supportive infrastructure (i.e., mobile showers, shelters, and transit) that exists nearby and in the city. The main service providers for people experiencing homelessness in the city are in the central core of the city while north Fresno and the fringe neighborhoods have fewer services available. The City utilizes the Fresno Madera Continuum of Care network as access sites (entry points) to homeless services. The access sites are part of the coordinated entry system for individuals that are experiencing homelessness or are at risk of homelessness. Access sites offer services ranging from shelter to diversion, depending on needs and availability of service. In addition to the 9 Fresno sites listed below, there are two mobile teams called Homeless Outreach Progressive Engagement (HOPE) teams which provide mobile services, connecting to locations known to be frequent camp locations or based on service requests. Fresno-Madera Continuum of Care Access Sites: * MAP Point at Poverello House * Naomis House * Poverello House Outreach Team * The Welcome Center * Fresno Home * Golden State Triage Center * Clinica Sierra Vista * Marjaree Mason Center * WestCare California Inc FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-89 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Figure 1E-3.33: Locations of Unsheltered Camping (2023) and Supportive Infrastructure <
> Source: City of Fresno, 2024 APPENDIX 1E: CITY OF FRESNO Throughout the FMCoC area, which includes both Fresno and Madera Counties, approximately 63 percent of the homeless population identified as male, 36 percent as female, and 1 percent as transgender, questioning, or a gender that is not singularly male or female (e.g., non-binary, genderfluid, agender). Approximately half of the population identified as Hispanic (51 percent), with Hispanic individuals in Fresno being disproportionately represented among those experiencing homelessness. By race, 7 percent identified as Native American or Alaska Native, 3 percent as Asian, 16 percent as Black or African American, 1 percent as Native Hawaiian or Pacific Islander, 70 percent as White, and 3 percent as multi-racial or belonging to another race. Additionally, 235 people, or 6 percent of the homeless population, were veterans — veterans are overrepresented compared to the general population and nearly twice as likely to experience homelessness. About 19 percent were survivors of domestic violence (769 people), a group that is particularly vulnerable to homelessness due to the nature of domestic violence leaving individuals with few safe housing options. Approximately 33 percent of the homeless population reported a mental health problem, compared to 14 percent of the general population with a disability in the city of Fresno. Additionally, 36 percent reported a substance use disorder. In Fresno, individuals with mental health issues or substance abuse disorders are significantly more likely to experience homelessness due to difficulties maintaining employment, housing stability, and social support. Among the FMCoC homeless population, 389 persons (9 percent) were under 18 and 278 persons (6 percent) were 64 or older, with older adults facing a heightened risk of homelessness due to fixed incomes. Single adults and couples accounted for 86 percent of the population experiencing homelessness, while persons in family households (with children) accounted for 14 percent. The PIT report does not distinguish the characteristics of the homeless population in Fresno County or the city of Fresno separately from the COC, so it is assumed that these statistics generally represent the City of Fresno and Fresno County population. Table 1E-3.10, Demographic Characteristics of Homeless Population, Fresno-Madera COC2023, identifies the proportion of each of protected characteristics identified in the 2023 Fresno-Madera COC dashboard report compared to the proportion of the population in Fresno and Madera counties, to identify whether any protected classes are disproportionately represented as part of the homeless population. Individuals that identify as White (including both White Hispanic and non-Hispanic) and Asian are the only demographic groups that are underrepresented in the homeless population compared to the total population living in Fresno and Madera counties. Residents identifying as Hispanic, Native American or Alaska Native, and Black or African American, are overrepresented in the homeless population. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Table 1E-3.10: Demographic Characteristics of the Homeless Population, Fresno-Madera COC, 2023 | Characteristic | Homeless Population | Total Population (Fresno and Madera Counties) | | :--- | :--- | :--- | | Hispanic | 51% | 45% | | Native American or Alaska Native | 7% | 3% | | Asian | 3% | 10% | | Black or African-American | 16% | 6% | | Native Hawaiian or Pacific Islander | 1% | 0.3% | | White[^p242-1] | 70% | 77% | | Other/Multiple Races | 3% | 3% | [^p242-1]: White is assumed to include both Hispanic and non-Hispanic. Source: Fresno/Madera Continuum of Care Point-in-Time Executive Summary, 2023. Homelessness is often a cross-jurisdictional issue; therefore, the City participates in and offers several homelessness resources and programs that are available regionally, identified in Table 1E-3.11. Table 1E-3.11: City and County of Fresno Services to Address Homelessness | Service/Resource | Description | Operator | Location | | :--- | :--- | :--- | :--- | | Multi-Agency Access Program (MAP Point) | Traveling food truck and fixed locations that provide linkage to government resources and services (housing, behavioral health, physical health, food linkages, and transportation) at no cost to all residents of Fresno County | Fresno County Department of Behavioral Health (funding)/ Kings View Corporation (operation) | Countywide Physical locations: Firebaugh, Fowler, Fresno, Huron, Kerman, Mendota, Parlier, and Reedley | | Fresno County Behavioral Health WARM Line | Available during weekday business hours for non-emergency emotional and coping support for residents throughout the county | Fresno County Department of Behavioral Health | Countywide | | Multi-Agency Response to Community Homelessness (MARCH) | Countywide collaboration to address homelessness through coordination of resources regionally and cross-jurisdictionally, engagement of the community, attracting private funding to support community-specific programs, and inclusion of rural representatives selected by FCOG | FCOG/Jurisdictions | Countywide | | Turning Point of Central California | Mental health services including a full-service partnership program | Contracted by Fresno County Department of Behavioral Health | Countywide | | Fresno County Department of Social Services Homeless Assistance | Temporary housing, permanent housing, or arrears payments for families eligible for CalWorks once during a 12-month period | Fresno County Department of Social Services | Countywide | | Service/Resource | Description | Operator | Location | | :--- | :--- | :--- | :--- | | Catholic Charities | Clothing, shelter, diapers, a food pantry, rent and mortgage assistance, DMV ID vouchers, application assistance for CalFresh and food stamps, application assistance for PG&E discounts, assistance with immigration services, and senior companionship assistance. Also has a Rural Outreach Program to serve residents throughout the region and work with migrant farmworkers. | Catholic Charities | Countywide Physical location: City of Fresno | | Emergency Housing Voucher | Assist persons experiencing, at-risk of becoming, or recently homeless and those fleeing domestic violence, dating violence, sexual assault, stalking, or human trafficking | Fresno Housing and FMoC | Countywide | | United Way | Emergency informational services to connect persons in need with Homeless Prevention Programs, food and shelter assistance, help with landlord-tenant issues, legal services referrals, and more | United Way | Countywide | | Groceries2Go | Provides grocery boxes of shelf-stable food items through an appointment-based system. | Central California Food Bank | Countywide | | CalFresh Enrollment Assistance | Application assistance and assistance navigating the CalFresh process. | Central California Food Bank | Countywide | | Fresh Produce Distribution | Mobile Pantry Program and Neighborhood Markets operating out of self-contained vehicles that travel to rural and remote areas throughout the county. A schedule of distribution locations is available online. | Central California Food Bank | Countywide | | Senior Hunger Program | Food boxes to senior-serving partners tailored to the dietary needs of seniors. | Central California Food Bank | Countywide | | Partner Feeding Sites | Provides food to over 220 sites including churches, community centers, and other organizations to feed hungry residents in local neighborhoods | Central California Food Bank | Countywide | | USDA Partnership | Distribute food acquired by the USDA to 47 organizations in Fresno County. | Central California Food Bank | Countywide | | Fresno County Food Map | Online service mapping locations of feeding sites, food banks, etc. | Fresno County | Countywide | | Projects for Assistance in Transition from Homelessness (PATH) | Street outreach for people experiencing or at risk of homelessness and referrals to housing resources, medical care, mental health counseling, and social services. | Fresno County Department of Behavioral Health (funding)/ Kings View Corporation (operation) | Countywide | | City of Fresno Mobile Shower and Restroom | Mobile trailers with bathing and restroom facilities for the unhoused. Facilities include showers, toilets and sinks, with ADA accessibility. | Contracted by City of Fresno | Various locations: City of Fresno | SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING | Service/Resource | Description | Operator | Location | | :--- | :--- | :--- | :--- | | Emergency Shelter services | Providing critical intervention for individuals and families experiencing homelessness with short-term shelter accommodations. | Elevate | Location: City of Fresno | | Youth Emergency Shelter services | Providing access to immediate help and supportive resources for youth in crisis. Also assisting with overnight shelter for homeless youth ages 18-24. | Fresno Economic Opportunities Commission (EOC) | Location: City of Fresno | | Fresno Home Bridge and Triage shelter | Providing temporary housing to homeless individuals that are located throughout the City of Fresno. | Mental Health System (TURN) | Countywide. Physical location: City of Fresno | | Emergency Shelters Services | Providing short-term shelter accommodation at multiple sites throughout the City. Poverello House provides 24-staffing, meals, case management to the unhoused community. | Poverello House | Citywide | | Domestic Violence Services | Marjaree Mason Center provides county wide collaboration to provides services that focus on services for victims of Domestic Violence. MMC also provides safe houses for survivors to ensure the victims have a safe place to reside. | Marjaree Mason Center | Countywide. Physical location: City of Fresno | | Fresno Rescue Mission | Providing 24-hour services for those in need. Services range from Case management, food services, counseling, employment and temporary housing | Fresno Rescue Mission | Physical Location: City of Fresno | *Source: City of Fresno, 2024* Emergency shelters also include Marjaree Mason Center, Fresno Rescue Mission, Evangel Home Inc., and Plaza Terrace. To address the needs of residents experiencing or at risk of homelessness, the Housing Element includes a program to connect vulnerable households with available resources and collaborate with County jurisdictions to increase the availability of homelessness resources. ## Displacement Risk The Urban Displacement Project, a joint research and action initiative of UC Berkeley and the University of Toronto, analyzes income patterns and housing availability to determine the level of displacement risk at the census tract level. Figure 1E-3.34 shows the communities in Fresno that are sensitive to displacement as of 2017, according to the Urban Displacement Project. Sensitive communities include areas where a high proportion of residents may be vulnerable to displacement due to rising housing costs and market-based displacement pressures present in and/or near the community. In total, 27 percent of census tracts in the state of California are identified as areas that are sensitive to displacement. APPENDIX 1E: CITY OF FRESNO # Figure 1E-3.34: Communities Sensitive to Displacement, Fresno <
> Source: Data downloaded from the AFFH Data Viewer in 2021. Based on data from the Urban Displacement Project. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-95 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Displacement pressures are generally defined as a percent change in rent greater than the county median for rent increases or a difference between the tract median rent and median rents for surrounding tracts that are greater than the median for all tracts in the county. Communities were designated “sensitive” if they met the following criteria: 1) They currently have populations vulnerable to displacement in the event of increased redevelopment and drastic shifts in housing cost. Vulnerability is defined as: * Share of very low-income residents is above 20 percent in 2017; and, * The tract meets two of the following criteria: * Share of renters is above 40 percent in 2017 * Share of people of color is above 50 percent in 2017 * Share of very low-income households that are severely rent burdened households is above the county median in 2017 2) They, or areas in proximity, have been experiencing displacement pressures. Displacement pressure is defined as: * A percent change in rent above the county median for rent increased between 2012 and 2017; or * Local and nearby increases in rent were greater than the regional median between 2012-2017 OR the 2017 rent gap is greater than the regional rent gap. As shown in **Figure 1E-3.34**, a substantial amount of the land area in the city is sensitive to displacement pressure. Tracts identified as sensitive to displacement correspond with concentrated areas of poverty and neighborhoods which generally have lower median incomes, greater populations of color, and larger proportion of renter households. While the Urban Displacement Project does not specify the conditions that led to the vulnerability determination for Fresno, it can be assumed that residents of Fresno experience heightened displacement risk compared to residents elsewhere in the county due to a combination of lower incomes and high housing prices. Notably, the West and north Woodward Park area neighborhoods, which are experiencing higher percentages of cost burden from housing costs but have lower percentages of renter-occupied households than central core neighborhoods, were not found to be sensitive to displacement (see **Figure 1E-3.34**). Using 2015 to 2019 data, Urban Displacement Project released an Estimated Displacement Risk (EDR) model for California that identifies varying levels of displacement risk for low-income renter households in all census tracts in the state. The model includes three separate displacement layers: the “Overall Displacement” layer, the “50-80% AMI” layer which shows the level of displacement risk for low-income households specifically, and the “0-50% AMI” layer which shows the level of displacement risk for extremely low-income and very low-income households combined.[^p247-25] These are shown for the City of Fresno below in Figures 1E-3.35 through 1E-3.37. Tracts are assigned to one of the following categories, with darker red colors representing higher displacement risk and lighter orange colors representing less risk: * **Low Data Quality:** the tract has less than 500 total households and/or the census margins of error were greater than 15 percent of the estimate (shaded gray). * **Lower Displacement Risk:** the model estimates that the loss of low-income households is less than the gain in low-income households. However, some of these areas may have small pockets of displacement within their boundaries. * **At Risk of Displacement:** the model estimates there is potential displacement or risk of displacement of the given population in these tracts. * **Elevated Displacement:** the model estimates there is a small amount of displacement (e.g., 10 percent) of the given population. * **High Displacement:** the model estimates there is a relatively high amount of displacement (e.g., 20 percent) of the given population. * **Extreme Displacement:** the model estimates there is an extreme level of displacement (e.g., greater than 20 percent) of the given population. In Fresno, very low-income and low-income households are experiencing elevated, high, or extreme displacement risk in downtown and in central core neighborhoods (displayed in the dark red tracts). Looking more closely at displacement risk by income group in Figure 1E-3.36 and Figure 1E-3.37, very low- and extremely low-income households (0-50 percent of AMI) are experiencing extreme levels of displacement risk California’s recent history has shown that environmental disasters such as wildfires, earthquakes, and floods can also be significant causes of displacement, and that climate change is accelerating the risk from such disaster events. [^p247-25]: Urban Displacement Project modeled displacement risk as the net migration rate of renter households at varying income levels. Tracts that have a predicted net loss within these groups are considered to experience displacement. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Figure 1E-3.35: Estimated Displacement Risk - 2019 <
> Source: Data downloaded from the AFFH Data Viewer in 2023. Based on data from the Urban Displacement Project and 2014-2019 5-year American Community Survey data. APPENDIX 1E: CITY OF FRESNO # Figure 1E-3.36: Estimated Displacement Risk - 0% - 50% AMI (2019) <
> *Source: Data downloaded from the AFFH Data Viewer in 2023. Based on data from the Urban Displacement Project and 2014-2019 5-year American Community Survey data.* SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Figure 1E-3.37: Estimated Displacement Risk - 50% - 80% AMI (2019) <
> *Source: Data downloaded from the AFFH Data Viewer in 2023. Based on data from the Urban Displacement Project and 2014-2019 5-year American Community Survey data.* APPENDIX 1E: CITY OF FRESNO # Displacement Avoidance Efforts The Fresno Transformative Climate Communities Collaborative (Collaborative) began with a participatory process to identify a series of projects to invest in that will result in significant environmental and economic benefits in Downtown, Chinatown, and Southwest Fresno. Anyone who lived, worked, or owned property in these areas was encouraged to participate. The purpose of the Collaborative was to promote and nurture creative project ideas, develop local criteria to define the type of catalytic and connective impact projects should have, and provide the City of Fresno with direction on the proposal of integrated projects included in the application to the Strategic Growth Council (SGC) for funding. The Collaborative met regularly in 2017 and resulted in an active, engaged, 164 member Community Steering Committee. During these meetings, participants were encouraged to propose projects, and eligible projects were then gathered into five packages that were presented for a community vote. At the final Community Steering Committee public meeting, voting members approved a project package designed by residents of Southwest Fresno and developed and submitted a proposal to SGC for $66.5 million from the Transformative Climate Communities Program (TCC). These engagement efforts resulted in Transform Fresno, a community-driven initiative to transform the 4.9 square mile project area— comprised of Chinatown, Downtown and Southwest Fresno —through a suite of projects and plans that will reduce greenhouse gas (GHG) emissions while also providing local environmental, health, and economic and social equity benefits (see Figure 1E-3.38, Transform Fresno Project Area). In early 2018, SGC awarded Transform Fresno a TCC grant of $66.5 million to implement the projects identified through community-driven planning processes. Transform Fresno is anticipated to bring a number of benefits to residents of the city; however, there are reasons to be concerned about the negative effect that increased investment and development might have on vulnerable populations as displacement can occur whether a neighborhood is experiencing disinvestment or reinvestment. Disinvestment-related displacement describes when the value of a property does not justify investing in its maintenance, leading to decay and abandonment. Reinvestment-related displacement refers to the process in which investments in a neighborhood result in increased rent to a point where it is profitable for landowners to sell or raise the rent and existing tenants are forced to leave. The City of Fresno has taken actions to prevent displacement of residents and businesses in and around the Transform Fresno project area. Notably, TCC funded projects will not cause direct displacement, as all proposed housing units will be constructed on vacant lots and transportation activities will occur within the public right-of-way. However, indirect displacement from rising property values - as a result of large-scale investment in historically underserved TCC neighborhoods - remains a concern for residents and business owners. To address these concerns in a meaningful way, the City of Fresno established an Anti-Displacement Task Force (ADTF) in November of 2018. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Figure 1E-3.38: Transform Fresno Displacement Program Area <
> Source: City of Fresno APPENDIX 1E: CITY OF FRESNO The TCC Program also requires policies and programs to avoid the displacement of existing residents and local businesses, to help ensure all members of the community benefit from the investment. The City of Fresno adopted a Displacement Avoidance Plan (DAP) in 2019 in efforts to reduce economic displacement risk within the Transform Fresno project area. The DAP outlines policies intended to understand the impact of TCC investments on existing households and businesses, while opening discussions about preventative measures and proactive solutions to displacement. To support this effort, Thrivance Group – a contracted local consultant selected to implement the DAP –gathered and analyzed data related to displacement vulnerability within the Transform Fresno project area, conducted educational and informational community workshops, and made 48 displacement avoidance policy recommendations in the 2021 “Here to Stay: A Policy-Based Blueprint for Displacement Avoidance in Fresno.” The City incorporated several recommendations from “Here to Stay” into the One Fresno Housing Strategy, which was the basis for several new implementation programs in this Housing Element. ### Farmworkers Farmworkers are traditionally defined as persons whose primary incomes are earned through seasonal or permanent agricultural labor. There are generally three types of farmworkers in the state: * Permanent Residents: Permanent residents of the county in which they work who may require housing that accommodates families, including housing affordable to extremely low-income households for seasonal workers who do not work in the off-season. * Migrant Farmworkers: Temporary residents who perform agricultural labor on a seasonal or temporary basis and typically need housing for individuals, such as single occupancy rooms, bunkhouses, or dormitory style living. * H-2A Visa Workers: Temporary residents who enter the U.S. under a federal guest worker program for a limited term and require a sponsor employer who provides housing, meals, and transportation to the job site. Farmworkers are essential to Fresno County’s and the city’s economies as well as to local and national food supplies. Across the state, housing for farmworkers has been recognized as an important and unique concern. Farmworkers are generally considered a special housing needs group due to their limited income and often-unstable nature of their employment. According to one of the more recent studies (2022) that touches on the housing needs of farmworkers, “Farmworker Health in California, Health in a Time of Contagion, Drought, and Climate Change,” published by the Community and Labor Center at UC Merced, over half of the state’s farmworker population lives in the San Joaquin Valley (61 percent). The study was based on interviews with a sampling of over 1,200 California farmworkers from five agricultural regions, including the San Joaquin Valley. Some key findings related to farmworker housing needs from the study included: SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING * Only three percent of farmworkers primarily speak English at home, which indicates that language barriers could pose a challenge to securing housing. * 92 percent of farmworkers rent their housing, indicating that there are barriers to accessing homeownership and that there may be a higher risk of displacement amongst farmworkers. * Farmworkers face a range of housing problems, indicating a need for assistance with repairs to housing or assistance with finding more suitable housing. The housing problems included lack of access to water inside the home (10 percent), bad tasting water at home (24 percent very bad; 13 percent bad), challenges in keeping the home cool (39 percent) or warm (36 percent), and other poor housing conditions such as rotting wood (16 percent), mold (14 percent), water damage (13 percent), water leaks (12 percent), cockroaches (24 percent), or rodents (17 percent). * Survey respondents, “lived in large, overcrowded households with low incomes and several household problems.” Approximately 70 percent of the sample lived with children under the age of 18. The median household size was four, and one-fourth of farmworkers lived in households with six or more persons, indicating a need for larger family-sized housing units, while more than one-fourth reported sleeping in a room with three or more persons, indicating overcrowding. * Along with large household sizes, the farmworkers reported a median annual household income of $25,000. Although the study acknowledged that this figure may have under-reported the income of the entire household, it likely still underscores the fact that housing affordability would be an acute need for a very large portion of farmworker households who would struggle to afford larger-sized homes on the relatively low wages associated with farm work. * The accompanying data dashboard[^p254-26] indicates that of the 512 responses received from farmworkers in the San Joaquin Valley region, 70.1 percent of respondents occupy a single-family home; 16.8 percent live in an apartment; 4.1 percent live in a labor camp/boarding house/ or motel; 8.6 percent are sleeping in a car, RV, or garage; and about 0.4 percent of respondents are renting a room or did not specify their living arrangement. Data collected as part of the USDA Census of Agriculture indicates that the composition of farmworker households has changed since 1996 to include more families and fewer individuals. As a result, farmworker housing needs have likely shifted from primarily seasonal housing for migrant workers (such as dormitory-style housing available during peak labor activity in May through October) towards more permanent affordable housing for low wage working families, although there remains a need for both housing types. [^p254-26]: UC Merced, 2022. Farmworker Health Study Data Dashboard. https://clc.ucmerced.edu/farmworker-health-study/farmworker-health-study-data-dashboard. Accessed March 2024. APPENDIX 1E: CITY OF FRESNO As shown in Table 1E-3.12, the 2017 USDA Agricultural Census reported 2,540 farms and an estimated 37,819 farmworkers in Fresno County. Most farmworkers were seasonal (55.4 percent), working less than 150 days per year. Estimates from the 2020 ACS report that there were 36,163 people in Fresno County (8.8 percent of the overall workforce) employed in the Agriculture, Forestry, Fishing and Hunting, and Mining industries. In the city of Fresno, there were 9,414 people employed in this category (4.3 percent of the overall workforce). However, ACS data does not accurately capture the farmworker population as it includes employment in various non-agricultural industries and excludes farm labor contractors, which significantly underestimates the number of farmworkers. Moreover, the seasonal and often migrant nature of farm labor, and accounting for undocumented workers, suggest that this data likely underrepresents the actual farmworker population, because undocumented residents do not often participate in traditional data collection. As such, there is little data available on farmworkers in the city. Table 1E-3.12: Hired Farm Labor (Countywide), 2017 | Labor Term | Number of Farm Operations | Number of Workers | | :--- | :--- | :--- | | Year-Round Labor (150 days or more) | 1,557 | 16,876 | | Seasonal Labor (Less than 150 days) | 1,753 | 20,943 | *Source: USDA Agricultural Census, Table 7, 2017.* Although census data indicates that there is a small population of farmworkers in the city relative to other jurisdictions in Fresno County, school enrollment data suggests that some of region’s farmworker population utilize services within Fresno. While these estimates are at the school district level (students can live in one city and attend a school located in a different city), the data shows there were approximately 5,902 migrant students enrolled in school districts throughout Fresno County with 2,975 migrant students enrolled in schools in the city of Fresno and 43 enrolled in Clovis Unified during the 2020-2021 school year, as shown in Table 1E-3.13. Generally, migrant student enrollment has increased steadily throughout the county. Nearly half of the county’s migrant population attend school in the city of Fresno. The greatest enrollment of migrant students is in Orange Center Elementary, located in the unincorporated county outside the southwestern fringe of the city. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Table 1E-3.13: Migrant Student Enrollment | School District | 2016-2017 | 2017-2018 | 2018-2019 | 2019-2020 | 2020-2021 | | :--- | :--- | :--- | :--- | :--- | :--- | | **Clovis** | | | | | | | Clovis Unified | 51 | 51 | 49 | 44 | 43 | | **City of Fresno** | | | | | | | American Union | - | - | - | - | - | | Fresno County Office of Ed | 32 | 22 | 39 | 32 | 33 | | Fresno Unified | 725 | 867 | 850 | 713 | 918 | | Monroe Elementary | 41 | 43 | 33 | 25 | 22 | | Orange Center Elementary | 1,139 | 1,289 | 1,392 | 1,481 | 1,607 | | Pacific Union Elementary | - | - | - | - | - | | Washington Colony Elementary | - | - | - | - | - | | Washington Unified | 155 | 175 | 189 | 203 | 218 | | Washington Union High | - | - | - | - | - | | West Fresno Elementary | - | - | - | - | - | | West Park Elementary | 14 | 19 | 17 | 15 | 13 | | Central Unified | 208 | 179 | 172 | 153 | 164 | | **Total City of Fresno** | **2,314** | **2,594** | **2,692** | **2,622** | **2,975** | | **Total Fresno County** | **4,780** | **5,061** | **5,185** | **5,445** | **5,902** | Source: California Department of Education, California Longitudinal Pupil Achievement Data System (CALPADS), Cumulative Enrollment Data (Academic Years 2016-2017, 2017-2018, 2018-2019, 2019-2020, 2020-2021) Farmworkers face unique challenges securing affordable housing due to a combination of limited English language skills, very low household incomes, and difficulty qualifying for rental units or home purchase loans. Based on farmworker employment figures collected by the California Employment Development Department (EDD) in 2022, the median wage for farmworkers statewide was $14.72 per hour or $30,625 annually. Farmworkers in the Fresno region had a slightly lower median wage of $14.52 per hour or $30,202 annually, which is considered a very low-income based on HCD's household income limits for Fresno County. Seasonal farmworkers (employed in farm labor less than 150 days per year) who do not find supplemental income during the off-season are often considered extremely low income. Many farmworkers pay market-rate prices for housing, despite having incomes qualifying for housing assistance, due to a shortage of employer-provided housing and difficulty securing publicly-assisted housing. Fresno Housing manages 194 units of seasonal farmworker housing for migrant farmworkers, none of which are within the city of Fresno. According to HCD's Employee Housing Facilities database, there are 23 permanent employee housing facilities in the city of Fresno which can house 478 employees. Of these, 12 facilities are reserved for workers with H-2A visa which often are bunkhouses, dorms, or motel rooms which could accommodate 185 workers. These units are privately funded and provided by employers as a requirement of the H-2A visa program. APPENDIX 1E: CITY OF FRESNO Between September 2021 and January 2022, Fresno County conducted a Farmworker Survey and a Farmworker Employer Survey. A second round of each survey was conducted between February 2022 and July 2022. In total, County staff surveyed a total of 240 farmworkers and 170 farm employers. Twenty-five farm employers currently have some type of farm labor housing on site (not necessarily in use); five of those employers would consider retaining the farm labor housing. Staff surveyed 145 farm employers who do not have any farm labor housing on site; 28 of those surveyed would consider adding labor housing as single houses or cottages; one farm employer specified labor housing as apartments. Farmworkers expressed a preference for detached single-family housing and a very small percentage (0.02 percent) expressed farmworker housing as desirable future housing. In summary, the surveys indicate that traditional farm labor/worker camp housing is not desired by the Fresno County farmworkers/laborers, and even though there was a small number of Fresno County farm employers that might be interested in providing housing, it would only be if the housing was subsidized. Similar to other special needs groups, much of the housing need for farmworkers, especially farmworker households with families, is best met near services, schools, and other resources and amenities. The following is a list of organizations that provide resources and support to Central Valley farmworkers that can be accessed by Fresno residents: * **Binational Central California:** Provides services related to immigration, health care, and educational resources. * **California Farmworker Foundation:** Provides services related to education, workforce development, health care, immigration, and community wellness. * **California Rural Legal Assistance:** Provides legal counseling and representation in matters of housing advocacy, immigration law, removal defense, impact litigation, labor and employment, pesticide and work safety, sexual harassment prevention. * **Central California Legal Services:** Provides legal counseling and support. * **Centro La Familia:** Offers domestic violence assistance, sexual assault and human trafficking services, consumer and family advocacy, CalFresh outreach and education, telecommunications education and assistance in multiple languages, and immigration support services. * **Cultiva la Salud:** Provides services to build leadership capacity and improve access to healthy food, beverages, and physical activity opportunities. * **Fair Housing Council of Central California:** Provides fair housing advocacy and tenant support. * **Green Raiteros:** Provides transportation assistance, workforce development, and small business support. * **Rural Mobile Health:** Offers medical services and screenings at no cost. * **Self-Help Enterprises:** Provides financial assistance, rental housing, housing rehabilitation, community development, and other support services to address housing and community development needs in rural and disadvantaged communities. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING * **United Farm Workers Foundation:** Provides assistance related to immigration status filings, including Deferred Action for Childhood Arrivals, family-based petitions, naturalization/citizenship, representation before the Board of Immigration Appeals, legislative advocacy, and referrals to other support services. In addition, the Housing Element includes **Program 24** to address the housing needs of farmworkers. Through **Program 24**, the City will identify development opportunities for farmworker housing and meet with farmworker housing developers and advocates on a biannual basis to discuss their needs and offer assistance in the form of letters of recommendation for grant applications and discuss incentives for constructing farmworker housing. The City will also offer incentives such as density bonuses, streamlined processing, and the minor deviation process to facilitate development of farmworker housing. ## Other Relevant Factors and Local Knowledge In addition to the indicators analyzed above, there are several other factors that can influence housing mobility and access to opportunity in a jurisdiction. Historic development patterns in Fresno have resulted in neighborhoods that are largely or exclusively made up of single-family homes and historic discrimination has influenced the city’s racial and ethnic composition. Further, given current market trends, newer market rate neighborhoods may not be financially accessible to low-, moderate-, and some above-moderate income households without overpayment or overcrowding. Other factors may include the distribution of public and private investments, local regulatory or economic development plans, and historic policies. Those factors that are considered relevant vary between jurisdictions and are described at the local level below. ## Local History of Fresno The San Joaquin Valley is the traditional homeland of the Yokuts people, who lived in the foothills, and Mono peoples, who occupied the upper reaches of Fresno County’s rivers.[^p258-27] Missionaries and trappers were the first non-native people to roam the area, beginning in the late 1770s. Miners soon followed during the “Gold Rush” period.[^p258-28] By 1869, railroad investors were constructing a railroad through the valley and speculating on sites for new town development. Fresno was founded by the Central Pacific Railroad Company in 1872, and Leland J. Stanford, a Director for the Railroad, is credited with selecting the site of the city.[^p258-29] The new site was formally named Fresno Station in 1874, and was later incorporated into the City of Fresno in 1885.[^p258-30] By the 1900s, the city of Fresno was the county’s metropolis, “a true Victorian city” with its horse-car lines, dirt streets, and wood sidewalks.[^p258-31] [^p258-27]: Fresno County Historical Society. The People and Communities of the 19th Century Central Valley - Native Americans. Accessed via: https://www.valleyhistory.org/native-americans [^p258-28]: UCLA Luskin Center for Innovation, 2023. 2023 Progress Report on Implementation of the Transformative Climate Communities Program Grant, “A Brief History of Fresno: The Legacy of Environmental Injustice” Accessed via: https://innovation.luskin.ucla.edu/wp-content/uploads/2023/06/Transform-Fresno-2023-Progress-Report.pdf [^p258-29]: City of Fresno, n.d. Historic Preservation. Accessed via: https://www.fresno.gov/planning/historic-preservation/ [^p258-30]: Calvarese, M., Osborne, B., Moulton, J. (2016). Downtown Land-Use Change: A Historical Geography of Fresno, California’s Central Business District, 1860–2010. The California Geographer, Volume 55, p 19-38. Accessed via: https://scholarworks.csun.edu/handle/10211.3/170952?show=full [^p258-31]: Fresno County Historical Society, Past and Present Journal Volume 42 No. 4. Accessed via: https://www.valleyhistory.org/history-of-fresno-county APPENDIX 1E: CITY OF FRESNO After Fresno was established, it saw a boom in agriculture that demanded an expanded labor force.[^p259-32] Throughout the 1850s and 1860s, Asian settlers were recruited as a major source of labor for the mining and railroad industries in the western U.S. Because of the railroad and its geographical location, the new city quickly attracted hundreds of settlers and became the county seat. In the early 1880s, the U.S. Congress passed the Chinese Exclusion Act of 1882, which restricted Chinese immigration to the U.S. Other exclusionary laws aimed at Chinese immigrants were passed by Congress between 1888 and 1902, effectively reducing the number of Chinese people entering the U.S. Although Chinese immigrants helped build the Central Pacific Railroad, they were viewed as outsiders by local White residents and were forced to settle west of the tracks in what is now Chinatown. Nearly all Valley cities including Lodi, Stockton, Modesto, Turlock, Merced, Madera, Fresno, Visalia, Tulare, and Delano developed strict land use policies to segregate and contain migrant immigrants, including Chinese settlers, to one “undesirable” side of town. In Fresno (home to California’s second largest Chinatown), White residents convinced major landowners not to allow Chinese residents to own property east of the railroad tracks and local police criminalized any Non-Whites found on the east side of town.[^p259-33] As the city grew, Black or African American people and many immigrant groups – including Germans and Armenians – were relegated to the Southwest and Downtown. Today, Germantown and Armeniantown along with Chinatown are cherished as some of Fresno’s early ethnic neighborhoods. In 1918, Fresno’s first City plan was created by Charles Henry Cheney, Architect and City Planner. It sought to establish a land use plan that limited industrial encroachment into residential areas and vice versa. At that time, the industrial area of the city was established in the south, strategically located to utilize the railroads and take advantage of the prevailing winds, which were from the northwest. Residential neighborhoods were shown equally distributed to the west, north, and east upwind of the industrial area. Building on development patterns that were already existing at the time, the plan designated areas for single family dwellings, flats, group housing and apartments, churches, schools and parks, businesses, and various types of industrial development. The development patterns in the plan are still reflected in the Downtown and surrounding neighborhoods as they stand today. The population continued to grow in the San Joaquin Valley where most jurisdictions, including Fresno, built tract housing and new subdivisions in formerly agricultural areas. As more and more people came to the city, migration from central neighborhoods began to occur. Development away from the urban core, in combination with newly constructed freeways, Clovis Unified School District’s high performing schools, available riverfront property, and a healthcare sector along Herndon Avenue, attracted White and residents of other races and ethnicities to the affluent neighborhoods of north Fresno. These new, often larger homes, attracted a variety of middle- and upper-class residents away from the urban core of the city. As these suburbs grew, resources were not distributed evenly due to the financial burden to provide schools, transit, and infrastructure. [^p259-32]: Pacheco-Werner, T. L., Corona, K., Corona, G., Chan, S., Conley, A., & Dhillon, H. (2018). Fresno Building Healthy Communities (BHC) Timeline. Central Valley Health Policy Institute. California State University, Fresno. Accessed via: https://www.sutori.com/en/story/fresno-bhc-timeline--wGb27reQQeEt6ZoHv1qgPZfx [^p259-33]: San Joaquin Valley Fair Housing and Equity Assessment. Ramon D. Chacon, “A Case Study of Ghettoization and Segregation: West Fresno’s Black and Chicano Community During the 1970s,” Standford Center for Chicano Research. Working Paper Series No. 12 (Jan 1986): 2,5, 7, Table 4. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING As a result of this outward expansion, the core of the city gradually became a severely concentrated area of poverty. Shaw Avenue, for example, is often described by local leaders as “an economic line of demarcation between the more affluent northern parts of Fresno and the modest-to-poorer neighborhoods in central and south Fresno.” 34 Several stakeholders consulted during the Housing Element update process also provided local knowledge reiterating a trend of disinvestment in west and southwest Fresno due to urban sprawl. According to CSU Fresno researchers, “obsolete buildings, congested roads, difficult access, and increased crime rates coupled with lower land prices outside the city core, left [the city] less alluring than in previous decades. With less investment and fewer middle class residents, the quality of the community in terms of crime rates and school quality suffered. However, adoption of the General Plan in 2014 with its focus on downtown and infill investment, as well as the Transform Fresno program are current efforts to reverse these trends. ## Redlining and Urban Renewal Many of the racial and spatial divisions described in the assessment above originated through land use patterns that paved the way for rural and urban concentrated areas of poverty. The process of urban renewal, prevalent practices of redlining, and the construction of high density, low-income housing projects perpetuated the segregation of lower income communities of color on one side of town, and higher income communities on the other. The Federal Housing Act of 1949 focused on eliminating substandard living conditions through the clearance of central-city slum areas and provided federal subsidies for cities attempting to remedy serious housing shortages. The Act originally centered on improving the housing stock in “blighted” communities and stipulated that all redevelopment projects be predominantly residential. During this era, government officials saw the opportunity to capitalize on state and national urban renewal programs to assist in the construction of State Routes 99, 41, and 180 to form a freeway loop through Downtown, redirect traffic around the city’s core rather than through it. The construction of the freeway loop had a devastating impact on Downtown and its surrounding neighborhoods. The efforts resulted in the demolition of more than 20 blocks of residences in West Fresno and isolation of historic immigrant neighborhoods from the rest of the city. Formerly unified neighborhoods were cut in two by freeways without surface crossings. The new freeway cemented racial divides and led to the northern areas of the city becoming increasingly affluent and White, while the south became increasingly poor, Latino, Black or African American, and Asian. Facilitated by the freeways, the City continued to stretch onto inexpensive land to the north and east, aiding the migration of people and businesses away from the city. [^p260-34]: Sheehan, T. 2019. “Fresno’s Tale of Two Cities: Which neighborhoods receive the most government aid?” Fresno Bee. Available via: https://www.fresnobee.com/news/local/article236821658.html [^p260-35]: San Joaquin Valley Fair Housing and Equity Assessment, 2014. Available via: https://academics.fresnostate.edu/oced/documents/SJV_Fair-Housing-and-Equity-Assessment_April-2014.pdf APPENDIX 1E: CITY OF FRESNO Redlining refers to the process of delineating neighborhoods worthy or unworthy of private investment. Even before the Depression, private lenders chose to avoid certain areas, particularly those home to certain ethic groups including Black or African Americans, new immigrants, and neighborhoods with older cheaper housing. During the 1930s, the federal government established the Home Owner’s Loan Corporation (HOLC) and HOLC developed an evaluation method to rate neighborhoods based on their desirability. Investors categorized neighborhoods as “red” or “yellow” if there was said to be an “infiltration of undesirable populations” or a “lack of homogeneity.” Once a neighborhood was “redlined,” banks refused to grant home mortgages and loans to residents in the area. Figure 1E-3.39 is an illustration of HOLC maps in Fresno. Red and yellow neighborhoods were prevalent. HOLC maps demonstrate the role that access to credit plays in the well-being of urban neighborhoods as most of the red and yellow neighborhoods remain low-income, low resource communities today. [^p261-36]: Amy E. Hillier. "Redlining and the Homeowners' Loan Corporation." of Urban History, Volume 29, Issue 4, 2003, pages 394-420. Available via: https://repository.upenn.edu/cgi/viewcontent.cgi?referer=https://www.google.com/&httpsredir=1&article=1002&context=cplan_papers SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Figure 1E-3.39: HOLC Maps, Fresno, 1936 <
> Source: Robert K. Nelson, LaDale Winling, Richard Marciano, Nathan Connolly, et al., “Mapping Inequality,” American Panorama, ed. Robert K. Nelson and Edward L. Ayers, accessed November 22, 2022, https://dsl.richmond.edu/panorama/redlining/#loc=13/36.751/-119.834&city=fresno-ca. 1E-3-112 FRESNO MUNICIPAL-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 # Land Use and Zoning Patterns Decisions regarding land use and zoning have a direct and profound impact on affordable housing and fair housing choice, shaping a community or region’s potential diversity, growth, and access to opportunity. Zoning determines where housing can be built, the type of housing that is allowed, and the amount and density of housing that can be provided. Zoning also can directly or indirectly affect the cost of developing housing, making it harder or easier to accommodate affordable housing. In Fresno, the Development Code (Chapter 15 of the Code of Ordinances) divides the city into 29 primary zoning districts, including six single family dwelling districts, three multifamily dwelling districts, one mobile/manufactured home district, and six mixed-use and Downtown residential districts, plus overlay zones (mostly related to historic and environmental resources protection). Figure 1E-3.40 displays the City’s Official Zoning Map. Through the adoption of the Fresno General Plan in 2014 and subsequent rezonings implemented through the new Development Code and Zoning Map in 2015, Fresno shifted from a preference for single-family detached housing to residential and mixed-use zones that allow more density and housing diversity. The Development Code and Zoning Map, however, still maintain single family detached only zoning districts (RE, RS-1, RS-2, and RS-3) – with no duplexes, townhomes, triplexes, row homes, garden homes, zero lot line dwellings, or the like. (Accessory/Secondary dwelling units are permitted, however, in all single-family districts.) Affordable housing development typically requires high density zones to support construction and financing; therefore, zones limited to single dwelling units on each lot do not support affordable development. Although there are opportunities to expand the array of housing types in traditionally single-unit neighborhoods, multiplexes are not sufficient to accommodate housing needs for all economic segments of the community. The flexibility of multi-unit and mixed-use zoning increases opportunities for affordable housing. As shown in Figure 1E-3.40, multi-family zones in Fresno are located along major corridors that span throughout the city. Rather than being concentrated in one area, the City has adopted amendments to the citywide development code to encourage higher density development along strategic infill corridors, referred to as Activity Centers in the Fresno General Plan. Some of these Activity Centers are generally located on land along the first phase of the BRT system, composed of corridors along Blackstone Avenue between Downtown and the major shopping centers from Herndon Avenue to Nees Avenue, and along Ventura Avenue-Kings Canyon Road from Downtown to Clovis Avenue. Fresno has made significant policy changes to make it easier to build higher-density housing in Downtown and along Bus Rapid Transit (BRT) corridors, creating the first by-right zoning district in the city through the adoption of the Downtown Neighborhoods Community Plan in 2016 and lifting the caps off maximum dwelling units in mixed-use zone districts through the adoption of the mixed-use text amendment in 2022. Despite the policy changes, it continues to be difficult to build any new affordable housing without significant public subsidy. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Also, through the adoption of the Fresno General Plan in 2014, Fresno prioritized locating roughly one-half of future development in infill areas (within the city limits as of December 31, 2012) and roughly one-half of future development in growth areas. Tracking residential development from July 2013 to July 2020 as shown in Table 1E-3.14 below, there were a total of 8,223 dwelling units built and the breakdown was as follows: 4,099 single family in city limits, 1,165 single family in Sphere of Influence (SOI), 2,787 multifamily in city limits, and 176 multifamily in SOI. A total of 6,886 dwelling units (84 percent) were built in the city limits and 1,341 dwelling units (16 percent) were built in the SOI. Table 1E-3.14: Residential Development Built Between July 2013 and July 2020 | Area | Type of Dwelling Unit | | Location of Development | | Total | | :--- | :--- | :--- | :--- | :--- | :--- | | | Multifamily and Townhouse | Single Family | Dwelling Units in City Limits (December 31,2012) | Dwelling Units in Growth Areas (SOI) Annexed after December 31, 2012 | | | Downtown Planning Area and BRT Corridors | 364 | 20 | 384 | 0 | 384 | | Established Neighborhoods South of Shaw | 272 | 2,304 | 2,563 | 13 | 2,576 | | Established Neighborhoods North of Shaw | 2,279 | 1,109 | 3,060 | 328 | 3,388 | | South Industrial | 0 | 0 | 0 | 0 | 0 | | DA-1: North | 7 | 834 | 658 | 183 | 841 | | DA-1: South | 41 | 2 | 43 | 0 | 43 | | DA-2: North | 0 | 279 | 0 | 279 | 279 | | DA-2: South | 0 | 402 | 0 | 402 | 402 | | DA-3: Southeast | 0 | 0 | 0 | 0 | 0 | | DA-4: East | 0 | 116 | 0 | 116 | 116 | | DA-4: West | 0 | 198 | 178 | 20 | 198 | | *Sub Totals* | *2,963* | *5,264* | *6,886* | *1,341* | *8,227* | | **Total Units 2013- 2020** | **8,227** | | **8,227** | | **8,227** | Source: City of Fresno, Annual Progress Report submitted to The Governor's Office of Planning and Research, April 1, 2021. Retrieved from: https://www.fresno.gov/darm/wp-content/uploads/sites/10/2022/07/6_2020-General-Plan-Annual-Progress-Report.pdf. In most cases, the Development Code and other land use code sections are reasonably permissive and allow for flexibility as to the most common fair housing issues. The highest density zones, and the majority of mobile home park designations are sited next to or close to State Routes. Medium and high density residential mixed use zones are equally distributed over all TCAC/HCD resource opportunity designations. APPENDIX 1E: CITY OF FRESNO # Figure 1E-3.40: Zoning Map, City of Fresno <
> | ZONING ADOPTION | | | | | | | :--- | :--- | :--- | :--- | :--- | :--- | | 2015-39 | | | 3-Dec-15 | | | | | REZONES | | | | | | Ordinance Number | Date | Ordinance Number | Date | Ordinance Number | Date | Ordinance Number | Date | | 2015-2 | 4-Feb-16 | 2017-49 | 14-Jul-17 | 2018-49 | 30-Jul-18 | 2021-052 | 8-Dec-21 | | 2016-3 | 4-Feb-16 | 2017-61 | 21-Sep-17 | 2018-63 | 6-Dec-18 | 2021-053 | 8-Dec-21 | | 2016-4 | 4-Feb-16 | 2017-65 | 30-Jul-17 | 2018-090 | 11-Apr-19 | 2021-054 | 8-Dec-21 | | 2016-8 | 15-Jun-16 | 2017-80 | 26-Oct-17 | 2019-11 | 25-Mar-19 | | | | 2016-15 | 12-Mar-16 | 2017-81 | 26-Oct-17 | 2019-015 | 25-Jul-19 | | | | 2016-23 | 30-Jul-16 | 2017-83 | 2-Nov-17 | 2019-020 | 8-Aug-19 | | | | 2016-25 | 18-Aug-16 | 2018-7 | 8-Feb-18 | 2019-025 | 15-Jun-19 | | | | 2016-29 | 1-Sep-16 | 2018-8 | 8-Feb-18 | 2019-47 | 5-Dec-19 | | | | 2016-31 | 2-Sep-16 | 2018-9 | 15-Mar-18 | 2019-49 | 19-Dec-19 | | | | 2016-36 | 22-Sep-16 | 2018-16 | 5-Apr-18 | 2020-001 | 16-Jan-20 | | | | 2016-41 | 20-Oct-16 | 2018-30 | 17-Jun-18 | 2020-005 | 14-Mar-20 | | | | 2016-45 | 17-Nov-16 | 2018-36 | 27-Apr-18 | 2020-011 | 30-May-20 | | | | 2016-49 | 1-Dec-16 | 2018-38 | 24-Apr-18 | 2020-021 | 18-Jun-20 | | | | 2016-58 | 15-Jan-17 | 2018-49 | 30-Jul-18 | 2020-032 | 27-Oct-20 | | | | 2017-3 | 12-Feb-17 | 2018-53 | 5-Dec-18 | 2020-055 | 1-Sep-20 | | | | 2017-4 | 12-Feb-17 | 2019-10 | 1-Jun-19 | 2020-056 | 13-Oct-20 | | | | 2017-15 | 2-Apr-17 | 2019-12 | 28-May-17 | 2020-057 | 13-Oct-20 | | | | 2017-27 | 25-May-17 | 2019-018 | 25-Jul-17 | 2020-058 | 13-Oct-20 | | | | 2017-31 | 9-Jun-17 | 2019-020 | 15-Aug-17 | 2022-003 | 18-Jan-22 | | | | 2017-32 | 16-Jul-17 | 2019-026 | 19-Aug-17 | 2022-009 | 4-Apr-21 | | | Source: City of Fresno, 2022. Accessed January 2023. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-115 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ## Public Investment Patterns Public and private investment typically includes construction, maintenance, and improvements to public facilities, including infrastructure, acquisition of land, and major equipment. Investments are typically prioritized based on need and available funding. Public investments such as subsidized housing, roads, infrastructure, and economic development can significantly impact access to opportunities in any given neighborhood. While the city has experienced patterns of disinvestment in certain areas particularly near the inner core of the city including such areas as Downtown, south, and southwest parts of the city, some of these patterns of disinvestment can be traced back to the variety of systemic factors that have influenced segregation nationwide including discriminatory lending practices, redlining, and urban renewal policies. Specific areas of the city have historically been underserved and have faced a lack of economic opportunity and social mobility, including various challenges like high poverty rates, limited job opportunities, and insufficient access to affordable housing or quality healthcare. This section will describe investments occurring in Fresno to improve quality of life throughout the city. In recent years, the City has focused on several key areas of investment, including: * **Parks and Recreation:** The City recently adopted a Parks Transactions and Use Tax through ballot Measure P. Measure P was developed by Fresno for Parks, a diverse, non-partisan group of Fresno residents who believed that safer, cleaner parks for all Fresnans was important to the health, safety and overall quality of life of the community and placed the measure on the November 2018 ballot after gathering more than 35,000 signatures of local support. The citizen-led measure provides a guaranteed, local funding source for parks through a 3/8-cent sales tax in the city of Fresno. It generates an estimated $38 million per year to be used for clean and safe parks; new parks and recreation facilities; youth and senior recreation and after-school facilities and job training; improved walking and biking trails; the San Joaquin River Parkway; beautification of streets; and expanded access to arts and culture. * **Public Safety:** Fresno has invested in public safety initiatives to reduce crime and improve community safety. These initiatives include the implementation of community policing programs and hiring more officers including the recently added Park Rangers to patrol city parks and addressing non-emergency calls for service while maintaining clean parks. * **Economic Development:** To attract new businesses and create new job opportunities in the city, the City has invested in several economic development initiatives including business incubators, workforce training programs, and Downtown revitalization. * **Transportation:** A multitude of transportation projects have been executed in the city to improve mobility and connectivity. Projects include the construction of new bike lanes, the expansion of the FAX bus system, and the development of the high-speed rail system. In September of 2013 the City of Fresno received a $15.9 million Transportation Investment Generating Economic Recovery (TIGER) grant from the U.S. Department of Transportation for the Fulton Mall Reconstruction Project which returned the Fulton Mall in Downtown to a complete street, reintroducing vehicle traffic to Downtown’s former main street. The restoration of Fulton Main Street occurred over 11 city blocks and included bicycle and pedestrian accommodations, streetscape improvement elements, and integration of existing fountains and sculptures. APPENDIX 1E: CITY OF FRESNO * **Housing:** The City also invests in housing initiatives to address housing needs in the city. The City utilizes Federal, State, and locally sourced funding to aid in the development of new housing, new affordable housing units, housing rehabilitation, displacement avoidance, emergency and supportive housing, and homebuyer assistance. In 2018, the City established its Rental Housing Registry Division of the Code Enforcement team. The purpose of the Rental Housing Division is to address the issue of substandard rental properties, promote greater compliance with health and safety standards and to preserve the quality of Fresno’s neighborhoods and available housing opportunities. The goal is to work with property owners to achieve compliance of health and safety code violations that are a threat to the occupant’s safety, structural integrity of the building, and have a negative impact on the surrounding neighborhoods. * **Infrastructure:** In 2023, the City was awarded funding from HCD to finance key infrastructure improvements to water, sewer, streets, and parking to support a minimum of 862 Downtown housing units — of which 557 are marked for affordable housing.[^p267-37] On top of the $250 million in state funds for revitalizing Downtown over the next three years, the City is set to receive $43.7 million in state grants to build Downtown infrastructure for housing. The following estimates depict how the City intends to allocate this funding: * $16.8 million for sewer improvements * $14.3 million for water infrastructure improvements * $11.7 million for a structured parking garage on Fulton Street * $913,000 for street improvements near the Tuolumne Street and Van Ness Avenue intersection ### High-Speed Rail Project The California High Speed Rail project is a major infrastructure investment impacting multiple communities across the state. One line of the rail system is designed to connect San Francisco to Los Angeles, running through the San Joaquin Valley with a stop in Fresno. The Fresno Station will be located in Downtown between H and G Streets and Fresno and Tulare Streets. The California High Speed Rail Authority has been working closely with the City of Fresno to ensure that the project is completed successfully. The authority has conducted environmental studies, community outreach, and design work in Fresno to ensure that the project meets the needs of the community and is integrated into the existing transportation infrastructure. The City also dedicated staff to help relocate residents and businesses located in the proposed High Speed Rail right of way. Sometimes the City offered creative solutions to help incentivize the move such as offering publicly owned land at the convention center for the Cosmopolitan to build a new restaurant. The High Speed Rail is expected to be completed in several phases, with the first phase connecting San Francisco to Los Angeles by 2033. [^p267-37]: Shaikh Rahsad,O. 2023. “Fresno mayor wants 10,000 people to live in the city’s downtown. Here’s the plan.” Fresnoland. Accessed via: https://fresnoland.org/2023/08/30/revitalizing-downtown-fresno/ SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING The project is expected to create thousands of jobs in Fresno, providing employment opportunities and stimulating economic growth in Fresno. New businesses and new job opportunities in Fresno are likely to increase demand for housing. The improved transportation connectivity resulting from the High Speed Rail project could also increase mobility for commuter households that want to live in the city and commute elsewhere. Overall, the high-speed rail system is expected to promote transit-oriented development around the transit station in Fresno which could increase access to affordable housing for residents who rely on public transportation. ### Funding for Housing, Economic, and Community Development The City receives HUD funding for capital improvement projects in qualifying low- and moderate-income neighborhoods within the city’s sphere of influence. The City’s Public Works Construction Management Division typically oversees the infrastructure projects that are approved. More than $200 million in funding has gone toward CDBG projects during the previous Housing Element cycle. Projects included street construction, parks, traffic signal, sewer and water, and transportation projects. In 2022 alone, the City initiated funding in two locations– the Burroughs Elementary Neighborhood Street Reconstruction Project (Phase I) and the West Fresno Elementary and MLK Neighborhood Street Improvements Project. The City also funded additional projects for overall neighborhood street improvements – the Yosemite Middle School Complete Streets Project, the Ericson Elementary Neighborhood Project, the Highway City Neighborhood Reconstruction Project, the Maple-Gettysburg-Holland Street Reconstruction Project, the Olive-Maple-Whitney-Chestnut Street Reconstruction Project, the Shields-Cedar-Dakota-Maple Street Reconstruction Project, and the Burroughs Elementary Neighborhood Street Reconstruction Project (Phase II). Across these eight projects, it is estimated that the City served 66,685 people. The City also used $4.9 million in CDBG funds to acquire property on Blackstone Avenue for the future development of a senior center. The senior center is anticipated to be about 29,000 square feet and will provide various services and indoor and outdoor amenities. The 2020-2024 Consolidated Plan also identifies Affordable Housing Development in high opportunity areas as a priority. In 2022, the City allocated $3.1 million in HOME funds for Affordable Housing Development or Rehabilitation and an additional $3.6 million in CDBG funds for land acquisition in support of affordable housing development. Additionally, the City allocated 28.5 percent of its third allocation of Permanent Local Housing Allocation (PLHA) for development of affordable multifamily rental housing and 28.5 percent for development of affordable single-family housing, focusing on areas of opportunity. Out of the total PLHA allocations, the City will have $4.1 million for the development of affordable multifamily rental housing and another $4.1 million for the development of single-family housing. The City is awaiting receipt of executed Standard Agreements from the State of California for these funds. APPENDIX 1E: CITY OF FRESNO # Priority Investments in Established Neighborhoods Roughly one half of development in the city is anticipated to be within infill areas through 2035, as described in the General Plan. The other half or so of development in the city is anticipated to be in new growth areas, which include unincorporated land planned for urban use. One of the City’s primary planning considerations is to address the need for increasing the affordable housing opportunities for low- and moderate-income households, with special emphasis on persons with disabilities, people experiencing homelessness, large families, persons living in substandard housing, and persons paying rent that exceeds 50 percent of their monthly income. Through the General Plan, the City prioritized specific areas within the core of the city for incentives and other benefits to accelerate reinvestment and rehabilitation for homes and businesses. Figure 1E-3.40 displays the City’s Priority Areas for Development Incentives, these areas include: * **“Infill Opportunity Zones” (IOZs) – Established Neighborhoods Generally South of Herndon Avenue,** including many of Fresno’s established neighborhoods, which are in need of both large, catalytic reinvestment projects, as well as smaller-scale strategic interventions; * **BRT corridors,** including the Phase 1 corridors along Blackstone Avenue and Ventura Avenue/Kings Canyon Road and the Phase 2 corridors along Shaw Avenue and California Avenue; * **Downtown Planning Area,** which includes the Central Business District, Civic Center and other Downtown centers, Chinatown, South Stadium/South Van Ness, Downtown neighborhoods and special districts; and * **South Industrial Area,** including much of Fresno’s established heavy industrial uses, which may need infrastructure investment to meet the needs of major job-creation industry sectors, as well as improvements to enhance current business operations. Priority for infrastructure projects will be given to serving established neighborhoods, including generally south of Herndon Avenue as shown in Figure 1E-3.41: Priority Areas for Development Incentives, along BRT and enhanced transit corridors, and in the Downtown Planning Area, consistent with General Plan policies. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Figure 1E-3.41: Priority Areas for Development Incentives, City of Fresno <
> Source: City of Fresno, 2014. Figure 1M-1 of the Fresno General Plan. APPENDIX 1E: CITY OF FRESNO Figure 1E-3.42 presents the sequencing of development on the fringe of the city, as presented in the City’s General Plan. To prioritize infrastructure investments within Growth Area 1 the City considers planned infrastructure expansion, public service capacity, and other fiscal considerations. The boundaries of these areas are Development Areas 1 North, 1 South, 2 North, and 2 South. Growth Area 2 has significantly less access to completed infrastructure. Any development in these areas would require all infrastructure costs to be borne by the new development. As part of the implementation of the Housing Element, programs are identified to upgrade the city’s infrastructure as needed in low- and moderate-income neighborhoods with the greatest needs. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING # Figure 1E-3.42: Sequencing of Development, City of Fresno General Plan <
> Source: City of Fresno, 2014. Figure 1M-2 of the Fresno General Plan. # Building Healthy Communities Initiative The City has been coordinating with community groups to address priorities of residents in south Fresno – generally those neighborhoods south of State Route 180. One such group, The California Endowment, launched a Building Healthy Communities Initiative (BHC). The BHC is a 10-year, $1 billion investment which began in 2010 with the goal of improving employment opportunities, education, housing, neighborhood safety, unhealthy environmental conditions, and inequitable access to healthy foods in 14 communities throughout the state. Central, Southeast, and Southwest Fresno have received and allocated funding as part of the BHC initiative. The BHC Initiative addresses a broad range of land use and social issues, which include: * Ensure that the built environment is clean, well maintained, and conducive to health in all city neighborhoods and includes adequate and equitable provision of sewer and water within a reasonably priced homeownership market. * Establish effective education and job training for area youth that is both academic and trade oriented. * Ensure that underserved neighborhoods are included in strategies for job creation, including opportunities for home grown business development. * Actively seek opportunities to create and maintain safe parks of all sizes in every city neighborhood to provide families with spaces to interact with their neighbors and promote physical activity. * Create opportunities both public and private for the Downtown neighborhoods that include entertainment, stores (e.g., retail, food, clothing), parks, recreation centers and after school programs, especially for youth. * Acknowledge and address attitudes within the government institutions, economic systems and law enforcement culture toward immigrant and ethnic minority communities that perpetuate inequality. * Develop a system of transportation that responds to the needs of the most vulnerable sectors of the community, including focused bus routes for specific geographic areas of need and/or particularly vulnerable subgroups (e.g., the elderly, disabled and farm workers). * Provide accessible healthcare services beyond emergency care. * Establish an equitable system of public safety that supports community while also reducing crime. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Transform Fresno As described previously the City is also actively engaged in the Transform Fresno initiative, which includes a number of community-driven projects to revitalize and improve the physical and social infrastructure in Chinatown, Downtown, and Southwest Fresno. Projects will reduce GHG emissions while also providing local environmental, health, and economic and social equity benefits. Much has happened after SGC’s announcement of Fresno’s TCC award in January 2018. From then through the close of the 2021-2022 fiscal year (June 30, 2022), a period of four and a half years, project partners have made considerable progress toward implementing an ambitious, unprecedented climate action initiative. Actions have included retrofitting homes to use less energy, increased urban tree cover, and workforce development. ### Location of Existing Publicly Supported Housing There are two divisions of Fresno Housing – one serves residents in the city of Fresno and the other serves residents in the greater Fresno County region. Fresno Housing’s 2023 Annual Plan provide the most recent record of the public housing inventory. Fresno Housing reports that there are 4,912 public housing units and 10,638 housing choice vouchers in use, totaling 15,550 publicly supported housing units in the city of Fresno, see Table 1E-3.15. There are more than 43,000 subsidized affordable housing units in the county of Fresno as a whole. Table 1E-3.15: Public Housing Units by Fresno Housing, 2023 | | Public Housing Units | Housing Choice Vouchers | Jurisdiction Total | | :--- | :--- | :--- | :--- | | City of Fresno Housing Authority | 4,912 | 10,638 | 15,550 | | Housing Authority of the County of Fresno | 19,505 | 8,294 | 27,799 | | **Region Total** | **24,417** | **18,932** | **43,349** | *Source: 2023 Annual Plan for Fresno Housing and the City of Fresno.* **Figure 1E-3.42** below depicts the location of individual buildings with public housing units throughout the city of Fresno, based on HUD’s national feature layer “Public Housing Buildings” from the National Geospatial Data Asset dataset. Public housing comes in all sizes and types, from scattered single family houses to high-rise apartments for elderly families. HUD administers federal aid to local housing agencies that manage the housing for low-income residents at rents they can afford. HUD furnishes technical and professional assistance in planning, developing and managing these developments. Publicly supported housing in Fresno is concentrated in certain areas of the city including in existing neighborhoods north of Shaw Avenue as well as in the southwest neighborhoods west of State Route 41 and north of the industrial district. (**Figure 1E-3.43**). APPENDIX 1E: CITY OF FRESNO ### Figure 1E-3.43: Public Housing Buildings <
> Source: HCD, AFFH 2.0 Data Viewer. HUD, 2021. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ## Food Access Food access is another important component of access to opportunity, as access to food that is both affordable and nutritious is a challenge for many individuals and families in the United States. While data on food access by neighborhood or census tract is not available for the city of Fresno, stakeholders interviewed to prepare the 2020 Analysis of Impediments to Fair Housing Choice noted a lack of access to fresh food outlets in south and west Fresno. In the survey issued to inform that planning process, respondents repeated concerns surrounding food access in the city, with 52 percent noting that grocery stores and other shopping opportunities are not equally provided. Only 22 percent of respondents described grocery stores and other shopping as equally provided in the city. As higher proportions of Hispanic residents live in south and west Fresno, lower levels of food access in these areas of the city may present fair housing concerns. ## Enforcement and Outreach Capacity ### Compliance with Fair Housing Laws Fair housing enforcement and outreach capacity refers to the ability of a locality and fair housing entities to disseminate information related to fair housing laws and rights and provide outreach and education to community members. Enforcement and outreach capacity also includes the ability to address compliance with fair housing laws, such as investigating complaints, obtaining remedies, and engaging in fair housing testing. The Fair Employment and Housing Act and the Unruh Civil Rights Act are the primary California fair housing laws. California state law further extends anti-discrimination protections in housing to several classes that are not covered by the federal FHA of 1968, including prohibiting discrimination on the basis of sexual orientation. California’s Department of Fair Employment and Housing (DFEH) has statutory mandates to protect the people of California from discrimination pursuant to the California Fair Employment and Housing Act (FEHA), Ralph Civil Rights Act, and Unruh Civil Rights Act (with regards to housing). * FEHA prohibits discrimination and harassment on the basis of race, color, religion, sex (including pregnancy, childbirth, or related medical conditions), gender, gender identity, gender expression, sexual orientation, marital status, military or veteran status, national origin, ancestry, familial status, source of income, disability, and genetic information, or because another person perceives the tenant or applicant to have one or more of these characteristics. * Unruh Civil Rights Act (Civ. Code, § 51) prohibits business establishments in California from discriminating in the provision of services, accommodations, advantages, facilities and privileges to clients, patrons and customers because of their sex, race, color, religion, ancestry, national origin, disability, medical condition, genetic information, marital status, sexual orientation, citizenship, primary language, or immigration status. APPENDIX 1E: CITY OF FRESNO * **Ralph Civil Rights Act (Civ. Code, § 51.7)** guarantees the right of all persons within California to be free from any violence, or intimidation by threat of violence, committed against their persons or property because of political affiliation, or on account of sex, race, color, religion, ancestry, national origin, disability, medical condition, genetic information, marital status, sexual orientation, citizenship, primary language, immigration status, or position in a labor dispute, or because another person perceives them to have one or more of these characteristics. The City enforces fair housing and complies with fair housing laws and regulation through a twofold process: review of local policies and code for compliance with state law and the referral of fair housing complaints for investigation and resolution by the regional fair housing provider. Table 1E-3.16 demonstrates the City’s compliance with fair housing laws and other related laws. In Fresno and Fresno County, local housing, social services, and legal service organizations include the Fair Housing Council of Central California, Central California Legal Services, California Rural Legal Services, and the Leadership Counsel for Justice and Accountability. A summary of each organization’s focus is included in Table 1E-3.17. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-127 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Table 1E-3.16: City of Fresno Compliance with Fair Housing Laws | State Law/ Requirement | Description of Compliance | | :--- | :--- | | **Housing Accountability Act and Housing Crisis Act.** The Housing Accountability Act (Government Code Section 65589.5) limits the ability of a local government to deny, reduce the density of, or make infeasible housing development projects, emergency shelters, or farmworker housing that are consistent with objective local development standards and contribute to meeting housing need. The Housing Crisis Act of 2019, commonly known as Senate Bill 330 (SB 330) expedites permit processing for housing projects and restricts local governments’ ability to downzone and limits fee increases on housing applications. | The City complies with the Housing Accountability Act and the Housing Crisis Act in reviewing and approving projects. The City has taken steps to facilitate housing in mixed use zones by removing maximum densities and adopting objective standards. Currently (2023), the City offers an optional preliminary application checklist for all entitlement applications to advise a prospective applicant of current City standards and requirements. Pre-application meetings have helped to shorten the review process and allow for better communication between applicants, City departments, and utility providers. The City has not yet developed an SB 330 preliminary application form, however it does enforce SB 330. The Housing Element includes a program to establish such an application to streamline processing procedures. The City complies with regulations set forth in state law for processing preliminary application for housing development projects, conducting no more than five hearings for housing projects that comply with objective general plan and development standards, and making a decision on a residential project within 90 days after certification of an environmental impact report, or 60 days after adoption of a mitigated negative declaration or an environmental report for an affordable housing project. The Housing Element includes a program to further review and amend site development and design standards in the Development Code for residential and mixed use zones to ensure standards are clear and objective (**Program 6 – Objective Design Standards**). | | **Density Bonus.** State Density Bonus Law (Gov. Code Section 65915-65918) allows developers to increase density on a property above the maximum set under a jurisdiction’s General Plan land use plan if specific conditions are met. | The City complies with State density bonus law. The City has included **Program 25** (Development Code Amendments for Compliance with State Law and to Reduce Barriers to Housing Development) to amend the ordinance to be consistent with the most recent changes in state law and to continue to monitor density bonus law to make further modifications as needed. | | **No-Net-Loss.** No Net Loss Law (Gov. Code Section 65863) requires a jurisdiction to always maintain a sufficient supply of adequate sites in its housing element throughout the housing element planning period to meet a jurisdiction’s remaining unmet share of the Regional Housing Needs Allocation (RHNA) for each income category. | The City will continue to comply with No-Net-Loss through identifying a surplus of sites available to meet the RHNA allocation and tracking the remaining capacity as projects are approved on sites in the inventory (**Program 1**). | | **Least Cost Zoning Law.** Gov. Code Section 65913.1 establishes a duty for local governments to designate and zone sufficient vacant land for residential use with appropriate standards. "Appropriate standards" means densities and requirements with respect to minimum floor areas, building setbacks, rear and side yards, parking, the percentage of a lot that may be occupied by a structure, amenities, and other requirements | The City conducted a comprehensive inventory of all vacant and non-vacant developable land within city limits, demonstrating that there is enough housing capacity to meet RHNA targets within the Housing Element planning period. By designating and zoning this land with appropriate standards, Fresno ensures the economic feasibility of producing housing at the lowest possible cost while balancing economic and environmental factors and maintaining public health and safety. | | State Law/ Requirement | Description of Compliance | | :--- | :--- | | imposed on residential lots pursuant to the zoning authority which contribute to the economic feasibility of producing housing at the lowest possible cost given economic and environmental factors, the public health and safety. | | | **Fair Housing Law / Discrimination in Land Use.** Government Code Section 65008 prohibits actions by a local government that deny residence, tenancy or ownership based on familial status or method of financing for proposed developments or intended occupancy of developments by persons of very low, low, moderate or middle-income. | The City complies with Government Code Section 65008. In addition, the Housing Element includes strategies to affirmatively further the objectives of fair housing law. Strategies include enforcing source of income protection and providing education to property owners on laws prohibiting the ability to refuse to rent to an applicant based on their source of income (**Program 20**); referring discrimination to appropriate State and Federal enforcement agencies (**Program 26**); and working to mitigate impediments to fair housing opportunities, with an emphasis on supporting the needs of populations and neighborhoods most impacted by fair housing issues (**Program 27**). | | **Anti-Discrimination.** California Government Code Section 11135 prohibits discrimination on the basis of sex, race, color, religion, ancestry, national origin, ethnic group identification, age, mental disability, physical disability, medical condition, genetic information, marital status, or sexual orientation, and provides protection from discrimination from any program or activity that is conducted, funded directly by, or receives any financial assistance from the State. | The City of Fresno recognizes the rights of all its residents, workers, and visitors, including the right to reside, work, and visit. No discrimination shall be exercised, threatened or promised by any person in the employ of the city against or in favor of any applicant, eligible or employee because of any classification protected by state or federal law. | | **Local Fair Housing Enforcement** | | | **Eviction Protection Program.** The Eviction Protection Program (EPP) is a local program which defends tenants renting an apartment or house in the City of Fresno from unlawful eviction. If the City determines a tenant is potentially facing unlawful eviction, the tenant may be eligible to receive a City-appointed attorney or legal services to assist in the judicial process at no charge. This program is open to any City of Fresno resident who is facing an unlawful eviction regardless of financial or documented status. | | | **Emergency Rental Assistance Program.** In response to the impacts of COVID-19, the City received nearly $64 million for emergency rental assistance from state and federal governments. The Emergency Rental Assistance Program provides relief to lower-income renters and landlords that were negatively impacted by COVID-19 and were unable to pay their rent and utilities. As of 2023, the City of Fresno’s Emergency Rental Assistance Program has distributed all available funding and the program is now closed. | | | **Mobile Home Park Rent Review and Stabilization Program.** Adopted in 1987, the purpose of this program is to protect mobile home park residents from excessive rent increases while at the same time providing mobile home park owners a level of rent sufficient to provide a just, fair and reasonable return on their investment in mobile home park property and to cover increased costs of repairs, maintenance, rehabilitation, capital improvements, services, amenities, upkeep and insurance. The ordinance provides a structure for consideration of proposed mobile home park rent increases through resident’s committees and a Mobile Home Park Rent Review and Stabilization Commission. See Fresno Municipal Code Article 20 for more information. | | *Source: City of Fresno, 2024.* SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Table 1E-3.17: Fair Housing Advocacy Organizations, Fresno County | Organization | Focus Area | | :--- | :--- | | Fair Housing Council of Central California | The Fair Housing Council of Central California is a professional, non-profit, civil rights organization dedicated to the elimination of discrimination in housing and the expansion of housing opportunities for all persons. The Fair Housing Council accomplishes its goal through the advocacy of equal housing opportunities, assisting victims of housing discrimination and enforcing compliance with fair housing laws, including the Community Reinvestment Act and the Equal Credit Opportunity Act. It provides a multifaceted program of private enforcement, education and outreach, research and advocacy to affirmatively further the goal of equal housing opportunity in the San Joaquin Valley | | Central California Legal Services | Central California Legal Services Inc. is a private, not-for-profit, public interest law firm established for the purpose of providing free civil legal assistance to low-income individuals, families, organizations, and communities. | | California Rural Legal Services | California Rural Legal Services, Inc. (CRLA) is a nonprofit law firm serving low-income residents of California's rural areas and small cities. | | Community Housing Council of Fresno | Community Housing Council of Fresno (CHC) is a nonprofit organization which provides first time homebuyer assistance, counseling and other assistance to home buyers and owners who are struggling with their mortgage obligations. | | Leadership Counsel for Justice and Accountability | The Leadership Counsel for Justice and Accountability (Leadership Counsel) advocates at the local, regional, and statewide levels on the overlapping issues of land use, transportation, climate change, safe and affordable drinking water, housing, environmental justice, equitable investment, and government accountability. Based in the San Joaquin and Eastern Coachella Valleys, Leadership Counsel services include community organizing, research, legal representation, and policy advocacy. | | Resources for Independence Central Valley | Resources for Independence, Central Valley is 1 of 28 Centers for Independent Living in California. Independent Living Centers, like Resources for Independence Central Valley, are community-benefit, nonprofit organization run by and for persons with disabilities. Both the staff and board of directors must consist of at least 51 percent persons with disabilities. As a hub for independent living services and disability resources, Resources for Independence, Central Valley provides a foundation of core consumer-controlled, community-based, cross-disability and person-focused programs and assistance. | | Central Valley Regional Center | Central Valley Regional Center is 1 of 21 regional centers in the State of California. Each regional center is a private non-profit entity on contract with California’s Department of Developmental Services (DDS). The Center’s mission is to help families and individuals with developmental disabilities. | Source: City of Fresno, Ascent, 2023. APPENDIX 1E: CITY OF FRESNO ## Fair Housing Complaints The City complies with federal and state fair housing laws, which are enforced by HUD and the California Department of Fair Employment and Housing (DFEH). Both the City and Fresno County refer discrimination complaints to FEH, which dual files fair housing cases with HUD’s Region IX Office of Fair Housing and Equal Opportunity (FHEO), as part of the Fair Housing Assistance Program. In Fresno County, the most common types of housing discrimination complaints between 2006 and 2020 were discrimination on the basis of disability or race (see Table 1E-3.18). Table 1E-3.18: Housing Discrimination Complaints Filed with HUD, Fresno County, 2006-2020 | Basis of Complaint | Number of Complaints | | :--- | :--- | | Race | 72 | | Color | 7 | | National origin | 28 | | Disability | 136 | | Familial status | 38 | | Religion | 5 | | Sex | 24 | | Retaliation | 39 | | Total Complaints Filed | 272 | *Source: HUD FHEO 2020.* HUD FHEO reported that there were 150 complaints filed by residents of the City of Fresno between 2015 and 2019. Of the complaints that resulted in a potential case, 76 cases were received and processed by HUD for housing in Fresno. As shown in Table 1E-3.19, disability was cited as the basis of discrimination in 42 cases, followed by race in 25 cases; retaliation in 11 cases; familial status in 9 cases; color in 6 cases; national origin in 5 cases; and sex in 5 cases. More than one basis of discrimination may be cited in a single complaint. Table 1E-3.19: Housing Discrimination Complaints Filed with HUD, City of Fresno, 2015-2019 | Basis of Complaint* | Number of Complaints | | :--- | :--- | | Race | 25 | | Color | 6 | | National origin | 5 | | Disability | 42 | | Familial status | 9 | | Religion | 0 | | Sex | 5 | | Retaliation | 11 | | Total Complaints Filed | 76 | *\*More than one basis of discrimination may be cited in a single complaint.* *Source: 2020 Analysis of Impediments to Fair Housing Choice, City of Fresno.* SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING The City contracts with local fair housing service providers to support enforcement of State and federal Fair Housing Laws and provide fair housing services that include, but are not limited to, the following fair housing services: * Referring inquiries and landlord/tenant complaints concerning housing discrimination to the applicable regulatory body (State Department of Fair Employment and Housing, HUD, or private counsel) for processing; * Disseminating fair housing information citywide by sponsoring workshops, housing information fairs, monitoring of affirmative marketing, and working closely with the State Department of Fair Employment and Housing; * Advertising fair housing laws and complaint procedures through literature displays at City and County offices, non-profit organizations such as Central California Legal Services, Lao Family Organization, Fresno Interdenominational Refugee Ministries, Central Valley Regional Center, property management organizations, lenders, and other such organizations. Literature is provided in English, Spanish, Hmong, Cambodian, Vietnamese, and Lao; and, * Disseminating fair housing information through radio, television, and other media. From 2016 to 2020, the City made annual CDBG contributions to the Fair Housing Council of Central California (FHCCC) for education, complaint, and referral services. During this time, FHCC addressed an average of 800 fair housing complaints per year. Table 1E-3.20 displays the cases that were opened by FHCCC for further investigation and/or referral for relief. A small percentage of complaints were referred to HUD for administrative or injunctive relief. FHCCC’s work often results in referral of cases to attorneys for further action or direct assistance to complainants. For example, FHCCC was able to cause reasonable accommodations to be provided that had initially been denied in several apartment complexes in Fresno. Table 1E-3.20: Fair Housing Cases Opened by FHCCC, City of Fresno, 2017-2020 | Discrimination Complaints (Protected Basis) | 2017 | 2018 | 2019 | 2020 | | :--- | :--- | :--- | :--- | :--- | | Race | 35 | 78 | 65 | 28 | | Religion | 2 | 0 | - | 2 | | Color | 30 | 76 | 64 | 30 | | Sex/Gender | 7 | 6 | 5 | 2 | | Disability | 47 | 50 | 76 | 32 | | Familial Status | 25 | 10 | 14 | 9 | | National Origin | 8 | 56 | 31 | 3 | | Other State Violations (FEHA, Unruh, Ralph Civil Rights) | 11 | 11 | 20 | 7 | | Total | 165 | 287 | 275 | 116 | Source: City of Fresno, Fair Housing Council of Central California Reports, 2017-2019 APPENDIX 1E: CITY OF FRESNO In 2021, CCLS received approximately 70 complaints of housing discrimination during the reporting period and made referrals, as appropriate, see Table 1E-3.21. Table 1E-3.21: Discrimination Complaints, City of Fresno (March 1 – August 30, 2021) | Discrimination Complaints (Protected Basis) | Number of Complaints | Discrimination Complaints (Issue/Type) | Number of Complaints | | :--- | :--- | :--- | :--- | | Race | 16 | Rental | 25 | | Religion | 0 | Sales | 0 | | Color | 4 | Advertisement | 0 | | Sex/Gender | 7 | Lending/Redlining | 0 | | Handicap | 2 | Zoning | 0 | | Familial Status | 0 | Accessibility | 0 | | National Origin | 3 | Terms/Conditions | 4 | | Other State Violations (FEHA, Unruh, Ralph Civil Rights) | 4 | Harassment | 5 | | **Total** | **36** | **Total** | **34** | *Source: City of Fresno, 2023. Central California Legal Services Quarterly Reports, 2021.* Since July 2021, the City has contracted with other service providers to provide various fair housing services including the Fresno Interdenominational Refugee Ministries (FIRM), Resources for Independence Central Valley, Inc. (RICV), Central California Legal Services (CCLS), and the Community Housing Council of Fresno. Through FIRM, in 2023-24, the City provided public Fair Housing education and outreach to 13,007 persons or households through webinars, in-person outreach events, ethnic media, and informational resource distribution both city-wide and by targeted canvassing (e.g., dropping materials off at relevant agencies and organizations). Outreach materials were distributed in five languages throughout areas where low-income Southeast Asian, Spanish, and Arabic-speaking communities congregate, including zip codes 93702, 93722, 93727, 93703, and 93725. RICV also worked on an outreach and education program for vulnerable populations in the city with specific emphasis on easy-to-understand information on housing rights, housing discrimination, housing resources and subsidies, and overall fair housing issues. Training and materials were made available through social media, direct mail, the RICV newsletter, and email blasts. RICV also distributed an easy-to-understand booklet to 217 low-income individuals through individual outreach. The City works with Central California Legal Services (CCLS) to refer inquiries and landlord/tenant complaints; and the Community Housing Council of Fresno to conduct fair housing workshops for prospective homebuyers and real estate/finance professionals. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Outreach Effectiveness Outreach reached significantly more persons and households from the prior year (13,007 households in 2024 compared to 3,700 households in 2023). The zip codes where the outreach was conducted included portions of the central, southeast, and northwest portions of the City. Downtown (93721) Southwest Fresno (93706) areas were harder to document due to difficulty in securing trusted locations (usually markets and bakeries) and participants who decline to share their demographic information, but these areas also house populations that may be vulnerable to fair housing issues. Tables 1E – 3.3 Racial Segregation by Census Tract and 1E-3.7, Distribution of Poverty, show high concentrations of people of color and over 40 percent of households living in poverty in the Downtown and Southwest areas of Fresno. In addition, Table 1E-3.10 shows a high percentage of population with a disability in these areas. Program 26, Fair Housing, includes strengthened language to ensure fair housing outreach is conducted in all neighborhoods of high need. ### Fair Housing Testing FHCCC conducted a Systemic Testing project in Fresno. The target area was all available new home developments on the basis of race and familial status. During PY 2019, 16 paired tests (32 tests) were completed. 5 paired tests were conducted on the basis of race and 11 paired tests were conducted on the basis of familial status. All testing was done according to the available rental market. Testing at 25 properties were located within the metropolitan area with most of the area zip codes. Results showed that people of color suffered some form of housing discrimination in new developments across the city 48 percent of the time (i.e., refusal to rent, lying about availability, or imposing different rules, terms, or conditions of tenancy). The Housing Element includes a program committing the City to continue working with local fair housing providers to ensure residents and landlords are aware of fair housing laws, rights, and requirements. Through this action, the City will ensure resources are accessible to residents should they experience discrimination. ### Fair Housing Lawsuits Several noteworthy lawsuits have been litigated during the previous Housing Element planning period regarding alleged housing discrimination practices affecting fair and affordable housing in Fresno or the region: a HUD negotiated settlement targeting unfair lending practices by California mortgage lenders and two state court lawsuits against local jurisdictions seeking to compel compliance with their obligations under their respective General Plans and Housing Elements to provide affordable housing and services to disadvantaged groups. ### [Redacted] v. Benchmark Communities, LLC, FHEO Case No. 09-16-5484-8 (Title VIII) (HUD Conciliation Agreement entered March 7, 2017). HUD facilitated a settlement agreement resolving accusations of unfair lending practices between a complainant and three California mortgage lenders, American Financial Network of Brea in Orange County, Benchmark Communities of Fresno, Brigantino Enterprise of Hollister, and also a Benchmark employee. The complainant filed a housing discrimination complaint with the FHEO in 2016 alleging he was unfairly denied an opportunity to pre-qualify for a mortgage loan based on his perceived Hispanic national origin, which precluded him from purchasing a home in Hollister. Equal access to credit for APPENDIX 1E: CITY OF FRESNO qualified individuals, regardless of their national origin or other protected status, is an important element of fair housing. Benchmark agreed to provide annual fair housing training to employees who interact with prospective homebuyers. American Financial agreed to train current and new employees and pay the complainant $5,000 in damages. ### Comunidades Unidas por un Cambio v. County of Fresno, Case Number 18CECG04586 (Fresno County Sup. Ct., file date Dec. 28, 2018). In 2018, Comunidades Unidas por un Cambio (Communities United for Change) with the assistance of nonprofit Leadership Counsel for Justice & Accountability, filed an action against Fresno County and its Board of Supervisors seeking to enforce the County’s obligations under its General Plan and Housing Element to facilitate the development and maintenance of affordable housing and to address the needs of disadvantaged unincorporated communities (specifically for clean water and functioning sewer services, stormwater drainage, and other infrastructure). The lawsuit outlines multiple deadlines the County has missed for accommodating affordable housing and improving infrastructure and other needs in historically disadvantaged communities. Plaintiffs allege that the County’s failure to comply disproportionately impacts Latinos and other minority groups and deprives them of the opportunity to live in decent, quality affordable housing and healthy and complete neighborhoods. The County asserted that it is currently in the midst of a revision and update to the General Plan that will include elements that address some of the purported concerns of the Plaintiffs. The County also contends that Plaintiffs’ suit is premature because the County should be given more time to complete the action items and programs identified in its General Plan, and also argues that the deadlines and HCD guidelines that Plaintiffs claim the County has failed to meet are nonbinding. In 2020, the Superior Court ruled in favor of the plaintiff, and issued a Preemptory Writ of Mandate ordering the County to implement several specific programs of the Housing Element and bring the General Plan into compliance by analyzing infrastructure needs in historically disadvantaged communities. Comunidades Unidas waived the other allegations of housing discrimination in violation of FEHA and discriminatory land use actions in violation of state law. ### Martinez v. City of Clovis, Case Number 19CECG03855 (Fresno County Sup. Ct., file date Oct. 23, 2019). In 2019, Central California Legal Services (CCLS), on behalf of local citizens, filed suit in the Fresno County Superior Court against the City of Clovis alleging that the City’s Housing Element was out of compliance with state law by failing to meet a commitment in the 2016 Housing Element to provide an adequate supply of suitably zoned land for lower-income housing development. The complaint also alleged that the inadequate supply of land zoned for affordable housing is discriminatory towards people based on race and income, in violation of both federal fair housing law and state law. The Superior Court ruled in favor of the plaintiff, finding that the City’s application of a zoning overlay for affordable high-density housing does not sufficiently meet the City’s obligation to provide suitably zoned land for housing affordable to lower-income households. The Court, however, did not find that the City’s housing policy violated federal fair housing law or that its actions were discriminatory. The City contended that its Housing Element was in full compliance with all regulations governing affordable housing. The City appealed, and FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-135 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING in April 2023, the appellate court upheld the zoning inadequacy ruling but remanded discrimination claims for further proceedings. The California Supreme Court denied the City’s petition for review in July 2023. A settlement was reached on February 20, 2024, in which the City agreed to implement several actions to facilitate affordable housing. ### HCD Technical Assistance Letter The City of Fresno is in receipt of a letter of Technical Assistance from the Department of Housing and Community Development dated August 7, 2024 noting the City Council’s vote to decline funds for Fresno’s Quality Inn Homekey project. The Technical Assistance letter analyzed the impact of this action in relation to the City’s obligation to Affirmatively Further Fair Housing and requested that the City strengthen program commitments to discourage similar decisions in the future. A requirement has been added to Program 2-Variety of Housing Opportunities in High Resource Areas to include in project approval documents a statement of the City’s obligation to Affirmatively Further Fair Housing and an accompanying analysis of project consistency with the law. ### Housing Sites Analysis State housing element law, Government Code Section 65583(c)(10), requires that the sites inventory (see Section 1E-2) be analyzed with respect to AFFH to ensure that affordable housing is dispersed equitably throughout the city rather than concentrated in areas of high segregation and poverty or low resource areas that have historically been underserved. By comparing the sites inventory to the fair housing indicators in this assessment, this section analyzes whether the sites included in the Housing Element sites inventory improve or exacerbate fair housing conditions, patterns of segregation, and access to opportunity throughout the city. As determined by the Fresno Council of Governments (FCOG), the City of Fresno’s Regional Housing Needs Allocation (RHNA) is a total of 36,866 new housing units. This RHNA includes 9,440 very low-income units, 5,884 low-, 5,638 moderate-, and 15,904 above moderate-income units. Note that the City’s extremely low-income RHNA is equal to 50 percent of the very low-income RHNA allocation (4,720 units). Within the city limits, available vacant and underutilized sites are adequate to accommodate the RHNA for all income categories. A summary of Fresno’s ability to meet the 2023-2031 RHNA of 36,866 housing units is provided in Section 1E-2: Sites Inventory. Using data and research from the HCD AFFH Data and Mapping Tool 1.0, Table 1E-3.22 presents the housing unit capacity and existing conditions as they relate to indicators of fair housing analyzed in this assessment for each census tract in the city. For more information about the indicators, refer to the local assessment discussed previously in this chapter. APPENDIX 1E: CITY OF FRESNO ### Table 1E-3.22: Housing Capacity by Census Tract, City of Fresno, 2023-2031 | Census Tracts | Existing Households | Housing Capacity | | | | | Patterns of Segregation | | | Access to Opportunity | | | | Disproportionate Housing Needs/ Displacement Risk | | | | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | Low | Mod | Above Mod | Total | %of Total | Population Majority | Median Income | Disability Rates | R/ECAP or RCAA | TCAC Score | Jobs Index | CES4 Scores | SB 35 DAC | Overcrowding | Overpayment (Renters) | Overpayment (Homeowners) | Displacement Risk | | 1.00 | 804 | 685 | 206 | 400 | 1,291 | 3.0% | Hispanic/Latino | <$55,000 | <30% | R/ECAP | No Data | >80 | >90-100 | DAC | <8.2% | 40%-60% | No Data | Y | | 2.00 | 728 | 471 | 0 | 140 | 610 | 1.4% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | >80 | >90-100 | DAC | 15%-20% | 40%-60% | 20%-40% | Y | | 3.00 | 1,103 | 667 | 97 | 539 | 1,303 | 3.0% | Hispanic/Latino | <$55,000 | 20%-30% | R/ECAP | HSR | >80 | >90-100 | DAC | 15%-20% | 40%-60% | 20%-40% | Y | | 4.00 | 1,337 | 781 | 0 | 418 | 1,199 | 2.8% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | >80 | >90-100 | DAC | >20% | 40%-60% | <20% | Y | | 5.01 | 829 | 18 | 0 | 18 | 35 | 0.1% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | >80 | >90-100 | DAC | >20% | 60%-80% | 60%-80% | Y | | 5.02 | 1,019 | 141 | 0 | 174 | 315 | 0.7% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | >80 | >90-100 | DAC | >20% | 40%-60% | <20% | Y | | 6.01 | 1,763 | 0 | 0 | 219 | 219 | 0.5% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | >80 | >90-100 | DAC | >20% | 40%-60% | 60%-80% | Y | | 6.02 | 366 | 625 | 0 | 389 | 1,014 | 2.3% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | >80 | >90-100 | DAC | >20% | 40%-60% | 60%-80% | Y | | 7.01 | 785 | 47 | 0 | 25 | 72 | 0.2% | Hispanic/Latino | No Data | 20%-30% | | HSR | >80 | >90-100 | DAC | 12%-15% | 40%-60% | 60%-80% | Y | | 7.02 | 426 | 778 | 0 | 1,633 | 2,410 | 5.5% | Hispanic/Latino | <$55,000 | 20%-30% | | HSR | >80 | >90-100 | DAC | 12%-15% | 40%-60% | 60%-80% | Y | | 9.01 | 760 | 547 | 0 | 619 | 1,166 | 2.7% | Hispanic/Latino | <$55,000 | 10%-20% | | HSR | >80 | >90-100 | DAC | 12%-15% | 40%-60% | 20%-40% | Y | | 9.02 | 1,578 | 468 | 0 | 317 | 785 | 1.8% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | >80 | >90-100 | DAC | >20% | 60%-80% | 60%-80% | Y | | 10.00 | 1,179 | 179 | 273 | 625 | 1,078 | 2.5% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | >80 | >90-100 | DAC | 15%-20% | 60%-80% | 60%-80% | Y | | 11.00 | 754 | 41 | 0 | 161 | 202 | 0.5% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | >80 | >90-100 | DAC | >20% | 40%-60% | 60%-80% | Y | | 12.01 | 1,387 | 0 | 0 | 59 | 59 | 0.1% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | 60-80 | >90-100 | DAC | >20% | 40%-60% | 20%-40% | Y | | 12.02 | 1,147 | 0 | 75 | 328 | 403 | 0.9% | Hispanic/Latino | <$55,000 | 10%-20% | | Low | 40-80 | >90-100 | DAC | 15%-20% | 40%-60% | 40%-60% | Y | | 13.01 | 1,521 | 109 | 12 | 72 | 192 | 0.4% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | Low | 20-80 | >90-100 | DAC | 15%-20% | 60%-80% | 40%-60% | Y | | 13.03 | 613 | 0 | 6 | 2 | 8 | 0.0% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | 60-80 | >90-100 | DAC | >20% | 40%-60% | <20% | Y | | 13.04 | 1,475 | 0 | 44 | 43 | 87 | 0.2% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | 40-60 | >90-100 | DAC | >20% | 40%-60% | 60%-80% | Y | | 14.07 | 1,526 | 117 | 4 | 21 | 142 | 0.3% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | 20-40 | >80-90 | DAC | 12%-15% | 60%-80% | 40%-60% | Y | | 14.08 | 1,082 | 0 | 0 | 3 | 3 | 0.0% | White | $55,001-$87,100 | <30% | | Moderate | 20-40 | >60-70 | DAC | <8.2% | 40%-60% | 20%-40% | Y | | 14.09 | 660 | 0 | 8 | 9 | 17 | 0.0% | White | $87,101-$99,999 | 10%-20% | RCAA | High | 20-40 | >50-60 | | <8.2% | <20% | 20%-40% | | | 14.11 | 2,099 | 403 | 240 | 70 | 712 | 1.6% | Hispanic/Latino | $55,001-$87,100 | 10%-20% | | High | 20-60 | >80-90 | DAC | 15%-20% | 40%-60% | 20%-40% | Y | | 14.12 | 755 | 0 | 0 | 162 | 162 | 0.4% | White | $55,001-$87,100 | 10%-20% | | High | 20-40 | >60-70 | | <8.2% | 40%-60% | 20%-40% | | | 14.13 | 1,846 | 42 | 0 | 39 | 81 | 0.2% | Hispanic/Latino | $87,101-$99,999 | <10% | | High | <20 | >60-70 | DAC | <8.2% | 40%-60% | 20%-40% | | | 14.15 | 1,481 | 0 | 121 | 751 | 872 | 2.0% | Hispanic/Latino | $55,001-$87,100 | 10%-20% | | Low | 20-60 | >80-90 | DAC | 12%-15% | 40%-60% | 20%-40% | | | 14.16 | 1,271 | 0 | 396 | 176 | 572 | 1.3% | Hispanic/Latino | $55,001-$87,100 | 10%-20% | | Low | 20-40 | >80-90 | DAC | 12%-15% | 40%-60% | 20%-40% | | | 14.17 | 1,684 | 77 | 0 | 282 | 359 | 0.8% | Hispanic/Latino | $100,000-$149,999 | 10%-20% | | High | <20 | >70-80 | | 8.3-12% | 40%-60% | 20%-40% | | | 14.18 | 731 | 1,005 | 0 | 26 | 1,031 | 2.4% | Hispanic/Latino | $100,000-$149,999 | 10%-20% | | High | <20 | >70-80 | | 8.3-12% | 60%-80% | 20%-40% | | | 15.00 | 627 | 0 | 0 | 0 | 0 | 0.0% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | Low | >80 | >90-100 | DAC | <8.2% | 40%-60% | 40%-60% | Y | | 18.00 | 1,299 | 0 | 0 | 0 | 0 | 0.0% | Hispanic/Latino | <$55,000 | 10%-20% | | Low | >80 | >90-100 | DAC | 8.3-12% | 20%-40% | 20%-40% | | | 20.00 | 1,969 | 906 | 1 | 195 | 1,102 | 2.5% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | <20-80 | >90-100 | DAC | 12%-15% | 40%-60% | 60%-80% | Y | | 21.00 | 2,080 | 0 | 2 | 27 | 29 | 0.1% | Hispanic/Latino | $55,001-$87,100 | 10%-20% | | Low | 40-80 | >90-100 | DAC | 8.3-12% | 40%-60% | 20%-40% | Y | | 22.00 | 1,490 | 0 | 0 | 64 | 64 | 0.1% | Hispanic/Latino | <$55,000 | 10%-20% | | Moderate | 40-80 | >80-90 | DAC | <8.2% | 40%-60% | 40%-60% | Y | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-137 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING | Census Tracts | Existing Households | Housing Capacity | | | | Patterns of Segregation | | | Access to Opportunity | | | | Disproportionate Housing Needs/ Displacement Risk | | | | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | Low | Mod | Above Mod | Total | %of Total | Population Majority | Median Income | Disability Rates | R/ECAP or RCAA | TCAC Score | Jobs Index | CES4 Scores | SB 35 DAC | Overcrowding | Overpayment (Renters) | Overpayment (Homeowners) | Displacement Risk | | 23.00 | 1,299 | 71 | 0 | 120 | 191 | 0.4% | Hispanic/Latino | <$55,000 | 10%-20% | | HSR | 60->80 | >90-100 | DAC | 8.3-12% | 60%-80% | 40%-60% | Y | | 24.00 | 1,474 | 33 | 50 | 32 | 115 | 0.3% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | 60->80 | >90-100 | DAC | 12%-15% | 60%-80% | 40%-60% | Y | | 25.01 | 1,214 | 0 | 0 | 41 | 41 | 0.1% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | 20-60 | >90-100 | DAC | 15%-20% | 60%-80% | 20%-40% | Y | | 25.02 | 1,233 | 0 | 13 | 50 | 63 | 0.1% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | 40-80 | >90-100 | DAC | >20% | 60%-80% | 40%-60% | Y | | 26.01 | 1,380 | 36 | 0 | 33 | 69 | 0.2% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | 40-<80 | >90-100 | DAC | 15%-20% | 60%-80% | 20%-40% | Y | | 26.02 | 990 | 0 | 0 | 31 | 31 | 0.1% | Hispanic/Latino | <$55,000 | 10%-20% | | Moderate | 60->80 | >90-100 | DAC | 8.3-12% | 60%-80% | 20%-40% | Y | | 27.01 | 1,300 | 0 | 0 | 60 | 60 | 0.1% | Hispanic/Latino | <$55,000 | 10%-20% | | HSR | 20-40 | >80-90 | DAC | 15%-20% | 60%-80% | 40%-60% | Y | | 27.02 | 1,272 | 21 | 0 | 66 | 86 | 0.2% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | 20-40 | >90-100 | DAC | >20% | 60%-80% | 40%-60% | Y | | 28.00 | 1,356 | 351 | 7 | 61 | 419 | 1.0% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | 20-40 | >90-100 | DAC | >20% | 60%-80% | 40%-60% | Y | | 29.03 | 1,206 | 130 | 70 | 99 | 299 | 0.7% | Hispanic/Latino | <$55,000 | 20%-30% | R/ECAP | HSR | 20-40 | >80-90 | DAC | >20% | 60%-80% | 20%-40% | Y | | 29.04 | 860 | 0 | 0 | 5 | 5 | 0.0% | Hispanic/Latino | <$55,000 | 10%-20% | | Low | 20-40 | >70-80 | DAC | 8.3-12% | 60%-80% | 20%-40% | Y | | 29.05 | 888 | 0 | 0 | 9 | 9 | 0.0% | Hispanic/Latino | <$55,000 | 10%-20% | | HSR | 20-60 | >80-90 | DAC | <8.2% | 40%-60% | 20%-40% | Y | | 29.06 | 1,583 | 0 | 0 | 0 | 0 | 0.0% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | Moderate | 40-80 | >70-80 | DAC | >20% | 40%-60% | 20%-40% | Y | | 30.01 | 916 | 503 | 57 | 3 | 562 | 1.3% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | Low | 40-60 | >90-100 | DAC | 15%-20% | 60%-80% | 20%-40% | Y | | 30.03 | 1,083 | 256 | 0 | 3 | 259 | 0.6% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | 20-40 | >80-90 | DAC | 15%-20% | 60%-80% | 20%-40% | Y | | 30.04 | 650 | 116 | 19 | 20 | 155 | 0.4% | Hispanic/Latino | $55,001-$87,100 | 20%-30% | | Moderate | 20-40 | >70-80 | DAC | <8.2% | 40%-60% | 20%-40% | Y | | 31.04 | 1,679 | 0 | 0 | 0 | 0 | 0.0% | White | $55,001-$87,100 | 10%-20% | | High | 60-80 | >60-70 | | <8.2% | 20%-40% | 40%-60% | Y | | 32.01 | 1,708 | 0 | 6 | 1 | 7 | 0.0% | Hispanic/Latino | $55,001-$87,100 | 10%-20% | | Low | 20-60 | >90-100 | DAC | 12%-15% | 40%-60% | 20%-40% | Y | | 32.02 | 1,581 | 0 | 4 | 0 | 4 | 0.0% | Hispanic/Latino | <$55,000 | 10%-20% | | HSR | 20-60 | >90-100 | DAC | >20% | 60%-80% | 20%-40% | Y | | 33.01 | 1,138 | 224 | 0 | 0 | 224 | 0.5% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | Moderate | 20-40 | >80-90 | DAC | 15%-20% | 60%-80% | 40%-60% | Y | | 33.02 | 1,668 | 0 | 0 | 2 | 2 | 0.0% | Hispanic/Latino | $55,001-$87,100 | 10%-20% | | Moderate | 20-40 | >80-90 | DAC | 8.3-12% | 40%-60% | <20% | Y | | 34.01 | 1,109 | 0 | 0 | 5 | 5 | 0.0% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | 40-60 | >90-100 | DAC | 8.3-12% | 60%-80% | 20%-40% | Y | | 34.02 | 710 | 0 | 0 | 5 | 5 | 0.0% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | 40-60 | >90-100 | DAC | 8.3-12% | 60%-80% | 20%-40% | Y | | 35.00 | 2,183 | 142 | 16 | 18 | 176 | 0.4% | Hispanic/Latino | $55,001-$87,100 | 20%-30% | R/ECAP | Moderate | 20-60 | >80-90 | DAC | 8.3-12% | 60%-80% | 20%-40% | Y | | 36.00 | 1,820 | 0 | 0 | 9 | 9 | 0.0% | White | $55,001-$87,100 | 10%-20% | | High | 20-60 | >40-50 | | <8.2% | 20%-40% | 20%-40% | | | 37.01 | 1,026 | 0 | 0 | 4 | 4 | 0.0% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | Low | 20-40 | >80-90 | DAC | 12%-15% | 40%-60% | 20%-40% | | | 37.02 | 1,671 | 0 | 23 | 0 | 23 | 0.1% | Hispanic/Latino | <$55,000 | 10%-20% | | HSR | <20-60 | >90-100 | DAC | 8.3-12% | 40%-60% | 40%-60% | Y | | 38.04 | 1,704 | 0 | 0 | 136 | 136 | 0.3% | Hispanic/Latino | $55,001-$87,100 | 10%-20% | | Moderate | <20 | >60-70 | DAC | 8.3-12% | 40%-60% | 20%-40% | | | 38.05 | 2,095 | 83 | 197 | 130 | 410 | 0.9% | Hispanic/Latino | <$55,000 | 10%-20% | | Low | <20-40 | >90-100 | DAC | 12%-15% | 60%-80% | 60%-80% | Y | | 38.07 | 1,056 | 0 | 91 | 155 | 246 | 0.6% | Hispanic/Latino | <$55,000 | 10%-20% | | HSR | <20-60 | >90-100 | DAC | <8.2% | 40%-60% | 20%-40% | Y | | 38.08 | 1,584 | 0 | 0 | 122 | 122 | 0.3% | Hispanic/Latino | $55,001-$87,100 | 10%-20% | | High | <20 | >60-70 | DAC | 12%-15% | 40%-60% | 20%-40% | | | 38.09 | 1,369 | 0 | 521 | 173 | 694 | 1.6% | Hispanic/Latino | <$55,000 | <10% | | Low | 40-80 | >80-90 | DAC | 12%-15% | 40%-60% | 20%-40% | | | 38.10 | 1,787 | 171 | 0 | 157 | 327 | 0.8% | Hispanic/Latino | $55,001-$87,100 | 10%-20% | | High | 20-40 | >60-70 | | 8.3-12% | 40%-60% | 20%-40% | | | 38.11 | 1,979 | 262 | 0 | 58 | 320 | 0.7% | Hispanic/Latino | $55,001-$87,100 | 10%-20% | | High | <20 | >60-70 | DAC | 8.3-12% | >80% | 20%-40% | | | 38.12 | 539 | 525 | 244 | 3,235 | 4,005 | 9.2% | Hispanic/Latino | $100,000-$149,999 | 10%-20% | | High | <20 | >60-70 | DAC | 8.3-12% | >80% | 20%-40% | | | 42.05 | 1,883 | 430 | 50 | 53 | 532 | 1.2% | Hispanic/Latino | $55,001-$87,100 | 10%-20% | | HSR | 60-80 | >80-90 | DAC | <8.2% | 40%-60% | 20%-40% | Y | APPENDIX 1E: CITY OF FRESNO | Census Tracts | Existing Households | Housing Capacity | | | | % of Total | Population Majority | Median Income | Disability Rates | R/ECAP or RCAA | TCAC Score | Jobs Index | CES4 Scores | SB 35 DAC | Overcrowding | Overpayment (Renters) | Overpayment (Homeowners) | Displacement Risk | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | Low | Mod | Above Mod | Total | | | | | | | | | | | | | | | 42.08 | 2,421 | 0 | 0 | 4 | 4 | 0.0% | White | $87,101-$99,999 | <10% | RCAA | Highest | <20 | >30-40 | | <8.2% | 40%-60% | 20%-40% | | | 42.10 | 1,300 | 0 | 4 | 3 | 7 | 0.0% | White | <$55,000 | 10%-20% | | High | <20-40 | >40-50 | | <8.2% | 40%-60% | 20%-40% | Y | | 42.11 | 2,408 | 0 | 0 | 0 | 0 | 0.0% | White | $55,001-$87,100 | 10%-20% | | High | <20-40 | >60-70 | | <8.2% | 40%-60% | 20%-40% | | | 42.12 | 4,323 | 241 | 109 | 26 | 376 | 0.9% | Hispanic/Latino | $55,001-$87,100 | 10%-20% | | High | 20-80 | >70-80 | DAC | 8.3-12% | 40%-60% | 20%-40% | | | 42.13 | 1,302 | 0 | 0 | 0 | 0 | 0.0% | White | $55,001-$87,100 | 10%-20% | | High | 60-80 | >40-50 | | <8.2% | 40%-60% | 20%-40% | | | 42.14 | 1,932 | 0 | 0 | 4 | 4 | 0.0% | White | $87,101-$99,999 | 20%-30% | | Highest | 20-60 | >20-30 | | <8.2% | 20%-40% | 20%-40% | | | 42.15 | 1,345 | 1,056 | 0 | 15 | 1,070 | 2.5% | White | $55,001-$87,100 | 10%-20% | | High | <20 | >60-70 | | <8.2% | 40%-60% | 20%-40% | | | 42.16 | 1,441 | 0 | 184 | 0 | 184 | 0.4% | White | $55,001-$87,100 | 10%-20% | | High | <20 | >60-70 | DAC | <8.2% | 40%-60% | 20%-40% | | | 42.17 | 987 | 367 | 90 | 96 | 553 | 1.3% | Hispanic/Latino | <$55,000 | 10%-20% | | Moderate | 40-60 | >80-90 | DAC | <8.2% | 40%-60% | 40%-60% | | | 42.18 | 1,853 | 2,032 | 1,937 | 695 | 4,665 | 10.7% | Hispanic/Latino | $87,101-$99,999 | 10%-20% | | Moderate | 20-40 | >80-90 | DAC | <8.2% | >80% | 40%-60% | | | 43.01 | 1,745 | 68 | 0 | 13 | 81 | 0.2% | White | $150,000-$199,999 | 10%-20% | RCAA | Highest | 40-80 | >20-30 | | <8.2% | 20%-40% | 20%-40% | | | 43.02 | 1,897 | 0 | 0 | 0 | 0 | 0.0% | White | $100,000-$149,999 | 10%-20% | RCAA | Highest | 60->80 | >30-40 | | <8.2% | 40%-60% | 20%-40% | | | 43.03 | 1,948 | 0 | 0 | 2 | 2 | 0.0% | White | $87,101-$99,999 | 10%-20% | RCAA | Highest | 60-80 | >30-40 | | <8.2% | 60%-80% | 20%-40% | | | 44.04 | 984 | 342 | 0 | 92 | 434 | 1.0% | Hispanic/Latino | <$55,000 | 10%-20% | | Moderate | >80 | >90-100 | DAC | >20% | 40%-60% | 20%-40% | Y | | 44.05 | 1,363 | 0 | 0 | 0 | 0 | 0.0% | White | $100,000-$149,999 | 10%-20% | RCAA | Highest | 60-80 | >20-30 | | <8.2% | 40%-60% | <20% | | | 44.06 | 2,393 | 0 | 0 | 0 | 0 | 0.0% | White | $55,001-$87,100 | <10% | | Highest | >80 | >30-40 | | <8.2% | 40%-60% | 20%-40% | | | 44.09 | 1,168 | 0 | 0 | 0 | 0 | 0.0% | White | $55,001-$87,100 | 10%-20% | | High | >80 | >60-70 | | <8.2% | 20%-40% | 20%-40% | | | 44.10 | 1,039 | 0 | 0 | 0 | 0 | 0.0% | White | $55,001-$87,100 | <10% | | Highest | >80 | >40-50 | | 8.3-12% | 20%-40% | 20%-40% | | | 44.11 | 777 | 0 | 0 | 66 | 66 | 0.2% | White | $87,101-$99,999 | <10% | | Highest | >80 | >40-50 | | 8.3-12% | 40%-60% | 20%-40% | | | 45.03 | 2,183 | 0 | 35 | 0 | 35 | 0.1% | White | $55,001-$87,100 | 20%-30% | | High | >80 | >50-60 | | <8.2% | 40%-60% | 40%-60% | | | 45.04 | 2,078 | 99 | 0 | 243 | 342 | 0.8% | White | <$55,000 | 10%-20% | | High | >80 | >80-90 | DAC | <8.2% | 40%-60% | 40%-60% | Y | | 45.05 | 2,083 | 836 | 217 | 57 | 1,110 | 2.6% | Hispanic/Latino | $55,001-$87,100 | 10%-20% | R/ECAP | Moderate | 60-80 | >80-90 | DAC | <8.2% | 40%-60% | <20% | Y | | 45.06 | 1,418 | 150 | 0 | 6 | 156 | 0.4% | White | $87,101-$99,999 | 10%-20% | RCAA | Highest | >80 | | | <8.2% | 40%-60% | <20% | | | 46.01 | 1,383 | 19 | 10 | 3 | 32 | 0.1% | White | $55,001-$87,100 | 10%-20% | | High | 40-80 | >40-50 | | <8.2% | 40%-60% | <20% | | | 46.02 | 913 | 59 | 5 | 0 | 64 | 0.1% | White | $87,101-$99,999 | <10% | RCAA | Highest | 60-80 | >40-50 | | <8.2% | 40%-60% | 20%-40% | | | 47.03 | 1,181 | 0 | 0 | 0 | 0 | 0.0% | Hispanic/Latino | <$55,000 | 10%-20% | | Moderate | 20-60 | >70-80 | DAC | <8.2% | 40%-60% | 40%-60% | Y | | 47.04 | 1,515 | 0 | 24 | 63 | 86 | 0.2% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | <20-40 | >80-90 | DAC | >20% | 60%-80% | 20%-40% | Y | | 47.05 | 654 | 0 | 0 | 0 | 0 | 0.0% | Hispanic/Latino | <$55,000 | 10%-20% | | Moderate | 40-80 | >70-80 | DAC | <8.2% | 60%-80% | 20%-40% | Y | | 47.06 | 1,812 | 0 | 0 | 0 | 0 | 0.0% | Hispanic/Latino | <$55,000 | 10%-20% | | Moderate | 40-80 | >70-80 | DAC | <8.2% | 40%-60% | 20%-40% | Y | | 48.01 | 1,791 | 0 | 0 | 0 | 0 | 0.0% | Hispanic/Latino | $55,001-$87,100 | <10% | R/ECAP | HSR | 20-40 | >60-70 | | 12%-15% | 40%-60% | 40%-60% | Y | | 48.02 | 1,441 | 0 | 84 | 0 | 84 | 0.2% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | <20-40 | >70-80 | DAC | 15%-20% | 60%-80% | 40%-60% | Y | | 49.01 | 1,659 | 0 | 12 | 3 | 15 | 0.0% | Hispanic/Latino | $55,001-$87,100 | 10%-20% | | High | 40-60 | >50-60 | | 12%-15% | 40%-60% | 20%-40% | Y | | 49.02 | 735 | 0 | 0 | 0 | 0 | 0.0% | Hispanic/Latino | $55,001-$87,100 | 10%-20% | | High | 40-60 | >40-50 | | 8.3-12% | 40%-60% | 20%-40% | | | 50.00 | 1,518 | 628 | 1 | 16 | 646 | 1.5% | White | $55,001-$87,100 | 10%-20% | | Moderate | 60->80 | >80-90 | DAC | <8.2% | 40%-60% | 20%-40% | | | 51.00 | 2,220 | 32 | 305 | 335 | 672 | 1.5% | Hispanic/Latino | <$55,000 | 10%-20% | | HSR | 40-80 | >90-100 | DAC | <8.2% | 60%-80% | 20%-40% | Y | | 52.02 | 1,139 | 0 | 0 | 0 | 0 | 0.0% | Hispanic/Latino | <$55,000 | 10%-20% | | HSR | 20-60 | >90-100 | DAC | >20% | >80% | 40%-60% | Y | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-139 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING | Census Tracts | Existing Households | Housing Capacity | | | | Patterns of Segregation | | | Access to Opportunity | | | | Disproportionate Housing Needs/ Displacement Risk | | | | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | Low | Mod | Above Mod | Total | %of Total | Population Majority | Median Income | Disability Rates | R/ECAP or RCAA | TCAC Score | Jobs Index | CES4 Scores | SB 35 DAC | Overcrowding | Overpayment (Renters) | Overpayment (Homeowners) | Displacement Risk | | 52.03 | 1,595 | 0 | 0 | 12 | 12 | 0.0% | Hispanic/Latino | <$55,000 | 10%-20% | | HSR | 20-60 | >80-90 | DAC | <8.2% | 60%-80% | 20%-40% | Y | | 52.04 | 1,287 | 0 | 5 | 16 | 21 | 0.0% | Hispanic/Latino | <$55,000 | 10%-20% | | Moderate | 40-80 | >80-90 | DAC | <8.2% | 40%-60% | 40%-60% | Y | | 53.01 | 1,866 | 0 | 0 | 0 | 0 | 0.0% | Hispanic/Latino | $55,001-$87,100 | 10%-20% | | Moderate | 60-80 | >80-90 | DAC | <8.2% | 40%-60% | 20%-40% | Y | | 53.02 | 1,888 | 0 | 0 | 11 | 11 | 0.1% | Hispanic/Latino | <$55,000 | 10%-20% | | HSR | 60-80 | >70-80 | | <8.2% | 40%-60% | 40%-60% | Y | | 53.04 | 2,076 | 0 | 0 | 14 | 14 | 0.0% | Hispanic/Latino | <$55,000 | 10%-20% | | Moderate | 60-80 | >70-80 | | <8.2% | 40%-60% | 20%-40% | | | 53.05 | 1,149 | 0 | 27 | 12 | 39 | 0.1% | Hispanic/Latino | $55,001-$87,100 | 10%-20% | | Moderate | 40-80 | >60-70 | DAC | <8.2% | 40%-60% | 20%-40% | Y | | 54.03 | 1,647 | 158 | 0 | 2 | 160 | 0.4% | Hispanic/Latino | <$55,000 | 10%-20% | R/ECAP | HSR | >80 | >80-90 | DAC | 8.3-12% | 60%-80% | 20%-40% | | | 54.05 | 1,759 | 0 | 0 | 0 | 0 | 0.0% | White | $55,001-$87,100 | 10%-20% | | High | >80 | >60-70 | | <8.2% | 40%-60% | 20%-40% | | | 54.06 | 1,475 | 0 | 0 | 5 | 5 | 0.0% | White | $55,001-$87,100 | 10%-20% | | High | >80 | >60-70 | | <8.2% | 40%-60% | 20%-40% | | | 54.07 | 1,338 | 0 | 0 | 0 | 0 | 0.0% | White | $55,001-$87,100 | 10%-20% | | High | 60-80 | >40-50 | | <8.2% | 40%-60% | <20% | | | 54.08 | 321 | 0 | 0 | 0 | 0 | 0.0% | White | $55,001-$87,100 | <10% | R/ECAP | Low | 60-80 | >90-100 | DAC | <8.2% | 40%-60% | <20% | | | 54.09 | 1,297 | 0 | 0 | 2 | 2 | 0.0% | White | $55,001-$87,100 | 10%-20% | | Moderate | >80 | >60-70 | DAC | 8.3-12% | 60%-80% | 20%-40% | | | 54.10 | 1,057 | 23 | 0 | 3 | 26 | 0.1% | White | $55,001-$87,100 | 10%-20% | | Moderate | >80 | >70-80 | DAC | 8.3-12% | 40%-60% | <20% | | | 55.03 | 2,369 | 211 | 89 | 1,241 | 1,541 | 3.5% | White | $100,000-$149,999 | <10% | RCAA | Highest | <20-40 | >10-20 | | <8.2% | 60%-80% | 20%-40% | | | 55.04 | 1,001 | 0 | 0 | 13 | 13 | 0.0% | White | $100,000-$149,999 | <10% | RCAA | Highest | <20 | >20-30 | | <8.2% | 20%-40% | 20%-40% | | | 55.05 | 1,834 | 0 | 0 | 0 | 0 | 0.0% | White | $100,000-$149,999 | 10%-20% | RCAA | Highest | <20 | >20-30 | | <8.2% | 40%-60% | 20%-40% | | | 55.07 | 2,214 | 50 | 0 | 13 | 63 | 0.1% | White | $100,000-$149,999 | <10% | RCAA | Highest | 40-80 | >10-20 | | <8.2% | 40%-60% | <20% | | | 55.08 | 2,094 | 0 | 0 | 30 | 30 | 0.1% | White | $100,000-$149,999 | <10% | RCAA | Highest | <20-60 | >10-20 | | <8.2% | 20%-40% | 20%-40% | | | 55.09 | 1,690 | 59 | 232 | 187 | 478 | 1.1% | White | $55,001-$87,100 | 10%-20% | | Highest | 40-80 | >50-60 | | <8.2% | 40%-60% | 20%-40% | | | 55.16 | 2,775 | 0 | 0 | 1 | 1 | 0.0% | White | $87,101-$99,999 | <10% | RCAA | Highest | <20-60 | >30-40 | | <8.2% | 40%-60% | 20%-40% | | | 55.26 | 799 | 0 | 0 | 2 | 2 | 0.0% | White | $55,001-$87,100 | 10%-20% | | Highest | >80 | >40-50 | | <8.2% | 40%-60% | <20% | Y | | 55.27 | 1,407 | 81 | 0 | 0 | 81 | 0.2% | White | $55,001-$87,100 | 10%-20% | | Highest | 60-80 | >40-50 | | <8.2% | 40%-60% | <20% | Y | | 55.28 | 659 | 0 | 0 | 0 | 0 | 0.0% | White | $87,101-$99,999 | <10% | RCAA | Highest | <20 | >10-20 | | <8.2% | 40%-60% | 20%-40% | | | 55.29 | 1,993 | 0 | 0 | 6 | 6 | 0.0% | White | $100,000-$149,999 | <10% | RCAA | Highest | <20 | >10-20 | | <8.2% | 60%-80% | 20%-40% | | | 56.05 | 500 | 0 | 0 | 0 | 0 | 0.0% | White | $87,101-$99,999 | 10%-20% | RCAA | High | 60-80 | >30-40 | | <8.2% | 20%-40% | 20%-40% | | | 58.04 | 1,942 | 0 | 0 | 0 | 0 | 0.0% | White | $55,001-$87,100 | 10%-20% | | High | 60-80 | >60-70 | DAC | <8.2% | 20%-40% | 40%-60% | Y | | 58.05 | 2,096 | 68 | 154 | 532 | 754 | 1.7% | White | $55,001-$87,100 | 10%-20% | RCAA | Highest | 60-80 | >50-60 | | <8.2% | 40%-60% | 20%-40% | | | 59.04 | 1,895 | 0 | 0 | 263 | 263 | 0.6% | White | $87,101-$99,999 | 10%-20% | RCAA | Highest | 20-40 | >40-50 | | <8.2% | 20%-40% | 20%-40% | | | 86.00 | 1,289 | 718 | 199 | 1,176 | 2,093 | 4.8% | Hispanic/Latino | <$55,000 | 10%-20% | | Low | 60-80 | >90-100 | DAC | 12%-15% | 40%-60% | 20%-40% | Y | | Total | | 18,755 | 6,579 | 18,179 | 43,512 | 100.0% | | | | | | | | | | | | | R/ECAP= Racially/Ethnically Concentrated Area of Poverty RCAA=Racially Concentrated Area of Affluence HSR= High Segregation & Poverty CES4=CalEnviroScreen 4.0 DAC= Disadvantaged Community Source: City of Fresno, Ascent, 2024. APPENDIX 1E: CITY OF FRESNO There are 135 census tracts in the city. Figure 1E-3.44 displays the housing capacity identified in the sites inventory relative to the city’s census tracts. The housing capacity identified in the Draft Housing Element is generally distributed throughout the city with the greatest opportunities in the Downtown, along commercial corridors designated for mixed use development, and in the new growth areas at the periphery of the city. As shown in Figure 1E-3.45, the West Area contains the most capacity from the inventory (26 percent of the total identified capacity) followed by Downtown (20 percent), the Southwest Fresno Specific Plan area (16 percent), and the Roosevelt Community Plan area (14 percent). The distribution of sites across the city displays a concentration of lower-income housing in areas like Downtown and the West Area, while other areas like McLane and Woodward Park have a higher proportion of moderate and above moderate-income housing, reflecting an unequal distribution of housing capacity across the city. This has the potential to exacerbate fair housing issues in Fresno by providing more capacity for lower-income housing in disproportionately impacted communities. The Housing Element includes several policies and programs to address these issues (see Table 1E-3.28 at the end of this section for a summary of these actions). Relative to all of the census tracts within the city, two census tracts have slightly higher concentrations than the rest. These are census tracts 38.12 and 42.18 which account for 9.2 percent and 10.7 percent of the housing capacity for the Draft Housing Element respectively. These tracts are located west of Highway 99 within the West Area. The West Area is one of the City’s new growth areas in which the City is preparing a Specific Plan that provides significant opportunities for new higher density, mixed use neighborhoods, which will be integrated with the urbanized areas of Fresno to the east through future BRT corridors. Census tract 38.12, on the periphery of the West Area, is largely vacant land zoned to accommodate medium density residential single-family development (RS-5 zoning), but also contains zoning for higher density multi-family housing. The inventory identifies capacity for 525 lower-income units, 244 moderate-income units, and 3,235 above moderate- income units in tract 38.12. It is a high resource area and there is a substantial amount of developable land in the area. The majority of the population in this census tract is Hispanic/Latino, although there are only about 539 existing households in the census tract. Median incomes typically average between $100,000 and $149,000. Although it is classified as high resource, it is also designated as an SB 35 Disadvantaged Community (DAC). This is in line with an estimated 85 percent of the city’s land area being designated as a DAC. The addition of housing units in this census tract on sites identified in the Housing Element inventory will likely improve performance indicators. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Figure 1E-3.44: Sites Inventory by Census Tract, City of Fresno, September 2024 <
> Source: City of Fresno, Ascent, 2024. APPENDIX 1E: CITY OF FRESNO ### Figure 1E-3.45: Distribution of Housing Capacity by Community Plan/Specific Plan Area <
> Source: City of Fresno and Ascent, 2024. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Census tract 42.18 is in the boundaries of the proposed West Area Neighborhood Specific Plan (WANSP). The Housing Element inventory identifies capacity for 2,032 lower-income units, 1,937 moderate-income units, and 695 above moderate- income units in tract 42.18. Given the significant amount of land zoned for high-density mixed use in this area, this is where the highest portion of the capacity for lower- and moderate-income units are. In total, there is capacity for 3,227 units included in the sites inventory in the West Shaw Avenue Town Center alone, including 1,177 lower-income, 1,585 moderate-income, and 395 above moderate-income units. Because the area has been and continues to transition from agriculture to urban development, many of the sites are larger in size than sites in other parts of the city. Approximately 1,853 people currently live in this census tract; households are predominantly Hispanic/Latino with mostly moderate- and lower- income households. Median incomes are generally moderate (exactly or within the range of $87,101-$99,999) and lower income (less than $50,000). The Town Center provides an opportunity for more rental developments at higher densities that could produce affordable housing units for lower- and moderate- income households. There is a substantial amount of developable land in the area, and it is currently designated moderate resource. The addition of a Town Center also provides foundations to increase access to opportunities, amenities, and resources. Sites in the inventory are also distributed throughout the city’s established neighborhoods north and south of Shaw Avenue. This includes in the Hoover community area, the Fresno High-Roeding community, McLane, and Roosevelt community. As there is little vacant land for new development in these neighborhoods, they contribute minimally to the overall housing capacity identified in the Housing Element inventory. For example, approximately 2 percent of the total inventory identified is in Fresno High-Roeding, comprising 1 percent of the lower-income capacity, 3 percent of the moderate-income capacity, and 2 percent of the above moderate-income capacity. Moreover, the Hoover and McLane communities account for 4 percent and 5 percent of the inventory respectively (see Table 1E.3.23). With regards to fair housing indicators, the established neighborhoods north of Shaw Avenue –including the Woodward Park, Bullard, and Hoover communities– have higher percentages of White residents with higher household incomes. According to the TCAC Opportunity Index, these communities have greater life outcomes for children from lower income households. Educational outcomes are higher in these communities than other areas of the city, there is greater labor market engagement, and environmental conditions are generally better. While the capacity in these areas is less than other community plan areas in the city, Table 1E.3.23 shows that the Housing Element identifies capacity for over 7,500 new housing units in the Woodward Park, Bullard, and Hoover community plan areas including an estimated 4,500 for lower-income households. More affordable housing in these areas will provide greater access to opportunity for lower-income residents. APPENDIX 1E: CITY OF FRESNO ### Table 1E-3.23: Housing Capacity by Community Plan/Specific Plan Area | | Lower-Income Capacity | Percent of Lower-Income Capacity | Mod-Income Housing Capacity | Percent of Mod-Income Capacity | Above Mod-Income Housing Capacity | Percent of Above Mod-Income Capacity | Total Capacity | Percent of Total Capacity | | :--- | :---: | :---: | :---: | :---: | :---: | :---: | :---: | :---: | | Bullard | 2,348 | 12.5% | 559 | 8.5% | 377 | 2.1% | 3,284 | 7.5% | | Downtown | 5,072 | 27.0% | 307 | 4.7% | 3,221 | 17.7% | 8,600 | 19.8% | | Fresno High-Roeding | 180 | 1.0% | 221 | 3.4% | 327 | 1.8% | 729 | 1.7% | | Hoover | 1,476 | 7.9% | 72 | 1.1% | 273 | 1.5% | 1,821 | 4.2% | | McLane | 362 | 1.9% | 474 | 7.2% | 1,170 | 6.4% | 2,006 | 4.6% | | Roosevelt | 2,648 | 14.1% | 1,108 | 16.8% | 2,241 | 12.3% | 5,997 | 13.8% | | Southwest Fresno Specific Plan | 2,541 | 13.5% | 472 | 7.2% | 4,160 | 22.9% | 7,173 | 16.5% | | West | 3,441 | 18.3% | 3,081 | 46.8% | 4,956 | 27.3% | 11,478 | 26.4% | | Woodward Park | 687 | 3.7% | 283 | 4.3% | 1,454 | 8.0% | 2,425 | 5.6% | | **CITYWIDE** | **18,755** | **100.0%** | **6,579** | **100.0%** | **18,179** | **100.0%** | **43,512** | **100.0%** | *Source: City of Fresno and Ascent, 2024.* In the established neighborhoods south of Shaw Avenue –including Fresno High-Roeding and McLane neighborhoods—fair housing indicators convey moderate fair housing conditions. These communities have a greater amount of diversity and are more racially integrated, as shown in Figure 1E-3.3 previously in this section. However, there are higher poverty rates than in northern Fresno neighborhoods. Fresno High-Roeding and McLane also contain several of the city’s identified R/ECAP areas. Notably, the eastern portion of McLane does not follow the same trends. Fair housing conditions in the eastern McLane community plan area reflect more positive outcomes that are in line with North Fresno and Clovis neighborhoods (e.g., it is classified as a RCAA as opposed to a R/ECAP, there are higher TCAC opportunity scores, fewer disproportionate housing needs, and less risk of displacement). About 12 percent of the moderate-income capacity (740 units) is identified in McLane which reflects the amount of area zoned for multi-family residential with densities below 30 units per acre. The addition of moderate-income housing is not likely to impact fair housing conditions in the McLane community. Depending on the type of housing that is built, it may alleviate pressure for housing in the developed core of the city. The Fresno High-Roeding community area has minimal housing capacity identified across all income levels in the Housing Element inventory. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING The City’s developed core neighborhoods – including Downtown and the Southwest Fresno Specific Plan area – have the poorest fair housing conditions. These communities contain the majority of the City’s R/ECAP areas as well as areas classified as high segregation and poverty by the 2021 TCAC Opportunity Index. Fair housing indicators show that there are higher rates of overcrowding and housing cost burden as well as higher percentages of Housing Choice Voucher usage in these communities. In addition, there is lower academic performance, fewer educational resources, low engagement with the labor market, and very poor environmental conditions. In fact, nearly 70 census tracts in Fresno are considered a SB 35 disadvantaged community, comprising an estimated 85 percent of the city’s land area.[^p296-38] Downtown Fresno, with its high density of housing and commercial activity, faces challenges such as air pollution, noise, and limited green spaces. The concentration of traffic and industrial activities contributes to higher levels of air pollutants, which can adversely affect residents' health. However, efforts to revitalize Downtown, including the introduction of more green spaces and improved public transportation, aim to mitigate these environmental health issues and make the area more livable. In the Southwest Fresno Specific Plan area, environmental health conditions are impacted and often more severe. This area has historically been home to a higher concentration of industrial facilities and lower-income housing, leading to issues such as poor air quality, soil contamination, and inadequate access to clean water and green spaces. Residents in this area are more likely to be exposed to environmental hazards, which can have significant impacts on health outcomes. Given the proximity to industrial uses, the City reviewed sites in the inventory adjacent to existing industrial uses, specifically near State Route 41, and removed those sites which would be most impacted during the timeframe of this Housing Element. These conditions present challenges for increasing housing capacity, as new developments must address and mitigate these environmental health risks to create safe and healthy living environments. As shown in Table 1E-3.23, both Downtown and the Southwest Fresno specific plan area contain a high capacity of the sites inventoried in this Housing Element. This includes 27 percent of the lower-income capacity and 20 percent of the above moderate-income capacity identified in the Downtown Community Plan area; and, 14 percent of the lower-income capacity and 16 percent of the above moderate income capacity in the Southwest Fresno Plan area. While new lower income housing in these areas could help to alleviate the demand for housing in communities that are already experiencing poverty, it could reinforce patterns of concentrated poverty in these areas. Both Downtown and Southwest Fresno are susceptible to displacement pressure as new developments are built. There are about 7,380 units of above moderate-income housing inventoried in the Housing Element in these communities. Consequently, future development has the potential to exacerbate disproportionate housing needs including risk of displacement. Notably, the capacity for higher density development can provide affordable housing for lower-income households and more options to mitigate displacement for residents. [^p296-38]: Under Senate Bill (SB) 535, a disadvantaged community includes census tracts receiving the highest 25 percent of overall scores in CalEnviroScreen 4.0. Refer to page 1E-3-52 for more discuss of SB 535 Disadvantaged Communities in Fresno. APPENDIX 1E: CITY OF FRESNO With regards to environmental health conditions, new higher density developments in the Southwest Fresno Specific Plan area could contribute to alleviating some of the existing environmental health issues, creating more sustainable and healthy urban environments. For example, new developments can integrate green infrastructure, such as parks, green roofs, and community gardens, which help improve air quality, manage stormwater, and provide residents with recreational spaces. This can mitigate urban heat island effects and improve overall environmental health. The Southwest Specific Plan, adopted in 2017, reimagines this area as transitioning from industrial to a series of small, complete neighborhoods made up of community-serving uses, including retail, a range of housing types, a school, and a park. In addition, the Southwest Fresno Specific Plan prohibits new industrial development near residential areas in the Specific Plan area to the maximum extent feasible and instead the zoning encourages complete neighborhoods that incorporate mixed-use designs, where residential, commercial, and recreational spaces are within walking distance. This can reduce the need for driving, lowering traffic congestion and vehicle emissions, thus improving air quality. As it transitions from industrial uses to complete neighborhoods, the City recognizes that there are land use incompatibilities that could have negative impacts. For this reason, the City reviewed sites for the Housing Element inventory closely and removed sites that would be most impacted by existing industrial uses in the short term. As the Housing Element is implemented, it will be essential that new developments are planned and executed with a strong focus on environmental and public health to maximize their positive impact. ## Potential Effects on Integration Trends ### Race and Ethnicity The population in the city of Fresno is predominantly Hispanic/Latino (50 percent) and White (26 percent). As described previously, neighborhoods north of Shaw Avenue are predominantly White households and neighborhoods south of Shaw, western neighborhoods, and the Downtown/Fulton corridor area are predominantly Hispanic/Latino. **Figure 1E-3.46** displays the housing capacity identified in this Housing Element by the racial/ethnic majority of each census tract. The housing capacity includes approximately 37,365 units in areas that are predominately Hispanic/Latino households (86 percent of the total capacity), and 6,147 units in areas that are predominantly occupied by White households (14 percent). As the established neighborhoods north of Shaw Avenue – including the Woodward Park, Bullard, and Hoover communities – continue to experience growth, there are opportunities for increased diversity with the addition of housing for lower income households. The Housing Element identifies capacity for over 7,500 new housing units in the Woodward Park, Bullard, and Hoover community plan areas for this planning period. About 4,500 of those are identified for lower-income households (see **Table 1E-3.23**). Additional lower-income housing units can provide options to increase housing mobility for lower-income non-White households in R/ECAPs and thereby increase diversity in the neighborhoods north of Shaw Avenue and improve conditions of segregation based on race and ethnicity. The California State University (CSU) Fresno campus is also adjacent to these established neighborhoods, so more development will provide additional housing opportunities for college students and faculty. The additional capacity identified for housing in the rest of the city will not substantially impact trends of integration given the predominance of non-White households throughout the city already. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Figure 1E-3.46: Sum of Total Housing Capacity by Population Majority of Census Tract <
> *Source: City of Fresno, 2023. Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on ACS data.* ### Income As was shown in the assessment above, most neighborhoods are composed of lower- and moderate- income households. In 2020, Fresno’s citywide median household income was $53,368. Neighborhoods north of Shaw Avenue, including portions of the Bullard and West community areas, have the highest median incomes. Otherwise, most census block groups in the city have higher rates of poverty with household incomes that fall below the statewide median. As displayed in **Table 1E-3.22** above, the typical income range across many census tracts in the city is less than $50,000 or in the range of $50,001 to $87,100. In fact, 47 percent of census tracts in the city have median incomes below $50,000 and 33 percent have median incomes between $50,000 and $87,100, meaning that in total 81 percent of census tracts have median incomes below the statewide median. Less than 9 percent of census tracts in Fresno have median incomes above $100,000. As shown in **Table 1E-3.24** below, which displays the housing capacity for this Housing Element by 2019 median incomes, about half of the inventoried capacity for new housing (21,939 units) is in neighborhoods with incomes less than $50,000, which mirrors the percentage of census tracts in this income range. **Figure 1E-3.47** shows this information. The distribution is largely due to the capacity for new housing in core activity centers where there is significant capacity for high-density infill housing, but existing household incomes are relatively low. This is followed by an additional 8,297 units in census tracts with incomes between $50,001 and $87,100 (19 percent) and 6,984 units in tracts with incomes between $100,000-$149,999 (16 percent). Relative to the percentage of census tracts in the higher income range, the sites inventory distributes a larger share of units to higher income census tracts relative to the percentage of tracts in this income category. This is reflective of the large number of sites in new growth areas at the periphery of the city with higher median incomes. APPENDIX 1E: CITY OF FRESNO ### Table 1E-3.24: Housing Capacity and Median Income of Census Tract | | Lower-Income Capacity | Percent of Lower-Income Capacity | Mod-Income Capacity | Percent of Mod-Income Capacity | Above Mod-Income Housing Capacity | Percent of Above Mod-Income Capacity | Total Capacity | Percent of Total Capacity | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | No Data | 47 | 0.2% | 0 | 0.0% | 25 | 0.1% | 72 | 0.2% | | <$50,000 | 9,954 | 53.1% | 2,464 | 37.5% | 9,521 | 52.4% | 21,939 | 50.4% | | $50,001-$87,100 | 4,467 | 23.8% | 1,677 | 25.5% | 2,153 | 11.8% | 8,297 | 19.1% | | $87,101-$99,999 | 2,401 | 12.8% | 2,104 | 32.0% | 1,632 | 9.0% | 6,138 | 14.1% | | $100,000-$149,999 | 1,818 | 9.7% | 333 | 5.1% | 4,834 | 26.6% | 6,984 | 16.1% | | $150,000-$199,999 | 68 | 0.4% | 0 | 0.0% | 13 | 0. | 81 | 0.2% | | **Total** | **18,755** | **100.0%** | **6,579** | **100.0%** | **18,179** | **100.0%** | **43,512** | **100.0%** | *Source: City of Fresno, 2023. Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on ACS data.* Looking more closely at the distribution of sites by income category, the lower-income sites are slightly more concentrated in lower-income census tracts compared to the moderate- and above moderate-income sites. About 53 percent of the lower-income capacity is in census tracts where the median income is below $50,000, compared to 52 percent of the above moderate-income capacity also in these areas, while only 10 percent of the lower-income site capacity is in tracts with median incomes above $100,000, compared to 27 percent of the above moderate-income capacity. The moderate-income capacity is fairly well distributed across census tracts by income. To address this disparity, the Housing Element includes a program to expand capacity for lower-income and missing middle housing types in traditionally single-family neighborhoods and high resource areas, which correspond with areas that are relatively higher income (**Program 2**). To improve economic opportunities, reduce poverty, and increase financial stability, the Housing Element also includes a program to provide targeted job training opportunities for residents (**Program 30**). SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Figure 1E-3.47: Housing Capacity and Median Income by Block Group <
> *Source: City of Fresno, 2023. Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on ACS data.* ### Concentrated Areas of Race and Income Based on available data using 2009-2013 ACS information, 39 census tracts were designated as R/ECAPs in the city of Fresno, which are neighborhoods where there are both racial concentrations and high poverty rates. As shown in Figure 1E-4.48, R/ECAPs are generally in more centralized parts of the city. The Housing Element identifies capacity for 13,410 units in R/ECAP areas, including 7,895 lower-, 1,182 moderate- and 4,333 above-moderate income units (Figure 1E-3.49). This accounts for 42 percent of the lower-income capacity, 18 percent of the moderate-income capacity, and 24 percent of the above moderate-income capacity. The reason that a large portion of the lower-income RHNA is accommodated within areas classified as R/ECAPs is because of City policies to encourage high density housing close to the central core of the city in proximity to jobs and transit. Program 28 (Equitable Community Investments) of this Housing Element, consistent with other policies in the General Plan, prioritizes reinvestment in the city’s core areas. It includes the Downtown Neighborhoods Community Plan Area, Phase 1 and Phase 2 Bus Rapid Transit (BRT) and High-Frequency Transit Corridors, Infill Opportunity Zones (IOZs)—which have been defined as established neighborhoods generally south of Herndon Avenue—and the South Industrial Area. These areas align closely with census tracts designated as concentrated areas of poverty. Incentivizing new residential development, expanding transit options, stimulating economic development, and business and job creation will contribute to a higher quality of life for existing and future residents of the city’s core areas. There are 19 census tracts in Fresno that are designated as RCAAs, which are neighborhoods where there are both high concentrations of White households and high household incomes. As shown in Figure 1E-3.50, areas of affluence are primarily in areas within the city SOI but located in unincorporated islands or new growth areas north of Nees Avenue. The sites inventory includes capacity for 2,993 housing units in these areas of affluence, as shown in Figure 1E-3.48, including capacity for 2,132 above moderate-income units, 256 moderate-income units, and 606 lower-income units. The capacity identified in areas designated as RCAAs is predominantly for above-moderate income units. To address the concentration of lower-income unit capacity in R/ECAPs and the lack of lower-income housing opportunity in RCAAs, the Housing Element includes a program to identify additional sites or rezoning options for land in high resource areas to provide opportunities for higher density development in all areas of the city and reduce concentrations of poverty (Program 2). This includes developing zoning standards to permit residential conversions in the Office Zone District and facilitating the development of missing middle and multi-unit housing types such as duplexes, triplexes, fourplexes, townhomes, and SB 9 lot splits. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Figure 1E-3.48: Sites Inventory and Racially/Ethnically Concentrated Areas of Poverty (R/ECAP) <
> Source: City of Fresno, 2023. Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on ACS data. APPENDIX 1E: CITY OF FRESNO Figure 1E-3.49: Sum of Total Housing Capacity by R/ECAP or RCAA <
> Source: City of Fresno, 2023. Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on ACS data. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-153 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING Figure 1E-3.50: Sites Inventory and Racially Concentrated Areas of Affluence (RCAA) <
> Source: City of Fresno, 2023. Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on ACS data. APPENDIX 1E: CITY OF FRESNO # Potential Effects on Access to Opportunity Fresno has a mix of low-resource, moderate-resource, and high or highest resources areas. There are also several areas categorized as high segregation and poverty. Growth areas on the periphery of established neighborhoods along the northern and eastern edges of the city are designated moderate and high resource, including an annexation area, designated as highest. The central portion of the city is designated as low resource and high segregation and poverty. Table 1E-3.25 displays the sum of census tracts in the city SOI by TCAC classification. ### Table 1E-3.25: TCAC Opportunity Areas by Census Tract, City of Fresno | 2022 TCAC Opportunity Area | Sum of Census Tracts in City SOI | Percent of Tracts | | :--- | :--- | :--- | | Highest Resource | 24 | 17.8% | | High Resource | 29 | 21.5% | | Moderate Resource | 23 | 17.0% | | Low Resource | 15 | 11.1% | | High Segregation and Poverty | 43 | 31.9% | | No Data | 1 | 0.7% | | **Total** | **135** | **100.0%** | *Source: City of Fresno, 2023. California Tax Credit Allocation Committee (CTAC), 2022.* Figure 1E-3.51 below estimates the number of housing units in each opportunity area. Generally, the sites inventory adds more housing in all resource areas. The most housing capacity is estimated in high or highest resource areas and areas of high segregation and poverty, which is consistent with the bulk of developable areas in Fresno (see Figure 1E-3.52). In total, the inventory includes capacity for approximately 12,818 units in high or highest resource areas (29 percent of the total capacity), 8,302 units in moderate resource areas (19 percent of the total capacity), 5,844 units in low resource areas (13 percent of the total capacity), and approximately 15,258 units in areas of high segregation and poverty (35 percent of the total capacity). One census tract (census tract 1.00 in the Downtown development area) does not have any data associated with it from the TCAC/HCD Opportunity Mapping tool, and this accounts for 1,291 units from the Housing Element inventory (3 percent of the total capacity). Over half of the above moderate-income housing capacity (53 percent) is in low resource areas and areas of high segregation and poverty, combined, creating opportunities to balance the concentration of poverty in these areas of the city with higher income households. Conversely, about 25 percent of the lower-income housing capacity is in high and highest resource areas, compared to 38 percent of the above moderate-income housing capacity. This is largely due to the predominance of single-family zoning in neighborhoods north of Shaw Avenue. Program 2, described above, has been added to the Housing Element to address this disparity by expanding opportunities for lower- and moderate-income housing in high and highest resource areas. SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Figure 1E-3.51: Sum of Total Housing Capacity and TCAC Opportunity Areas <
> Source: City of Fresno, 2023. Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on ACS data. APPENDIX 1E: CITY OF FRESNO ### Figure 1E-3.52: Sites Inventory and TCAC Opportunity Areas <
> *Source: City of Fresno, 2023. Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on ACS data.* FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-157 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING # Potential Effects on Disproportionate Housing Needs ## Cost Burden or Overpayment Across all census tracts, the average percent of housing cost burdened populations is between 40 and 60 percent for renters and 20 to 40 percent for homeowners. Table 1E-3.26 and Table 1E-3.27 below display where housing capacity exists relative to housing cost burden. Approximately 25,336 units (58 percent) of the housing capacity is identified in tracts with a renter overpayment between 40 and 60 percent; 8,852 units (20 percent) of the capacity is in tracts with rates between 60 and 80 percent; and 8,989 units (21 percent) are in tracts with rates above 80 percent. The majority of capacity for lower income units (63 percent) is within census tracts where 40 to 60 percent of renters are overpaying for housing, primarily located in southwest, southeast, west, and central Fresno. The capacity for lower income households in these areas can facilitate housing mobility opportunities for renters who need more affordable options to avoid displacement and homelessness. With regards to overpayment for homeowners, more than half (55 percent) of the capacity in the inventory is in areas where 20 to 40 percent of homeowners are overpaying for housing. As shown in Table 1E-3.27, this includes 9,360 lower-income units, 3,283 moderate-income units, and 11,403 above moderate-income units. The addition of these units could help to alleviate existing overpayment by offering lower- and moderate-income units to current and future residents where there is need and increasing the housing stock overall to alleviate the demand on an existing shortage of housing at affordable price points. Additionally, the site capacity and distribution of units by income category can facilitate mobility opportunities for all households. Table 1E-3.26: Housing Capacity by Percent of Renter Overpayment | | Sum of Lower Income Housing Capacity | Percent of Lower Income Capacity | Sum of Moderate Income- Housing Capacity | Percent of Moderate Income Capacity | Sum of Above Moderate -Income Housing Capacity | Percent of Above Moderate Income Capacity | Total Capacity | Percent of Total Capacity | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | <20% | 0 | 0.0% | 8 | 0.1% | 9 | 0.0% | 17 | 0.0% | | 20%-40% | 0 | 0.0% | 0 | 0.0% | 318 | 1.7% | 318 | 0.7% | | 40%-60% | 11,791 | 62.9% | 3,182 | 48.4% | 10,362 | 57.0% | 25,336 | 58.2% | | 60%-80% | 4,144 | 22.1% | 1,207 | 18.3% | 3,501 | 19.3% | 8,852 | 20.3% | | >80% | 2,820 | 15.0% | 2,181 | 33.2% | 3,988 | 21.9% | 8,989 | 20.7% | | Total | 18,755 | 100.0% | 6,579 | 100.0% | 18,179 | 100.0% | 43,512 | 100.0% | Source: City of Fresno, 2023. Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on ACS data. APPENDIX 1E: CITY OF FRESNO Table 1E-3.27: Housing Capacity by Percent of Homeowner Overpayment | | Sum of Lower Income Housing Capacity | Percent of Lower Income Capacity | Sum of Moderate Income- Housing Capacity | Percent of Moderate Income Capacity | Sum of Above Moderate -Income Housing Capacity | Percent of Above Moderate Income Capacity | Total Capacity | Percent of Total Capacity | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | <20% | 2,141 | 11.4% | 237 | 3.6% | 679 | 3.7% | 3,057 | 7.0% | | 20%-40% | 9,360 | 49.9% | 3,283 | 49.9% | 11,403 | 62.7% | 24,046 | 55.3% | | 40%-60% | 3,423 | 18.3% | 2,337 | 35.5% | 1,943 | 10.7% | 7,702 | 17.7% | | 60%-80% | 3,145 | 16.8% | 515 | 7.8% | 3,755 | 20.7% | 7,415 | 17.0% | | >80% | 685 | 3.7% | 206 | 3.1% | 400 | 2.2% | 1,291 | 3.0% | | Total | 18,755 | 100.0% | 6,579 | 100.0% | 18,179 | 100.0% | 43,512 | 100.0% | Source: City of Fresno, 2023. Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on ACS data. ### Displacement As described above, a substantial amount of the city land area is vulnerable to displacement pressure using the methodology from UC Berkeley’s Urban Displacement Project. There are 77 census tracts in the city that are considered susceptible to displacement risk, making up more than half of the city (57 percent). Figures 1E-3.53 and 1E-3.54 below display the quantity and location of the sites inventory capacity relative to displacement risk in Fresno. The inventory provides a substantial capacity for new housing in areas identified as vulnerable. This includes capacity for 11,484 lower income units and 9,588 above-moderate income units in areas that are susceptible to displacement. Although the addition of lower-income housing should alleviate some of the pressures of displacement, the Action Plan also includes Program 34 – Eviction Protection Program to protect tenants from eviction and displacement pressures. Figure 1E-3.53: Sum of Housing Capacity and Areas at Risk of Displacement <
> Source: City of Fresno, 2023. Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on data and methodology from the Urban Displacement Project. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-3-159 SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING ### Figure 1E-3.54: Sites Inventory and Areas at Risk of Displacement <
> *Source: City of Fresno, 2023. Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on data and methodology from the Urban Displacement Project.* # Fair Housing Issues, Contributing Factors, Meaningful Actions HCD defines a fair housing issue as “a condition in a geographic area of analysis that restricts fair housing choice or access to opportunity, which includes such conditions as ongoing local or regional segregation or lack of integration, racially or ethnically concentrated areas of poverty and affluence, significant disparities in access to opportunity, disproportionate housing needs, and evidence of discrimination or violations of civil rights law or regulations related to housing.” In Fresno, there are substantial barriers to homeownership especially for communities of color and lower income households as denoted by lower income households, POC households, and individuals living below the poverty line concentrated in south and west neighborhoods in the city. Fresno has concentrated areas of poverty and many of these same census tracts have been identified as R/ECAPs or designated as “Low Resource” or “High Segregation & Poverty” by the HCD/TCAC Opportunity mapping methodology. In addition, most of the city is considered vulnerable to displacement from housing market pressures and poor environmental quality, or impacts from extreme heat and climate change. Pursuant to Government Code Section 65583 (c)(10)(A)(v), the Housing Element includes several policies and programs to work towards addressing fair housing issues and replacing segregated living patterns with integrated and balanced communities. Table 1E-3.28 below summarizes the fair housing issues, contributing factors, and implementation programs included in the Housing Element to affirmatively further fair housing in the city of Fresno. For more details on the actions in each implementation program, refer to Section 1E-1: Action Plan. ### Table 1E-3.28: Summary of Fair Housing Issues, Contributing Factors, and Meaningful Actions to AFFH, City of Fresno | Identified Fair Housing Issue | Contributing Factor | Priority Level | Meaningful Action | | :--- | :--- | :--- | :--- | | Segregation based on race and income; and presence of Racially and Ethnically Concentrated Areas of Poverty (R/ECAPs) and Racially and Ethnically Concentrated Areas of Affluence (RCAAs) | Past land use and zoning practices favoring outward expansion and resulting in subsequent disinvestment in core, south, and west neighborhoods | High | Program 2 – Variety of Housing Opportunities in High Resource Areas
Program 3 – Encourage and Facilitate Accessory Dwelling Units and Small Homes
Program 11 – Incentives for Housing Development
Program 20 – Housing Choice Voucher Incentive Program | | | Public housing and other forms of affordable housing are limited by location and type | High | Program 11 – Incentives for Housing Development
Program 12 – Local Housing Trust Fund
Program 14 – Partnerships with Affordable Housing Developers
Program 18 – Mixed Income Neighborhood Trust (MINT) | SECTION 1E-3: LOCAL ASSESSMENT OF FAIR HOUSING | Identified Fair Housing Issue | Contributing Factor | Priority Level | Meaningful Action | | :--- | :--- | :--- | :--- | | Unequal Access to Opportunity including Access to Safe and Healthy Environments, Reliable Public Transit, and Access to Education | Lack of lower- and moderate-income capacity in high and highest resource areas | High | Program 2 – Variety of Housing Opportunities in High Resource Areas
Program 3 – Encourage and Facilitate Accessory Dwelling Units and Small Homes
Program 11 – Incentives for Housing Development
Program 20 – Housing Choice Voucher Incentive Program | | | Continued need for reinvestment in low-and moderate- income census tracts | High | Program 28 – Equitable Community Investments | | | Disparities in access to healthy environments based on location of residence | High | Program 27 – Environmental Justice
Program 28 – Equitable Community Investments | | Disproportionate Housing Needs and Elevated Displacement Risk, Particularly for Lower Income Households | Rising housing costs without effective tenant protections to ensure stable housing (including for mobile homes) and prevalence of sensitive communities due to economic pressures, market, and environmental hazards/ climate change conditions | High | Program 16 – Community Land Trust
Program 18 – Mixed Income Neighborhood Trust (MINT)
Program 22 – Housing Rehabilitation
Program 32 – Opportunity to Purchase Act
Program 33 – Mobile Home Parks
Program 34 – Eviction Protection Program | | | Rising incidence of homelessness | High | Program 36 – Homeless Assistance | | Barriers to Homeownership for Black and Indigenous People of Color (BIPOC) communities | Past land use and zoning practices including redlining, racial covenants, and urban renewal projects have created systemic disparities to access homeownership | Medium | Program 19 – Home Buyer Assistance | | | Difficult to find rental housing that is accessible | Medium | Program 24 – Special Needs Housing | | | Stakeholder input and data on housing discrimination complaint calls and filings indicate that more fair housing education is needed for landlords, lenders, and the general public | Medium | Program 20 – Housing Choice Voucher Incentive Program
Program 26 – Fair Housing Services | Source: City of Fresno and Ascent, November 2023. APPENDIX 1E: CITY OF FRESNO # SECTION 1E-4: CONSTRAINTS ## Land Use Controls ### Analysis #### General Plan The Fresno General Plan sets forth policies that guide new development, including new residential development. As described in the Urban Form, Land Use, and Design Element, growth in the City of Fresno over the past few decades has traditionally been low density suburban style development, which has resulted in conditions of sprawl in various areas of the city. With the adoption of an updated General Plan in 2014, the City shifted emphasis to encourage more balanced development patterns between low density suburban growth and higher density urban development to establish complete communities through the following: infill, rehabilitation, Downtown and neighborhood revitalization, transit-oriented development along major streets, and mixed-uses in growth areas. Table 1E-4.1 summarizes the General Plan land use designations within the city that allow residential uses and corresponding zoning districts from the Development Code, as well as their permitted net densities (without application of a density bonus). Table 1E-4.1: Fresno General Plan Land Use Designations | General Plan Designation | Minimum Density (DU per acre) | Maximum Density (DU per acre) | Maximum Floor Area Ratio (non-residential only) | Development Code Zoning District | | :--- | :--- | :--- | :--- | :--- | | Buffer | -- | 0.05 (1 unit per 20 net acres) | -- | (B) Buffer | | Low Density Residential | 1 unit per 5 acres | 3.5 | -- | (RE) Residential Estate (RS-1) Residential Single Family, Extremely Low Density (RS-2) Residential Single Family, Very Low Density (RS-3) Residential Single Family, Low Density | | Medium Low Density Residential | 3.5 | 6 | -- | (RS-4) Residential Single Family, Medium Low Density | | Medium Density Residential | 5 | 12 | -- | (RS-5) Residential Single Family, Medium Density | | Medium High Density Residential | 12 | 16 | -- | (RM-MH) Mobile Home Park (RM-1) Residential Multi-Family Medium High Density | | Urban Neighborhood Density | 16 | 30 | -- | (RM-2) Residential Multi-Family, Urban Neighborhood | | High Density Residential | 30 | 45 | -- | (RM-3) Residential Multi-Family, High Density | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-4-1 SECTION 1E-4: CONSTRAINTS | General Plan Designation | Minimum Density (DU per acre) | Maximum Density (DU per acre) | Maximum Floor Area Ratio (non-residential only) | Development Code Zoning District | | :--- | :--- | :--- | :--- | :--- | | Neighborhood Mixed Use | 12 | No Limit | 1.5 | (NMX) Neighborhood Mixed Use | | Corridor/Center Mixed Use | 16 | No Limit | 1.5 | (CMX) Corridor/Center Mixed Use | | Regional Mixed Use | 30 | No Limit | 2.0 | (RMX) Regional Mixed Use | | Downtown Neighborhood | -- | No Limit | No Limit | (DTN) Downtown Neighborhood | | Downtown General | -- | No Limit | No Limit | (DTG) Downtown General | | Downtown Core | -- | No Limit | No Limit | (DTC) Downtown Core | *DU= Dwelling Unit* *Source: Fresno General Plan, Urban Form, Land Use, and Design Element; Table 3-1.* ### Zoning and Development Code The City’s Development Code provides for the following districts to permit residential uses including the Buffer[^p314-1] designation, six single-family districts, four multi-family districts, three mixed-use districts, three downtown districts, and two commercial districts. These districts are designed to implement the General Plan vision for new infill and redevelopment, transit-oriented development along major streets, and new Activity Centers with mixed-uses and neighborhoods in growth areas. * **Residential Single-Family Districts (RE, RS-1, RS-2, RS-3, RS-4, RS-5)** -- The Residential zones are intended to provide specific areas in the city where residential developments of varying densities may be developed as specified in the land use element of the General Plan. * **Residential Multi-Family Districts (RM-1, RM-2, RM-3, RM-MH)** -- The purpose of the Residential Multi-Family (RM) Districts are to provide opportunities for the development of higher-density and affordable housing in neighborhoods throughout the city implementing regulations for "Medium High Density Residential," "Urban Neighborhood Density Residential," and "High Density Residential" General Plan classifications. [^p314-1]: The Buffer land use designation in the City of Fresno General Plan, Urban Form, Land Use, and Design Element is intended to separate urban uses from long-term agricultural uses in order to preserve long-term viable agricultural areas and intensive farming operations adjoining but outside the Planning Area. APPENDIX 1E: CITY OF FRESNO * **NMX Neighborhood Mixed-Use** -- The NMX district is intended to provide for mixed-use residential districts that include local-serving, pedestrian-oriented commercial development, such as smaller independent retail shops and professional offices in two- to three-story buildings. Development is expected to include ground-floor neighborhood retail uses and upper-level housing or offices, with a mix of small lot single-family houses, townhomes, and multi-family dwelling units on side streets, in a horizontal or vertical mixed-use orientation. The maximum FAR for non-residential development is 1.5.[^p315-2] * **CMX Corridor/Center Mixed-Use** -- The CMX district is intended to allow for either horizontal or vertical mixed-use development along key circulation corridors in the city where height and density can be easily accommodated. Ground-floor retail and upper-floor residential or offices are the primary uses, with residential uses, personal and business services, and public and institutional space as supportive uses. The maximum FAR for non-residential development is 1.5. * **RMX Regional Mixed-Use** -- The RMX district is intended to support regional retail and mixed-use development in large-scale activity centers outside of Downtown, as identified by the General Plan. It accommodates urban-scale mixed-use development that serve residents and businesses of the region at large. Medium-scale retail, housing, office, civic and entertainment uses, and shopping malls with large-format or "big-box" retail are allowed, as are supporting uses such as gas stations, hotels, and residential in mixed-use or single-use buildings. The maximum FAR for non-residential development is 2.0 * **DTN Downtown Neighborhood** -- The DTN District is intended to create walkable, mixed-use urban neighborhoods surrounding the Downtown Core. * **DTG Downtown General** -- The DTG District is intended to support a high concentration of regional activity generators such as governmental buildings and convention centers within a pedestrian-oriented, mixed-use urban setting. * **DTC Downtown Core** -- The DTC District will foster the enhancement of Fresno's business, shopping, and cultural heart by guiding the development of the densest, most active, and most interesting mixed-use urban center in the region. * **CMS Commercial - Main Street** -- The CMS district is intended to preserve or promote small-scale, fine-grain commercial development in neighborhoods where single-family residential and townhomes are predominant. A traditional "Main Street" character is achieved with active storefronts, outdoor seating and pedestrian-oriented design. [^p315-2]: Per Zoning Code Section 15-309 (Determining Floor Area Ratio), “Floor area ratio (FAR) is the measure of the intensity of non-residential development. It is the ratio of the non-residential floor area, excluding the areas described below, of all principal and accessory buildings on a site to the site area. To calculate FAR, non-residential floor area is divided by site area, and typically expressed as a decimal. For example, if the non-residential floor area of all buildings on a site totals 20,000 square feet, and the site area is 10,000 square feet, the FAR is expressed as 2.0.” SECTION 1E-4: CONSTRAINTS * **CR Commercial – Regional** -- The CR district is intended to meet local and regional retail demand, such as large-scale retail, office, civic and entertainment uses, shopping malls with large-format or "big-box" retail, and supporting uses such as gas stations and hotels. Buildings are typically larger-footprint and urban-scaled. Development and design standards will create a pedestrian-orientation within centers and along major corridors, with parking generally on the side or rear of major buildings, but automobile-oriented uses also will be accommodated on identified streets and frontages. ## Downtown Development Code The Downtown Development Code (DDC) is a form-based code that contains most of the standards and requirements for development and land use activity within the Downtown Neighborhoods Community Plan and Fulton Corridor Specific Plan areas. Regulations regarding development patterns are generally consistent with the existing scale and character of the plan areas' various neighborhoods districts and corridors. Form-based codes address the relationship between building facades and the public realm (streets and parks), the form and massing of buildings in relation to one another, and the scale and types of streets and blocks. The City incorporated the DDC into the Citywide Development Code in 2016 and implements these form-based standards through the DTN, DTC, and DTG zoning district standards. ## Residential Development Standards Table 1E-4.2 lists the zoning districts from the City of Fresno Development Code that allow residential development and describes the development standards for residential projects. Zoning regulations are designed to implement the policies of the City’s General Plan and protect and promote health, safety, and general welfare of residents. The Code sets forth the City’s specific residential development standards to preserve the character and integrity of existing neighborhoods and at the same time offer flexibility in providing a wide range of residential opportunities and dwelling unit types. The section below provides an overview of primary development standards that affect the maximum development intensity of a housing project, including density, height, setbacks, parking, and open space requirements. To accelerate housing production in infill areas and incentivize investment along the City’s transit and mixed-use corridors, the City adopted amendments to: (1) remove maximum density limitations in the Mixed Use Districts and (2) modify the restriction that prohibits ground floor residential uses in mixed-use districts so that only corner properties along arterials with Bus Rapid Transit (BRT) stops will have mandated commercial uses. With those amendments, the City now relies on height limits rather than regulating density. This action was intended to encourage higher density development in mixed-use districts. APPENDIX 1E: CITY OF FRESNO Prior to adoption, the City performed an analysis of a typical development project comparing the existing density limits with the new height-based limits to determine how this change could affect project buildouts. For the purpose of the environmental analysis, consultants analyzed 10 parcels (2 within each district) and applied the applicable development standards for the corresponding zone district to create conceptual site plans. It was determined that the following are reasonable densities that would be developed based on typical multi-family and mixed-use developments built in Fresno: * **CMS:** 48 dwelling units per acre * **CMX:** 75 dwelling units per acre * **CR:** 80 dwelling units per acre * **NMX:** 64 dwelling units per acre * **RMX:** 90 dwelling units per acre SECTION 1E-4: CONSTRAINTS ### Table 1E-4.2: City of Fresno Development Standards by Zoning District | Zoning District | Max. Height | Min. Lot Width | Minimum Yard Setback | Min. Lot Area | Density (DU per Acre) | Max. Floor Area Ratio (FAR) (non-residential only) | Max. Lot Coverage | Permitted Uses | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | | Front | Side | Rear | | | | | | | **Buffer (B) District** | | | | | | | | | | | | B | 35 | 130 | 35 | 20-35 | 20 | 26,000 | 1 | - | 5% | SF/MF* | | **Residential Single Family (RS) Districts** | | | | | | | | | | | | RE | 35 | 80-160 | 35 | 10-35 | 20 | 5 acres | 0.2 | - | 30% | SF* | | RS-1 | 35 | 80-160 | 35 | 10-25 | 20 | 36,000 | 1.2 | - | 30% | SF* | | RS-2 | 35 | 80-130 | 30 | 10-25 | 20 | 20,000 | 2.2 | - | 30% | SF* | | RS-3 | 35 | 60-90 | 25 | 5-20 | 20 | 9,000 | 0.2-3.5 | - | 35% | SF* | | RS-4 | 35 | 40-70 | 13 | 4-10 | 10 | 5,000 | 3.5-6 | - | 50% | SF* | | RS-5 | 35 | 30-60 | 13 | 3-10 | 10 | 4,000 | 5-12 | - | 60% | SF/MF* | | **Residential Multi-Family (RM) Districts** | | | | | | | | | | | | RM-1 | 40 | -- | 10-20 | 10-15 | 20 | -- | 12-16 | - | 50% | SF/MF* | | RM-2 | 50 | -- | 10-20 | 10-15 | 15 | -- | 16-30 | - | 50% | MF* | | RM-3 | 60 | -- | 10-20 | 10-15 | 15 | -- | 30-45 | - | 60% | MF* | | RM-MH | 35 | -- | 10-20 | 10-15 | 10 | -- | 12-16 | - | 50% | MF* | | **Mixed-Use (MX) Districts** | | | | | | | | | | | | NMX | 40 | -- | -/10 | -- | -- | -- | Min. Density – 12 du/ac No Max. Density | 1.5 | -- | SF/MF* | | CMX | 60 | -- | -/10 | -- | -- | -- | Min. Density – 16 du/ac No Max. Density | 1.5 | -- | SF/MF* | | RMX | 75 | -- | -/10 | -- | -- | -- | Minimum Density – 30 du/ac No Maximum Density | 2.0 | -- | SF/MF* | APPENDIX 1E: CITY OF FRESNO | Zoning District | Max. Height | Min. Lot Width | Minimum Yard Setback | Min. Lot Area | Density (DU per Acre) | Max. Floor Area Ratio (FAR) (non-residential only) | Max. Lot Coverage | Permitted Uses | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | | | **Front** | **Side** | **Rear** | | | | | | | **Commercial (C) Districts Allowing Residential Development** | | | | | | | | | | | CMS | 35 | -- | 0 | 0 | 0 | -- | No Limit | 1.0 | -- | SF/MF* | | CR | 75 | 100 | 15 | 0 | 0 | 10,000 | No Limit | 1.0 | -- | SF/MF* | | **Downtown (DT) Districts** | | | | | | | | | | | DTN | 90 | -- | 2-10 | 0-10 | 0 | -- | No Limit | No Limit | -- | SF/MF* | | DTG | 140 | -- | 2-10 (1) | 0-10 (2) | 0 | -- | No Limit | No Limit | -- | SF/MF* | | DTC | 190 | -- | 2-10 | 0-10 | 0 | -- | No Limit | No Limit | -- | SF/MF* | Notes: Densities in the Residential Single-Family Districts are based on corresponding land use designation in the Fresno General Plan. For Mixed Use zones, minimum residential density is not required for projects on lots less than 20,000 sq. ft. in area or projects further than 1,000 feet from a planned or existing BRT route. For mixed-use and commercial districts, all permitted uses are allowed either alone or in combination with other permitted uses unless otherwise stated. Specific Limitations: ¹ Front setback along Mariposa Street between M Street and P Street (min./max.): 10/18 ft. ² Street Side setback along Mariposa Street between M Street and P Street (min./max.): 10/15 ft. *See Development Code for more information. Source: City of Fresno Development Code, 2022. SECTION 1E-4: CONSTRAINTS The environmental assessment prepared for the projects estimated that there are approximately 791 acres of mixed-use zoned property that has the potential to be developed in the next few decades. These 791 acres consist of land that is considered vacant and underutilized and includes parcels that have an existing land use of ‘vacant,’ ‘parking,’ or ‘open space/ag’ per City of Fresno Existing Land Use layer. Based on this acreage and the reasonable densities identified above, the potential development of residential units that could result from the amendment would be 60,880 units, as compared to the previous 20,434-unit capacity (see Table 1E-4.3). ### Table 1E-4.3: Summary of Mixed-Use Density Increases | Zone Districts | Acres | Previously Allowed Density | Achievable Density under New Standards | | :--- | :--- | :--- | :--- | | | | DU/AC | Units | DU/AC | Units | | CMS | 10 | 16 | 165 | 48 | 495 | | CMX | 320 | 30 | 9,590 | 75 | 23,975 | | CR | 248 | 16 | 3,966 | 80 | 19,830 | | NMX | 99 | 16 | 1,577 | 64 | 6,308 | | RMX | 114 | 45 | 5,136 | 90 | 10,272 | | **Total** | **791** | **-** | **20,434** | **-** | **60,880** | *Note: The numbers are rounded to the nearest whole number.* *Source: City of Fresno Mitigated Negative Declaration for General Plan Amendment/Development Code Text Amendment Application No. P22-02413 Environmental Assessment. August 2022.* As mentioned above, the text amendment revised the restriction that prohibits ground floor residential uses in mixed-use districts so that only corner properties along arterials with BRT stops will have mandated commercial uses. Other high-activity uses may be approved at the discretion of the Review Authority. However, this does not impose a constraint on housing development in these areas because larger multi-family developments can be activated with active ground floor additions or a residential lobby. ### Lot Sizes Density in single-family zones is driven by the minimum lot area requirements. The lot size requirements in single family zones typically reflect the development pattern of the surrounding subdivision. Lot sizes range from a minimum of 5 acres in the RE zone, 36,000 square feet in the RS-1 zone, and 4,000 square feet in the RS-5 zone. There are no minimum lot area requirements for multi-family and mixed-use zones except in the CR district, where the minimum lot area is 10,000 square feet. APPENDIX 1E: CITY OF FRESNO Per State law, local governments may not impose minimum lot size requirements on accessory dwelling units (ADUs) (referred to as second units in the Fresno Development Code) since these development types are not required to observe minimum lot size requirements for the underlying zoning district. Currently (2022), the City states the following minimum lot sizes for these units: 6,200 square feet for second dwelling units, 6,000 square feet for an interior lot and 5,000 square feet for a corner size lot for backyard cottages, and 5,000 square feet for accessory living quarters. This language pre-dates the adoption of the State laws, therefore the City defers to the State regulations when reviewing ADU applications. The Housing Element includes a program to amend these standards for second units, backyard cottages, accessory living quarters and SB 9 units (i.e., accessory dwelling units (ADUs). ### Maximum Floor Area Ratio The City does not have maximum floor area ratio (FAR) requirements for residential uses in residential zones, as it is typically the measure of the intensity of non-residential development. However, the Development Code and General Plan do have standards that limit FAR in the mixed-use zones. The total allowable FAR per lot includes the floor area of residential units. * **CMS:** Maximum FAR of 1.0 * **CMX:** Maximum FAR of 1.5 * **CR:** Maximum FAR of 1.0 * **NMX:** Maximum FAR of 1.5 * **RMX:** Maximum FAR of 2.0 ### Height Requirements Height limitations are intended to allow projects to achieve the maximum allowable density, while also being responsive to community character. The districts that provide the highest densities for residential development also provide for the highest maximum heights. The maximum height in all residential single-family districts, including the mobile home residential district (RM-MH), is 35 feet, which allows for three stories. Developments in multi-family districts have the following height limits: 40 feet in the RM-1 district; 50 feet in RM-2; and 60 feet in RM-3. These height limits allow for the maximum densities to be achieved in each zone. With a minor deviation, an applicant can add up to 10 percent to a building’s height and with the approval of a Planned Development (PD) Permit, additional deviations from the Development Code and/or General Plan could also be permitted. Developments in Mixed Use Districts have the following height limits: 40 feet in the NMX; 60 feet in CMX; and 75 feet in RMX. Commercial districts allowing for mixed uses including residential development permit buildings up to 35 feet in the CMS zone and 75 feet in the CR zone. This could include small-scale development such as attached single-family residential and townhomes. Downtown Districts allow the most intense development patterns. Height limits are: 90 feet in DTN (approximately 6 stories), 140 feet in DTG (approximately 10 stories), and 190 feet in DTC (approximately 15 stories). These height standards allow for a range of high-density housing types in the Downtown. SECTION 1E-4: CONSTRAINTS ### Setbacks A setback is the required minimum or maximum horizontal distance between the front, sides, and rear of the lot to the building. The City’s setback standards are comparable to those of other jurisdictions and are not a constraint to achieving maximum densities. In RS Districts, front setbacks range from 13 feet in the RS-4 and RS-5 zones to 35 feet in the RE and RS-1 zones. Rear setbacks range from 10 feet in RS-4 and RS-5 zones to 20 feet in the rest of the RS zones. Side setbacks in the RS Districts vary from 3 to 35 feet. Downtown, Mixed-Use, and Commercial zones allowing residential development have lower frontage setbacks, averaging about 10 feet, with no rear property setback requirements in mixed use zones or a minimum of 0 feet in downtown and commercial zones. Side property setbacks range from 0 feet in Mixed-Use Districts to 15 feet in the CR district. ### Parking Table 1E-4.4 shows the residential parking requirements in Fresno. The City determines the required number of parking spaces based on the type and size of the residential unit and has found the required parking spaces to be necessary to accommodate the number of vehicles typically associated with each residence. Requirements for covered parking spaces or garage parking are due in large part to the climate of Fresno and extreme heat events. With the passage of AB 2097 in 2022, the City cannot impose minimum parking requirements on projects within a half mile of public transit if the project (1) dedicates a minimum of 20 percent of the total number of housing units to very low-, low-, or moderate-income households for students, the elderly, or persons with disabilities, (2) contains fewer than 20 housing units, or (3) is subject to parking reductions based on any other applicable law. Public transit in this case is defined as a major transit stop with an intersection of 2 or more high frequency bus route stops with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods. Figure 1E-4.1 shows the areas within the city that would be subject to AB 2097 in relation to the sites inventory. Areas subject to AB 2097 in the northern part of the city are north of Herndon Avenue between N. Blackstone Avenue and State Route (SR) 41, and along Shaw Avenue at N Blackstone Avenue, First Street, and Cedar Avenue. Additional areas exist Downtown, in and around the Downtown Transit Center, and in the South Industrial area along E Jensen Avenue. The Housing Element includes a program to amend the Development Code to remove parking minimums within a half mile of public transit, consistent with AB 2097. Parking requirements for ADUs, emergency shelters, and transitional and supportive housing are inconsistent with current (2023) state law therefore the Housing Element includes a program to amend parking requirements for these uses. Additionally, parking for emergency shelters should be based on staffing at the shelter at a rate of one space per employee. The City provides several reductions in parking requirements, including for affordable housing developments (up to 2-bedroom units), mixed-use residential uses (up to 1-bedroom units), specific multi-family developments with transit accessibility, and developments that have shared parking. Residential care developments are eligible for these parking reductions; however, feedback from recent developers state that while the parking reduction is advantageous, the overall number of parking required before and after reduction is high. In response to this feedback, the City has added an action to reduce the parking standard for Residential Care, General. APPENDIX 1E: CITY OF FRESNO ### Table 1E-4.4: Residential Parking Requirements | Use | Parking Requirement | Notes | | :--- | :--- | :--- | | Single-unit residential constructed prior to adoption of 2016 Development Code | 1 space per dwelling unit | Must be covered. | | Single-unit residential | 1 space per dwelling unit | Must be within a garage. | | Duplex | 1 space per dwelling unit | Must be within a garage. | | Accessory Dwelling Units (ADUs)/ Second Dwelling Units, Backyard Cottages, or Accessory Living Quarters | 1 covered space per 1-bedroom unit; 1 additional, covered or uncovered, parking space for 2 or more bedrooms in the second dwelling unit. | A tandem parking space may also be used to meet the parking requirement for the Second Dwelling Unit, providing such space will not encumber access to a required parking space for the primary single-unit dwelling. An existing 2 vehicle garage and/or carport may not be provided in-lieu of these parking requirements unless the parking spaces are accessed from different garage doors. | | Multi-Unit Residential (Studio and 1-bedroom) | 1 space per unit; 0.75 spaces per unit in MX and CMS Districts; 0.5 spaces per unit in DT Districts | Required parking shall be covered. One additional uncovered guest parking space shall be provided for every 4 units. | | Multi-Unit Residential (2-bedrooms) | 1 space per unit; 0.5 spaces per unit in DT Districts | Required parking shall be covered. One additional uncovered guest parking space must be provided for every 2 units. In MX and CMS Districts, one additional guest parking space must be provided for every 4 units for projects greater than 4 units. | | Multi-Unit Residential (3+ bedrooms) | 1.5 spaces per unit; 0.5 spaces per unit in DT Districts | Required parking shall be covered. One additional uncovered guest parking space must be provided for every 2 units. In MX and CMS Districts, one additional guest parking space must be provided for every 4 units for projects greater than 4 units. | | Affordable Housing (studio, 1-, and 2- bedroom) | 0.75 spaces per unit | -- | | Affordable Housing (3+ bedrooms) | 1.5 spaces per unit | -- | | Residential Care, Limited (6 or fewer clients) | None in addition to parking required for residential use. | -- | | Residential Care, General (more than 6 persons) | 2 spaces for the owner-manager plus 1 for every 5 beds and 1 for each non-resident employee. | -- | | Residential Care, Senior | 1 space for every 7 residents plus 1 for each live-in caregiver. Facilities serving more than 15 residents shall also provide 1 space for each caregiver, employee, and doctor on-site at any one time. | -- | | SRO | 0.5 spaces per unit | -- | | Emergency Shelters | 1 per 500 sq. ft. of floor area. | | | Transitional and Supportive Housing | Subject to parking requirements of the same residential type. | | *Source: City of Fresno Development Code, 2022.* FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-4-11 SECTION 1E-4: CONSTRAINTS ### Figure 1E-4.1: Assembly Bill 2097 Areas, Fresno 2023 <
> *Source: City of Fresno and Ascent, October 2023.* APPENDIX 1E: CITY OF FRESNO ## Open Spaces and Parks All new residential developments have an obligation to provide parkland and/or contribute to the development and maintenance of parks consistent with the Quimby Act. Fresno City Code requires that a minimum of 3 acres per 1,000 population be set aside for parks. Pursuant to State law, in-lieu fees may be paid instead of land dedication. The Park Quimby Fee is $1,542 per unit for single-family dwellings and $1,164 per unit for multi-family dwellings. Article 4.7 Section 12-4.705 states that single-family developments with fewer than 50 parcels shall be responsible for paying the park fee but not for dedicating land. Subdivisions with 50 parcels or more shall pay the fee and dedicate 0.6 acres per 1,000 residents in the form of pocket parks. Residential developments are required to set aside specific minimum areas of the lot as usable open space, which may include balconies and up to 50 percent of the area in required yards. In Residential Multi-Family (RM) districts, commercial districts allowing residential development (CMS and CR), Mixed-Use (MX) districts, and Downtown (DT) districts, the minimum requirement for on-site open space is based on the size of the lot, as shown in Table 1E-4.5. These requirements may be met through a combination of private open space, common open space, or public plazas. ### Table 1E-4.5: Minimum On-Site Open Space Requirements, City of Fresno | Zoning District | Percent of Total Lot Area Required to be Dedicated to Open Space* | | :--- | :--- | | RM-1 | 20% | | RM-2 | 15% | | RM-3 | 10% | | CMS | 15% | | CR | 8% | | CMX | 10% | | NMX | 15% | | RMX | 8% | | DTN | 10% | | DTG | 8% | | DTC | 5% | *Note: These requirements may be met through a combination of private open space, common open space, or public plazas. Source: City of Fresno Development Code, 2022. Table 15-1003 and 15-1004-D. SECTION 1E-4: CONSTRAINTS The minimum amount of open space required in DT and MX districts could be reduced by 25 percent in the following circumstances: * Any portion of the lot is located within 400 feet of a transit stop with regular, scheduled service. * There is a public park within 400 feet of the site, or * The parcel is 15,000 square feet or less in area. These requirements are in addition to park in-lieu fees which contribute to the public park system. Overall, these open space requirements and the park in-lieu fees do not represent excessive constraints on residential development. The City provides flexibility in how developers can meet the open space requirements. ### Additional Standards in Mixed Use Districts On October 13, 2022, the City adopted the Mixed-Use General Plan and Development Code Text Amendments to modify the development standards for MX Districts and encourage new residential development. Additional standards were added under Section 15-1106 as part of this action. Under these provisions, all projects proposing residential development must prepare a Phase I Environmental Site Assessment (ESA) prior to site approval. In addition, all projects proposing to utilize fill material must conduct property soil testing to ensure the soil is free of contamination. Additional standards listed in Section 15-1106 include not overburdening any existing or planned infrastructure capacities, including, but not limited to, capacities for water, runoff, storm water, wastewater, and solid waste systems. Projects must also comply with all applicable standards from Public Works and the City Public Utility Services. The goal was that if the development complied with all of the items, further environmental analysis could be avoided and a system to process applications ministerially could effectively be established. ### Cumulative Impacts Conclusion The Development Code, like the General Plan, supports increased land use intensity and mixed-use development throughout the city, especially near transit. The cumulative impacts of Fresno’s development standards established in the Zoning Code do not unduly constrain achieving the densities permitted by the zones. The components of the City’s development standards are described as follows: * The Zoning Code allows multifamily residential properties in residential zones to have densities ranging from 12 dwelling units per acre to up to 45 dwelling units per acre. For multifamily residential developments in mixed-use zones, there is no maximum density. * There are no minimum lot area requirements for multifamily residential developments. * The City does not have maximum FAR requirements for residential uses in residential zones. In mixed-use zones FARs may range between 1.5 and 2.0. There is no maximum FAR requirement for projects in Downtown districts. * Parking requirements vary, with opportunities for reduced parking in infill areas and for affordable housing. * Multifamily residential developments have maximum height limits ranging from 35-60 feet. Mixed Use Districts have the following height limits: 40 feet in the NMX; 60 feet in CMX; and 75 feet in RMX. Height limits are: 90 feet in DTN (approximately 6 stories), 140 feet in DTG (approximately 10 stories), and 190 feet in DTC (approximately 15 stories). Table 1E-4.6 analyzes the cumulative impact of development standards on the ability to achieve maximum densities in the City’s multifamily zones. Each of the examples assumes a rectangular one-acre lot and applies the City’s setback, lot coverage, parking, and open space standards to determine if projects complying with City standards can achieve maximum densities. The analysis shows that development standards in the RM-1, RM-2, and RM-3 zones do not limit the ability to achieve maximum densities. There is sufficient excess site area remaining after application of the City’s development standards to allow the incorporation of additional project amenities that are not required, such as additional parking and open space features. ### Table 1E-4.6: Analysis of Multifamily Zone Requirements for Prototype Site Development | Development Standards | RM -1 Zone Standards | RM-2 Zone Standards | RM-3 Zone Standards | | :--- | :--- | :--- | :--- | | Prototype Project Site Size | 43,560 | 43,560 | 43,560 | | Net site size w/ required setbacks | 33,724 | 34,668 | 34,668 | | Maximum site volume at story limit | 101,173 | 138,672 | 173,340 | | Maximum lot coverage (Sq. Ft.) | 21,780 | 21,780 | 26,136 | | Maximum permitted density (units) | 16 | 30 | 45 | | 1 bedroom (900 sf) | 11 | 20 | 30 | | 2 bedroom (1,100 sf) | 5 | 10 | 15 | | Unit square footage total | 15,400 | 29,000 | 43,500 | | Unit square footage per story | 5,133 | 7,250 | 8,700 | | Parking requirement | | | | | 1-bedroom units @ 1.25 sp/unit | 14 | 25 | 38 | | 2-bedroom units @ 1.5 sp/unit | 7 | 15 | 22 | | Total parking required | 21 | 40 | 60 | | Square footage for surface parking @ 350 sq. ft/space[^p327-1] | 7,438 | 14,000 | 21,000 | | Open Space (sq. ft.) | 8,712 | 6,534 | 4,356 | | Total sq. ft to accommodate project[^p327-2] | 21,283 | 27,784 | 34,056 | | Total excess sq. ft. available[^p327-3] | 12,442 | 6,884 | 612 | [^p327-1]: 200 sf/space + 150 sp. Ft. of drive aisle per space [^p327-2]: Calculated at the net building sq. ft. of the first story + parking sq. ft. + open space sq. ft. [^p327-3]: Calculated as the net site size – total sq. ft. to accommodate the project Source: Ascent, 2023. The City’s development standards are reasonable and typical, allow for maximum densities to be achieved, and do not serve to constrain housing development. The recent mixed use text amendments greatly increased the capacity for residential development in commercial and mixed use zones throughout the city. SECTION 1E-4: CONSTRAINTS ## Recommended Action Development and zoning codes can facilitate the very types of development needed. Although the City’s land use controls are permissive and flexible, there are additional opportunities to relieve regulatory constraints and facilitate more housing production. Parking standards are one area where many communities are seeking to decrease housing costs. The Housing Element includes a program to identify further ways to facilitate increased housing production throughout the city, including establishing a non-discretionary process to approve qualifying developments based on size, type, affordability level, and location. ## Site Improvements ### Analysis Site improvements and property dedications are important components of new development and contribute to the creation of decent housing. Developers are generally responsible for covering the full cost of water, sewer, road, and drainage improvements within their projects. Typically, site improvements are requested during the planning review process. Improvement requirements are the same throughout the city of Fresno, however some sites require fewer improvements if the infrastructure already exists and is in good condition. Typical off-site infrastructure improvements for new projects include constructing new streets, which include undergrounding of utilities, parkway landscaping, curbs, gutters, sidewalks, and street lighting that are in compliance with standards as defined in the General Plan and the Municipal Code. Local residential streets require a dedication of 56 feet with a curb-to-curb width of 36 feet for a design with parking on both sides of the street (Public Works Standard P-56). In areas already served by infrastructure, site improvement requirements vary depending on the existing condition of each project site. Usually, only standard connection laterals are required for most project utilities. The undergrounding of utilities from the nearest pole to the project is required of all projects (although there is a process for the granting of waivers in hardship cases), and street tree planting may also be required. New subdivisions typically require public and circulation improvements for the orderly and efficient development of the community. As stated in the Municipal Code (Section 15-3804), site improvements for residential subdivisions include: * Grading of streets and alleys, installation of street lighting, drainage pipes or lines, and drainage structures. * Installation of sidewalks, curbs, gutters, and driveway approaches, unless the Standard Specifications for the Street Section do not require the improvements. * Surfacing of a width and quality suitable for the particular type of street or alley as established in specifications adopted therefore. * Pedestrian ways, including paving, landscaping, and fences and walls as may be required. * Bikeways as may be required. APPENDIX 1E: CITY OF FRESNO * Trails, greenways, or parks, as may be required. * A water system of sufficient design and capacity to furnish an adequate water supply for each lot in the subdivision and for adequate fire protection to the area, as determined by the City Engineer. * Sanitary sewer facilities and connections for each lot. * Services from all utilities for each lot, made in such manner that will avoid or minimize disturbance of completed street improvements. * The installation and planting of median islands, as may be required. * Street trees * Street signs * The installation of an underground street lighting system approved by the City Engineer, as required. Overall, the purpose of on- and off-site requirements is to ensure the health and safety of residents. On- and off-site improvements vary from about 5 to 20 percent of total development costs depending on the infrastructure improvements needed for the project. Developers indicated that costs in Fresno are equal or slightly higher than other communities, particularly for multifamily housing. In addition to its Inner City Planning Application Fee Incentive Program, the City of Fresno has several fee waiver programs that apply to infill development in economically disadvantaged areas. The most notable of these for affordable housing is the Infill Incentive Program, which has resulted in the waiver of approximately $3.5M in development impact fees for 10 infill projects totaling 603 residential units since 2021. The average fee waived per unit is $5,918, which can be the financial tipping point that allows affordable projects to attain economic feasibility. The Infill Incentive Program waives development impact fees for police and fire facilities, park facilities, regional streets, new growth streets and traffic signals for qualifying projects. # Conclusion On- and off- site improvements can be costly, but with the fee waiver programs available, infrastructure costs are not considered a major constraint to development, as the required infrastructure and public facilities are necessary to serve the project. While required on- and off-site improvements may add to the cost of housing, there is not evidence that these requirements and associated costs represent a significantly higher standard than other jurisdictions in the County and beyond. # Recommended Action None required. SECTION 1E-4: CONSTRAINTS # Zoning for a Variety of Housing Types ## Analysis The Development Code classifies residential development projects based on type, use, size, and location in order to determine whether the project is Permitted, Conditionally Permitted (through conditional use permit), or Not Permitted. The Development Code provides for a range of housing types, including single-family, multi-family, second dwelling units (i.e., accessory dwelling units), mobile homes, residential care facilities, emergency shelters, supportive housing, transitional housing, and single room occupancy (SRO) units. Refer to Table 1E-4.8 for a summary of Fresno’s Development Code as it relates to ensuring a variety of housing opportunities. ## Multifamily The Development Code allows multifamily units at varying densities in the following districts: Medium High Density (RM-1), Urban Neighborhood (RM-2), High Density (RM-3), Neighborhood Mixed Use (NMX), Corridor/Center Mixed Use (CMX), Regional Mixed Use (RMX), Downtown Neighborhood (DTN), Downtown General (DTG), Downtown Core (DTC), Commercial – Main Street (CMS), and Commercial - Regional (CR) districts. The Development Code and General Plan provide for a range of densities for multifamily in the RM districts (up to 45 units/acre without density bonus in the RM-3 district); and, in the Commercial, Mixed-Use, and Downtown districts with no density limits. ## Accessory Dwelling Units - Second Units, Backyard Cottages, and Accessory Living Quarters In Fresno, Second Dwelling Units, Backyard Cottages, and Accessory Living Quarters are permitted as accessory uses to single-unit dwellings, consistent with the Government Code Section 65852.2. State law refers to these housing types as accessory dwelling units (ADUs). The City’s Development Code contains the following descriptions of these permitted unit types: * **Second Dwelling Unit.** Provides separate, independent living quarters for one household. Units may be attached, detached, or located within the living areas of the primary dwelling unit on the lot. Kitchens, including cooking devices are permitted. * **Backyard Cottage.** May provide separate, independent living quarters for one household. Units may be attached, detached, or located within the living areas of the primary dwelling unit on the lot. Kitchens, including cooking devices are permitted. Backyard Cottages shall be located behind the primary dwelling unit, unless attached and integral to the primary dwelling unit. A Tiny House may be considered a Backyard Cottage. APPENDIX 1E: CITY OF FRESNO * **Accessory Living Quarters.** Accessory Living Quarters provide dependent living quarters. They may be attached, detached, or located within the living areas of the primary dwelling unit on the lot. Accessory Living Quarters may not provide kitchen facilities, however a bar sink and an under-counter refrigerator are allowed, but no cooking devices or other food storage facilities are permitted. Accessory Living Quarters shall not be located in front of the primary single-family dwelling. Regulations regarding development standards for Second Dwelling Units, Backyard Cottages, and Accessory Living Quarters are delineated in Section 15-2754 of the Development Code. Second dwelling units, backyard cottages, tiny houses, and accessory living quarters may be established on any lot in any residential district where single-unit dwellings are existing or permitted. Only one second unit, backyard cottage, tiny house, or accessory living quarters may be permitted on any one lot. Units shall conform to the height, setbacks, lot coverage and other zoning requirements of the zoning district in which the site is located. Minimum lot sizes for these developments are as follows: 6,200 square feet for Second Dwelling Units, 6,000 square feet for an interior lot and 5,000 square feet for a corner size lot for Backyard Cottages, and 5,000 square feet for Accessory Living Quarters. Minor deviations and/or variances to meet the minimum lot sizes are not permitted. Per State law, local governments may impose certain development standards on accessory dwelling units however, these standards should not include minimum lot size requirements. The City last updated its Second Dwelling Units, Backyard Cottages, and Accessory Living Quarters ordinance in 2018. New changes to State ADU Law became effective January 1, 2021, to further reduce barriers, streamline approval processes, and expand capacity to accommodate the development of ADUs and Junior ADUs. A program has been added to make further amendments to the ordinance to comply with State law. The City of Fresno’s ADU Program encourages the development of ADUs by offering a selection of pre-approved plans to homeowners (www.fresno.gov/ADU). The plans offer a variety of sizes and styles that will match the diversity of Fresno’s neighborhoods and the needs of households throughout the city. These plans can also be used to build small primary homes to help first-time buyers enter the housing market or assist those seeking to downsize. ### Senate Bill 9 Subdivisions Senate Bill 9 (SB 9) became effective January 1, 2022. The bill mandates local jurisdictions to ministerially approve two unit developments and urban lot splits within a single-family residential zone, without discretionary review or hearing, if the proposed development meets certain requirements. For SB 9 developments, the City may apply objective zoning, subdivision, and design standards. The City has developed a submittal checklist application for SB 9 projects. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-4-19 SECTION 1E-4: CONSTRAINTS ### Manufactured Housing State law requires local governments to permit manufactured or mobile homes to meet federal safety and construction standards on a permanent foundation in all single-family residential zoning districts (Section 65852.3 of the California Government Code). In Fresno, a manufactured/factory-built house is considered to be a single-family detached dwelling unit and is treated as such. ### Residential Care Facilities Residential Care Facilities Limited (those serving 6 or fewer clients) are allowed by right in all zones that allow residential uses subject to the same development standards and permit processing standards as other residential uses in those zones, pursuant to the California Lanterman Developmental Disabilities Services Act. Residential Care Facilities General (providing care for more than 6 persons) are permitted by right in the RM-2 and RM-3 districts and conditionally permitted in the residential single-family districts (RS-1 to RS-5), the RM-1 district, and in the CMS district. In order for the conditional use to be approved, the following findings must be made by the Director: * The proposed use is allowed within the applicable zoning district and complies with all other applicable provisions of the Development Code and all other chapters of the Municipal Code; * The proposed use is consistent with the General Plan and any other applicable plans and design guidelines the City has adopted; * The proposed use will not be substantially adverse to the public health, safety, or general welfare of the community, nor be detrimental to surrounding properties or improvements; * The design, location, size, and operating characteristics of the proposed activity are compatible with the existing and reasonably foreseeable future land uses in the vicinity; * The site is physically suitable for the type, density, and intensity of use being proposed, including access, emergency access, utilities, and services required; and * The proposed use is consistent with the Fresno County Airport Land Use Compatibility Plan (as may be amended) adopted by the Fresno County Airport Land Use Commission pursuant to California Public Utilities Code Sections 21670-21679.5. The City’s obligation to affirmatively further fair housing (AFFH) under CA Government Code Section 65580 requires that the findings for a conditional use permit for residential care facilities must be objective. To comply with Housing Element Law, including its AFFH provisions, the Housing Element includes a program to review the CUP findings to ensure they are objective and do not serve as a barrier to approving residential care facilities for more than six. If determined to be a barrier or subjective then the City will amend CUP findings for residential care facilities. The City will continue to allow reasonable accommodations in the permitting of residential care facilities. # Farmworker/Employee Housing The California Employee Housing Act requires that housing for six or fewer employees be treated as a regular residential use. The Employee Housing Act further defines housing for agricultural workers consisting of 36 beds or 12 units be treated as an agricultural use and permitted where agricultural uses are permitted. The Fresno Development Code defines Agricultural Labor Housing as living accommodations for employees and their immediate families employed for the exclusive purpose of agricultural pursuits either on the premises or off site. It includes single- or multi-unit dwellings, including mobile homes and dormitories. The definition does not place a limitation on the number of beds or units, and the Development Code states that in the event of a conflict between the Development Code and California Health and Safety Code Section 17021.6, relating to agricultural land use designations for employee housing, the Health and Safety Code would prevail. Agricultural labor housing is permitted by right in the Buffer (B) district. The Buffer District is intended to separate urban uses from commercial agricultural uses to preserve long-term viable agricultural areas and intensive farming operations in adjacent areas. The Buffer District serves to prevent urban residential and related uses from developing near agricultural operations, and thereby infringing on full operation of farmland of importance. While the definition of Agricultural Labor Housing and the allowance in the Buffer District are in compliance with State law, the Development Code allows agricultural uses, such as crop cultivation, in all single family and multifamily residential districts and therefore should allow Agricultural Labor Housing in these districts in order to fully comply with State law. In addition, the Employee Housing Act requires all employee housing for six or fewer occupants, not just agricultural labor housing, to be treated similar to any other residential use. The Fresno Development Code does not explicitly address this requirement. The previous 2015 Housing Element included a program directing City Staff to review the Development Code to ensure continued compliance with the Employee Housing Act. The Code was found to meet the requirements of the Employee Housing Act regarding Agricultural Labor Housing and no changes to the Development Code were determined to be necessary. However, in order to increase clarity between the Code and State law, the Housing Element includes a program to permit employee housing for six or fewer as a residential use and permit agricultural labor housing in all zoning districts where agricultural uses are permitted. SECTION 1E-4: CONSTRAINTS ## Transitional and Supportive Housing Under Housing Element law, transitional housing means buildings configured as rental housing developments, but operated under program requirements that require the termination of assistance and recirculating of the assisted unit to another eligible program recipient at a predetermined future point in time that shall be no less than six months from the beginning of the assistance (California Government Code Section 65582(h)). Supportive housing means housing with no limit on length of stay, that is occupied by the target population, and that is linked to an onsite or offsite service that assists the supportive housing resident in retaining the housing, improving his or her health status, and maximizing his or her ability to live and, when possible, work in the community. Target population means persons with low incomes who have one or more disabilities, including mental illness, HIV or AIDS, substance abuse, or other chronic health condition, or individuals eligible for services provided pursuant to the Lanterman Developmental Disabilities Services Act of the Welfare and Institutions Code and may include, among other populations, adults, emancipated minors, families with children, elderly persons, young adults aging out of the foster care system, individuals exiting from institutional settings, veterans, and people experiencing homelessness (California Government Code Sections 65582(f) and (g)). Accordingly, State law establishes transitional and supportive housing as a residential use and therefore local governments cannot treat it differently from other similar types of residential uses (e.g., requiring a use permit when other residential uses of similar function do not require a use permit). The City of Fresno Development Code (Section 15-2762) specifies that transitional and supportive housing constitute residential use and are subject only to those restrictions that apply to other residential uses of the same type in the same district. With the passage of AB 2162 (2018), Section 65651(a) of the Government Code now prohibits local governments from applying a conditional use permit or other discretionary review to the approval of 100 percent affordable developments that include a percentage of supportive housing units, either 25 percent or 12 units, whichever is greater, on sites that are zoned for residential use. While supportive housing is generally a permitted use in all zones, the City’s Development Code does not explicitly comply with this new requirement of state law. APPENDIX 1E: CITY OF FRESNO # Emergency Shelters Emergency shelters are allowed without discretionary review in the Regional Mixed-Use (RMX), Commercial – General (CG), Regional Business Park (RBP), Light Industrial (IL), Public and Institutional (PI), Downtown Neighborhood (DTN), Downtown General (DTG), and Downtown Core (DTC) zoning districts. State law (Government Code Section 65583) requires that the Housing Element demonstrate sufficient capacity to meet unmet housing needs for people experiencing homelessness. Chapter 654, Statutes of 2022 (AB 2339), added additional specificity on how cities and counties plan for emergency shelters. Generally, AB 2339 amended State Housing Element Law regarding identification of zones and sites for emergency shelters. Government Code Section 65583 (a)(4) now requires that the zoning designations identified to allow emergency shelters as a permitted use without discretionary review must allow residential uses. In addition, the Housing Element must identify specific sites that could accommodate emergency shelters. If a vacant site is zoned for a non-residential use but allows residential development, such as a mixed-use zone, the site must be located near amenities and services that serve people experiencing homelessness. If the site is nonvacant, the analysis must provide substantial evidence that the existing use is likely to be discontinued during the planning period. Table 1E-4.7 outlines a summary of vacant land by zoning district that could be utilized to develop an emergency shelter in Fresno. Based on the 2022 Point in Time (PIT) Count, the estimated unhoused population in the City of Fresno is 3,397. There are approximately 1,500 shelter beds available in the city on any given night. Thus, there is a net approximate need of 1,900 new emergency shelter beds to address the City of Fresno’s unmet needs. ### Table 1E-4.7: Summary of Potential Sites for Emergency Shelters, Fresno, 2023 | Zoning District | Number of Potential Sites for Emergency Shelters | Total Acreage (Acres) | Vacancy Status | Capacity (# of people) | | :--- | :--- | :--- | :--- | :--- | | DTC | 3 | 0.81 | Vacant | 176 | | DTG | 16 | 4.08 | Vacant | 889 | | DTN | 87 | 23.98 | Vacant | 5,224 | | DTN-AH | 2 | 0.61 | Vacant | 133 | | RMX | 25 | 63.65 | Vacant | 13,862 | | Total | 133 | 93.13 | - | 20,284 | *Source: City of Fresno, 2023. Ascent, 2023.* To comply with State law, the Housing Element only identifies vacant sites in zoning districts that allow residential use. As such, the sites identified in Table 1E-4.7 and Figure 1E-4.2 below are all in either the RMX, DTN, DTG, or DTC Districts, which allow residential and nonresidential mixed uses. A full list of these sites can be found in Table 1E-4.8 below. There is additional capacity for emergency shelter beds in the remaining nonresidential and industrial zones that allow emergency shelters by right, or without discretionary review (i.e., CG, RBP, LI, and PI districts). SECTION 1E-4: CONSTRAINTS This page intentionally left blank. Figure 1E-4.2: Potential Sites for Emergency Shelters, Fresno, 2023 <
> Source: Ascent, 2023. SECTION 1E-4: CONSTRAINTS This page intentionally left blank. APPENDIX 1E: CITY OF FRESNO Table 1E-4.8: Potential Sites for Emergency Shelters, Fresno, 2023 | APN | Address | Size (Acres) | Vacancy Status | Zoning | Capacity (# of people) | | :--- | :--- | :--- | :--- | :--- | :--- | | 41714021 | 614 W SAN JOSE AVE | 0.09 | Vacant | RMX | 229 | | 41723120 | 575 W SAN JOSE AVE | 0.43 | Vacant | RMX | 499 | | 41845014 | | 0.29 | Vacant | RMX | 1,202 | | 41806054 | 83 E BARSTOW AVE | 0.59 | Vacant | RMX | 514 | | 41808085 | | 0.34 | Vacant | RMX | 395 | | 41808082 | | 0.17 | Vacant | RMX | 515 | | 43602210 | | 0.17 | Vacant | RMX | 39 | | 43602228 | | 0.11 | Vacant | RMX | 67 | | 43619308T | | 0.21 | Vacant | RMX | 31 | | 43627015 | 2111 E DAKOTA AVE | 0.17 | Vacant | RMX | 154 | | 42464010 | 3441 W SHAW AVE | 0.34 | Vacant | RMX | 55 | | 42466004 | 3471 W SHAW AVE | 0.22 | Vacant | RMX | 49 | | 42466007 | 3421 W SHAW AVE | 0.48 | Vacant | RMX | 52 | | 42466005 | 3425 W SHAW AVE | 0.34 | Vacant | RMX | 48 | | 42466002 | 3477 W SHAW AVE | 0.17 | Vacant | RMX | 51 | | 41504440 | | 0.26 | Vacant | RMX | 185 | | 50803025 | | 0.28 | Vacant | RMX | 2,890 | | 50803004 | 5708 W SHAW AVE | 0.33 | Vacant | RMX | 1,211 | | 51203031 | | 0.55 | Vacant | RMX | 363 | | 51203038 | | 0.36 | Vacant | RMX | 363 | | 46504004 | 1454 G ST | 0.25 | Vacant | DTN | 169 | | 46504003T | 1416 G ST | 0.17 | Vacant | DTN | 131 | | 46504022ST | 1350 G ST | 0.06 | Vacant | DTN | 110 | | 46504021S | 1304 G ST | 1.55 | Vacant | DTN | 183 | | 46703023ST | 1266 G ST | 1.31 | Vacant | DTN | 72 | | 46703019ST | 1248 G ST | 1.47 | Vacant | DTN | 75 | | 46703025ST | 1206 G ST | 7.23 | Vacant | DTN | 148 | | 46706124T | 1535 FRESNO ST | 11.16 | Vacant | DTN | 73 | | 46706123T | | 0.22 | Vacant | DTN | 26 | | 46703017T | 1602 FRESNO ST | 0.02 | Vacant | DTN | 195 | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-4-27 SECTION 1E-4: CONSTRAINTS | APN | Address | Size (Acres) | Vacancy Status | Zoning | Capacity (# of people) | | :--- | :--- | :--- | :--- | :--- | :--- | | 46703004T | 1068 G ST | 0.03 | Vacant | DTN | 143 | | 46706211T | 1526 FRESNO ST | 0.28 | Vacant | DTN | 56 | | 46710305 | | 0.17 | Vacant | DTN | 45 | | 46706611 | 1427 TULARE ST | 0.08 | Vacant | DTN | 38 | | 46706613 | 1047 F ST | 0.18 | Vacant | DTN | 28 | | 46706334U | | 0.09 | Vacant | DTN | 94 | | 46706333 | 1042 F ST | 0.43 | Vacant | DTN | 19 | | 46706332 | | 0.29 | Vacant | DTN | 9 | | 46706330 | 1033 CHINA ALY | 0.59 | Vacant | DTN | 19 | | 46706329 | | 0.34 | Vacant | DTN | 38 | | 46706328 | | 0.17 | Vacant | DTN | 6 | | 46706326 | 1020 F ST | 0.17 | Vacant | DTN | 9 | | 46706325 | 1016 F ST | 0.11 | Vacant | DTN | 38 | | 46706319T | | 0.21 | Vacant | DTN | 16 | | 46706320 | | 0.17 | Vacant | DTN | 4 | | 46706338U | | 0.34 | Vacant | DTN | 57 | | 46706303U | | 0.22 | Vacant | DTN | 19 | | 46706304 | | 0.48 | Vacant | DTN | 9 | | 46706344 | 1034 CHINA ALY | 0.34 | Vacant | DTN | 60 | | 46706339 | | 0.17 | Vacant | DTN | 25 | | 46706311 | | 0.26 | Vacant | DTN | 19 | | 46706312 | 1022 CHINA ALY | 0.28 | Vacant | DTN | 56 | | 46706335 | | 0.33 | Vacant | DTN | 31 | | 46706337T | 1545 TULARE ST | 0.55 | Vacant | DTN | 18 | | 46706318T | | 0.36 | Vacant | DTN | 8 | | 46707412 | 950 E ST | 0.25 | Vacant | DTN | 75 | | 46707411 | | 0.17 | Vacant | DTN | 38 | | 46707202 | 811 G ST | 0.06 | Vacant | DTN | 263 | | 46707316T | 730 F ST | 1.55 | Vacant | DTN | 131 | | 46707305T | 723 G ST | 1.31 | Vacant | DTN | 19 | | 46707306T | | 1.47 | Vacant | DTN | 39 | | APN | Address | Size (Acres) | Vacancy Status | Zoning | Capacity (# of people) | | :--- | :--- | :--- | :--- | :--- | :--- | | 46708105T | | 7.23 | Vacant | DTN | 14 | | 46708123 | | 11.16 | Vacant | DTN | 10 | | 46708122T | | 0.22 | Vacant | DTN | 4 | | 46712118 | | 0.02 | Vacant | DTN | 19 | | 46712117 | 615 E ST | 0.03 | Vacant | DTN | 43 | | 46712112 | 625 E ST | 0.28 | Vacant | DTN | 34 | | 46712113 | 637 E ST | 0.17 | Vacant | DTN | 26 | | 46712115 | | 0.08 | Vacant | DTN | 28 | | 46827717 | 101 VAN NESS AVE | 0.18 | Vacant | DTN | 153 | | 46823527 | | 0.09 | Vacant | DTN | 261 | | 46827423 | | 0.43 | Vacant | DTN | 38 | | 46827109 | 2115 MONTEREY ST | 0.29 | Vacant | DTN | 54 | | 46827104 | 343 L ST | 0.59 | Vacant | DTN | 27 | | 46827105 | 333 L ST | 0.34 | Vacant | DTN | 36 | | 46823413 | 351 M ST | 0.17 | Vacant | DTN | 18 | | 46823113 | | 0.17 | Vacant | DTN | 37 | | 46830504 | 1804 SAN BENITO ST | 0.11 | Vacant | DTN | 54 | | 46705013ST | 555 H ST | 0.21 | Vacant | DTN | 319 | | 46829506 | 550 H ST | 0.17 | Vacant | DTN | 135 | | 46829205 | 514 BROADWAY | 0.34 | Vacant | DTN | 88 | | 46829301 | 461 FULTON ST | 0.22 | Vacant | DTN | 41 | | 46829319 | 447 FULTON ST | 0.48 | Vacant | DTN | 16 | | 46826209 | 511 L ST | 0.34 | Vacant | DTG | 36 | | 46822212T | 550 M ST | 0.17 | Vacant | DTG | 65 | | 46822215T | 525 N ST | 0.26 | Vacant | DTG | 56 | | 46822216T | 505 N ST | 0.28 | Vacant | DTG | 75 | | 46822301T | 461 N ST | 0.33 | Vacant | DTG | 38 | | 46822302T | 453 N ST | 0.55 | Vacant | DTG | 19 | | 46822319T | | 0.36 | Vacant | DTG | 38 | | 46819213T | 2504 VENTURA ST | 0.25 | Vacant | DTG | 33 | | 46819214T | 2518 VENTURA ST | 0.17 | Vacant | DTG | 65 | SECTION 1E-4: CONSTRAINTS | APN | Address | Size (Acres) | Vacancy Status | Zoning | Capacity (# of people) | | :--- | :--- | :--- | :--- | :--- | :--- | | 46819222 | 2526 VENTURA ST | 0.06 | Vacant | DTG | 31 | | 46819227 | 2534 VENTURA ST | 1.55 | Vacant | DTG | 25 | | 46821220T | 800 M ST | 1.31 | Vacant | DTG | 160 | | 46826117 | | 1.47 | Vacant | DTG | 38 | | 46826111 | | 7.23 | Vacant | DTG | 38 | | 46828607 | 702 H ST | 11.16 | Vacant | DTN | 38 | | 46825401 | 2030 TULARE ST | 0.22 | Vacant | DTC | 19 | | 46825402 | 2060 TULARE ST | 0.02 | Vacant | DTC | 94 | | 46620518T | 1408 H ST | 0.03 | Vacant | DTC | 64 | | 46611308 | 2301 FRESNO ST | 0.28 | Vacant | DTG | 128 | | 46608122 | 2528 TUOLUMNE ST | 0.17 | Vacant | DTN | 74 | | 46608104 | 1333 P ST | 0.08 | Vacant | DTN | 37 | | 46605512 | | 0.18 | Vacant | DTN | 37 | | 46605509 | 2615 MERCED ST | 0.09 | Vacant | DTN | 25 | | 46605607 | 2627 FRESNO ST | 0.43 | Vacant | DTG | 45 | | 46607101 | 75 N BLACKSTONE AVE | 0.29 | Vacant | DTN | 37 | | 46607406 | 1509 O ST | 0.59 | Vacant | DTN | 75 | | 45932701 | 1660 N ST | 0.34 | Vacant | DTN | 48 | | 45932702 | 2415 CALAVERAS ST | 0.17 | Vacant | DTN | 105 | | 46614209 | 1528 VAN NESS AVE | 0.17 | Vacant | DTN | 75 | | 46613418 | 2024 AMADOR ST | 0.11 | Vacant | DTN | 38 | | 46613213 | 1762 VAN NESS AVE | 0.21 | Vacant | DTN | 56 | | 46610332 | 14 N PARK AVE | 0.17 | Vacant | DTN | 62 | | 46613328 | 1845 VAN NESS AVE | 0.34 | Vacant | DTN | 72 | | 46604311 | 1045 U ST | 0.22 | Vacant | DTN | 119 | | 46604201 | 1050 S ST | 0.48 | Vacant | DTN- with Apartment House Overlay | 78 | | 46603505 | 2831 MARIPOSA ST | 0.34 | Vacant | DTN- with Apartment House Overlay | 55 | | 46823403 | | 0.17 | Vacant | DTN | 38 | | 46827501 | | 0.26 | Vacant | DTN | 12 | APPENDIX 1E: CITY OF FRESNO | APN | Address | Size (Acres) | Vacancy Status | Zoning | Capacity (# of people) | | :--- | :--- | :--- | :--- | :--- | :--- | | 41808086 | | 0.28 | Vacant | RMX | 338 | | 41808087 | | 0.33 | Vacant | RMX | 286 | | 41808083 | | 0.55 | Vacant | RMX | 320 | | 50803026 | | 0.36 | Vacant | RMX | 1,575 | | 50803005 | | 0.25 | Vacant | RMX | 2,431 | | 46710306 | | 0.17 | Vacant | DTN | 49 | | 46706327 | | 0.06 | Vacant | DTN | 3 | | 46706321 | | 1.55 | Vacant | DTN | 7 | | 46707307T | | 1.31 | Vacant | DTN | 61 | | 46827110 | | 1.47 | Vacant | DTN | 36 | | 46827121 | 347 L ST | 7.23 | Vacant | DTN | 18 | | 46823423 | 348 L ST | 11.16 | Vacant | DTN | 38 | | **TOTAL** | | **93.13** | | | **20,284** | *Source: City of Fresno and Ascent, 2023.* Per state law requirements, the capacity on each site was determined by dividing the square footage of the site by a minimum of 200 square feet per person. As shown in the table below, within the RMX, DTN, DTG, and DTC Districts, there is approximately 93.13 acres of vacant land available that could be developed into a new emergency shelter, which is a sufficient capacity to accommodate the need for 1,900 new emergency shelter beds. These sites are all located within close proximity to frequent transportation, employment opportunities, food, and other resources. Most sites are within walking distance to services and amenities (see **Figure 1E-4.1**). In addition to the same land use regulations and development standards that apply to all development within the identified districts (e.g., lot size, setbacks, building height), an emergency shelter proposed in these districts must comply with the following operational standards found in Section 15-2729 of the Development Code: * **Number of Residents.** The number of adult residents, not including staff, who may be housed on a lot that is smaller than one acre shall not exceed the number of persons that may be accommodated in any hospital, elderly and long term care facility, residential, transient occupancy, or similar facility allowed in the same district. * **Length of Occupancy.** Occupancy by an individual or family may not exceed 180 consecutive days unless the management plan provides for longer residency by those enrolled and regularly participating in a training or rehabilitation program. * **Outdoor Activities.** All functions associated with the shelter must take place within the building proposed to house the shelter, except for children's play areas, dog parks, outdoor recreation areas, SECTION 1E-4: CONSTRAINTS parking, and outdoor waiting. Outdoor waiting for clients, if any, may not be in the public right-of-way, must be physically separated from the public right-of-way, and must be large enough to accommodate the expected number of clients. * **Minimum Hours of Operation.** At least eight hours every day between 7 a.m. and 7 p.m. * **Employee Presence.** On-site employee presence must be provided at all times. * **Toilets.** At least one toilet must be provided for every 15 shelter beds, unless a greater number is required by State law. * **Management Plan.** The operator of the shelter must submit a management plan for approval by the Director. The Plan must address issues identified by the Director, including transportation, client supervision, security, client services, staffing, and good neighbor issues. Most of these requirements are in compliance with State law. However, the hours of operation are expressed incorrectly as shelters are operated at night, not during the day. Public comments also pointed to the standards for the toilets as being excessive. As shown in Table 1E-4.4 above, the parking requirements for emergency shelters is one (1) space per 500 square feet of floor area. As noted in that section, the Housing Element includes a program to amend parking requirements to achieve consistency with State law. The program also includes amending the Development Code to correct the hours of operation, review and confirm standards for toilets, and to ensure that all standards are compliant with State law. ### Low Barrier Navigation Centers Assembly Bill (AB) 101, passed in 2019, requires that a low barrier navigation center be a use permitted by right in mixed-use zones and nonresidential zones permitting multifamily uses if it meets specified requirements. AB 101 defines “low barrier navigation center” as a housing first, low-barrier, service-enriched shelter focused on moving people into permanent housing that provides temporary living facilities while case managers connect individuals experiencing homelessness to income, public benefits, health services, shelter, and housing. The Housing Element includes an implementation program to amend the Zoning Code to comply with this new requirement of Government Code Section 65662. ### Single Room Occupancy (SRO) Units Single room occupancy (SRO) hotels and/or boarding homes, which house between five and 15 guests, are collectively referred to as SROs in the City of Fresno Development Code. SRO units are one room units intended for occupancy by a single individual. It is distinct from a studio or efficiency unit, in that a studio or efficiency unit is a one-room unit that must contain a kitchen and bathroom. Although SRO units are not required to have a kitchen or bathroom, many SROs have one or the other. Buildings that provide SRO units are permitted by right in the CG zone and conditionally permitted in the RM-2, RM-3, NMX, CMX, and RMX districts. The Housing Element includes a program to review standards for SROs and evaluate objective design standards to ensure that units are maintained and safe for all residents long term. ## Summary Table 1E-4.9 summarizes the housing types permitted and conditionally permitted under the Development Code. ### Table 1E-4.9: Variety of Housing Types – Land Use Regulations | Uses | B | RE | RS-1 | RS-2 | RS-3 | RS-4 | RS-5 | RM-MH | RM-1 | RM-2 | RM-3 | NMX | CMX | RMX | CMS | CR | CG | DTN | DTG | DTC | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | Single-Unit Dwelling | P | P | P | P | P | P | P | - | P | - | - | P (1) | P (1) | P (1) | P(2) (4) | P(2) (4) | - | P | P | - | | Second Dwelling Units / Accessory Living Quarters | P | P | P | P | P | P | P | P | P | P | P | P (1) | P (1) | P (1) | P(2) (4) | P(2) (4) | - | P | P | - | | Duplex | - | - | - | - | - | - | C | - | P | P | P | - | - | - | - | - | - | P | P | P | | Multi-Unit Residential | - | - | - | - | - | - | C | - | P | P | P | P (1) | P (1) | P (1) | P(2) (4) | P(2) (4) | - | P | P | P | | Manufactured/ Mobilehomes | - | P | P | P | P | P | P | P | P | - | - | - | - | - | - | - | - | P | P | - | | Mobilehome Park | - | - | - | - | - | - | - | P | - | - | - | - | - | - | - | - | - | - | - | - | | Agricultural Labor Housing | P | - | - | - | - | - | - | - | - | - | - | - | - | - | - | - | - | - | - | - | | SRO | - | - | - | - | - | - | - | - | - | C | C | C | C | C | - | - | P | - | - | - | | Group Residential (six or fewer) | P | P | P | P | P | P | P | - | P | P | P | P (1) | P (1) | P (1) | P (3) | P(2) | - | P | P | P | | Group Residential (seven or more) | - | - | C | C | C | C | C | - | C | C | C | P (1) | P (1) | P (1) | P (3) | P(2) | - | P | P | P | | Residential Care Facilities, Limited (six or fewer) | P | P | P | P | P | P | P | - | P | P | P | P (1) | P (1) | P (1) | P (3) | P(2) | - | P | P | P | | Residential Care Facilities, General (seven or more) | - | - | C | C | C | C | C | - | C | P | P | - | - | - | C(3) | - | - | P | P | P | | Residential Care, Senior | - | - | - | - | - | - | - | - | C | P | P | P (1) | P (1) | P (1) | C (3) | - | - | P | P | P | | Emergency Shelter | - | - | - | - | - | - | - | - | - | - | - | - | - | P | - | - | P | P | P | P | Notes: P = Permitted; C = Requires Conditional Use Permit; “-” = Not Permitted 1 Not allowed on the ground floor within 200 feet of an intersection (measured from the lot line) of two or more major streets with the exception of main building entrances and active community spaces. Other high-activity uses may be approved at the discretion of the Review Authority. Projects with frontage on more than one major street may be excepted from this restriction on one of the major streets at the discretion of the Review Authority. 2 Not allowed on the ground floor along arterials or collectors. 3 Not allowed on the ground floor. 4 Housing projects shall meet the requirements of § 15-1104, § 15-1106, § 15-5102-E, and Table 15-1203-1 in the Development Code. Source: City of Fresno Development Code, 2022. SECTION 1E-4: CONSTRAINTS This page intentionally left blank. APPENDIX 1E: CITY OF FRESNO # Conclusion and Recommended Actions The following amendments to the City’s Development Code are required to address the provision of a variety of housing types The Housing Element includes implementation programs to amend the Zoning Code to address second, units, residential care facilities, and low barrier navigation centers in addition to tracking legislative changes. * **Accessory Dwelling Units:** The Development Code is not consistent with State law requirements for accessory dwelling units as new requirements became effective in 2021 including that no minimum lot sizes may be required and new guidance from the State has clarified that a local government must allow one (1) converted ADU, one (1) detached, new construction ADU, and one (1) JADU, in any order, totaling three units. The Code must be updated to achieve consistency with State law and expand capacity to accommodate the development of ADUs and JADUs. * **Residential Care Facilities:** The Development Code needs to be amended to permit community care facilities for more than six persons in all zones where other residential uses are permitted. * **Single Room Occupancy (SRO) Units:** The Development Code limits SROs to serve a maximum of 15 guests. This is a potential constraint and will be amended. * **Low Barrier Navigation Centers:** The Development Code is not consistent with State law requirements for Low Barrier Navigation Centers. * **Parking Requirements:** The Development Code is not consistent with State law requirements for parking for ADUs, emergency shelters, and supportive housing. * **Supportive Housing.** The Development Code does not explicitly comply with Government Code Section 65651(a) (i.e., AB 2162) requirements for affordable housing developments containing a specified percentage of supportive housing units. * **Farmworker and Employee Housing:** There is ambiguity between the Development Code and State law so the amendments are recommended to permit employee housing for six or fewer as a residential use and permit agricultural labor housing in all zoning districts where agricultural uses are permitted. # Density Bonus ## Analysis Under current state law (Government Code Section 65915), cities and counties must provide a density increase of 20 to 80 percent, determined on a sliding scale, over the otherwise maximum allowable residential density under the Municipal Code and the Land Use Element of the General Plan. In addition to the density bonus, eligible projects may receive one to four additional development incentives or concessions, depending on the proportion of affordable units and level of income targeting. These incentives/concessions could address a height limitation, a setback requirement, a floor area ratio, an on-site open-space requirement, or other requirements. State law also provides additional relief from parking requirements if requested by a developer for a density bonus project. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-4-35 SECTION 1E-4: CONSTRAINTS Article 22 of the City’s Development Code outlines the Density Bonus Ordinance that is in accordance with California Government Code Section 65915. Development Code Section 15-2202 states that “where conflict may occur between the provisions of this section and State law, the State law shall govern.” ### Conclusion and Recommended Action The City last updated the Density Bonus Ordinance in 2019 and it does not reflect the latest state law requirements, which require cities and counties to grant up to four incentives or concessions for density bonus projects that include 100 percent of units to low- or very low-income households. The Housing Element includes a program to update the City’s Density Bonus programs and monitor legislation from the State on density bonus requirements and maintain up-to-date marketing and educational materials such as website information or permit bulletins. ### Processing and Permit Procedures #### Analysis Processing and permit procedures can affect the time and cost of developing a residential project. Ineffective or unclear processing and permit procedures may also discourage a developer from taking on the risk of proposing a housing project altogether. #### Transparency in Development Regulations The City of Fresno complies with the requirement of providing transparency in development regulations. The Planning & Development page of the City website provides all necessary information on Planning and Building and Safety divisions (https://www.fresno.gov/darm/). The information on the website covers the following: * Long-range planning documents, including the General Plan, the City Development Code, and adopted community plans and specific plans * Permit requirements and development process * Planning applications, forms, and informational handouts * Schedule of fees * Property information * Efficiency and Incentive Programs #### Permit Processing Development review is conducted by the City of Fresno Planning and Development Department with responsibilities including current and advance planning functions. Current planning includes staffing the public counter to receive applications and answer questions, processing and analysis of various entitlements, permit issuance and corrected exhibit processing for public and private projects. It also involves providing engineering and technical staff support to commercial and residential projects. APPENDIX 1E: CITY OF FRESNO Advanced planning includes updates to the General Plan and Development Code, preparation of various community and specific plans, and special environmental, transportation, housing and demographic studies. This division also promotes regional planning coordination with various agencies. ### Primary Planning Permits and Actions The following table displays a brief summary of the permits and actions that are administered under the City’s Development Code (Table 1E-4.10). The table is not regulatory. For complete regulations, procedures, and requirements, see Articles 49 through 66 of the Municipal Code. ### Table 1E-4.10: Planning Permits and Actions* | Proposed Activity | Permit or Action Required | Type of Decision | Review Authority | | :--- | :--- | :--- | :--- | | **Use-Only Proposals** | | | | | Establishment of a (P) Permitted use, not associated with development of property | Zone Clearance | Ministerial | Director | | Establishment of a (C) Conditional use | Conditional Use Permit | Discretionary Quasi-Judicial | Director (PC on referral) | | Establishment of a Temporary use | Temporary Use Permit | Discretionary Quasi-Judicial | Director | | Establishment of use which is not listed in this Code | Director's Determination | Ministerial | Director | | **Development Proposals** | | | | | Development of one single-family home, duplex, or qualifying Downtown housing** which complies with all provisions of the Code | Zone Clearance | Ministerial | Director | | Development of property to a greater extent than is covered by a Zone Clearance | Development Permit (Formerly Site Plan Review) | Discretionary Quasi-Judicial | Director (PC on referral) | | Request for relief from property development standards due to unique conditions in conjunction w/a Development Permit | Variance | Discretionary Quasi-Judicial | Director (PC on referral) | | Request for relief from property development standards of 10% or less in conjunction with a Development Permit | Minor Deviation | Discretionary Quasi-Judicial | Director | | Innovative development proposal which does not comply with the provisions of any zone district within this Code | Planned Development Permit | Discretionary Quasi-Judicial | Director (PC on referral) | | **Other Proposals or Actions** | | | | | Formal interpretation of this Code, verifications of prior permits, or confirmation of zoning district | Zoning Inquiry | Ministerial | Director | | Minor changes to approved plans, consistent with original findings and conditions | Minor Modification | Ministerial | Director | | Change to discretionary permit or change to approved plans that would affect findings or conditions | Major Modification | Discretionary Quasi-Judicial | Review Authority of Original Permit | SECTION 1E-4: CONSTRAINTS | Proposed Activity | Permit or Action Required | Type of Decision | Review Authority | | :--- | :--- | :--- | :--- | | Violation of conditions or terms of permit | Revocation of Permit | Discretionary Quasi-Judicial | Director, PC, or CC | | Modifications of or exceptions from regulations to ensure equal access to housing for individuals with disabilities | Reasonable Accommodation for Housing | Discretionary Quasi-Judicial | Director | | Proposals to change a regulation within this Code | Development Code Text Amendment | Discretionary Legislative | CC | | Proposal for development which complies to regulations of an existing district, but not the one currently applied to the site | Rezone | Discretionary Legislative | CC | | Change of the General Plan land use designation for a site | Plan Amendment | Discretionary Legislative | CC | | Large, multi-phase project which needs certainty regarding regulations over time in exchange for public benefits | Development Agreement | Discretionary Legislative | CC | *For complete regulations, procedures, and requirements, see Articles 49 through 66 of the Municipal Code.* ** Downtown projects that meet all of the following criteria qualify for a Zone Clearance: * *Located within a DT District;* * *A minimum of 16 total dwelling units in the project;* * *A residential density of no less than 20 du/ac;* * *Residential uses must occupy 50 percent or more of the total floor area; and* * *No historic resources or potential historic resources are located on the site.* *PC = Planning Commission and CC= City Council* *Source: City of Fresno, Table 15-4907 of the Municipal Code, 2022.* ### Preliminary Application Process As of October 1, 2022, the Development Review Committee (DRC) Preliminary Application Review Process is voluntary, and a “formal” DRC Pre-Application is no longer required for most projects. Preliminary application review is required for subdivisions and voluntary for any project that requires a discretionary approval, including, but not limited to, Development Permits, Conditional Use Permits, Variances, Planned Developments, Rezones, General Plan Amendments, and Annexations. This affords a developer flexibility to determine the feasibility of a project prior to preparing detailed plans and paying the more extensive entitlement. The Fresno Planning and Development Department conducts the pre-application review every Tuesday as part of a Development Review Committee. ### Zone Clearance Zone Clearance is a ministerial, or non-discretionary, entitlement that is reviewed and approved at the staff level. A Zone Clearance is required to confirm that the project is being proposed in a manner which is compliant with, and without any deviations from, all applicable development standards prior to securing a building permit. The purpose of the Zone Clearance process is to streamline the review of many permitted uses. If a proposed development project does not meet the threshold for a Zone Clearance, it’s required to get a Development Permit. APPENDIX 1E: CITY OF FRESNO The City classifies Zone Clearance projects into Low-Level, Moderate-Level, and Major-Level Zone Clearances. Low Level Zone Clearance applies to projects that are typically approved “over-the-counter” and require confirmation by the Current Planning Division that the proposed business or use is consistent with applicable development or performance standards of the Development Code. Applicable uses could include a home occupation or a bed and breakfast – up to 2 rooms. A Low-Level Zone Clearance typically takes 1-7 business days for review if submitted digitally through Citizen’s Portal or the day of, if handled in person “over-the-counter.” Moderate-Level Zone Clearances applies to a single-family residence, duplex, or accessory dwelling unit (ADU) and typically takes 1 to 14 business days to review. Major-Level Zone Clearances apply to projects that typically require input from other internal departments or outside agency staff. To that end, the City’s review of Major-Level Zone Clearance applications requires additional analysis to determine consistency with other department or agency conditions as well as applicable development or performance standards of the Development Code. Certain projects requiring a Major-Level Zone Clearance may also include courtesy noticing to surrounding property owners. Applicable uses could include a streamlined multi-family development. A Major-Level Zone Clearance typically takes 30 business days for review. ### Conditional Use Permit, Variance, and Development Permit The Conditional Use Permit (CUP) is intended to apply to uses that are generally consistent with the purposes of the district where they are proposed but require special consideration to ensure that they can be designed, located, and operated in a manner that will not interfere with the use and enjoyment of surrounding properties or adversely affect the City's infrastructure, the built or natural environment, City resources, or the City's ability to provide public services. A CUP application is required for exceptions to certain development standards. In order for a CUP to be approved, the following findings must be made by the Director: * The proposed use is allowed within the applicable zoning district and complies with all other applicable provisions of the Development Code and all other chapters of the Municipal Code; * The proposed use is consistent with the General Plan and any other applicable plan and design guideline the City has adopted; * The proposed use will not be substantially adverse to the public health, safety, or general welfare of the community, nor be detrimental to surrounding properties or improvements; * The design, location, size, and operating characteristics of the proposed activity are compatible with the existing and reasonably foreseeable future land uses in the vicinity; * The site is physically suitable for the type, density, and intensity of use being proposed, including access, emergency access, utilities, and services required; and * The proposed use is consistent with the Fresno County Airport Land Use Compatibility Plan (as may be amended) adopted by the Fresno County Airport Land Use Commission pursuant to California Public Utilities Code Sections 21670-21679.5. SECTION 1E-4: CONSTRAINTS A Variance is a request to modify development standards due to special circumstances. Variances may be granted in conjunction with a Development Permit to vary or modify dimensional and performance standards, but Variances may not be granted to allow uses or activities or increase density that this Code does not authorize for a specific lot or site. Applications for a Variance shall be filed with the Planning Division then the Review Authority of the associated Development Permit shall approve, conditionally approve, or deny applications for Variances based on the following findings: * There are exceptional or extraordinary circumstances or conditions applicable to the property involved that do not apply generally to property in the vicinity and identical zoning classification, and that the granting of a Variance will not constitute a granting of a special privilege inconsistent with the limitations on the property in the vicinity and identical zone classifications; * The granting of the application is necessary to prevent a physical hardship which is not of the applicant's own actions or the actions of a predecessor in interest; * The granting of the application will not be detrimental or injurious to property or improvements in the vicinity, and will not be detrimental to the public health, safety, general welfare, or convenience, nor the preservation and conservation of open space lands; and * The granting of the Variance will be consistent with the general purposes and objectives of this Code, any applicable operative plan, the Fresno County Airport Land Use Compatibility Plan (as may be amended) adopted by the Fresno County Airport Land Use Commission pursuant to California Public Utilities Code Sections 21670-21679.5, and of the General Plan. A Development Permit (formerly Site Plan Review) is required for all new structures, with the exception of one single-family home, a duplex, or a qualifying Downtown housing project which complies with all provisions of the Development Code, which can be completed through a ministerial Zone Clearance. These permits are intended to ensure that projects can be designed, located, and operated in a manner that will not interfere with the use and enjoyment of surrounding properties or adversely affect the built or natural environment, the city’s infrastructure, city resources, or the City’s ability to provide public services. Applications are reviewed by Planning staff and are only considered by the Planning Commission or City Council by appeal. Processing normally does not exceed 60 business days; however, some decisions may be appealed to the Planning Commission, and in such instances, the processing time can be extended by as many as 30-45 business days. The Director or Planning Commission may only approve a Development Permit application if it finds that the application is consistent with the purposes of the Development Code and with the following: * The applicable standards and requirements of the Code. * The General Plan and any operative plan or policies the City has adopted. * Any applicable design guidelines adopted by the City Council. * Any approved Tentative Map, Conditional Use Permit, Variance, or other planning or zoning approval that the project required. APPENDIX 1E: CITY OF FRESNO * Fresno County Airport Land Use Compatibility Plan (as may be amended) adopted by the Fresno County Airport Land Use Commission pursuant to California Public Utilities Code Sections 21670—21679.5. ### Design Review Standards Site design development standards as well as façade development standards are incorporated into the Development Code for all districts. For mixed use and multifamily, the City provides applicants with a “certainty” option based on objective standards as well as a “flexibility” option if an applicant desires to deviate from objective standards. The standards for site designs are objective for the most part; however, there are some components of façade design standards that rely on the discretion of the Review Authority leaving room for subjectivity. For example, the Development Code states that windows, cladding, and finishing materials in residential single-family districts must be similar to, or within proportion of, adjacent homes. The Review Authority also has discretionary approval to determine the sufficiency of screening in multifamily developments. While the City’s standards are mostly objective, there are a few standards that could be modified to remove subjectivity. ### Subdivision, Tentative Parcel Map Review Subdivision of real property is initiated via the tentative tract or tentative parcel map process. Tentative maps are processed and approved in 75-90 business days when not being processed along with other entitlements such as Rezones or Plan Amendment applications. The final map process is essentially ministerial with major responsibility for prolonged processing resting with the developer and the developer’s engineer. ### Environmental Assessment An environmental assessment of a residential development is usually conducted simultaneously with the subdivision/parcel map review process or as special permits are processed. The assessment does not substantially add to overall processing time unless significant adverse environmental effects are determined, and evidence indicates that an EIR is required which can then take 9 to 12 months. Since the City of Fresno has certified a Program EIR (PEIR SCH No. 2019050005) for its General Plan and Development Code, some residential development is able to be streamlined by tiering from the citywide analysis of impacts associated with implementing the General Plan and Development Code. ### Annexation The City and County of Fresno continue to process annexations, in conjunction with a joint policy that all urban-intense development within the City’s Sphere of Influence is referred to the City for annexation and the processing of entitlements. The time necessary to process annexations on the urban fringe averages about one year, even with the City’s concurrent processing of entitlements policies. There is sufficient annexed and zoned land within the city to accommodate the housing needs for this Housing Element planning period. The City monitors land supply, underutilized parcels, areas planned for redevelopment, and resulting development to ensure a balance. SECTION 1E-4: CONSTRAINTS ### Historic Preservation Section 12 Article 16 of the Municipal Code codified the City’s Historic Preservation Ordinance. The overarching goal of the Historic Preservation Ordinance is to sustain historic resources, particularly their character-defining features. For this, there is a Historic Review process in place to consider project proposals. Under the provisions of the Ordinance, Historic Review is required for all demolition permit applications and all permit applications on a designated historic property. All permit applications that require Historic Review should be routed to the Historic Preservation Specialist through Current Planning or Building and Safety Services staff. The Pre-Application process is helpful for many to learn the general rules and procedures applicable to projects involving historic resources and can assist the applicant in determining whether a potential project is likely to be permissible under the Ordinance. Applicants are encouraged to have a pre-submittal meeting with the Historic Preservation Specialist prior to the submittal of application materials. The Specialist may approve, in the name of the Historic Preservation Commission (HPC), non-substantial alterations based on the application presented. Prior to submitting a formal application, applicants have the option of submitting conceptual plans to the Historic Preservation Commission for review and comment in order to seek advisement before moving forward in preparation for a proposed project. Initial review for all permit applications that require Historic Review could take up to 10 business days upon receipt by the Historic Preservation Specialist. Additional materials and further review may be required. ### Processing Timelines Considerable holding costs are associated with delays in processing development applications and plans. The City of Fresno’s development review process is designed to accommodate housing development applications of various levels of complexity and requiring different entitlements. Processing times vary with the complexity of the project. Single-family dwelling unit applications typically take 1 to 14 days if a single unit on one lot; 6 to 8 months if part of a subdivision. Multi-family development applications take 2 to 3 months through the Development Permit (previously Site Plan Review) process and an additional 14 to 21 days for building permits. Table 1E-4.11 shows the approval body and typical processing times for the City’s permitting and processing procedures. These timelines are consistent with the Permit Streamlining Act and are not considered a constraint on housing development. APPENDIX 1E: CITY OF FRESNO ### Table 1E-4.11: Timelines for Permit Procedures | Type of Approval or Permit | Typical Processing Time (# of Business Days) | Approval Body | | :--- | :--- | :--- | | Ministerial Review | 1-30 days, depending on Level | City Staff | | Conditional Use Permit | 30-90 days, depending on Level | Planning Director[^p355-1] | | Variance | 75-90 days | Planning Director [^p355-1] | | Minor Deviation Assessment | 1-14 days | Planning Director[^p355-1] | | Zone Change | 90-120+ days | City Council | | General Plan Amendment | 90-120+ days | City Council | | Tract Maps | 75-90 days | Planning Commission | | Parcel Maps | 75-90 days | Planning Director[^p355-1] | | Historic District Review | 10 days | Historic Preservation Commission | | Environmental Assessment | Categorical Exemption = 1-14 days Negative Declaration (ND) & Mitigated ND = 75-90 days Environmental Impact Report = 9-12 months | Same approval body as Type of Approval or Permit | [^p355-1]: Subject to appeal *Source: City of Fresno, 2023.* ### Typical Development Processing Procedures for Residential Projects Processing procedures vary by the residential use and the size of the proposed development. Residential development projects, based on type and size, are subject to one or more of the procedures listed above. The Planning and Development Department is responsible for application intake, plan checking, permit issuance, and inspection services for public and private projects. This Department provides public counter services, subdivision processing, urban growth management, various entitlements associated with development, and engineering and technical staff support to commercial and residential projects. The Current Planning Division and Building and Safety Services Division within the Department have as a primary objective the expeditious and accurate review of all development projects. For single-family developments, it typically takes up to 30 days for developers to pull building permits after receiving entitlements are approved. For multifamily developments, the time between entitlement approvals and building permit submittals is longer. Based on recent projects, it can take three months to a year for developers to pull building permits after entitlements are approved. To encourage development in the central, more urbanized parts of Fresno, the City provides priority processing to all projects within the boundaries of the Downtown Planning Area and in Inner City Residential areas. SECTION 1E-4: CONSTRAINTS Table 1E-4.12 generally identifies the typical approvals required for various residential projects along with the estimated processing times of the planning and building departments. ### Table 1E-4.12: Approvals and Processing Times for Typical Developments | Project Type | Typical Approval Requirements | Approval Body | Typical Processing Time (# of Business Days) | Number of Public Hearings | Findings | | :--- | :--- | :--- | :--- | :--- | :--- | | Accessory Dwelling Units | • Zone Clearance
• Building Plan Review
• Permitting
• Inspection | City Staff | Planning = 2 days

Plan Check = 14-21 days[^p356-2] | 0 | No findings required | | Single-Family | • Zone Clearance
• Building Plan Review
• Permitting
• Inspection | City Staff | Planning = 1-14 days

Plan Check = 14-21 days[^p356-2] | 0 | No findings required | | Multi-family | • DP/CUP[^p356-1]
• Building Plan Review
• Permitting
• Inspection | Development Permit: City Staff
CUP: City Staff or PC on referral | Planning = 75-90 days

Plan Check = 21 days[^p356-2] | 0-1 | Development Permit Required Findings (Sec. 15-5206)
Conditional Use Permit Required Findings (Sec. 15-5306) | | Subdivision | • Tentative Map
• Subdivision Review Committee
• Environmental Assessment
• Planning Commission
• Building Plan Review
• Public Works Plan Review
• Final Map
• Permitting
• Inspection | Planning Commission | Planning = 75-90+ days if no accompanying rezone or plan amendment application.

Plan Check = 14-21 days[^p356-2] | 1 | Tentative Maps required findings (Sec. 15-3309) | [^p356-1]: Subject to appeal. A CUP only applies when multifamily housing is proposed in the RS-5 (single family) zone district. [^p356-2]: Varies by sq. ft., building type, design, complexity and volume of workload; inspection times not included DP = Development Permit Source: City of Fresno, 2023. APPENDIX 1E: CITY OF FRESNO # Required Findings The following are the findings required for the various permit types identified in the table above: * **Development Permit Required Findings:** The Director or Planning Commission may only approve a Development Permit application if it finds that the application is consistent with the purposes of this article and with the following: A. The applicable standards and requirements of this Code. B. The General Plan and any operative plan or policies the City has adopted. C. Any applicable design guidelines adopted by the City Council. D. Any approved Tentative Map, Conditional Use Permit, Variance, or other planning or zoning approval that the project required. E. Fresno County Airport Land Use Compatibility Plan (as may be amended) adopted by the Fresno County Airport Land Use Commission pursuant to California Public Utilities Code Sections 21670—21679.5. * **Conditional Use Permit Required Findings:** A Conditional Use Permit shall only be granted if the decision-maker determines that the project as submitted or as modified conforms to all of the following criteria. If the decision-maker determines that it is not possible to make all of the required findings, the application shall be denied. A. The proposed use is allowed within the applicable zoning district and complies with all other applicable provisions of this Code and all other chapters of the Municipal Code; B. The proposed use is consistent the General Plan and any other applicable plan and design guideline the City has adopted; C. The proposed use will not be substantially adverse to the public health, safety, or general welfare of the community, nor be detrimental to surrounding properties or improvements; D. The design, location, size, and operating characteristics of the proposed activity are compatible with the existing and reasonably foreseeable future land uses in the vicinity; and E. The site is physically suitable for the type, density, and intensity of use being proposed, including access, emergency access, utilities, and services required; and F. The proposed use is consistent with the Fresno County Airport Land Use Compatibility Plan (as may be amended) adopted by the Fresno County Airport Land Use Commission pursuant to California Public Utilities Code Sections 21670-21679.5. * **Tentative Maps Required Findings:** A. Findings. The Review Authority may approve or conditionally approve a Tentative Parcel Map or Tentative Map if it makes all of the following findings: SECTION 1E-4: CONSTRAINTS 1. Consistency. The proposed subdivision, together with the provisions for its design and improvement, is consistent with the General Plan, any applicable operative plan, adopted policies or guidelines, and the Municipal Code. 2. Passive and Natural Heating and Cooling. A subdivision for which a Tentative Map is required shall provide pursuant to the Map Act (Section 66473.1), to the extent feasible, for future passive or natural heating or cooling opportunities in the subdivision. Examples of passive or natural heating opportunities in subdivision design include: a. Design of lot size and configuration to permit orientation of a structure in an east-west alignment for southern exposure and to take advantage of shade or prevailing breezes. Consideration shall be given to local climate, to contour, to configuration of the parcel to be divided, and to other design and improvement requirements, and such provision shall not result in reducing allowable densities or the percentage of a lot which may be occupied by a building or structure. b. The requirements of this section do not apply to condominium projects that consist of the subdivision of airspace in an existing building when no new structures are added. c. For the purposes of this section, "feasible" means capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors. 3. Availability of Water. Water will be available and sufficient to serve a proposed subdivision with more than 500 dwelling units in accordance with the Map Act (Section 66473.7). 4. Infrastructure Capacity. There exists sufficient infrastructure capacity for water, runoff, storm water, wastewater, and solid waste systems to serve the proposed subdivision. In cases where existing infrastructure is found to be deficient, plans shall show how sufficient capacity will be provided. 5. Compliance with Floodplain Regulations. The proposed subdivision is compliant with the City of Fresno Floodplain Management Ordinance and the State of California Code of Regulations Title 23, as well as any other applicable State or federal law. B. Supplemental Findings. In addition to the findings required for approval of a Tentative Map or Tentative Parcel Map by Subsection A above, the Review Authority shall not approve a Tentative Parcel Map or Tentative Map unless it can also make the following findings, when they are applicable to the specific subdivision proposal. 1. Construction of Improvements. It is in the interest of public health and safety, and it is necessary as a prerequisite to the orderly development of the surrounding area, to require the construction of improvements within a specified time after recordation of a Parcel Map of four or fewer parcels where improvements are required. 2. Condominiums. Any applicable findings required by Section 15-3913, Findings, for Condominium Conversions. 3. Dedications or Exactions. Any applicable findings required by Article 37, Dedications and Reservations, if dedications or exactions are required. 4. Waiver of Parcel Map. The findings required by Section 15-3503, Waiver of Parcel Map, if waiver of a Parcel Map has been requested with the Tentative Map application. ### Permit Streamlining The State Permit Streamlining Act (Government Code Section 65920) identifies timeframes for review of development applications. The Act also contains provisions that require cities to identify information needed for a complete application, and to provide follow-up information requests within certain timeframes. Government Code Section 66300 (Senate Bill 330, 2019) and Government Code Section 65913.4 (Senate Bill 35, 2017) also address permit processing streamlining. As described below, Senate Bill 330 applies to housing developments, including mixed-use projects with at least two-thirds of the square footage dedicated to residential. Senate Bill 35 established a streamlined ministerial approval process for qualified affordable housing projects or infill projects of 10 units or fewer. Both of these laws also establish specific timeframes for project approval. ### Senate Bill 330 Senate Bill 330 (SB 330) prohibits cities and counties from enacting a development policy, standard, or condition that would impose or enforce design standards that are not objective design standards on or after January 1, 2020 [Government Code Section 66300 (b)(C)]. The bill also established specific requirements and limitations on development application procedures. In addition, the legislation creates a preliminary application process. Submittal of a SB 330 preliminary application allows a developer to provide a specific subset of information on the proposed housing development before providing the full amount of information required by the local government for a housing development application. Submittal of the preliminary application secures the applicable development standards and fees adopted at that time. The project is considered vested, and all fees and standards are frozen, unless the project changes substantially. Currently (2023), the City offers an optional preliminary application checklist for all entitlement applications to advise a prospective applicant of current City standards and requirements. Pre-application meetings have helped to shorten the review process and allow for better communication between applicants, City departments, and utility providers. However, the City has not yet developed an SB 330 preliminary application form. The Housing Element includes a program to establish such an application to streamline processing procedures. The City has adopted objective design standards for multifamily districts, contained in Section 15-1005 of the Development Code. SECTION 1E-4: CONSTRAINTS ## Senate Bill 35 Government Code Section 65913.4 requires jurisdictions that have not approved enough housing units to meet their RHNA to provide a streamlined, ministerial entitlement process for housing developments that incorporate affordable housing. However, to be eligible, projects must also meet a long list of other criteria, including prevailing wage requirements for projects over 11 units. In order for applicants to take advantage of Senate Bill 35 (SB 35), per Government Code Section 65913.4 (10)(b)(1)(a)(et seq.) they need to submit a Notice of Intent and jurisdictions need to give Native American tribes an opportunity for consultation. Fresno accepts SB 35 applications consistent with the law. As of January 1, 2022, planners include the following note during the Development Review Committee (DRC) process for projects with more than 25 dwelling units: > *The City of Fresno encourages the development of safe, decent, and affordable housing. A streamlined development process may be available for affordable housing projects meeting certain criteria based on Senate Bill 35. For more information on affordable housing incentives please contact your project planner.* Approximately one applicant has requested SB 35 streamlining as of June 2023. Per HCD Guidelines, a local government that has been designated as subject to the Streamlined Ministerial Approval Process by the Department shall provide information, in a manner readily accessible to the general public, about the locality’s process for applying and receiving ministerial approval, materials required for an application as defined in Section 102(b) of the Streamlined Ministerial Approval Process Guidelines, and relevant objective standards to be used to evaluate the application. The Housing Element includes a program to establish written procedures for SB 35 streamlined ministerial approval and make them available on the City’s website. ## Conclusion and Recommended Actions The City's permit procedures do not unduly constrain housing development and average project review process timelines comply with the requirements of the Permit Streamlining Act. The City has made several updates to the development review process to simplify and enhance the process for applicants. The City also provides technical assistance and development incentives (e.g., Infill Incentive Fee Waivers) to make development cheaper and easier. For mixed use and multifamily, the city provides applicants with flexible site design development standards as well as façade development standards. The City attempts to run some processes and approvals concurrently where feasible to limit the approval time frame. Atypical projects are subject to any number of factors, many outside the control of the City, which may extend the processing time, including environmental review under CEQA and permitting requirements of other agencies. The City offers an optional preliminary application checklist for all entitlement applications which has helped to shorten the review process and allow for better communication between applicants, City departments, and utility providers. The City has been generally successful in executing priority processing for new projects in the Downtown Planning area, with approvals being issued on average in less than 75 days. Additionally, the City continues to provide impact fee waivers for qualifying projects and offers reduced application fees and priority processing for single-family and multi-family projects within the Inner City Fee Program area. While the City has made significant efforts to streamline the permitting process, there are still additional opportunities to streamline the process. The Housing Element includes programs to further streamline residential development, including exploring ways to approve housing for qualifying developments based on size, type, affordability level, and location, establishing a preliminary application process consistent with SB 330, preparing written procedures for SB 35 applications, and reviewing design standards to ensure objectivity and approval certainty. Local advocates commented that higher density development in Fresno is prone to local opposition which can slow down the approval of multi-family housing that requires a use permit. Programs to further streamline the development process can address this constraint. ## Building Codes and Enforcement ### Analysis The City currently uses the 2022 California Building Code. The 2023 edition will become effective on January 1, 2024. The 2022 California Residential Code (CRC) and the 2022 California Green Building Standards Code apply to single family residential projects as well as the following codes by reference: * 2022 California Mechanical Code; * 2022 California Plumbing Code; * 2022 California Electrical Code; and * 2022 California Energy Code The following codes apply to multi-family residential building projects: * 2022 California Building Code, * 2022 California Green Building Standards Code, * 2022 California Mechanical Code; * 2022 California Plumbing Code; * 2022 California Electrical Code; and * 2022 California Energy Code. SECTION 1E-4: CONSTRAINTS ## Amendments to the California Building Code Amendments to the California Building Code (CBC) per Section 11-102 of the Fresno Municipal Code are as follows: ### CBC Chapter 1 *103.1 Creation of the Enforcement Agency.* The Planning and Development Department of the City of Fresno is hereby established in the City of Fresno as the appropriate code enforcement agency that shall be under the administrative and operational control of the Department Director. *104.1 General.* The Director of the Planning and Development Department or his/her designee shall act on behalf of the City of Fresno as "Building Official." The Building Official is hereby authorized and directed to enforce all provisions of this code. The Building Official shall have the power to render interpretations of this code and to adopt and enforce rules and supplemental regulations in order to clarify the application of the code provisions. *109.2 Schedule of Fees.* All fees assessed in accordance with the provisions of the Fresno Building Code shall be set forth in the City of Fresno Master Fee Resolution. *109.5 Related Fees.* Where plans are of such complexity, incomplete, or are changed so as to require additional plan review time than contemplated by the fees set forth herein, an additional fee shall be shall be charged in accordance with the special services request provision under the Master Fee Resolution with the following exception: a) For commercial plans with multiple buildings of identical building footprints and floor plans, the plan review fee shall be as determined by the Building Official. The fee shall be based upon circumstances pertaining to the specific application and shall be designed to recover reasonable costs of the Development and Resource Management Department. *110.3.8 Other Inspections.* The Building Official may at his/her discretion require inspections of differing trades to be combined in proper chronological order consistent with construction practices to facilitate the use of combination inspection assignments. *112.1 Connection of Service Utilities.* Utility connections shall not be permitted until compliance with the provisions of the Fresno Municipal Code as set herein. Electrical Meter: Electrical meters shall be required to be in place and operational prior to final electrical inspection to facilitate testing and acceptance of the entire system. Installation of devices, fixtures, and wiring shall be completed and in working order for testing purposes. *112.2.1 Construction Utilities.* The Building Official may permit use of utilities for the purpose of construction provided no potential hazards to life or property is created and compliance with Article 590. CEC (Electrical) or Section 1208.0 CPC (Gas) is satisfied. APPENDIX 1E: CITY OF FRESNO 112.2 Temporary Power. The Building Official may permit use of utilities for temporary occupancy of a building or structure when circumstances exist to justify the issuance of a Temporary Certificate under Chapter 1 Section 111.3 of the CBC, and the owner enters into a security agreement with the City of Fresno, in a form approved by the Building Official, to insure completion of the required improvements. In addition, a deposit to secure such performance shall be made with the City of Fresno in an amount determined by the Building Official. The Building Official may, in his/her sole discretion, waive the requirement of a deposit. Section 113 Board of Appeals Note. Note: For additional requirements refer to Section 10-50108 of the Fresno Fire Code as established by the City of Fresno Fire Department. 113.1. General. In order to hear and decide appeals of orders, decisions or determinations by the Building Official relative to the application and interpretation of the Fresno Building Code, there shall be and is hereby created a board of appeals (hereafter referred to as the "Building Standards Appeals Board") consisting of members who are qualified by experience and training to pass on matters pertaining to building construction and who are not employees of the City of Fresno. The Building Standards Appeals Board shall perform the following appeal duties: a) Determine the suitability of alternate materials, engineering designs, methods of construction and equipment. b) Provide reasonable interpretations of the provisions of the Fresno Building Code and other relevant codes. c) Hear and decide appeals from the orders of the Building Officials directing the vacation, repair, rehabilitation or demolition of dangerous buildings under the provisions of Chapter 11, Article 3 of the Fresno Municipal Code as applicable to compliance to the provisions set forth in the Fresno Building Code and other relevant codes. d) Hear and decide appeals pursuant to the provisions of Section 10-50108 of the Fresno Municipal Code. e) Hear and decide appeals from orders of the Building Official directing the vacation, repair, rehabilitation or demolition of substandard buildings under the provisions of Chapter 11, Article 4 of the Fresno Municipal Code as applicable to compliance to the provisions set forth in the Fresno Building Code and other relevant codes. The Building Official shall serve as an ex officio member of and shall act as secretary to said board but shall have no vote on any matter before the board. The Building Standards Appeals Board shall be appointed by the Mayor and shall hold office at the pleasure of the Mayor. The Building Standards Appeals Board shall adopt rules of procedure for conducting its business, and shall render all decisions and findings in writing to the appellant with a duplicate copy to the Building Official. SECTION 1E-4: CONSTRAINTS 113.2.1 Limitations of Authority. The Building Standards Appeals Board shall have no authority relative to interpretation of the administrative provisions of this code nor shall the board be empowered to waive requirements of this code. 114.4.1 Violations. The person, firm, or corporation violating any of the provisions of this code shall be deemed guilty of a misdemeanor. CBC Chapter 9 Fire Protection Systems Note. Note: For additional requirements refer to Fresno Fire Code Section as established by the City of Fresno Fire Department. CBC Chapter 10 Section 1024 Luminous Egress Path Markings Note. Note: For additional requirements refer to Section 10-51024 of the Fresno Fire Code as established by the City of Fresno Fire Department. CBC Chapter 12 [1208.4] Efficiency dwelling units shall comply with the following: 1. The unit shall have a living room of not less than 150 square feet (13.9m 2) of floor area. An additional 100 square feet (9.3m 2) of floor area shall be provided for each occupant of such unit in excess of two. 2. The unit shall be provided with a separate closet. 3. The unit shall be provided with a kitchen sink, cooking appliance and refrigeration facilities, each having a clear working space of not less than 30 inches (762 mm) in front. Light and ventilation conforming to this code shall be provided. 4. The unit shall be provided with a separate bathroom containing a water closet, lavatory and bathtub or shower. CBC Title 24 Appendix O104 Title 24 Appendix O104 of the California Building Code regarding Emergency Sleeping Cabins was in Section 11-102 of the Fresno Municipal Code to read: APPENDIX 1E: CITY OF FRESNO A. General. Emergency sleeping cabins shall have an interior floor area of not less than 100 square feet (9.3 m 2) for a maximum of four occupants. Emergency sleeping cabins shall be limited to two occupants with an interior floor area of not less than 100 square feet (9.3 m 2) for the duration of any City-declared public health emergency. Where more than four persons occupy the cabin at any time, the required floor area shall be 70 square feet (6.5 m 2) for the first occupant and increased at the rate of 50 square feet (4.65 m 2) for each additional occupant. The interior floor area shall not exceed 400 square feet (37 m 2), excluding lofts. B. Live loads. Emergency sleeping cabins shall be designed to resist intrusion of wind, rain, and to support the following live loads: 1. Floor live loads not less than 40 pounds per square foot (1.92 kPa) of floor area. 2. Horizontal live loads not less than 15 pounds per square foot (718 Pa) of vertical wall and roof area. 3. Roof live loads not less than 20 pounds per square foot (958 Pa) of horizontal roof area. 4. In areas where snow loads are greater than 20 pounds per square foot (958 Pa), the roof shall be designed and constructed to resist these additional loads. C. Minimum ceiling height. Habitable space and hallways in emergency sleeping cabins shall have a ceiling height of not less than 80 inches (2,032 mm). Bathrooms, toilet rooms, and kitchens, if provided, shall have a ceiling height of not less than 76 inches (1,930 mm). Obstructions shall not extend below these minimum ceiling heights including beams, girders, ducts, lighting and other obstructions. Exception: Ceiling heights in lofts constructed in accordance with Section N108 are permitted to be less than 80 inches (2,032 mm). D. Means of egress. Emergency sleeping cabins shall be provided with at least two forms of egress placed remotely from each other. One form of egress may be an egress window complying with Section 0104.4.1. When a loft is provided, one form of egress shall be an egress window complying with Section 0104.4.1, provided in the loft space. E. Egress window. The bottom of the clear opening of the egress window shall not be more than 44 inches (1,118 mm) above the floor. The egress window shall have a minimum net clear opening height of 24 inches (610 mm), and a minimum net clear opening width of 20 inches (508 mm). The egress window shall have a minimum net clear opening area of five square feet (0.465 m 2). F. Plumbing and gas service. If an emergency sleeping cabin contains plumbing or gas service, it shall comply with all applicable requirements of the California Plumbing Code and the California Mechanical Code. G. Electrical. Emergency sleeping cabins shall be provided with all of the following installed in compliance with the California Electrical Code: 1. Continuous source of electricity. Exception: The source of electricity may be solar power or emergency generator. SECTION 1E-4: CONSTRAINTS 2. At least one interior lighting fixture. 3. Electrical heating equipment listed for residential use and a dedicated receptacle outlet for the electrical heating equipment. Exception: Electrical heating equipment and a dedicated receptacle outlet for said equipment are not required if a nonelectrical source of heat is provided. 4. At least one GFCI-protected receptacle outlet for use by the occupant(s). H. Ventilation. Emergency sleeping cabins shall be provided with means of ventilation (natural and/or mechanical) allowing for adequate air replacement, as determined by the enforcing agency. I. Smoke alarms. Emergency sleeping cabins shall be provided with at least one smoke alarm installed in accordance with the California Residential Code, Section R314. J. Carbon monoxide alarms. If an emergency sleeping cabin contains a fuel-burning appliance(s) or a fireplace(s), a carbon monoxide alarm shall be installed in accordance with the California Residential Code, Section R315. ### Amendments to the California Mechanical Code Amendments to the California Mechanical Code (CMC) per Section 11-106 of the Fresno Municipal Code are as follows: #### CMC Chapter 9 *936.0 Wood-burning Appliances* *936.1 Definitions.* Whenever the following terms are used in Section 933, they shall have the following meanings: a) EPA shall mean the United States Environmental Protection Agency. b) EPA CERTIFIED WOOD HEATER shall mean any wood heater that meets or exceeds combustion emissions standards set forth in the Code of Federal Regulations, Title 40, Part 60, 26 February 1988. c) FIREPLACE shall mean any masonry or factory-built device to burn wood, composition fire logs, or other solid fuel, with or without a gas log or log lighter, which may have a firebox in excess of 20 cubic feet, which may weigh in excess of 800 kilograms, and which is not a pellet-fueled wood stove. d) FIREPLACE INSERT shall mean a type of wood heater which is designed to be installed in the opening of a wood-burning fireplace and is connected to the chimney. e) NEW CONSTRUCTION shall mean any construction or reconstruction or remodeling of any structure requiring the issuance of a building permit by the City of Fresno. f) PELLET-FUELED WOOD STOVE shall mean any commercially manufactured enclosed combustion appliance that is designed to operate on automatically fed pelletized wood fuel and has a usable firebox volume of less than 20 cubic feet. g) MANUFACTURED FIREPLACE shall mean any fireplace that is of unitary commercial manufacture and is not synthesized on site of masonry construction components. h) STATE OF OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY STANDARDS shall mean the performance and emission standards set forth in Sections 100 through 190 of Chapter 340, Division 21, Oregon Administrative Rules. i) WOOD-BURNING APPLIANCE shall mean any device that is designed or used to burn wood, composition wood pellets, or composition fire logs for aesthetic, space heating, cooking, and/or water heating purposes within a structure; to include fireplaces, pellet-fueled wood stoves, and wood heaters. j) WOOD HEATER shall mean a commercially-manufactured, enclosed wood-burning appliance that meets all the following criteria: 1) A usable firebox volume of less than 20 cubic feet; and 2) A maximum weight less than 800 kilograms, exclusive or chimney and other accessory devices that are not an integral part of the appliance; and 3) A combustion air-to-fuel consumption ratio which averages less than 35-to-1, as determined by EPA certification test procedures set forth in code of Federal Regulations, Title 40, Part 60, 26 February 1988; and 4) A minimum burn rate with less than five kilograms per hour fuel consumption, as determined by EPA certification test procedures set forth the Code of Federal Regulations, Title 40, Part 60, 26 February 1988. 936.1.1 All Wood-burning Appliances Prohibited in New Construction. Notwithstanding any other provision in the Fresno Municipal Code, no wood burning appliance, as defined herein, shall be installed in any new construction. This section shall not apply to any residential structure or dwelling unit having a lawfully installed wood burning appliance in place as of the effective date of this ordinance. 936.2 Installation of Wood-burning Appliances not permitted in Higher Density Residential Developments. Permits shall not be issued for wood-burning appliances to be installed in dwelling units of residential projects that have densities of more than 10.37 dwelling units per gross acre. However, one wood-burning appliance may be constructed or installed in each common-use recreation facility in these developments. SECTION 1E-4: CONSTRAINTS 936.3 Wood-Burning Appliances Require Air Pollution Emissions Certification. Permits shall be issued only for replacement of existing wood burning appliances lawfully installed prior to the effective date of this ordinance and be issued only for those wood burning appliances certified by the U.S. Environmental Protection Agency (EPA) as meeting the EPA Phase I or Phase II emissions standards; or meeting equivalent State of Oregon Department of Environmental Quality Standards. Effective March 1, 1991, all wood burning appliances to be installed must be EPA-certified as at least meeting Phase II emissions standards. A permit shall only be issued for installation of a wood burning appliance when adequate EPA-approved documentation is provided to demonstrate that the wood burning appliance or fireplace stove model being installed has the appropriate emissions certification. EXCEPTION: Those pellet-fueled wood stoves not affected by EPA's testing program under the Code of Federal Regulations Title 40, Part 60, Sub-installation by substituting independent, approved, nationally-recognized testing laboratory documentation showing that they emit less than 4.1 grams per hour of particulate matter. 936.4. Coal-burning Appliances Prohibited. No permit shall be issued to install any fireplace or domestic heating or cooking appliance that is designed and intended to use coal as combustion fuel. 936.5. Installation of Wood-burning Appliances Without Permits. Wood-burning appliances found to be installed on or after November 30, 1990, without required permit(s) shall be cause for an inspection/investigation fee to be charged to the property owner, pursuant to the Master Fee Resolution, and the issuance of a notice to abated (required permits secured, all work completed, and permit final inspection done) within sixty days of owner's receipt of the notice, 75% of the inspection/investigation fee shall be rebated. If permit(s) were secured to abate the illegal installation, prior to discovery of the illegal installation by the City, no notice shall be issued nor inspection/investigation fee incurred unless the permit(s) to abate the nuisance are not finalized within 90 days. ### Amendments to the California Plumbing Code Amendments to the California Plumbing Code (CPC) per Section 11-106 of the Fresno Municipal Code are as follows: #### CPC Chapter 6 604.0 Materials 604.1 Pipe, Tube, and Fittings. The third paragraph of section 604.1 of the California Plumbing Code is hereby deleted in its entirety and amended to read: Materials for building water piping and building supply piping shall be in accordance with the applicable standards referenced in Table 604.1. Galvanized malleable iron, galvanized wrought iron or galvanized steel are prohibited materials for use both underground and in buildings. # Code Enforcement The Code Enforcement Division enforces the City’s Minimum Housing Code, which covers safety and livability requirements in housing by processing a variety of cases ranging from public nuisance to zoning. Code Enforcement has specialty teams as well as area teams that respond to complaints and possess specialized training to enforce violations. The City of Fresno recently switched to a more proactive code enforcement system. They require all rental property owners to register in a public database and subject all units to a baseline inspection and regular follow ups thereafter. To promote quality neighborhoods and reporting of potential violations, the City of Fresno encourages residents to use the “FresGO” app and by calling 3-1-1, which allows residents to anonymously report issues, concerns, track requests, provide comments, and learn about city services. All complaints are addressed based on their priority level, with the most dangerous cases getting the most urgent response. The City of Fresno also created the “Quality Neighborhoods Guide” to provide residents with facts about City requirements and identifies the 15 most common violations, to encourage voluntary compliance among property owners. The City works to bring code violation(s) to the attention of the responsible party, typically the property owner. A reasonable amount of time is provided to resolve the violation. Compliance at this stage is referred to as voluntary compliance. Voluntary compliance takes minimal City resources and is often achieved quickly because the property owner is responsive. In the case of unresponsive property owners, however, the City often takes enforcement action, using one or more of the following approaches to achieve compliance: Administrative Citations, Penalties, Abatement by Contractor, Court Appointed Receivership, Property Liens, Judicial Remedies, Referrals, etc. # Conclusion Local amendments to the California Building Code, California Mechanical Code, and California Plumbing Code do not pose a significant constraint to the production of housing in the city. # Recommended Action None needed. # Fees and Exactions ## Analysis Housing construction imposes certain short- and long-term costs upon local government, such as the cost of providing planning services and inspections. As a result, the City relies upon various planning and development fees to recoup costs and ensure that essential services and infrastructure are available when needed. In addition to local planning departments, developers must also work through the Air District, Water Districts, School District and sometimes Local Agency Formation Commissions (LAFCO) to obtain entitlements for construction of housing. Each additional Agency requirement adds cost to the project and ultimately the housing unit. The time necessary for processing these requirements also raises housing cost. Coordination and simultaneous processing among agencies should assist in reducing processing time and cost. SECTION 1E-4: CONSTRAINTS ## Planning and Development Fees Typical City fees related to planning and development are summarized in Table 1E-4.13 below. Fees are updated every July 1. Table 1E-4.13: Fees for Residential Development as of July 1, 2022 | Application Type | Fee | | :--- | :--- | | **Addressing** | | | Assignment - Parcel Map | $248.47 | | Assignment - Tract Map first 50 lots or less | $528.01 | | Assignment - Tract Map per ea. Additional 50 lots or less | $207.43 | | Change of Address | $264.00 | | **Annexations** | | | Inhabited | $13,653.836 | | Uninhabited | $10,137.49 | | **Conditional Use Permit – Standard (1)(2)** | | | New Application/Full Review | $12,878.46 | | Amendment | $5,648.33 | | Major Revised Exhibit | $2,937.31 | | Moderate Revised Exhibit | $590.12 | | Minor Revised Exhibit | $207.43 | | **Conditional Use Permit – Special (1) (2)** | | | Condominium Conversion – Base Fee | $24,825.13 | | Per 100 unit fee | $4,137.53 | | **Development Permit (1)(2)** | | | New Application/Full Review | $11,730.38 | | Amendment | $7,447.54 | | Major Revised Exhibit | $2,937.31 | | Moderate Revised Exhibit | $590.12 | | Minor Revised Exhibit | $186.36 | | **Plan Amendment (2)** | | | Plan Amendment – New application | $20,170.70 | | Plan Amendment & Rezone Combo | $22,239.46 | | Plan Mod – Change to plan in process | $5,596.19 | | Traffic Review | $163.00 | | **Tentative Parcel Maps** | | | Technical Verification | $3,103.69 | | *Credited to base fee upon acceptance* | | | Tentative Map (5 or more lots) | $8,275.04 | APPENDIX 1E: CITY OF FRESNO | Application Type | Fee | | :--- | :--- | | Tentative Parcel Map (4 or less lots) | $6,206.28 | | Traffic Review (Level 3) | $518.00 | | Traffic Review (Level 4) | $1,036.00 | | Fire Review | $134.00 | | Parks, Recreation & Community Review | $31.00 | | Revised Parcel Map – Major | $1,655.01 | | Revised Parcel Map – Minor | $827.50 | | Time Extension/Continuation at request of applicant | $2,068.76 | | Revised Conditions – Major | $2,482.51 | | Revised Conditions – Minor | $827.50 | | **Tentative Tract Maps** | | | Technical Verification | $4,344.95 | | *Credited to base fee upon acceptance* | | | Base Fee (per map) | $21,928.87 | | Lot Fee (per each 50 lots) | $8,275.04 | | *Charged in addition to the Base Fee* | | | Traffic Review (Level 3) | $518.00 | | Traffic Review (Level 4) | $1,036.00 | | Fire Review (per review) | $134.00 | | Parks, Recreation & Community Review | $124.00 | | Revised Tentative Tract Map – Major | $12,412.57 | | Revised Tentative Tract Map – Minor | $4,137.53 | | Time Extension/Continuation of Scheduled Item (at the request of the applicant) | $5,586.21 | | Revised Conditions – Major | $2,482.51 | | Revised Conditions – Minor | $827.50 | [^p371-1]: Fees listed are base amounts. Additional DP and CUP Application Review Fees and Environmental Review and Related Fees apply. [^p371-2]: Fees listed shall be reduced by 50% for applications in inner-City areas. In the Herndon Townsite, Highway City and Pinedale areas, fees shall only be reduced for residential uses and properties. No inner-City fee reduction will be applied to applications filed by government agencies. [^p371-3]: No additional environmental review fees shall be charged, unless it is determined that a higher level of review than an exemption is required. [^p371-4]: Fees are updated every July 1st based on CPI. Source: City of Fresno, 2022. SECTION 1E-4: CONSTRAINTS ## Urban Growth Management Fees Urban Growth Management (UGM) fees apply to residential projects located on the geographic fringe of the city. The process is not intended to prevent development, but it does preclude inordinate costs to the City and limits disorganized growth. The process is specifically intended to ensure adequate municipal facilities, improvements, and services are available when needed, and to protect the city and its residents by minimizing costs. ## Fee Exemptions and Reductions To reduce some of the costs associated with residential development, the City offers various exemptions and reductions in fees. The City’s Fee waiver program permits the exemption of development impact fees when a “small residential development” is replaced or reconstructed, if the development is substantially similar to the unit being replaced or reconstructed and the replacement or reconstruction does not significantly expand or intensify the use of the property. Applications for fee exemption must be submitted to the Director of Public Works. To incentivize infill development, the City reduces application fees by 50 percent on properties in the following core neighborhoods: existing neighborhoods south of Herndon Avenue, Bus Rapid Transit (BRT) corridors, and in the Downtown Planning Area. In Herndon Townsite, Highway City, and Pinedale areas, these reduced fees are limited to residential projects. ## Typical Fees for Residential Projects Development impact fees provide a mechanism for development projects to contribute financially to the cost of improving and expanding the infrastructure and facilities needed to accommodate that development. Fees are a one-time, non-recurring revenue source paid at the start of a development project, typically at building permit issuance. Although development fees help support vital local services to serve incoming residents, locally imposed fees for new residential projects can be a potential constraint as it can be an expensive component of development. Table 1E-4.14 shows the assessed fees for three examples of typical residential developments, including a 90-lot single family subdivision, a 105-unit multifamily housing development in a new growth area, and a 42-unit multifamily housing development in an infill area. In addition to City fees, several regional fees are charged for development: Fresno Metropolitan Flood Control District, San Joaquin Valley Air Pollution Control District (SJVAPCD), Regional Transportation Mitigation and local school districts. For school fees, the Fresno Unified School District fees for residential construction is $4.79 per square foot (as of June 15, 2022); and the fees for Clovis Unified School District are $4.79 per square foot for level 1 residential construction such as residential additions/remodels and $5.36 per square foot for level 2 development including residential new construction and multi-family developments (as of July 1, 2022). Fees for the 90-lot single family subdivision total $2,315,746 ($25,731 per unit); fees for the 105-unit multi-family development total $1,934,333 ($18,422 per unit); and fees for the 42-unit multifamily infill development total $602,450 ($14,344 per unit). Table 1E-4.14: Fees for Sample Residential Developments | Fee | Estimated Fee per Unit | | | | :--- | :--- | :--- | :--- | | **Project Type** | **90 Lot Single-Family Residential** | **Multi-family - Apartments (New Growth Area)** | **Multi-family - Apartments (Infill)** | | Total Number of Units | 90 | 105 | 42 | | Entitlement Permit Processing | $ 38,455 | $15,679 | $ 9,722 | | Water Connection Charges | $547,698 | $124,136 | $58,873 | | Sewer Connection Charges | $319,320 | $113,985 | $ 0 | | **Citywide/Regional Impact Fees** | | | | | Fire Facilities Impact Fee | $205,650 | $183,015 | $ 62,370 | | Park Facility Impact Fee | $320,940 | $404,460 | $ 132,594 | | Quimby Parkland Dedication Fee | $138,780 | $ 0 | $ 0 | | Citywide Regional Street Charge | $160,431 | $121,083 | $ 44,773 | | New Growth Area Major Street Charge | $366,135 | $379,310 | $ 0 | | Police Facilities Impact Fee | $85,320 | $75,915 | $ 20,328 | | Traffic Signal Mitigation Impact Fee | $68,580 | $62,055 | $ 15,228 | | *Subtotal Citywide/Regional Impact Fees* | *$980,121* | *$1,225,838* | *$275,293* | | Fresno Metropolitan Flood Control District (Drainage Fees + Service Charges) | $243,801 | $30,713 | $12,000 | | School Fee | $ $185,789 | $324,900 | $177,000 | | San Joaquin Valley Air Pollution Control District (SJVAPCD) | $ 562 | $562 | $562 | | Regional Transportation Mitigation Fee | $ 190,620 | $98,520 | $69,000 | | **Total** | **$2,315,746** | **$1,934,333** | **$602,450** | | **Cost per Unit** | **$25,731** | **$18,422** | **$14,344** | *Source: City of Fresno, 2023.* ### Conclusion and Recommended Action The City works to reduce fees to the extent feasible. Fees for entitlement permit processing constitute approximately 2 percent of the total costs. School and regional impact fees make up 20 to 25 percent of the total costs except for the infill example in which school and regional impact fees made up more of the total costs. Generally, fees do not serve to constrain housing development in Fresno. The City will continue to provide reduced application fees and priority processing for single-family and multi-family projects within the Inner City Fee Program area, as referenced in the Municipal Code, to create housing units in infill areas. In addition, the City will continue to offer impact fee waivers for qualifying infill projects in priority areas. As the City explores additional strategies to increase housing production, the City will consider the reduction or modification of fees. SECTION 1E-4: CONSTRAINTS ## Constraints on Housing for Persons with Disabilities Persons with disabilities have a number of housing needs related to accessibility of dwelling units; access to transportation, employment, and commercial services; and alternative living arrangements that include on-site or nearby supportive living services. Government Code Section 65583(a) and (c) requires municipalities to analyze potential and actual constraints upon the development, maintenance, and improvement of housing for persons with disabilities, and demonstrate local efforts to remove governmental constraints that hinder the locality from meeting the need for housing for persons with disabilities. Cities are required to include programs that remove constraints and provide reasonable accommodation for housing designed for persons with disabilities. ## Analysis ### California Codes and Regulations The City has adopted Title 24 of the California Code of Regulations, and the 2019 California Building Code. The 2022 codes are adopted and will be effective on January 1, 2023. ### Definition of Family There are a number of state and federal rules that govern the definition of family, including the Federal Fair Housing Amendments Act of 1988, the California Fair Housing and Employment Act, the California Supreme Court case City of Santa Barbara v. Adamson (1980), and the California Constitution privacy clauses. The laws surrounding the definition of family have a few primary purposes: to protect people with disabilities, to protect nontraditional families, and to protect privacy. According to HCD and Mental Health Advocacy Services, there are three major points to consider when writing a definition of family: * Jurisdictions may not distinguish between related and unrelated individuals. * The definition may not impose a numerical limit on the number of persons in a family. * Land use restrictions for licensed group homes for six or fewer individuals must be the same as those for single families. Although the City’s Zoning Districts use "Single-Family" terminology, the Development Code does not define “family.” Section 15-6702 of the Municipal Code references single-unit and multi-unit dwellings as the primary residential use classifications. ### Residential Housing Types Single-Unit Dwelling, Detached. A dwelling unit designed for occupancy by one household and located on a separate lot from any other unit (except second living units, where permitted). This classification includes individual manufactured housing units installed on a foundation system pursuant to Section 18551 of the California Health and Safety Code. APPENDIX 1E: CITY OF FRESNO Single-Unit Dwelling, Attached. A dwelling unit designed for occupancy by one household, located on a single lot and typically grouped together in a row of similar units. They may be attached through common vertical party wall(s) to one or more dwellings on abutting lots, or may appear to be attached, but are structurally independent. Multi-Unit Residential. Three or more dwelling units on a site or lot. Types of multiple unit dwellings include townhouses, garden apartments, senior housing developments, and multi-story apartment buildings. This use includes multi-unit development in which individual units are occupied exclusively by one or more persons 62 years of age or older. The Housing includes a program to amend the City’s zoning ordinance to address the definition of “family.” ### Reasonable Accommodation Procedure Building and development standards may constrain the ability of persons with disabilities to live in housing units that are suited to their needs. The City is required to make reasonable accommodations in rules, policies, practices, and services when such accommodations may be necessary to afford a person with a disability the equal opportunity to use and enjoy a dwelling. Reasonable accommodation refers to flexibility in standards and policies to accommodate the needs of persons with disabilities. Per state law, a request for a reasonable accommodation may only be denied if: * The individual on whose behalf the accommodation was requested is not an individual with a disability; * There is no disability-related need for the requested accommodation (in other words, there is no connection between the disability and the requested accommodation); * The requested accommodation would constitute a fundamental alteration of the services or operations of the person who is asked to provide the accommodation; * The requested accommodation would impose an undue financial and administrative burden on the person who is asked to provide the accommodation; or * The requested accommodation would constitute a direct threat to the health or safety of others (i.e., a significant risk of bodily harm) or would cause substantial physical damage to the property of others, and such risks cannot be sufficiently mitigated or eliminated by another reasonable accommodation.3 [^p375-3]: California Code of Regulations, Title 2, § 12179. SECTION 1E-4: CONSTRAINTS The City’s Reasonable Accommodation Ordinance is codified in Article 57 of the Development Code. A request for reasonable accommodation may be submitted on an application form provided by the City or be made orally to the Director. Additionally, the City is required to help assist the applicant in preparing the application if needed. Generally, an application for a reasonable accommodation shall be granted in 30 days. It is the responsibility of the Planning and Development Director (the "Director") under the Development Code to approve, conditionally approve, modify, or deny requests for deviations to dimensional requirements and requests for reasonable accommodation, pursuant to Article 56, Minor Deviations, and Article 57, Reasonable Accommodation for Housing. The following findings are required by the City: * The housing, which is the subject of the request for reasonable accommodation, is to be used by an individual protected under fair housing laws; * The requested accommodation is necessary to make specific housing available to an individual protected under fair housing laws; * The requested accommodation does not impose an undue financial or administrative burden on the City; and * The requested accommodation does not require a fundamental alteration in the nature of a City plan, policy, rule, regulation, or code. Any denial of an application for reasonable accommodation may be appealed in accordance with Section 15-5017 of the Development Code. A Director decision may be appealed to the Planning Commission by filing a written appeal with the Director within 15 days of the decision being made. The appeal will be heard by the Planning Commission within 40 days from the date the appeal is filed. ### Permits and Processing The City does not impose special permit procedures or requirements that could impede the retrofitting of homes for accessibility. The City’s requirements for building permits and inspections are the same as for other residential projects and are straightforward and not burdensome. City officials are not aware of any instance in which an applicant experienced delays or rejection of a retrofitting proposal for accessibility to persons with disabilities. ### Universal Design Element and Retrofit Assistance Since 2008, the City has implemented a Universal Design Ordinance to govern new construction or modifications of City-subsidized housing. The City defines “Universal Design” as a broader, more comprehensive "design for all" approach to the development of products, architecture, and environments around human diversity. Universal Design is a broad comprehensive house design that makes a home safe and comfortable for everyone, young or old, whether they have a disability or not. The program includes the following four items: 1) one “no step” entry, 2) accessible interior routes, 3) accessible kitchen counter space, and 4) ground floor facilities for units over 750 square feet in size. The City requires the incorporation of Universal Design features in affordable housing developments through a development agreement. APPENDIX 1E: CITY OF FRESNO ## Conclusion and Recommended Action The City’s development standards do not unduly constrain housing for people with disabilities. Findings for reasonable accommodations are objective and the City continues to implement the Universal Design Ordinance to govern new construction or modifications of City-subsidized housing and provide accessible features in housing. Amendments to the City’s zoning ordinance are required to address the definition of “family.” The Housing Element includes a program to add a definition of family and consistently replace "single family" and "multi-family" terms with "single-unit" and "multi-unit" for internal consistency. ## At-Risk Analysis In the City of Fresno, there are more than 8,500 publicly assisted affordable housing units. Covenants and deed restrictions are the typical mechanisms used to maintain the affordability of these units. Over time, there is a risk of losing the affordable units due to the expiration of covenants and deed restrictions. As the housing market continues to put upward pressure on market rents in the Bay Area, San Joaquin Valley property owners could be inclined to convert the assisted units to market-rate housing or other use. While Fresno has a rich stock of publicly assisted housing, of the total stock, 695 units in 7 developments are at risk of conversion to uses other than low-income residential within 10 years from the Housing Element adoption deadline (i.e., by December 31, 2033). Table 1E-4.15 provides an inventory of these assisted rental housing units and categorizes their level of conversion risk. * ‘Very-High’ Risk – affordable homes that are at-risk of converting to market rate within the next year that do not have a known overlapping subsidy that would extend affordability and are not owned by a stable non-profit, mission-driven developer/owner. * ‘High’ Risk – affordable homes that are at-risk of converting to market rate in the next 1-5 years that do not have a known overlapping subsidy that would extend affordability and are not owned by a stable non-profit, mission-driven developer/owner. * ‘Moderate’ Risk – affordable homes that are at-risk of converting to market rate in the next 5-10 years that do not have a known overlapping subsidy that would extend affordability and are not owned by a stable non-profit, mission-driven developer/owner. * ‘Low’ Risk – affordable homes that are at-risk of converting to market rate in 10+ years and/or are owned by a stable mission-driven non-profit developer/owner. The California Housing Partnership considers at-risk homes to be those with ‘Very-High’ and ‘High’ risk levels. housing market conditions, all assisted housing developments at risk of conversion by December 31, 2033, are included in the at-risk analysis. SECTION 1E-4: CONSTRAINTS Table 1E-4.15: Assisted Housing Developments At-Risk of Conversion by 2033, City of Fresno | Name | Address | Affordable Units | Total Units | Active Program(s) | Estimated Affordability End Year/Date | Risk Level | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | Garland Gardens | 3726 N. Pleasant Ave, Fresno, 93705 | 51 | 51 | HUD | 2025 | Low | | Delno Terrace | 1480 N. Delno St, Fresno, 93728 | 60 | 61 | HUD | 2026 | Low | | Fresno Senior Housing aka Las Casitas Del Ser | 156 South Willow Ave, Fresno, 93727 | 25 | 125 | HCD | 2027 | Moderate | | Lula Haynes Plaza | 855 E. Lorena St, Fresno, 93706 | 46 | 46 | HUD | 2028 | Moderate | | Sierra Meadows | 107 East Sierra Avenue, Fresno, 93710 | 44 | 220 | CalHFA | 2031 | Moderate | | Pleasant View Apartments | 3513 N. Pleasant Ave, Fresno, 93705 | 60 | 60 | HUD | 2032 | Low | | Papillon Apartments | 5464 North Figarden Drive, Fresno, 93722 | 27 | 132 | CalHFA | 2033 | Low | | Total | -- | 313 | 695 | -- | -- | -- | *Source: California Housing Partnership Preservation Database, July 2022.* ### Preservation Options for At-Risk Properties State law requires that housing elements include a comparison of the costs to replace the at-risk units through new construction or to preserve the at-risk units. Preserving at-risk units can be accomplished by facilitating a transfer of ownership to a qualified affordable housing organization, purchasing the affordability covenants, and/or providing rental assistance to tenants. Each of these options is described below. APPENDIX 1E: CITY OF FRESNO ### Acquisition and Rehabilitation Transferring ownership of an at-risk project to a non-profit housing provider would make the project eligible for re-financing using affordable housing financing programs, such as low-income housing tax credits and tax-exempt mortgage revenue bonds. These financing programs would ensure affordability for at least 55 years. Generally, rehabilitation accompanies a transfer of ownership. Actual acquisition costs depend on several variables such as condition, size, location, existing financing, and availability of financing (government and market). Based on listings of for-sale multifamily buildings throughout Fresno County, prices ranged from $72,916 per unit for a 48-unit complex building in Fresno to $300,000 per unit for a 15-unit complex. Additionally, if the property needs significant rehabilitation, or financing is difficult to obtain, it is important to consider these factors in the cost analysis. Assuming that renovations cost around $25,000 per unit, acquisition and rehabilitation costs could be between $68 million and $226 million for 695 units in 7 developments. ### Construction of Replacement Units New construction is often more expensive than acquisition and rehab. The cost of developing housing depends upon a variety of factors, including density, size of the units, location, land costs, and type of construction. According to a recent report from the Terner Center[^p379-4] in 2020, the estimated construction costs for new multifamily units are around $400,000 per unit. Based on this research, the total cost to replace the affordable units that are at-risk within the seven developments (313 units) with newly constructed units is estimated at $125 million. ### Rent Subsidy Rent subsidies can also be used to preserve affordability of housing, although there are limited funding sources to subsidize rents. The amount of a rent subsidy would be equal to the difference between the HUD-defined fair-market rent (FMR) for a unit and the cost that would be affordable to a lower-income household based on HUD income limits. Table 1E-4.16 shows this calculation. The total cost to subsidize the 313 affordable units at-risk of conversion is estimated at $788,800 annually. Another way rent subsidies could be structured is as a rent buy-down. This would involve the City providing a one-time assistance loan to the property owner to cover the present value of the decrease in rents associated with the extended affordability term compared with market rents achievable on the units. This approach offers a benefit to the owner in that they receive cash upfront from the loan, providing funds for rehabilitation improvements. [^p379-4]: Reid, Carolina. 2020. The Costs of Affordable Housing Production: Insights from California’s 9% Low-Income Housing Tax Credit Program. Retrieved from: https://ternercenter.berkeley.edu/wp-content/uploads/2020/08/LIHTC_Construction_Costs_2020.pdf SECTION 1E-4: CONSTRAINTS ### Table 1E-4.16: Estimated Cost to Subsidize Rents, Fresno, 2022 | | Per Unit Affordable Rent | Unit Size | Total | | :--- | :--- | :--- | :--- | :--- | :--- | | | | 1BR | 2BR | 3BR | | | A | Low-Income Rent (60% AMI) | $904 | $1,024 | $1,144 | | | B | Very Low-Income Rent (50% AMI) | $753 | $853 | $954 | | | C | Average (A & B) | $828 | $938 | $1,049 | | | D | Per Unit Fair Market Rent[^p380-2] | $904 | $1,137 | $1,607 | | | E | Monthly Per Unit Subsidy (D–C) | $76 | $199 | $558 | | | F | Annual Subsidy/Unit (E * 12) | $911 | $2,383 | $6,695 | | | | Total “At Risk” Units[^p380-3] | 157 | 94 | 63 | 313 | | | Total Annual Subsidy | $ 143,027 | $ 224,002 | $ 421,785 | $ 788,814 | [^p380-1]: Affordable rent calculation is based on 1.5 persons per bedroom. [^p380-2]: 2022 HUD Fair Market Rent [^p380-3]: Actual unit size of at-risk units is unknown. Assumes 50% of total “At Risk” units are 1-bedroom, 30% are 2-bedroom, and 20% are 3-bedroom. AMI = Area Median Income Source: U.S. HUD, Fair Market Rents, Fresno County, 2022. # SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS State housing element law (Government Code Section 65588) requires cities and counties to assess the achievements under their adopted housing programs to inform the development of new programs. State law also requires that local governments review the effectiveness of the housing element goals, policies, and related actions to meet the community’s special housing needs. ## Major Accomplishments The City has made significant progress in implementing the programs adopted in the 2013-2023 Housing Element. Some major accomplishments are listed below. * Received Prohousing Designation status and now eligible or funding incentives and additional resources through state grant programs to speed the production of housing. * Established a Local Housing Trust Fund with $6.5 million dedicated to date. * Awarded $300,000 in funding from the Local Early Action Planning (LEAP) program to accelerate housing development by funding site and infrastructure plans for catalyst sites throughout the city. * Provided $827,000 for mobile home rehabilitation. City also took over enforcement of mobile home parks including building permitting of new mobile home placement. * Dedicated $170 million in neighborhood associated infrastructure improvements for 189 park, sewer, street, traffic, and water projects. * Developed pre-approved accessory dwelling unit (ADU) home plans for residents to use free of charge. * Created the Anti-displacement Task Force and hired Thrivance Group to study displacement in the city. Most recently prepared “Here to Stay: Displacement Avoidance Policy Report.” * Adopted a Lodging-to-Dwelling Conversion Ordinance and converted two hotels into apartments with many more projects in the works. * Established a Rental Housing Registry and Rental Inspection Program. To date 86,350 rental units have registered, 13,375 inspections have been conducted, and numerous improvements to rental units have been completed. * Established the School Area Code Enforcement Team to improve neighborhoods, reduce blight, enhance safety, equip residents for civic engagement, and connect low-income residents to housing resources. Reached 20 school areas and received an Innovative Program of the Year Award from California Association of Code Enforcement Officers. * Between 2016 and 2019, 2,141 households received temporary shelter, 2,258 people received emergency shelter, 425 people received Rapid Re-housing assistance, and 231 clients with HIV/AIDS received Special Needs Housing Service. SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS * Between 2020 and 2021, 12,430 unsheltered persons received supportive services; 983 beds were added to the system; 4,812 unduplicated persons were assisted with overnight shelter, triage, or bridge housing; 5,243 people exited the system; and 1,687 people exited to permanent housing. # Progress Toward Meeting the RHNA Each jurisdiction in California is responsible for accommodating its share of the region’s housing needs. The process of determining each jurisdiction’s share of housing needs is called the Regional Housing Needs Assessment (RHNA). The RHNA projection period for the previous Housing Element was from January 1, 2013 to December 1, 2023. The City of Fresno was assigned a RHNA of 23,565 units, divided into four income categories: * Very Low-Income (less than 50 percent of the Area Median Income): 5,666 units * Low-Income (50 to 80 percent of the Area Median Income): 3,289 units * Moderate-Income (80 to 120 percent of the Area Median Income): 3,571 units * Above Moderate-Income (greater than 120 percent of the Area Median Income): 11,039 units Table 1E-5.1 summarizes the City’s accomplishments in meeting the RHNA during the previous RHNA projection period. Table 1E-5.1: Building Permits Issued During Fifth Cycle RHNA Period | Income Level | 2013-2023 RHNA | 2013-2015 | 2016 | 2017 | 2018 | 2019 | 2020 | 2021 | 2022 | 2023 | Total to Date | Unmet RHNA | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | Very Low | 5,666 | 290 | 23 | - | 135 | 41 | 68 | 92 | 67 | 311 | 1,027 | 4,639 | | Low | 3,289 | 268 | 8 | 4 | - | 5 | | 25 | 70 | 72 | 452 | 2,837 | | Moderate | 3,571 | 384 | 334 | 787 | - | - | | 11 | 0 | - | 1,516 | 2,055 | | Above Moderate | 11,039 | 2,328 | 923 | 676 | 1,202 | 1,970 | 2,184 | 2,134 | 1,305 | 1,455 | 12,722 | | | Total | 23,565 | 3,270 | 1,288 | 1,467 | 1,337 | 2,016 | 2,252 | 2,262 | 1,442 | 1,838 | 17,172 | 9,531 | *Note: Units serving extremely low-income households are included in the totals for very low-income permitted units.* Source: City of Fresno, 2023 Annual Progress Report. # Program Evaluation The following section reviews and evaluates the City’s progress in implementing programs from the previous planning period. As part of analyzing prior programs, the City must assess the effectiveness of programs for special needs populations. Table 1E-5.2 summarizes progress on the implementation programs from the previous Housing Element, including programs addressing special needs populations summarized below. **Seniors and Persons with Disabilities.** As discussed in Section 1E-0: Summary of Needs for the City of Fresno, about 11 percent of the population in Fresno was aged 65 or older in 2020. In the same year, nearly half of the senior population (44.5) percent had a disability. Due to proximity to services, Fresno has a higher rate of residents with disabilities than the county as a whole (13.8 percent compared to 12.9 percent across the county). Seniors and persons with disabilities are especially likely to live on fixed incomes and require accessibility modifications to homes to support mobility and independent living. The City implemented programs to support seniors and special needs households, including Program 7 – Special Needs Housing, Program 10A – Mobile Home Parks, Program 10B – Housing Choice Vouchers, Program 21 – Neighborhood Infrastructure, and Program 22 – Housing Rehabilitation. The City continues to encourage and support development of senior housing and senior residential care facilities that offer a wide range of housing choices and community services. The City also implements a Universal Design Ordinance for new construction or modification of City-subsidized housing using aging in place as a guiding principle (Program 7). The program includes: one “no step” entry, accessible interior routes, accessible kitchen counter spaces, and ground-floor facilities for units over 750 square feet in size. Any developer receiving City funds is required to comply with the Universal Housing Ordinance. Every development project that has received City funds since the Ordinance was adopted has complied with this requirement. The City also funds home repair and rehabilitation programs with its Community Development Block Grant (CDBG) and HOME Investment Partnership Act (HOME) funding. The City offers a Senior Paint Program in which CDBG funds are used to pay for a licensed contractor to paint home exteriors, occasionally providing minor repairs (e.g., screens, broken windowpanes, loose or damaged gutters) as funds are available. The program serves low-income seniors who own and occupy their home. During the previous planning period, more than 100 projects were completed through the City’s Senior Paint Program. However, home repairs continue to be a need throughout the city, particularly for senior occupied households. Stakeholders and public meeting participants involved in the Housing Element update process identified various remaining needs including mobile home improvements, particularly accessibility accommodations, weatherization, and roof repairs for seniors. The City has allocated $553,717 of its Permanent Local Housing Allocation (PLHA) funding for a total of $1.38 million in PLHA assistance to further its program focused on owner-occupied home rehabilitation for low-income people not eligible for funding through other programs, such as mobile home residents. Once the City receives its executed Standard Agreements for PLHA funds from the State of California, it will implement the program (refer to Program 22 for more information). The City has also worked to increase the availability of affordable housing in the city by using HOME funds to support the development of affordable housing, including housing for seniors and people with disabilities, and to provide housing rehabilitation for low-income homeowners. Senior housing developments completed/underway during the previous planning period included Self-Help Enterprises Annadale Commons Senior Housing Project in Southwest Fresno (40 new multi-family senior housing units), FCTC Fancher Creek Senior Housing Project (180 new multi-family senior housing units); and Cesar Chavez Foundation’s Las Palmas de Sal Gonzales Sr. Apartments Project located at 5070 E. Kings Canyon (mix of 135 senior and multi-family units). SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS Fresno residents with disabilities are served by the Fresno County Senior Resource Center, which operates an Adult Protective Services program, assisting both disabled adults and seniors with all requests for assistance. The Fresno County Human Services System Department of Adult Services also provides housing and basic needs assistance to elderly persons. The Fresno/Madera Area Agency on Aging (FMAAA) provides connections to programs, services, and resources elderly residents can use to maintain and improve their quality of life as they age. For seniors and other persons requiring a supportive housing setting, there are 210 licensed care facilities in Fresno County with 4,953 beds. The majority of these facilities are located in the City of Fresno, with some 67 facilities in the City of Clovis, one in the cities of Fowler, Huron and Kerman, three in the City of Reedley, and three in the City of Sanger. Furthermore, the Housing Authority provides rental assistance to eligible seniors and disabled residents through housing choice vouchers and project-based vouchers. Of the Housing Authority’s 7,412 vouchers (as of July 2023), 8 percent were used by a senior household and 19 percent were used by households with a disabled member. With both new housing and rental vouchers, housing needs for seniors and disabled people continue to be addressed, however 7,571 individuals are on the interest list for vouchers and public housing. Program Effectiveness: During the 5th Cycle, the programs described above served 355 households with new accessible affordable housing, 100 households with home rehabilitation, and provided 2001 HCV to senior households and households with a disabled member. Some households may have been served by the supportive housing available depending on cost. While the services and housing made available during the 5th cycle were effective in serving the targeted populations, data indicates that the needs still exceed the available resources. The following programs in this housing element aim to address more of the need and will depend on resource availability (both public and private) to be effective: * **Program 2** – Variety of Housing Opportunities in High Resource Areas- * **Program 3** – Encourage and Facilitate Accessory Dwelling Units and Small Homes * **Program 19** – Home Buyer Assistance * **Program 20** – Housing Choice Voucher Incentive Program * **Program 22** – Housing Rehabilitation * **Program 24** – Special Needs Housing * **Program 26** – Fair Housing Services * **Program 33** – Mobile Home Parks * **Program 34** – Eviction Protection Program * **Program 37** – At-Risk Housing APPENDIX 1E: CITY OF FRESNO **Persons with Developmental Disabilities.** Living arrangements for disabled persons depend on the severity of the disability. If a disability prevents an individual from working or limits income, then the cost of housing and the costs of modifications are likely to be even more challenging. For this reason, many persons live independently or with other family members. To maintain independent living, disabled persons may need special housing design features, income support, and in-home supportive services for persons with medical conditions. Special design and other considerations for persons with disabilities include single-level units, availability of services, group living opportunities, and proximity to transit. Stakeholders and public meeting participants in the 2020 Analysis of Impediments process highlighted the need for housing for people with developmental disabilities stating that affordability, safety, and landlords who understand their clients are important because it is difficult to obtain housing for this group and evictions are common. For people with developmental disabilities, safety is a key factor and varies from neighborhood to neighborhood even within the same area of the city. The Analysis of Impediments recommended the provision of more disabled-accessible units and housing for persons with mental and physical disabilities. The City of Fresno, along with other jurisdictions in the County, is serviced by the Fresno Center, which provides one point of entry to services for people with developmental disabilities. The Fresno center partners with the Central Valley Regional Center to help individuals with developmental disabilities. Central Valley Regional Center advocates for clients with developmental disabilities and consults with attorneys regularly on legal issues. **Program Effectiveness:** Many of the programs available for seniors and individuals with disabilities also support individuals with developmental disabilities. In order to address more of the need, more financial resources are needed. The following programs in this housing element aim to address more of the need and will depend on resource availability (both public and private) to be effective: * **Program 2** – Variety of Housing Opportunities in High Resource Areas * **Program 3** – Encourage and Facilitate Accessory Dwelling Units and Small Homes * **Program 19** – Home Buyer Assistance * **Program 20** – Housing Choice Voucher Incentive Program * **Program 22** – Housing Rehabilitation * **Program 24** – Special Needs Housing * **Program 26** – Fair Housing Services * **Program 33** – Mobile Home Parks * **Program 34** – Eviction Protection Program * **Program 37** – At-Risk Housing SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS **Large Households.** Homes consisting of five or more members residing together typically lack adequately sized and affordable housing options. Approximately 17 percent of all households in Fresno have 5 or more members (28,411 households), as of 2020. This consists of 13,282 owner-occupied large households and 15,129 renter-occupied large households. The most critical housing need of large households is access to larger housing units with three or more bedrooms. According to estimates from the U.S. Census American Community Survey (ACS), of the 170,137 housing units in the city as of 2020, approximately 68,131 units have at least three bedrooms and an additional 29,738 units have more than four bedrooms. Among these larger units, 69.4 percent are owner occupied (67,935 units) and 30.6 percent are renter occupied (29,934 units).¹ Based on this data, the City concludes that there is a sufficient availability of units suitable for large family households. However, large households would also benefit from the additional development of affordable rental multi-family units with three or more bedrooms. During the previous Housing Element cycle, the City and Housing Authority of the City of Fresno investigated funding sources, developed partnerships, and applied for available local, State, and federal funds to assist in the production of large family units. **Program Effectiveness:** While the data indicates that Fresno’s housing stock can accommodate the number of large households in Fresno, data shows a lack of affordable housing for this population. In response to these needs, the City is including Program 24, which seeks to apply additional funding sources for a variety of housing types for special needs groups, including large households. Other programs that could support the provision of affordable housing for large households include the following: * **Program 2** – Variety of Housing Opportunities in High Resource Areas * **Program 12** – Local Housing Trust Fund * **Program 13** – Pursue State and Federal Funding Sources for Housing Development * **Program 14** – Partnerships with Affordable Housing Developers * **Program 19** – Home Buyer Assistance * **Program 20** – Housing Choice Voucher Incentive Program * **Program 26** – Fair Housing Services * **Program 34** – Eviction Protection Program * **Program 37** – At-Risk Housing [^p386-1]: Source: U.S. Census Bureau, ACS 16-20 (5-year Estimates), Table B25042. APPENDIX 1E: CITY OF FRESNO **Single Female-Headed Households.** Many single parent households, especially female-headed households, have a greater risk of poverty due to higher family expenses and single-wage incomes. Given the availability of jobs, transit, housing, educational facilities and other services, Fresno has a greater presence of single female-headed households than other cities in the county, except Clovis. As discussed in Section 1E-0: Summary of Needs for the City of Fresno, nearly 31 percent of households in Fresno had single female heads of household in 2020. Additionally, 36 percent of single-female-headed households in Fresno were living under the poverty level (11,582 households). Single-parent households can benefit from most affordable housing programs, including Housing Choice Vouchers (Program 10B), the Homebuyer Assistance Program (Program 8), and the Housing Rehabilitation Program (Program 22). The City offers information on these programs on their website and refers individuals when queried. Assistance programs offered by organizations like First Five Fresno County can also assist these households with securing affordable childcare and housing. **Program Effectiveness:** Although the City passed several amendments to the zoning code to encourage the development of more affordable housing near transit and employment centers during the previous planning period, there still had not been enough new development to support the need. However since passage of the zoning code amendment to remove mixed use density caps along transit corridors in 2022, several affordable housing projects in the downtown and along transit corridors have been constructed or are in the pipeline. The City will continue to incentivize this type of development and provide available resources to single parent households as available and while encouraging affordable housing in high opportunity neighborhoods. Programs that could support housing for single female-headed households include the following: * **Program 2** – Variety of Housing Opportunities in High Resource Areas * **Program 11** – Incentives for Housing Development * **Program 12** – Local Housing Trust Fund * **Program 13** – Pursue State and Federal Funding Sources for Housing Development * **Program 14** – Partnerships with Affordable Housing Developers * **Program 19** – Home Buyer Assistance * **Program 20** – Housing Choice Voucher Incentive Program * **Program 24** – Special Needs Housing * **Program 25** – Development Code Amendments for Compliance with State Law and to Reduce Barriers to Housing Development SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS **Farm Workers.** Farmworkers living in urban and suburban areas often have similar needs for affordable rental housing as other lower-wage earners. Due to a combination of limited English language skills and very low household incomes, the ability to obtain housing loans for home purchase is extremely limited. For the same reasons, rentals are also difficult to obtain although farmworkers are more likely to be renters. Research suggests that farmworkers generally experience overcrowded and substandard, potentially hazardous, housing conditions. As a result, needs are generally accommodated through housing programs and policies that assist low- and very low-income households such as the HCV program (Program 10B) and the Housing Rehabilitation Program (Program 22). In addition, the Fresno Housing Authority manages 194 units of seasonal farmworker housing for migrant workers and 131 units in three year-round housing complexes, exclusively for farm laborers. The City has a relatively small population of farmworkers compared to other jurisdictions in the county but will continue to support regional efforts to provide seasonal and permanent housing facilities for farmworkers. **Program Effectiveness:** In the prior planning period, City staff were to conduct a review of the Development Code to verify compliance with the California Employee Housing Act regarding housing for agricultural employees. The Agricultural Employee Housing (AEH) Act was reviewed and no changes to the Development Code were found to be necessary, however the City finds that it can provide clarification between the Code and State Law. In terms of effectiveness in meeting farmworker housing needs, the City did not have access to localized data in the prior period, however the City will be more proactive in reaching out to Fresno Housing and others working to address farmworker housing needs moving forward. This has already started to occur, as the City has applied for Rural Housing Services funding through the US Department of Agriculture for a 54-unit deed restricted farmworker housing project on City-owned land at Ventura and 7th. This Housing Element includes a program to permit employee housing for six or fewer as a residential use and permit agricultural labor housing in all zoning districts where agricultural uses are permitted (Program 25 – Development Code Amendments for Compliance with State Law and to Reduce Barriers to Housing Development). In addition to Program 25, programs that could support housing for farmworkers include the following: * **Program 2** – Variety of Housing Opportunities in High Resource Areas * **Program 3** – Encourage and Facilitate Accessory Dwelling Units * **Program 11** – Incentives for Housing Development * **Program 19** – Home Buyer Assistance * **Program 20** – Housing Choice Voucher Incentive Program * **Program 22** – Housing Rehabilitation * **Program 24** – Special Needs Housing * **Program 25** – Development Code Amendments for Compliance with State Law and to Reduce Barriers to Housing Development * **Program 26** – Fair Housing Services * **Program 33** – Mobile Home Parks APPENDIX 1E: CITY OF FRESNO **Homeless.** Without sufficient protections and affordable housing options, many low-income renters are at risk of experiencing homelessness. The 2023 Point-in-Time (PIT) count estimated that 3,207 persons were experiencing homelessness in the city of Fresno at the time of the count. It is estimated that approximately 1,819 of those residents were unsheltered, representing a 7 percent increase in the unsheltered homeless population in Fresno. The City of Fresno collaborates with service agencies dedicated to providing shelter, housing, and case management services to those in need (Program 9). In addition to coordination at the local level, Fresno has received technical assistance and, in some cases, has been designated a high-priority city as part of initiatives aimed at preventing and ending homelessness. Between July 2019 and December 2021, the Fresno area received more than $144 million from federal, state, and local sources to increase homelessness services. In 2023, funding that has been allocated to the City in addition to annual funding from HUD’s Community Planning and Development Office includes: Homeless Housing, Assistance, and Prevention (HHAP) Round 1, in the amount of $6,158,246; HHAP Round 2, in the amount of $2,911,171; HHAP Round 3, in the amount of $7,524,257; and an initial disbursement of $5,632,712 from HHAP Round 4. Using state and/or federal emergency funding, the City funded the operations of multiple homeless shelters: Mental Health Systems Triage Center at the Hacienda; Turning Point of Central California’s Golden State Triage Center, Bridge Point Triage Center, Step Up on 99, and Journey Home at Welcome Inn; Sage Commons; and Elevate Community Service’s Villa, Ambassador, and Travel Inn Triage Centers. In 2023, the City’s federally funded programs, designed to assist people experiencing homelessness, assisted 2,464 people with emergency shelter; 269 people with tenant-based rental assistance or rapid rehousing; and 2,837 people with public service activities like street outreach, tenant and landlord counseling, and referral and housing services (all unduplicated). These funds went to the City, the County, the Fresno Madera Continuum of Care, and the Fresno Housing Authority. The City used its funding allocation to add 983 shelter beds and provide emergency and temporary shelter, and transitional housing. In an effort to provide “housing-first” opportunities for the unsheltered population, the City of Fresno recently approved $1 million in HOME Investment Opportunities (HOME) Investment Partnerships Program funds to be directed to the Fresno Housing Authority for the formation of a local Tenant Based Rental Assistance (TBRA) program. The need to provide assistance for the homeless and those at risk of becoming homeless through safe low-barrier shelter options, housing-first collaborations, and associated supportive services was a priority area identified in the 2020-2024 Consolidated Plan, and in 2022, activities were funded to work toward alleviating housing instability and homelessness for the people of Fresno. SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS **Program Effectiveness:** The 2023 Point-in-Time count estimated that 3,207 persons were experiencing homelessness in the city of Fresno at the time of the count. It is estimated that approximately 1,819 of those residents were unsheltered, representing a 7 percent increase in the unsheltered homeless population in Fresno. The City used its funding allocation to add 983 shelter beds and provide emergency and temporary shelter, and transitional housing, and 40 units of permanent supportive housing. The program was effective in serving the target population, however the need exceeds the resources available. To prevent displacement and homelessness in the City of Fresno, the City has included * **Programs 32** - Opportunity to Purchase Act * **Program 33** – Mobile Home Parks * **Program 35** – Replacement Units * **Program 36** – Homeless Assistance * **Program 37** – At Risk Housing APPENDIX 1E: CITY OF FRESNO ### Table 1E-5.2: Evaluation of Fresno 2015-2023 Housing Element Implementation Measures | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | 1 | Adequate Sites to meet 2013-2023 RHNA and to meet 2008-2013 RHNA. The City will maintain an inventory of available sites for residential development and provide it to prospective residential developers upon request. The City of Fresno is not responsible for the actual construction of these units. The City is, however, responsible for creating a regulatory environment in which the private market could build these units. This includes the creation, adoption, and implementation of General Plan policies, zoning and development standards, and/or incentives to encourage the construction of various types of units. | The City is maintaining, on an ongoing basis, an inventory status report of all Housing Element Inventory Sites. The inventory status report is available to City staff to address current planning projects for consistency with the Housing Element. As of December 31, 2023, the City of Fresno has a surplus of capacity in all income categories for the 2013-2023 RHNA. See evaluation of Program 2 for more discussion on adequate sites. | Continue to maintain an inventory of available sites for residential development. | | 2 | Residential Densities on Identified Sites. The City of Fresno will evaluate residential development proposals for consistency with goals and policies of the General Plan and both (2008-2013 and 2013-2023) Housing Element Sites Inventories to ensure development on identified sites is occurring as expected related to development types, densities, and quantities. Should a project propose a reduction in density, the City shall make written findings that the density reduction is consistent with the General Plan and that the remaining sites identified in the Housing Element are adequate to accommodate the RHNA. So long as the residential sites inventory continues to exceed the City’s RHNA as set forth in Program 1, the City shall make the necessary written findings regarding the reduction’s consistency with the General Plan. If a proposed reduction of residential density will result in the residential sites inventory failing to accommodate the RHNA, the City shall consider an amendment to the Housing Element in order to restore capacity to the sites inventory, before acting on a density | In 2016, the City established procedures for the review and monitoring of sites identified in the Housing Element sites inventory. During the entitlement review process, new projects are evaluated for their consistency with General Plan housing objectives and RHNA obligations. In 2018, the City began integrating Policy and Procedure No. G005 - Housing Element Sites Inventory Entitlement Review Process Procedure with Accela, the City’s new land management system. Several development projects have requested reduced densities during the 2013-2023 Housing Element cycle and most were found to be consistent with the General Plan and included an assessment of the Housing Sites Inventory capacity. In 2019, the projects that proposed a reduction in density were found to impact the capacity of the 2008-2013 Housing Sites Inventory so in order to restore adequate capacity, the City Council adopted Plan Amendment P19-00980 to add 91 sites in Downtown (approximately 54.16 acres) for an estimated 9,374 units to the 2008-2013 Inventory. In subsequent years, the projects that proposed a reduction in density were found in writing to be consistent with the General Plan and included an assessment of the Housing Sites Inventory capacity. Consistency was maintained because the inventory currently has a | Continue to implement the Housing Element Sites Inventory Entitlement Review Process Procedure to ensure development on identified sites is occurring as expected related to development types, densities, and quantities. Combine with Program 1, above. | SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | reduction. Sites selected to restore capacity to the inventory shall provide equivalent capacity, be of an equivalent size, and provide appropriate density relative to the site subject to the density reduction in order to qualify as a sufficient replacement site. If a site requires a rezone in order to be counted as a replacement site in the sites inventory, the rezone application shall be processed concurrently with the Housing Element amendment. As part of this process, the City will encourage and support the expansion of affordable housing opportunities that prevent the concentration of single-family and multifamily dwelling units affordable to low- and moderate-income households and will consider concentration of affordable housing when selecting replacement sites for the inventory. | surplus of adequate sites identified in the Housing Element to meet its RHNA obligations. | | | 3 | The City devotes considerable effort to engage housing advocates, stakeholders, and organizations on housing-related programs and policies maintained by the City. Fresno has a Housing and Community Development Commission (HCDC) that helps facilitate annual evaluations and the City also completes Housing Element Annual Progress Reports (APR). The City facilitates public workshops for stakeholders and interested parties to present accomplishments and receive public feedback on: affordable housing development in Fresno, future actions/assistance the City could provide, the impact of State laws, and other City housing-related programs and policies. Community meetings are promoted through the Fresno Bee, Vida en el Valle, social media, utility bill inserts, email, media outlets, flyer distributions at schools, door-to-door canvassing, local events, neighborhood meetings, food distributions, and congregations. In March 2020, the process went digital due to COVID-19. Meetings often include Spanish and Hmong interpretation and most recently (2022) Punjabi. Draft plans and materials are made available via the City’s website or printed in the City Clerk’s office, the Code Enforcement public counter, and in all of the public libraries. | Continue Program. | | Annual Reporting Program. Partner with housing advocates, organizations, and developers to provide annual information to the community on housing density and affordable housing. Actively work toward Housing Element implementation, and reach out to the community regarding these topics annually as part of a Housing Element Annual Report on annual progress. Notify and invite interested community members to attend and discuss housing production progress at a public hearing, and continue to provide avenues for community input on the implementation of the Housing Element. Utilize multiple methods of outreach to engage all members of the Fresno community, including multilingual notices and media outlets. Encourage input on other housing and fair housing-related programs and policies maintained by the City, including but not limited to those contained in the Analysis of Impediments to Fair Housing Choice (or Assessment of Fair Housing) and relevant General Plan policies and Development Code provisions. Allow residents | | | | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | and stakeholders the opportunity to discuss and provide information and feedback to City staff and policy-makers. | | | | 4 | Density Bonus Programs. The City will encourage use of the State Affordable Housing Density Bonus and City of Fresno TOD Height and Density Bonus provisions through technical assistance and information dissemination. | During the pre-application process for entitlements the City meets with applicants to provide assistance. Projects that are eligible for density bonuses are informed of the State Density Bonus and City of Fresno Transit Oriented Development (TOD) Height and Density Bonus (which can be combined with a State density bonus for affordable housing). Approximately 22 projects have claimed a Density Bonus in Fresno between 2016 and 2022. | Maintain program and monitor legislative updates to State Density Bonus law. | | 5 | Housing Funding Sources. The City will actively pursue funding to assist in the development, preservation, and rehabilitation of any housing type with a particular emphasis on the development of mixed-income neighborhoods. The City will identify these funding opportunities to both for-profit and non-profit developers as part of the residential and mixed-use development processes, especially those projects that have the potential for affordable housing. The City will also continue to assist Low Income Housing Tax Credit (LIHTC) applications and Affordable Housing and Sustainable Communities (AHSC)/Cap and Trade applications. The actions that the City will take specifically include, but are not necessarily limited to: | The City primarily receives funding through annual entitlement programs administered by the Department of Housing and Urban Development (HUD) and the California Department of Housing and Community Development (HCD). However, in 2021 the City established a local housing trust fund (LHTF) to establish a local source of funding for various community-supported housing programs and activities. In 2022, the City received $6.8 million through the Community Development Block Grant (CDBG) Program, $603,908 through the Emergency Solutions Grant (ESG) Program, $3.6 million through the HOME Program, and $875,943 through the Housing Opportunities for People with AIDS/HIV (HOPWA) Program. The City’s administration also allocated $42 million of its funding through the American Rescue Plan Act (ARPA) for the development of affordable housing. For more information about how this funding was used, refer to Programs 6 and 7. The City has also been awarded entitlement grants from the California Department of Housing and Community Development. In 2022, it was awarded $54 million through Homekey 2 to fund projects to sustain and rapidly expand housing for people experiencing homelessness or at risk of homelessness. The City also submitted a joint application with RH Community Builders and UpHoldings and were awarded $16.7 million in Homekey 2 funds from the State of California to acquire and convert motels into affordable housing. The City was also awarded $5 million through the State of California’s Encampment Resolution Fund Program. Funds are used to provide street outreach to people experiencing homelessness in encampments within a specified area | Maintain program. | SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | | downtown. The funds are also used to provide shelter operations to house individuals identified in the encampment and will be used to acquire tiny houses to add 26 permanent housing units. The City also applied for a fourth allocation of the Homeless Housing Assistance and Prevention (HHAP) Program totaling $11 million and for its third allocation of the Permanent Local Housing Allocation (PLHA) Program totaling $5.8 million. | | | 6 | Strengthening Partnerships with Affordable Housing Developers. The City will continue to strengthen partnerships and relationships with affordable housing developers, including but not limited to the Fresno Housing Authority, by doing the following: Encouraging and assisting in funding applications to applicable federal, State, and local funding sources Supporting local capacity building efforts around affordable housing finance, including convening affordable housing developers, community development leaders, lenders, and advocates to identify ongoing regulatory and funding barriers to affordable and mixed-income development Attracting large investors to facilitate the construction of new affordable housing units and incentivize self-help type single-family housing construction for extremely low-income households Reviewing published notices for funding availability and causing applications to be prepared for various City housing programs, projects, and activities Administering Community Housing Development Organization (CHDO) funds for affordable housing projects with service providers including Habitat for Humanity | The City actively collaborates with affordable housing developers to fund and build affordable housing. During the previous planning period, the City worked closely with the Fresno Housing Authority, Self Help Enterprises, and Habitat for Humanity. Staff provide frequent communication with partners about Federal, State, and local funding sources, and continue to assist developers applying for Low Income Housing Tax Credits (LIHTC) by reviewing applications, evaluating possible leveraging with local programs, and submitting letters of support and certifications of consistency with the Consolidated Plan. In 2018 and 2019, the City provided assistance to five projects– Mariposa Meadows, Annadale Commons, Renaissance at Cincotta, Econo Inn, and Fancher Creek Senior Housing. Also in 2019, the City of Fresno collaborated with Self Help Enterprises, the Fresno Housing Authority, and Habitat for Humanity to use HOME funding for three residential projects. • Self-Help Enterprises’ Annadale Commons Phase II in the amount of $1,462,000 for 35 single-family houses • Fresno Housing Authority’s Chinatown Housing Project in the amount of $397,118 for 57 multi-family housing units, and • Habitat for Humanity’s Central Lots Project Phase II in the amount of $392,000 for two single-family houses. The City is currently working in collaboration on the Fancher Creek Master Planned Development, a 90-acre project in Southeast Fresno that would consist of 970,000 square feet of commercial and retail businesses, a senior housing development, a multifamily housing development, a plaza, recreational space, and approximately 1.5 miles of trail along the canal. The City is currently (2023) in financing negotiations. | Maintain program. Explore opportunities for affordable housing in higher opportunity areas. | | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | Encouraging non-profit organizations to seek funding for development of new farmworker housing projects, as well as local affordable housing and mixed-income projects in transit-oriented developments along transit corridors throughout the City | To attract more investors and increase the availability of housing, the City offers development incentives in the form of TOD height and density bonuses, which can be combined with the State density bonus for affordable housing. Most recently the City removed maximum densities in Downtown and Mixed-Use zoning districts to streamline higher density development. | | | **Special Needs Housing.** The City will continue to encourage the development of adequate housing to meet the needs of persons with special needs (such as seniors, survivors of domestic violence, and people with disabilities, including persons with developmental disabilities), including the following efforts:

The City will continue implementation of its Universal Design Ordinance for new construction or modification of City-subsidized housing using visitability and aging in place as guiding principles. The program includes:
• One “no step” entry
• Accessible interior routes
• Accessible kitchen counter space
• Ground-floor facilities for units over 750 square feet in size

The City will partner with and encourage local and State non-profits to seek funding for development of new farmworker housing projects.

The City will use funding programs such as the Emergency Shelter Grant (ESG) and Housing Opportunities for Persons with HIV/AIDS (HOPWA) to support needed social services and review applications annually.

The City will continue to utilize available funds and/or seek funding to support the Fresno-Madera Continuum of Care, a local collaborative of | The City uses many programs and funding sources to address special needs housing. Activities undertaken with CDBG, HOME, ESG, HOPWA, and City General Funds include efforts to reduce poverty and improve the quality of life for residents.

The City’s ESG and HOPWA funds provide direct assistance to homeless individuals or those at risk of becoming homeless. From July 1, 2021 to June 30, 2022, annual HUD entitlement funds of $603,908 in ESG and $875,943 in HOPWA were awarded to subrecipients who provided 2,591 people with emergency shelter and street outreach services; 610 people with supportive, referral, and housing services; 17 people with homelessness prevention; and 195 people with rapid rehousing, short-term rent, tenant-based rental assistance, or housing through short-term or transitional facilities (all unduplicated). | Maintain program. | SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | homeless service providers, to construct transitional and supportive housing units.

The City will provide technical assistance to developers with proposed Single Room Occupancy (SRO) projects to create units during the plan period.

The City and Housing Authority of the City of Fresno will investigate funding sources, develop partnerships, and apply for available local, State, and federal funds to assist in the production of large family units.

The City and Housing Authority of the City of Fresno will seek and apply to funding sources and partner with local and statewide non-profits and for-profits in applying for funds and encouraging the construction of units for extremely low-, very low-, and low-income income seniors (typically age 65 years and over; may vary by funding source or program). | | | | 8 | Home Buyer Assistance. The City of Fresno administers a first-time homebuyer program that provides up to $50,000 as a silent second loan to an eligible homebuyer. The program helps low-income households purchase their first home in qualified census tracts in Fresno (excluding County islands) and is funded by the California Department of Housing and Community Development’s CalHome program.

The City also converts new single-family housing development loans to first-time homebuyer assistance loans upon transfer of the property to the homebuyer. The City will continue to pursue funds for the first-time homebuyer program to assist City households during the planning period. The City will also conduct targeted marketing to real estate professionals, lenders and eligible homebuyers as part of the program and will include high opportunity areas in the marketing plan. | The City assisted 9 first-time homebuyers in Calendar year 2016, but then the State HCD CalHome agreement expired in April 2017. In 2020, the City allocated $971,100 of funding through its first allocation of PLHA program for a down payment assistance program for low- and moderate-income first-time home buyers. In 2021, the City allocated $1.5 million of its second allocation of PLHA funds for the down payment assistance program. In 2022, the City allocated an additional $1.6 million of funding through its third allocation of PLHA for a down payment assistance program. The total allocated to the down payment assistance program to date is $4.1 million. Once the City receives its executed Standard Agreements for PLHA funds from the State of California, it will implement the down payment assistance program. | Modify the program with updated homebuyer assistance program funded with PLHA funds. Explore opportunities to expand program. | | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | **Homeless Assistance.** The City will apply for, or support applications for funding for emergency shelters, transitional or supportive housing. The City will continue to use Emergency Solutions Grant (ESG) Program funds to support needed social services and review applications annually. The City is also utilizing the HOME Investment Partnerships (HOME) Program and is contracted with the Fresno Housing Authority to implement a $1 million tenant-based rental assistance program for persons that are homeless, threatened with homelessness, or in need of housing assistance after completing a transitional living program. In addition to ESG and HOME funds, during fiscal year 2016, the City allocated approximately $520,000 in general funds for the MAP Point at the Poverello House, outreach, and assessment of homeless individuals. The City will continue to participate in and support the Fresno Madera Continuum of Care and the MAP Point at the Poverello House. | The City funded multiple activities with its federal allocations through HOME, CDBG, ESG, and HOPWA programs. The Tenant Based Rental Assistance (TBRA) program, funded with HOME dollars, is run in coordination with FMcOC, the Housing Authority, and other subrecipient vendors to provide emergency shelter, homeless prevention and rapid rehousing for clients in need.

The Living Room, funded with HOPWA dollars, is a WestCare California program that provides short-term rental and mortgage assistance, tenant-based rental assistance, transitional housing, homelessness prevention, rapid re-housing, supportive services, and housing information to homeless individuals and those at-risk of homelessness affected by HIV/AIDS. The primary goals of the program were to help participants achieve both permanent housing and health stability. WestCare California also operated Project Unite with ESG funds to provide rapid rehousing and homelessness prevention services through weekly outreach activities. The program focused on engaging homeless and chronically homeless extremely low-income individuals and families, including Veterans who are not eligible for housing assistance through Supportive Services for Veteran Families and VASH.

The City also used CDBG to fund the Marjaree Mason Center to support the operation of an emergency shelter, five rooms within a transitional housing safe house, and transitional services for victims of domestic violence.

Poverello House was awarded ESG funds for its Homeless Outreach Progressive Engagement (HOPE) Team to provide street outreach to people experiencing homelessness that live in the City of Fresno. The purpose of the team is to link people experiencing homelessness to navigation services and shelter. The Rapid Rehousing Program through Poverello was also funded with ESG to provide direct case management and rental support for those experiencing homelessness in the City for up to one year. The program helped pay for security deposits, past-due PG&E bills, and direct rental support. Case managers also worked with participants to develop a plan to sustain housing beyond the rapid rehousing program support. | Maintain program. | SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | | Using state and/or federal emergency funding, the City funded the operations of multiple homeless shelters: Mental Health Systems Triage Center at the Hacienda; Turning Point of Central California’s Golden State Triage Center, Bridge Point Triage Center, Step Up on 99, and Journey Home at Welcome Inn; Sage Commons; and Elevate Community Service’s Villa, Ambassador, and Travel Inn Triage Centers. Funding that has been allocated to the City in addition to HUD CPD annual funding includes the Homeless Housing, Assistance, and Prevention (HHAP) Round 1 ($6.1 million); the HHAP Round 2 ($2.9 million); and an initial disbursement of the $7.5 million in HHAP Round 3 funding. The City was also awarded $5 million in Encampment Resolution Funding that will be used to address a large encampment in downtown Fresno, including the provision of emergency shelter at Poverello House’s Village of Hope I. The City has also allocated $1 million of its ARPA funds to a voucher assistance and/or landlord incentive program to ensure there are resources available to support permanent housing options for individuals as they exit emergency shelters or temporary housing. As of 2022, the City has assisted 3,533 unsheltered people through federally-funded programs and 1,071 unduplicated people were assisted with overnight shelter. | | | 10A | Mobile Home Parks. In an effort to preserve the city’s mobile home parks, the City will: Compile a list of resources and provide technical assistance to facilitate the maintenance and preservation of mobile home parks. Conduct yearly outreach to mobile home residents and park owners regarding potential funding sources, including the State’s Mobilehome Park Rehabilitation and Ownership Program. Outreach may be facilitated by going to mobile home clubhouses and posting information in readily visible locations. Conduct and publish an assessment of housing-related needs in mobile home parks through communications with residents and | Between 2016 and 2019, the City held public meetings, workshops, and hearings annually for residents (including mobilehome parks residents) to voice their concerns and request needs for the neighborhoods, such as sidewalks, better lighting, better crime prevention strategies, and more neighborhood parks. The City also distributes information annually to inform owners and residents of the Mobile Home Rent Stabilization Ordinance. The City adopted the Mobile Home Park Act in 2021 and in July, by agreement with HCD, the City took over enforcement of mobile home parks within city limits. As a result of the adoption of the Mobile Home Park Act, the City's Code Enforcement Department created the Mobile Home Inspection Team, which oversees the health and safety ordinances and the Planning and Development Department created a new review and inspection process and team to oversee the permitting of mobile home placement and site improvements. In 2021 and 2022, | Maintain program. | | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | owners, identifying city, state, federal, and private resources available to address those needs.

Provide assistance with funding applications to mobile home park owners, residents, and non-profit organizations to assist in mobile home preservation.

Compile a list and map of mobile home parks in Fresno. Develop a list of mobile-home preservation experts and nonprofit organizations that can assist in the preservation of mobile home units. Provide this information to interested mobile home park residents, owners, and non-profit organizations. | there were 66 mobile home placements on site submitted, 105 entitled and permitted, and 12 placed on site. | | | 10B | **Housing Choice Vouchers.** The Housing Choice Voucher (HCV) program, formerly the Section 8 program, provides rent subsidies to very low-income households which overpay for housing. Prospective renters secure housing from HUD-registered apartments that accept the certificates. HUD then pays the landlords the difference between what the tenant can afford (30 percent of their income) and the payment standard negotiated for the community. In Fresno, the Fresno Housing Authority administers the HCV program. To facilitate access to the Housing Authority’s program, the City will collaborate with and support the Housing Authority’s program on an annual and ongoing basis by:

Providing information about Housing Choice Vouchers at the planning counter, on the City/ website and in other public places to increase awareness.

Assisting the Housing Authority in maintaining a list of multifamily rental developments that accept vouchers and hold regular discussions with | In 2017 and 2018 the City of Fresno increased the visibility of Housing Choice Vouchers through its website and developed a methodology to define High Opportunity Areas (HOAs), sharing the boundaries and list of information on apartments within the HOAs with the Housing Authority. In 2019, the Housing Authority initiated a Landlord Outreach program to educate and encourage new landlords to participate in the HCV program, as well as ensure current landlords are educated and providing quality housing.

In January and February of 2020, the Landlord Outreach Assistant Manager met separately with 27 landlords of properties located within HOAs to provide training and information and a few agreed to accept vouchers. During the COVID-19 closures in 2020, the department focused on providing a seamless virtual customer service experience for both landlords and tenants, which included serving as liaison and growing the Partnership between Fresno Housing and Landlords. Landlord outreach efforts continued during the pandemic, encouraging landlords to participate in Fresno Housing programs. These efforts led to seven new landlords and two property management companies accepting HCVs, two of which are in HOAs. In January, Fresno Housing submitted a Mobility Demonstration application to HUD in efforts to provide support to families who desire to lease up in HOAs.

The Fresno Housing Authority launched a Landlord Incentive Pilot program in March 2021 and added additional incentives in June 2021 to | Maintain program. Expand marketing efforts and education about the Emergency Rental Assistance Program in addition to the HCV program. | SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | potential new landlords to expand the number of developments that accept HCV tenants.

Collaborating with the Housing Authority to conduct outreach to developments in high opportunity areas about participation in the Housing Choice Voucher program by exploring best practices to target areas for voucher education, such as areas with high-performing schools or areas with high area median income, as well as areas near jobs and transit. The City’s role will be to assist in the geographic analysis necessary to target the outreach. The outreach will be performed on an annual and ongoing basis. | encourage landlords to either stabilize or bring on new units to the program in efforts to encourage them to house families during the COVID-19 pandemic. The pilot was funded through the use of CARES funding to monetarily incentivize landlords to rent to voucher recipients searching for affordable units within FHA’s jurisdiction. Approximately $140,000 was distributed to landlords during the incentive period from mid-June 2021 to mid-December 2021, however all incentives expired December 31, 2021, in accordance with the sunset of CARES funding availability.

In 2023, Fresno Housing has partnered with the City of Fresno to launch the Voucher Incentive Program (VIP) to assist voucher holders find housing. Developing from the pilot, the lead VIP coordinator will promote the HCV program, work with current voucher holders to conduct tenant education on eligibility for additional types of assistance through the VIP program such as security deposit and rental fee assistance. The coordinator will also promote and provide information on the incentives offered through the VIP program to recruit eligible, non-participating property owners.

As of January 2023, the number of HCV holders in the city is about 7,400 and the number in HOAs is 147, or 1.29 percent of all voucher holders in the city. In addition to HCV, the Fresno Housing Authority also administers special programs such as VASH and HOME, which are rental assistance programs that extend into HOAs as well. Combining these special programs with HCVs the total number of households receiving rental assistance in HOAs is 154 or 1.35 percent of all voucher holders in the city. | | | 11

Fresno Green. The City will continue implementation of the Fresno Green program and work with developers to lower long-term housing costs through energy-efficient housing developments. The City will also monitor grant funds for applicable housing related energy-efficient items and pursue funding on an ongoing basis. | The City continues to offer the Fresno Green program to developers as an incentive to build sustainably, which in turn reduces utility costs to homeowners or renters. In 2016, two housing projects received Fresno Green Certification and both were affordable housing sites. One was the 51 dwelling unit South Fulton Project at 829 Fulton Mall and the other was the 8 dwelling unit Glenn Avenue Apartments at 146 N. Glenn Avenue.

In 2017, the City began an update of the Fresno Green program to better align it with the 2035 Fresno General Plan and state policies and goals associated with greenhouse gas (GHG) reduction; however, funding ran out after the first phase of the update and additional funding was not | Delete program. | | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | | pursued by grant partners, therefore the revitalization and implementation were stalled. No housing projects received the Fresno Green Certification between 2017 and 2023. The Fresno Green program has been mostly superseded by the CalGreen Building Code and California Energy Code and other State mandates such as the Model Water Efficient Landscape Ordinance. The City's updated sustainability measures for new buildings are outlined in the City's GHG Reduction Plan, adopted in 2021. | | | 12 | Downtown Development. In 2016, the City adopted the Downtown Development Code (DDC) to encourage infill development at the City's core that is compact and walkable, offers a mix of uses, and creates a sense of place. The Downtown zoning standards contain a residential capacity limit for the Downtown Planning Area (9,990 dwelling units), with unlimited density on individual Downtown properties. Residential capacity in the area is significantly increased with the DDC and allows residential development where it was not previously permitted. The Downtown standards provide a streamlined and clear set of zoning regulations, making good projects easier to build in Downtown and the surrounding neighborhoods. To facilitate higher-density mixed-use development in Downtown, an environmental impact report assessed the proposed Downtown plans and code so that new development that complies with Code will not be subject to further environmental analysis. The City will ensure that the Downtown Development Code standards will not constrain the potential for developing housing and that zoning standards for the sites ensure continued adequate capacity to meet the City's RHNA obligation. | Downtown Development Standards were adopted by the Fresno City Council on October 20, 2016. There have been no rezones or plan amendments in Downtown Fresno and no changes have been made to the Downtown Development Standards since then. | Delete. Program was completed. | SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | 12A | **Downtown Displacement Prevention.** The City will implement Policy 7.12.1 of the Downtown Neighborhoods Community Plan which calls for the convening of a displacement task force to explore ways to provide opportunities for low income residents and merchants to remain in their neighborhoods if displacement is observed due to substantial and sustained increases in rent. The task force should work in conjunction with low income residents, community organizations serving low income residents, experts on displacement, low income business owners, and property owners in the plan area.

The intent of the displacement task force is to establish measurements and collect data on those measurements that can identify gentrification and/or displacement of residents or businesses in Downtown. The data gathering measures are intended to establish baseline conditions which will be used to compare to future conditions as the Downtown area redevelops. The following action items are included in the Plan:

Convening a displacement task force to explore ways to provide opportunities for low-income residents and merchants to remain in their neighborhoods if displacement is observed. The Task Force shall be convened in 2018, within 3 months of the release of the first annual report on displacement.

Annually gathering data on lease rates, vacancy rates, rent burden, rental rates, restricted affordable housing covenant expirations, and, if applicable, direct displacement for use by the task force. An annual report on data gathered shall be released for public review and input. | An Anti-Displacement Task Force was established by City Council in 2018 and Task Force appointees began meeting regularly in 2019, after which the Task Force decided to meet on a quarterly basis.

In 2019, the City hired the Thrivance Group to craft specific measurements applicable to key concerns identified by both homeowners and renters, including strategies to prevent displacement of both people and culture. Specifically, the Thrivance Group’s scope of work consisted of social climate analysis and data collection, identification of groups especially vulnerable to displacement, and strategy development to prevent and avoid displacement. Extensive community engagement around displacement was conducted. In 2021, the Thrivance Group produced the “Here to Stay: A Policy-Based Blueprint for Displacement Avoidance in Fresno” report for the City, which included suggested anti-displacement priorities and strategies.

The Anti-Displacement Task Force’s recommendations on displacement prevention priorities were presented to the Planning Commission in January 2022. The recommendations also informed the One Fresno Housing Strategy, presented to the City Council in April 2022. The goal of the One Fresno Housing Strategy, a three-year framework for fast-tracking the implementation of the City’s existing housing plans, is to “create an environment that leads to the 3-year completion, rehabilitation, and preservation of 6,926 affordable and 4,110 market-rate housing units by identifying available land, vacant property, and financial resources while deploying a wide range of development partners to increase housing options across the housing spectrum throughout the City.”

The One Fresno Housing Strategy contains 71 programs for accomplishing this goal, organized under the objectives of housing preservation, displacement prevention, and promotion of equity, with a special set of programs designed to house the unhoused. Programs that were adopted by the City Council in 2022 include:
• Allocation of $1,950,000 to the Central Fresno Neighborhood Trust, to prevent displacement and acquire and rehabilitate 50 units of rental housing;
• Allocation of $222,500 to Central California Land Trust, a mechanism that allows for permanent affordability; | Program Completed. Delete. | | | Program Summary | Progress Evaluation | Recommendation | |---|---|---|---| | | Identifying a set of actions that give displaced persons or businesses the opportunity to remain in the area if they wish to do so within 6 months of the Task Force finding that displacement is occurring, which will be carried out within one year of identifying the actions. | • Allocation of an additional $2M to the City’s Eviction Protection Program; | | | | Seeking funding for mixed income and affordable housing within the plan area, including potential set-asides for affordable housing for tax increment generated within any future Enhanced Infrastructure Financing Districts formed or a future citywide affordable housing trust fund. | • Allocation of an additional $3.5 Million to the City’s recently created local housing trust fund; | | | | Working with the owners of affordable housing properties to ensure that affordability is maintained over the long term. | • Allocation of $5M for a No Place Like Home Downpayment Assistance Program. | | | | Creating and maintaining a webpage to post information provided by staff to the task force, task force minutes, reports issued by the task force, and other relevant materials. | • Allocation of $5M for a No Place Like Home for the creation of two tiny home villages | | | | | • $850,000 to Fresno City College to allow students to create 24 tiny homes for low-income households. | | | 13 | **City of Fresno’s Home Energy Tune-Up (HETU) Program.** The City of Fresno provides the Home Energy Tune-Up (HETU) Program to residents of Fresno and seven other counties from Bakersfield to Stockton California in the PG&E electric service territory. This program is funded by California utility customers and administered by PG&E under the auspices of the California Public Utilities Commission. The City managed the HETU program since 2011 and is committed to continuing to provide local residents with this vital service to help drive down energy costs, improve indoor air quality, and make homes more comfortable for Fresno residents. | Funding was discontinued for this program so the City has stopped offering this program. Instead, the City has focused on implementing the GHG Reduction Plan and pursued opportunities to ensure its municipal buildings are using energy resources efficiently. In 2021, the City finished energy efficiency and solar projects at Fresno City Hall and the Municipal Service Center (MSC) and launched several parks and Parks & Public Safety Energy Efficiency Projects in 2022. Projects include LED lighting upgrades, HVAC upgrades, system controls upgrades, transformer upgrades, installation of mobile backup generators at one Fire and at one police station, and energy efficiency improvements at parks in highest need neighborhoods. | Delete program. | SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | 14 | Expedited Processing/Business Friendly Fresno. The City's Business Friendly Fresno program presents prospective developers with an easy-to-follow and customer-focused approval process. The program has established accountability and clear protocols and authority for decision-making that align with the General Plan and the Development Code. The City will continue to implement the Business Friendly Fresno program as it applies to residential development projects and also continue to provide fast track or one-stop permit processing for housing developments affordable to lower-income households or other priority housing needs (i.e., extremely low-income, large families, persons with disabilities, farmworkers). As needed, the City will assess the incentives needed to facilitate the development of affordable housing. | The City has made several updates to the development review process to simplify and enhance the process for customers. The City also provides technical assistance and development incentives (e.g., Infill Incentive Fee Waivers) to make development cheaper and easier. In 2017, Business Friendly Fresno completed the implementation of new Accela software to improve processing of applications, accountability, and transparency. In 2018 the City reorganized the Development Review Committee (DRC) such that applicants now work with one administrator who answers questions, receives and assigns submittals, and sends response letters. This new process has increased productivity, cost effectiveness, and responsiveness; initial feedback from applicants has been positive. The Planning Division made additional updates to the DRC process in 2020 and 2021 to simplify and enhance the process. In 2021 and 2022, the Building & Safety Services Division made improvements to the permit and approval process for customers including hiring new staff members in key positions, creating a new review process and inspection team for mobile home parks, creating a streamlined housing team, creating an Accela Information Services Division Team, reducing timelines for back checks, developing a new electronic submittal record request (LP records), offering new standard plan templates for ADUs, and improving coordination between City departments to streamline site plan permit process. Notably, in 2019, the City instituted a Money Back Guarantee Program to enforce mandatory processing timelines for planning entitlements and building plan check reviews but repealed the program in 2020 so the program is no longer effective. Between 2019 and 2020, there were no overdue plan reviews that resulted in any money being returned. | Delete program. Combine with Program 15 below. | | 15 | Development Incentives. The City will continue to provide priority processing for the construction of new housing in the Downtown Planning Area by processing completed plans, consistent rezoning, and Development Permit review and Conditional Use Permit applications for permitting within an average of 75 working days. The City will continue to provide reduced application fees | The City has been generally successful in executing priority processing for new projects in the Downtown Planning area, with approvals being issued on average in less than 75 days. Additionally, the City continues to provide impact fee waivers for qualifying projects and offers reduced application fees and priority processing for single-family and multi-family projects within the Inner City Fee Program area. | Maintain program. | APPENDIX 1E: CITY OF FRESNO | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | and priority processing for single-family and multi-family projects within the Inner City Fee Program area, as referenced in the Municipal Code, to create housing units. In addition, impact fee waivers are available for qualifying infill projects in priority areas of the City pursuant to Ordinances 2013-21 (The Build Act), and Fresno Municipal Code Article 4.14 (Fee Waivers for Certain Projects in Economically Disadvantaged Areas). As funding is available, the City will reduce or subsidize development and impact fees for affordable housing. | | | | 16 | Large and Small Lot Development. The Sites Inventory includes 2,644 acres of vacant and underutilized sites that are over 10 acres in size (53.8 percent of all residential capacity on vacant and underutilized sites). To encourage a strategic approach to the development of large sites and to facilitate the development of housing, the City will encourage the development of large sites through an allowance of phasing of development and off-site improvements and, where applicable, through the Specific Plan process.

The City will assist interested developers/property owners in identifying opportunities for lot consolidation or lot splitting. The City will continue to streamline the processing of requests for lot consolidation and lot splitting concurrent with other development reviews. The City will also facilitate splitting of large lots to promote the efficient use of land for residential development in compliance with the Subdivision Map Act, when an applicant submits an application. Currently, the City utilizes tools such as ministerial processing and other streamlining tools, as appropriate, to facilitate lot merging and parcelization. | In 2016, the City reduced the Voluntary Parcel Merger application fee from $5,360 to $627 which resulted in the greatest number of Voluntary Parcel Mergers since the inception of the program in 2011. That year the City approved 15 voluntary parcel mergers. Between 2017 and 2022, the City approved between 14 and 22 parcel mergers per year. Some of these projects involved Housing Element sites while others did not. A monitoring program for large and small lots was established in July 2016 with procedures prepared as part of Program 2 above.

Between 2016 and 2022, construction occurred on 283 Housing Element sites that are under 1 acre and 83 sites that are over 10 acres. There were also 3 projects that included sites that were both over 10 and under 1 (these projects were both rezoned in 2017 through the Southwest Fresno Specific Plan (SWFSP) adoption and associated General Plan cleanup).

The monitoring program also identifies affordability. Projects that occurred on Housing Element sites larger than 10 acres were not explicitly designated with an affordable housing component as they were typically developed as single family subdivisions. | Maintain program. | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-5-25 SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | The City will also establish a program to monitor development trends on small and large lots, identify regulatory barriers, and adjust incentives and/or development standards accordingly. The monitoring program will include a threshold defining small and large lots and may vary by neighborhood, community plan area, or zoning district. The monitoring program will include a biennial review of development on large and small lots, and will seek input from developers and property owners on regulatory barriers to development of these lots. The monitoring program will further track the percentage of affordable units developed on large lots on an annual basis and after the first year of monitoring, will identify a minimum threshold of affordable units for the total number of large lots. Monitoring will begin upon receipt of the first application for development on a large lot included within the sites inventory. If the total number of affordable units being developed on large lots does not reach the identified minimum threshold beginning in the second year of monitoring, then the City may develop and apply incentives in order to encourage development of affordable units. If development on large lots will lead to the need for an amendment to the sites inventory, such analysis will consider any necessary rezoning consistent with Program 2. | | | | 16a State Laws Related to Housing Development. As part of an ongoing effort to ensure compliance with emerging state laws, the City will identify appropriate revisions to the City’s Development Code and present them for consideration consistent with FMC procedures. As part of this effort, the City will work to increase awareness of standards that allow second dwelling units, backyard cottages, tiny houses and accessory living quarters by providing written information at the City’s planning counter and on the City’s website. | The Planning & Development Department regularly reviews and evaluates the latest State laws as they relate to the Development Code to determine what, if any, changes are needed to the Code. Beginning in 2019, the City began providing information on State ADU standards and has continued to build its local program to encourage residents to develop ADUs. The City intends to amend the Development Code by 2024. | Continue to make appropriate revisions to the City’s Development Code to maintain compliance with state laws. | | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | 17 | Agricultural Employees (Farmworker) Housing. The California Employee Housing Act requires that housing for six or fewer employees be treated as a regular residential use. The Employee Housing Act further defines housing for agricultural workers consisting of 36 beds or 12 units as an agricultural use and permitted where agricultural uses are permitted. The City of Fresno Development Code allows agricultural labor housing by right in the Buffer (B) district and specifically indicates that in the case of any conflict the California Health and Safety Code relating to agricultural employee housing, State law supersedes the Development Code. The City will review the Fresno Development Code to ensure continued compliance with the California Employee Housing Act. Based on the review of the Development Code, the City will amend or revise the Fresno Development Code, if needed, to comply with the Employee Housing Act. | The Agricultural Employee Housing (AEH) Act was reviewed and no changes to the Development Code are necessary, because it currently meets the requirements of the AEH as Development Code Section 15-2716 states “Regarding Agricultural Labor Housing, in the event of a conflict between this Code and California Health and Safety Code section 17021.6, relating to agricultural land use designations for employee housing, the Health and Safety Code shall prevail.” However, in order to increase clarity between the Code and State law, Planning staff will prepare a Text Amendment to update the Code's Use Tables to add "agricultural labor housing" as a permitted use in each zone that currently permits agricultural uses. Staff intends to pursue this update by 2024. | Modify timeframe to reflect 2024 development code amendment if not already completed. | | 18 | Infrastructure Priority Program. The Department of Public Utilities has established written policies and procedures that ensure water and sewer services are to be provided as a priority for developments that include units affordable to lower-income households, contingent on the development application's compliance with all entitlement requirements. The City will ensure that all development applications are considered, reviewed, and approved without prejudice to the proposed residents, contingent on the development application's compliance with all entitlement requirements. | There are administrative orders in place to ensure that all development applications are considered, reviewed, and approved without prejudice. | Maintain as a policy, but no additional implementing action is required. | SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS | | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | :--- | | 19 | Water and Sewer Service Providers. The City of Fresno Department of Public Utilities (DPU) provides potable water to the majority of the City, and the City is the Regional Sewer Agency for the Fresno-Clovis Metropolitan Area. In accordance with Government Code Section 65589.7, immediately following City Council adoption, the City must deliver to all public agencies or private entities that provide water or sewer services to properties within the City of Fresno a copy of the 2015-2023 Housing Element. | A copy of the Fresno General Plan 2015-2023 Housing Element was sent to the City of Fresno Department of Public Utilities Water Division and Wastewater Division, as well as to the Pinedale County Water District and the Bakman Water Company which supply water to a segment of households within the city limits. | Delete program. This is a required practice and progress does not need to be annually monitored. | | 20 | Comprehensive Code Enforcement. The City of Fresno, in conjunction with private businesses and developers and community-based non-profit organizations, will continue to collectively increase neighborhood revitalization activities. The Community Revitalization Division will continue to assertively conduct targeted neighborhood inspections of housing units for potential health and safety issues. The Community Revitalization Division’s Safe Housing and Vacant Structure Team, and all Area Teams as needed, will continue to improve neighborhoods throughout Fresno and increase livability by creating safe and healthy conditions, removing blight, educating citizens, promoting pride of ownership and building collaborative relationships with the community.

In 2016, the City established a Neighborhood Revitalization Team (NRT) that is assigned to targeted neighborhood revitalization activities. The City adopted and implemented a revised blighted vacant building ordinance and has established the Strike Team on Problem Properties. The Mayor-Council Code Enforcement Task Force is currently discussing options to improve property conditions and | The Community Compliance Unit is responsible for traditional code enforcement complaints and enforcement. This Unit gained one employee to have 29 inspectors assigned to 7 City Council Districts and is primarily focused on life safety and blight violations. In 2022, this Unit addressed 12,452 unique code cases. This Unit is also responsible for monitoring vacant residential and commercial buildings and monitoring and addressing homeless encampments on private property including vacant lots and structures. The Special Teams Unit is comprised of 6 specialty teams, each responsible for addressing specific code enforcement matters.

The School Area Team (SAT) provides pro-active code enforcement and community outreach near schools to improve neighborhoods, reduce blight, enhance safety, equip residents to become civically engaged, and connect low-income residents to housing resources to improve their quality of life. Awarded 2021 Innovative Program of the Year Award by the California Association of Code Enforcement Officers (CACEO), SAT conducted enforcement and outreach in 28 school areas in 2022.

The Demolition Team facilitates abatements of severely damaged structures by demolition, responds to structure fires in need of summary abatement demolition, and monitors demolition and/or rehabilitation by property owner. There were 29 demolition cases finalized in calendar year 2022.

The Rental Housing Unit is comprised of 5 separate teams. The Proactive Inspection Team, through the Proactive Rental Housing Improvement Program, requires all rental properties to be registered | Maintain program. | APPENDIX 1E: CITY OF FRESNO | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | preserve the city’s existing rental housing stock. The City will pursue resolution of cases identified through the inspection process, including through enforcement actions against landlords if necessary. | with the Rental Housing Registry. Currently, there are 86,862 individually registered rental units located across 30,732 registered rental properties. The City requires registration of all rental properties and they are subject to Baseline Health & Safety Inspections pursuant to a random sampling formula to ensure habitability. The purpose of the Proactive Rental Housing Improvement Program is to address the issue of substandard rental properties, promote greater compliance with health and safety standards and to preserve the city’s neighborhoods and available housing opportunities. Through the Proactive Rental Housing Improvement Program, 16,763 inspections have been conducted at both multi-family and single-family homes. The Reactive Inspection Team responds to all complaints of code violations received with regards to multi-family properties. They enforce substandard housing, public nuisance, and zoning violations. In 2022, reactive inspectors responded to 1,711 cases, successfully resolved 1,519 of them, and currently carry a case load of 234 active cases. The Anti-Slum Enforcement Inspection Team (ASET), in conjunction with the Police Department, Fire Department and County Housing Authority conducts proactive inspections of multi-family properties deemed to be slum properties based on Police, Fire, and Code Enforcement calls for service. They inspect the interior of all units, the exterior of all buildings and the property grounds for substandard building, public nuisance, and zoning code violations. The ASET Team currently has 13 cases open representing 161 units. The Mobile Home Inspection Team enforces the California Health & Safety Code, Mobilehome Parks Act and the California Code of Regulations Mobilehome Parks Act by investigating all Mobilehome and Mobilehome Park complaints at the 29 parks within the city of Fresno. In addition, the team conducts proactive maintenance inspections of mobilehome parks throughout the year. In 2022, the team conducted 9 park inspections representing 812 spaces. | | | 21 | **Neighborhood Infrastructure.** The Public Works Department will commit its best efforts to provide households, within budgetary allocations, with neighborhood infrastructure improvements such as curbs, gutters, sidewalks, streets, curb ramps, driveway approaches, curb cuts, and street lights. In addition, the City will provide services | The City of Fresno Department of Public Works Construction Management Division completed various infrastructure projects during the previous Housing Element cycle. At an overall cost greater than $200 million, projects included: street construction, parks, traffic signal, sewer and water, and transportation projects. HUD CDBG funds were used to fund projects in low- and moderate-income neighborhoods. | Maintain actions, combine with Program 27. | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-5-29 SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | to facilitate development of undeveloped or underdeveloped properties. The City, through the Disability Advisory Commission and the ADA Transition Plan for the Public Right of Way, will continue to receive citizen suggestions on needed ADA improvements and implement the most needed projects on a priority basis. | The City has developed a supplementary map, "Fresno General Plan Housing Element Annual Progress Report for 2018 - City of Fresno Infrastructure Projects Completed (Capital Improvements and CDBG Funded) In Relation to Housing Sites," that addresses relationship between infrastructure projects and Housing Element sites. | | | 22 Housing Rehabilitation. The City offers programs that provide paint and minor repair to seniors, distressed property grant, and home rehabilitation funds for lower-income households. These activities have been funded primarily with HOME and CDBG program funds. The Homeowner Rehabilitation Program provides a grant to low-income, owner-occupied households to make needed repairs and improvements to their homes. The maximum allowable amount for a rehabilitation grant is $65,000. The City also offers a Senior Paint Program in the form of a grant to low-income senior citizens (62 years of age or older) who own and occupy their home. Grant funds provide for a licensed lead-certified painting contractor to paint the exterior of the home. The Distressed Property Grant provides up to $15,000 per property to assist low-income homeowners with correction of code violations. | The Housing and Community Development Division (HCDD) works to complete housing rehabilitation projects for homeowners with low or moderate incomes. Between 2016 and 2022 projects were completed under the following programs:
- City of Fresno Senior Paint Program
- Fresno EOC Roof Program
- Minor Code Compliance Program
- Targeted Distressed Area Program
- Self Help Home Repair Program and
- Habitat for Humanity Home Repair Program

The rehabilitation programs experienced delays due to the COVID 19 pandemic. The City continued to support owner-occupied home repair programs by allocating $700,000 in Program Year 2022 CDBG funds to home repair programs for low- and moderate-income seniors. The funds were used to maintain the City's in-house owner-occupied home repair programs. The City has also allocated $553,717 of its third allocation of PLHA to further its program focused on owner-occupied home rehabilitation for low-income people not eligible for funding through other programs, such as mobile home residents. Once the City receives its executed Standard Agreements for PLHA funds from the State, it will implement the program. | Maintain program. | | 23 Franchise Tax Board Building Code Program. The Franchise Tax Board (FTB) operates the Substandard Housing Program, which assists State and local agencies responsible for abating unsafe living conditions that violate health and safety codes. Property owners in violation of health and safety code standards are not allowed to make certain deductions on their personal tax | The City investigated participation in the Franchise Tax Board's (FTB) Substandard Housing Program, researched necessary notices and procedural requirements, and began participating in the Program as it relates to ASET properties. The City has only issued two notices since participation in the program, this was in 2017. Typically, the City does not need to issue notices because remedies have been found within the required six-month window of non-compliance. | Delete program. | | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | returns pursuant to California Revenue & Taxation Code (CR&TC) Sections 17274 and 24436.5. The additional revenue collected by FTB is transferred to the Local Code Enforcement Rehabilitation fund. These funds are allocated and disbursed to the cities and counties which generated the notification of substandard housing to the FTB.

The City will investigate participation in this program as a tool to reduce the number of substandard units in Fresno. | | | | 24

At-Risk Housing. The City will continue or undertake the following activities during the Housing Element planning period to guard against the loss of housing units available to lower-income households. The efforts listed below represent a varied strategy to mitigate potential loss of at-risk units due to conversion to market-rate units. These local efforts utilize existing City and local resources. They include efforts to secure additional resources from the public and private sector should they become available.

Provide ongoing preservation technical assistance and education to affected tenants and the community at-large on the need to preserve the existing affordable housing stock.

Monitor owners of at-risk projects on an ongoing basis, at least annually, in coordination with other public and private entities to determine their interest in selling, prepaying, terminating or continuing participation in a subsidy program.

Monitor at-risk projects through the use of existing databases (e.g., HUD, State HCD and California Tax Credit Allocation Committee). | In 2016, the City of Fresno approved an assumption and assignment agreement for DHI to assume a $2.9 million note from the Annadale Housing Partners for the substantial rehabilitation of the King's View Estates, a 116-unit affordable housing complex in southwest Fresno.

In 2017, the Housing and Community Development Division received a request from Opportunity Builders to consider an assignment and assumption of its HOME Program Agreement and related documents to EAH. EAH has proposed to acquire the Village at Kings Canyon Apartments, a 48-unit affordable rental property in southeast Fresno.

In 2020, the City became aware of five properties designated as at-risk of converting to market rate by the California Housing Partnership’s Preservation Clearinghouse. The City did not receive any notices of intent to convert to market rate for any properties during the 2018-2022 calendar years. | Maintain program. Modify to include required timeframe for noticing. | SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | The City will respond to any federal and/or State notices, including Notice of Intent to Pre-Pay, owner Plans of Action, or Opt-Out Notices filed on local projects, by contacting property owners upon receipt of notices. | | | | Work with the Fresno Housing Authority to determine the availability of tenant-based vouchers for tenants who choose to move from at-risk units or are displaced by conversion. | | | | Establish contact with public and non-profit agencies interested in purchasing and/or managing units at-risk to inform them of the status of such projects. Where feasible, provide technical assistance and support to these organizations with respect to financing. The City will actively pursue affordable housing opportunities and maintain a list of interested and qualified affordable housing developers. | | | | 25 Enhanced Police Service to High Crime Neighborhoods. The Police Department shall continue to focus on strategies to reduce Part I crimes, which are measured by the Federal Bureau of Investigation to assist cities in comparing themselves against other cities in the following categories: murder, rape, robbery, aggravated assault, arson, burglary, theft and auto theft. The Department shall also continue to utilize the Violent Crime Impact Team (VCIT), Multi-Agency Gang Enforcement Consortium (MAGEC), Street Violence Section (SVS), and Patrol Division in reaching this goal. In addition, the Department shall continue its prevention and intervention programs such as the Police Activities League, Citizens on Patrol (COP), and Mayor's Gang Prevention Initiative in an effort to reduce crime in high-crime neighborhoods. | The Police Department continued to use Problem Oriented Policing Officers, Multi-Agency Gang Enforcement Consortium Detectives (MAGEC), Street Violence Bureau Detectives (SVB), the Patrol Division, District Safety Teams, Police Activities League, Building Better Neighborhoods (formerly known as Bringing Broken Neighborhoods Back to Life), SRO (Student Resource Officers), the Fresno Housing Officer (formerly known as ENPH) the Police-Community Relations Unit, K9 Officers, Skywatch, the Traffic Unit, Bicycle Patrol, and tools such as ShotSpotter (gunshot detection) in an effort to reduce crime in high crime neighborhoods. The City was awarded the FY22 COPS Hiring grant in October 2022 to hire twelve (12) officers, assigned to go Bike Patrol, in four policing districts – Central, Southeast, Northeast, and Northwest. The Officers will work with the residents in the high violent crime areas and homelessness as needed. Also, the City has continued partnership with the Housing Authority of Fresno along with other Housing organizations to fund two dedicated police officers for HUD contracts. These officers, one located in Southwest Fresno and the other in Southeast Fresno service local housing developments to eradicate crime. The City continues to be a part of | Delete program. Not relevant to the Housing Element. | | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | In 2015, the City of Fresno was awarded $1,875,000 in grant funding through the Department of Justice's Office of Community Oriented Policing Services (COPS Office) COPS Hiring Program (CHP). The money will be used to hire neighborhood police officers and school resource officers for the City of Fresno. | and operate within the Multi-Agency Gang Enforcement Consortium (MAGEC), Street Violence Bureau, Patrol Division, Citizens On Patrol, and the newly established Police Community Relations Unit. Additional community education programs hosted by the Fresno Police Department are the Residents Academies – English, Spanish, Hmong and recently added Sheikh, Police Explorer Program, Teen Police Academy, Police Activities League (PAL), and Fight Girl Fitness (through PAL). The MAGEC Unit has a working relationship with the Fresno Economic Opportunities Commission (FEOC) Advance Peace (a non-profit organization) and Project Safe Neighborhood Task Force which focuses on violence intervention and prevention. The City continues to utilize the expertise of Crime Data Specialists for crime mapping and data analysis as well as technology tools such as ShotSpotter, a gunshot detection system in an effort to reduce crime in high-crime neighborhoods. Grants awarded in FY 2021 and utilized in FY 2022 include: Sexual Assault Kit Initiative (SAKI) grant, Law Enforcement Specialized Units Program – Domestic Violence (a partnership with Marjaree Mason Center), the Law Enforcement Mental Health and Wellness Act 2021 (LEMHWA), De-Escalation and Project Safe Neighborhood (PSN) 2021 and 2022 grants. | | | **Fair Housing Services.** The City will continue to contract with a fair housing service provider (Fair Housing Council of Central California [FHCCC]) to support enforcement of State and federal Fair Housing Laws and provide fair housing services that include, but are not limited to, the following fair housing service:

Referring inquiries and landlord/tenant complaints concerning housing discrimination to the applicable regulatory body (State Department of Fair Employment and Housing, HUD, or private counsel) for processing

Disseminating fair housing information citywide by sponsoring workshops, housing information fairs, monitoring of affirmative marketing and working closely with the State Department of Fair Employment and Housing | From 2016 to 2020, the City made annual contributions (~$40,000) to the Fair Housing Council of Central California (FHCCC) for education, complaint, and referral services. During this time, FHCC addressed an average of 800 fair housing complaints per year. A small percentage of complaints were referred to HUD for administrative or injunctive relief. In 2019, FHCCC conducted a Systemic Testing project in Fresno to determine the commonality of discrimination in new home developments on the basis of race and familial status. All testing was done according to the available rental market. Results showed that people of color suffered some form of housing discrimination in new developments across the city 48 percent of the time (i.e., refusal to rent, lying about availability, or imposing different rules, terms, or conditions of tenancy).

The City completed an updated Analysis of Impediments to Fair Housing Choice (AI) in 2020. The AI includes an assessment of socioeconomic conditions, segregation and integration, access to opportunity, housing profile including publicly supported housing, housing for persons with disabilities, and fair housing activities. The AI | Maintain program. | SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | Advertising fair housing laws and complaint procedures through literature displays at City and County offices, non-profit organizations such as Central California Legal Services, Lao Family Organization, Fresno Interdenominational Refugee Ministries, Central Valley Regional Center, property management organizations, lenders, and other such organizations. Literature will be provided in English, Spanish, Hmong, Cambodian, Vietnamese and Lao.

Disseminating fair housing information through radio, television and other media | also identifies barriers to fair housing choice within the City, and provides recommended activities to address those barriers. The activities fall into three main categories: fair housing complaint and referral services, public fair housing education and outreach, and fair housing education and outreach to housing industry professionals.
In 2021 the City awarded $35,000 of CDBG funds for fair housing outreach and education for tenants and landlords through Central California Legal Services and $15,000 to the Community Housing Council of Fresno to conduct a series of fair housing workshops for prospective homebuyers and real estate/finance professionals. In 2021, the City increased its Fair Housing allocation by 70 percent over the prior year. It entered into Agreements with the Fresno Interdenominational Refugee Ministries (FIRM) and Resources for Independence Central Valley, Inc. (RICV) to address the impediments to Fair Housing the City identified. Through FIRM, the City provided public Fair Housing education and outreach through workshops, ethnic media, and informational resource distribution both city-wide and by targeted canvassing. Outreach materials were distributed in five languages throughout areas where low-income Southeast Asian, Spanish-, and Arabic-speaking communities congregate. Resources for Independence Central Valley also worked on an outreach and education program for vulnerable populations in the City with specific emphasis on easy-to-understand information on housing rights, housing discrimination, housing resources and subsidies, and overall fair housing issues. The City also allocated $580,000 of CDBG COVID-19 funds in 2020 and 2021 to Community Housing Council to provide counseling to assist tenants and landlords impacted by COVID-19. Additionally, the City allocated $971,167 in 1st-year and $1,509,494 in 2nd-year Permanent Local Housing Allocation (PLHA) funds for a down payment assistance program for low- and moderate-income individuals. Once the City receives its executed Standard Agreements for PLHA funds from the State of California, it will implement the program. | | | 27 | **Equitable Communities.** The City has initiated efforts to improve property values, living conditions, public safety, and the overall quality of life in older neighborhoods through the Fresno General Plan. The | The City receives HUD funding for capital improvement projects in CDBG areas of Fresno. The City initiated funding for pavement reconstruction, sidewalk improvements, and curb and gutter improvements in low- and moderate-income neighborhoods in two | Maintain and update to narrow the scope of actions for the program. | | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | General Plan identifies Priority Areas for Development Incentives in Chapter 12 (Implementation), Figure IM-1. This figure identifies areas that have been designated as a priority for investment through policies established within the Plan. It includes the Downtown Neighborhoods Community Plan Area, Phase 1 and Phase 2 Bus Rapid Transit (BRT) and High-Frequency Transit Corridors, Infill Opportunity Zones (IOZs)—which have been defined as established neighborhoods generally south of Herndon Avenue—and the South Industrial Area. While specific investments were not identified in the General Plan, the City has focused internally on ensuring that future discretionary and formula dollars, especially related to housing, community development, streets, transit, and parks, align with these priority areas. To supplement this effort and focus on the equitable distribution of housing resource and public investment, the City will: Publish a General Plan Annual Report every December which will detail the location of public investments as they relate to Figure IM-1 and Figure IM-2 in the Plan, in addition to the location of building permit activity by sector as a metric of private investment. This report would be for use by the public and by the Implementation Committee described below as a basis for making recommendations on General Plan implementation. Establish a General Plan Implementation Committee with cross-sector involvement from the private sector, including developers and community organizations, as well as other relevant public institutions, to review progress on the priorities established in the General Plan to invest in older and disadvantaged neighborhoods and continue to refine and review City policy and practice to ensure investments and policies are furthering the goals of the Plan. This committee | locations in 2022 – the Burroughs Elementary Neighborhood Street Reconstruction Project (Phase I) and the West Fresno Elementary and MLK Neighborhood Street Improvements Project. The City also funded additional projects for overall neighborhood street improvements – the Yosemite Middle School Complete Streets Project, the Ericson Elementary Neighborhood Project, the Highway City Neighborhood Reconstruction Project, the Maple-Gettysburg-Holland Street Reconstruction Project, the Olive-Maple-Whitney-Chestnut Street Reconstruction Project, the Shields-Cedar-Dakota-Maple Street Reconstruction Project, and the Burroughs Elementary Neighborhood Street Reconstruction Project (Phase II). Across these eight projects, it is estimated that the City will serve 66,685 people in low- and moderate-income areas. The City also used $4.9 million in CDBG funds and to acquire property on Blackstone Avenue for the future development of a city-wide senior center. The senior center is anticipated to be about 29,000 square feet and will provide various services and indoor and outdoor amenities. The 2020-2024 Consolidated Plan also identifies Affordable Housing Development in high opportunity areas as a priority. In 2022, the City allocated $3.1 million in HOME funds for Affordable Housing Development or Rehabilitation and an additional $3.6 million in CDBG funds for land acquisition in support of affordable housing development. Additionally, the City allocated 28.5% of its third allocation of Permanent Local Housing Allocation for development of Affordable Multifamily Rental Housing and 28.5% for development of Affordable Single-Family Housing, focusing on areas of opportunity. Out of the total PLHA allocations, the City will have $4.1 million for the development of Affordable Multifamily Rental Housing and another $4.1 million for the development of Single-Family Housing. The City is awaiting receipt of executed Standard Agreements from the State of California for these funds. | | SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | will convene in early 2017 and have opportunities to provide annual recommendations to the City on prioritization of future investments.

Continue implementing the written policies and procedures that the City of Fresno Department of Public Utilities has established that ensure water and sewer services are to be provided as a priority for developments that include units affordable to lower-income households.

Track infrastructure projects in the City to assess the distribution of projects in the different areas of the City. Seek out funding to address infrastructure and public service deficiencies in high-need areas. As funding sources allow, prioritize basic infrastructure improvements including water, sewer, and street lights in high-need communities.

As recommended by the Mayor/City Council Task Force, consider a residential rental inspection program to proactively ensure rental housing units in the City of Fresno meet minimum health and safety standards and are safe to occupy.

Assess the interaction between transportation network pathways and affordable housing sites to identify any barriers to affordable housing and employment access by July 2018. An action plan with specific timelines to address identified barriers will be developed within one year of completing the assessment.

Continue to actively seek resources for disadvantaged communities throughout the City, including sources such as Affordable Housing and Sustainable Communities, Urban Greening, Housing Related Parks, Active Transportation Program, Transit and Intercity Rail Capital Program, Fresno COG Active Transportation and TOD Funds, EPA Brownfields Planning and Cleanup Programs, Highway Safety Improvement Program, and other funds. The City | | | | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | will actively seek resources annually and on an ongoing basis. Wherever possible, the City will partner with local community-based organizations and local affordable housing developers to build additional local capacity to seek funding and implement programs. As part of the partnership with community-based organizations, the City will explore zoning opportunities with respect to a variety of housing types, such as multi-family housing, in several areas within the City, including high opportunity areas. Beginning in 2019 and every two years thereafter, the City will present rezoning options for vacant land in high opportunity areas for Council consideration in order to provide opportunities for higher density development in all areas of the City. Rezoning option presentations shall include at least five sites, between one and ten acres in size. The City will identify and pursue opportunities to promote the development of affordable and mixed-income housing on rezoned sites through outreach to affordable housing developers and supporting the attainment of financing, such as CDBG, HOME Funds, tax credits, and state AHSC funds. These rezoning option presentations are not part of a program described by Government Code Section 65583(c)(1)(A). Finally, specific planning efforts should emphasize incentivizing multi-family housing in high opportunity areas.

Expand affordable housing opportunities that prevent the concentration of single-family and multifamily dwelling units affordable to low- and moderate-income households. This includes, but is not limited to Development and Resource Management Department facilitation and streamlining of owner-initiated zoning and General Plan land use amendments that expand affordable housing opportunities outside of low- and moderate-income areas for Council consideration, consistent with FMC | | | SECTION 1E-5: REVIEW OF PAST ACCOMPLISHMENTS | Program Summary | Progress Evaluation | Recommendation | | :--- | :--- | :--- | | procedures. It also includes the City’s monitoring program (Program 2) to ensure maintenance of adequate housing sites with capacity to accommodate lower income housing, and the inclusion of affordable housing options in the zoning code, such as tiny houses, which are currently allowed as accessory buildings.

Work with the Fresno Housing Authority to assist households in using vouchers to rent in higher-opportunity areas and to identify landlords who are willing to accept vouchers in communities where vouchers are infrequently used. Develop a recommendation of best practices to target areas for voucher education, such as areas with high-performing schools or areas with high Area Median Income, as well as areas near jobs and transit. | | | | 28

**Relocation Services.** In certain situations, tenants who have been served with a notice to vacate may be entitled to relocation assistance. Where individuals or families are displaced due to redevelopment or rehabilitation activities funded by the City, the City shall provide relocation assistance as prescribed by law. | Temporary relocation assistance was provided to tenants of the Glenn Avenue Apartments in 2016 during rehabilitation efforts.

There was no relocation assistance required during 2017-2019.

The Fresno Housing Authority had two sites with relocation during 2020. Mariposa Commons completed construction in mid-2020, and 28 families received relocation assistance to pay for moving expenses to return. Housing Authority also submitted a permanent relocation plan to the City for its proposed Blackstone/Simpson mixed-use project which displaced a small auto sales business and the City approved the plan on February 16, 2021.

There was no relocation assistance required during 2021-2022. | Maintain program. | Source: City of Fresno, 2015-2023 Annual Housing Element Progress Report # SECTION 1E-6: PUBLIC OUTREACH AND ENGAGEMENT State law requires cities and counties to make a diligent effort to achieve participation from all segments of the community in preparing a Housing Element. Section 65583[c][6] of the California Government Code specifically requires that “[t]he local government shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the Housing Element, and the program shall describe this effort.” This means that local jurisdictions must take active steps to inform, involve, and solicit input from the public, particularly low-income and racial and ethnic households that might otherwise not participate in the process. To meet the requirements of State law, the City of Fresno completed outreach at both the local level and as part of the regional Fresno County Multi-Jurisdictional Housing Element effort to encourage community involvement. These efforts included: * Information about the Housing Element posted on the Regional Project Website (https://fresnomjhe.com/housing-elements/) * Stakeholder Consultations and Focus Groups * Study Sessions with Planning Commissions, City Councils, and the County Board of Supervisors * Community Workshops * Community Survey Regional efforts which included a community workshop, consultations, and a community survey, were facilitated with the California Coalition of Rural Housing (CCRH). These efforts are all discussed in Chapter 1 (Public Outreach and Engagement) of the Multi-Jurisdictional Housing Element. In addition to the outreach coordinated through the Multi-Jurisdictional Housing Element update, the City of Fresno partnered with the Housing Division to conduct community meetings and contracted with a local nonprofit, Every Neighborhood Partnership (ENP), to help conduct meetings throughout the city in order to receive broader input from more residents and stakeholders. ## Community Workshops and Meetings The City, from August 2022 to August 2023, conducted a number of community workshops and meetings on the Housing Element update. Table 1E-6.1 summarizes the workshops and meetings held to date, followed by more details on each event. SECTION 1E-6: PUBLIC OUTREACH AND ENGAGEMENT ### Table 1E-6.1: Community Workshops and Meetings on the Fresno Housing Element to Date | Event # | Date | Type of Event | Location | Number of Participants | | :--- | :--- | :--- | :--- | :--- | | 1 | August 31, 2022 6:00 p.m. | Community Workshop | Manchester Gate Elementary School, 2307 E Dakota Avenue, Fresno, CA, 93726 | 22 | | 2 | October 27, 2022 11:00 a.m. | Community and Stakeholder Meeting | Romain Neighborhood Center, 745 N First St, Fresno | 5 | | 3 | October 28, 2022 11:00 a.m. | Community and Stakeholder Meeting | Virtual | 11 | | 4 | November 1, 2022 6:00 p.m. | Community and Stakeholder Meeting | Mosqueda Neighborhood Center, 4670 Butler Ave, Fresno | 3 | | 5 | November 2, 2022 6:00 p.m. | Community and Stakeholder Meeting | Virtual | 5 | | 6 | November 7, 2022 6:00 p.m. | Community and Stakeholder Meeting | Virtual | 7 | | 7 | November 9, 2022 6:00 p.m. | Community and Stakeholder Meeting | Teague Elementary School, 4725 N Polk Ave, Fresno | 16 | | 8 | November 15, 2022 10:00 a.m. | Community and Stakeholder Meeting | Virtual | 18 | | 9 | November 16,2022 2:00 p.m. | Community and Stakeholder Meeting | Ted C Wills Neighborhood Center, 770 N San Pablo Ave, Fresno | 30 | | 10 | November 28,2022 11:00 a.m. | Community and Stakeholder Meeting | Legacy Commons Apt Community Room | 6 | | 11 | February 25, 2023 10:00 am | Community Workshop with El Dorado Park Community Development Corporation | El Dorado Park Community Center, 1338 San Ramon, Unit B, Fresno, CA 93710 | 17 | | 12 | March 1, 2023 5:15 p.m. | Community Workshop with Lowell Community Development Corporation | Helm Home, 1719 L. Street, Fresno, CA 73721 | 18 | | 13 | March 1, 2023 5:30 p.m. | Community Workshop with Highway City Community Development Corporation | Community Resource Center, 4718 N. Polk Ave, Fresno, CA 93722 | 45 | | 14 | March 11, 2023 12:30 p.m. | Community Workshop with Hidalgo Community Development Corporation | Hidalgo Elementary School, 3550 E. Thomas Ave, Fresno, CA 93722 | 27 | | 15 | March 14, 2023 5:30 p.m. | Southwest Fresno Community Development Corporation | Westside Church of God, 1422 W California Ave, Fresno, CA 93706 | 24 | | 16 | July 20, 2023 5:30 p.m. | Community Workshop with Southwest Fresno Development Corporation | Westside Church of God, 1422 W California Ave, Fresno, CA 93706 | 26 | | 17 | July 22, 2023 2:00 p.m. | Community Workshop with El Dorado Park Community Development Corporation | Paul Caprioglio Community Center, 5191 N. 6th Street, Fresno, CA 93710 | 23 | | 18 | July 28, 2023 4:30 p.m. | Community Workshop with Hidalgo Community Development Corporation | Hidalgo Neighborhood Resource Center, 646 N. Bond Street, Fresno, CA 93702 | 27 | | 19 | August 3, 2023 5:30 p.m. | Community Workshop with Highway City Community Development Corporation | Teague Community Resource Center, 4718 N. Polk Ave., Fresno, CA 93722 | 25 | | 20 | August 8, 2023 5:00 p.m. | Community Workshop | Nelson Elementary School, 1336 W. Spruce Ave., Fresno, CA 93650 | 19 | | 21 | August 9, 2023 4:30 p.m. | Community Workshop with Lowell Community Development Corporation | Ted C. Wills Community Center, 770 N. San Pablo Ave., Fresno, CA 93728 | 46 | | TOTAL | | | | 420 | Source: City of Fresno, California Coalition of Rural Housing, and Every Neighborhood Partnership, October 2023. APPENDIX 1E: CITY OF FRESNO # Event #1: Community Workshop (August 31, 2022) The first community workshop for the Housing Element update was held on August 31, 2022 in-person at Manchester Gate Elementary School to provide information on the Housing Element and solicit input from the community. The City notified the community of this meeting with flyers distributed in English, Spanish, Hmong and Punjabi through the Fresno Council of Governments (FCOG) listserv of regional stakeholders and community-based organizations (CBOs), and through the Fresno Housing Authority. Linguistica interpreters were available for Spanish, Hmong, and Punjabi monolingual speakers. Materials in Spanish, Hmong and Punjabi were available in-person at the workshop and online at the project website, accessible via QR code. An Eventbrite registration page and Facebook event was created advertising that Spanish, Hmong, and Punjabi language interpretation would be provided, along with refreshments, and activities for kids. Flyers were sent out through the Fresno Housing Authority to affordable housing residents. City staff distributed the event to the email lists that they maintain for General Plan updates and the Anti-Displacement Task Force. Fresno City Community Affairs Representatives distributed the event to Hmong and Punjabi speaking communities. **Figure 1E-6.1: Community Workshop For The Housing Element Update, August 31, 2022** <
> FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-6-3 SECTION 1E-6: PUBLIC OUTREACH AND ENGAGEMENT In the presentation, members of the public were introduced to the process of developing the Housing Element both for the region and for the City of Fresno. They were also given information about current housing conditions in the region and in Fresno and were invited to participate in a discussion about local housing needs. The discussion was prompted by the following questions: * What are Fresno’s greatest assets? * What do you think are the most critical housing issues in Fresno? * What groups within the community have the greatest housing needs? * What are Fresno’s most significant fair housing issues? * Do you have suggestions for addressing housing issues in Fresno? * Any suggestions for getting more community involvement? There were 22 community participants that attended the event and about 5 attendees were Spanish monolingual speakers and they received interpretation from Linguistica. Attendees expressed that some of the most critical issues in Fresno are related to affordability, lack of information and education, and lack of community amenities. Participants identified a number of special needs groups including residents with low incomes, undocumented residents, seniors, single-parent families, people with disabilities and mental disabilities, and college students/youth. When asked about Fresno’s most significant fair housing issues, participants alluded to historical disinvestment in southwest and west Fresno, access to credit, housing costs, and access to opportunities. Participants expressed support for building more affordable housing and suggested the City develop more programs to provide financial assistance to low-income families, funding to rehabilitate homes, rent control, and more housing near amenities like grocery stores. Participants also made suggestions for increasing community involvement in the Housing Element update. Below is a summary of feedback, along with responses to discussion questions. ### Summary of Feedback * **What are Fresno’s greatest assets?** * Citizens of Fresno * Culture * Zoo * Desire for change * Diversity * Diversity in sports * Water parks * Different public events * Proximity to other places (i.e., San Francisco, Los Angeles) * The community * The people * Labor force * People APPENDIX 1E: CITY OF FRESNO * **What do you think are the most critical housing issues in Fresno?** * Frequent rent increases * High cost of rent * Lack of affordable housing * Not enough amenities in apartments * Lack of information and education on housing * Down payment assistance * Including citizens in decision making * Need enough diversity * Slum lords * Education on credit and how to keep good credit * Lack of community amenities (parks, trees, housing) * **What groups within the community have the greatest housing needs?** * Low to moderate income * Undocumented residents * Seniors * Single parent families * People with disabilities * People experiencing homelessness * People without transportation or a car * College students/youth * Couch surfers/people living out of cars * People with mental disabilities * Veterans * Underserved communities * **What are Fresno’s most significant fair housing issues?** * Historical disinvestment in southwest and west Fresno * Access to credit * Access to housing close to amenities * Racial barriers * High rental cost * City of Fresno should implement recommendations 1-48 from “Here to Stay” report * Affordable housing and rentals are mostly located in southeast Fresno, where a lot of growth is happening, concerns regarding pricing out and displacement * Fair housing for all, not just some * More housing for families on fixed incomes with a cap on rent increases * More accessible housing for people with disabilities * **Any suggestions for addressing housing issues in Fresno?** **Figure 1E-6.2: Participant Responses** **“What do you think are the most critical housing issues in Fresno?”** <
> SECTION 1E-6: PUBLIC OUTREACH AND ENGAGEMENT * Building more affordable housing – start with meeting RHNA numbers from 5th cycle * Provide more financial assistance to low-income families who have a hard time paying for housing – both renters and owners * Restoration program for people who live in older sections of town * Funding to rehabilitate homes and weather updates, such as solar * Rent control * More mixed use * Build up, not out * Provide more housing near amenities, especially grocery stores * “Affordable” housing isn't affordable for low-income residents * Not enough people buy to live here, people buy to profit * **Any suggestions for getting more community involvement?** * Hire a professional outreach or marketing firm, hire people to canvas in each census tract and hold community meetings there, have a survey, get feedback for housing plans * Have a non-rushed event, take time to workshop more what the housing element is in a calmer and more relaxing environment, with language people can understand * Get data on how to best hold workshops (Who, what, when, where) * Reach out to housing advocates in the community * Work with organizations that have direct access to and with citizens and special needs households * Radio/TV ads * Community outreach and meeting community members where they are at * Build trust in providing more transparency and accountability * Involve Council and City Staff in getting information out Figure 1E-6.3: Participant Responses to “Any suggestions for more community involvement?” <
> APPENDIX 1E: CITY OF FRESNO # Events #2-10: Community and Stakeholder Meetings #(October/November 2022) Between October 27, and November 28, 2022, a series of joint community meetings were held by the City of Fresno Long Range Planning Division and the Housing Division to gather feedback from community members and stakeholder organizations about the Multi-Jurisdictional Housing Element and the Annual Action Plan. The format of the meetings included a presentation at the beginning, followed by 6 subject specific staff facilitated tables (Public Infrastructure and Facilities, Fair Housing/Compliance, Public Services, Homelessness and Homelessness Prevention, Affordable Housing, and Housing Element) where the public shared their thought on each subject, then the staff member at each table shared with the larger group the key points shared at their table, and the meeting concluded with each participant voting on their highest priorities. Community members were invited to vote on suggestions at virtual and in-person meetings. The goals, and activity suggestions, are outlined below to provide a high-level overview of input received. ## Summary of Feedback ### Affordable Housing * **Most Popular Suggestions** * Homebuyer assistance and more extensive funding programs which allow people to build their own homes. * Purchasing buildings (with a preference for abandoned buildings and homes) for emergency shelters with additional wrap-around services (e.g., vocational training, addiction services). * Developing multi-family housing. * Encouraging mixed-income neighborhoods. * Affordable housing location equity, specifically north of Shaw Avenue. * Tiny home villages in coordination with local religious institutions that own undeveloped land. * Ideally small projects (1-4) homes. * CDCs as managers of the villages. * Allow development of mobile tiny homes. * Received feedback from Habitat for Humanity and Poverello that tiny homes are expensive and time consuming to develop. * Housing targeting those with mental health needs. * Rent control. * Reducing bureaucratic processes to fast-track affordable housing. * In Chinatown, develop the single-room, second floor apartments above businesses. * Mitigation fund – pays a percentage of large repairs necessitated by high-risk renters. * Change covenant from 30 years to 50 years. * Consider the Community Land Trust Model for long-term affordability. Partner with Central Valley Land Trust for development areas. * Improved technical assistance for developers looking to complete proposals. * Provide feedback on proposals so they can be made better in the future. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-6-7 SECTION 1E-6: PUBLIC OUTREACH AND ENGAGEMENT * Provide an opportunity for developers to pitch projects to evaluate whether changes to zoning or permitting are necessary. * Extending impact fee reduction waiver (expires in June). * Inclusionary zoning. * Roommate matching. * Inclusionary housing. * Housing co-op for ownership in apartments and condos. * Rent Controls/ Rental stabilization program/ Rent controls in mobile home parks. * Weatherization program. * **Additional Suggestions** * Prioritization tool for infrastructure. * Provide affordable student housing near campuses and near high quality transit. Engage with Fresno State. (Parent/family housing) * Housing for veterans, seniors, and people with disabilities. * Housing rehabilitation. * Conference between City and lenders to discuss current programs operated by local banks. * Leverage funds for affordable housing development. * Increase efforts and funding towards developing relationships with the larger organized groups (trusted messengers) such as CDCs to improve public participation. * Presenting to Executive Directors and workshopping/piloting new projects (continuous feedback/ capacity building). ### Fair Housing/Compliance * **Most Popular Suggestions** * Landlord/owner education on vouchers and more incentives to accept Section 8 (HCV) vouchers. * Education about the Annual Action Plan process via trusted messengers like pastors CBO leaders. * Work with Office of Community Affairs and place-based organizations. * Report out environmental impact of development throughout Fresno. * **Additional Suggestions** * Assistance with helping tenants to understand lease terms. * Improved outreach via social media (paid advertisements). * Outreach via water bill inserts. * Eviction Protection Program continuation. * Focus on LGBTQ+ rights in housing. * Regular roundtable meeting with community leaders. * Increased online access to ongoing/current information. * Better promotion of ongoing/current info via social media. * Landlord registry to combat slumlord issues. * Fair Housing hotline. APPENDIX 1E: CITY OF FRESNO # Homelessness and Homelessness Prevention * **Most Popular Suggestions** * Rental and utility assistance based on income, housing stabilization (e.g., building credit scores, providing security at buildings). Also programs to offset apartment application fees. * Landlord engagement to prevent evictions. * Mobile medical clinic in partnership with neighborhood-specific organization to determine locations and resource hubs. * Mobile MAP Point pilot project to reduce transportation barriers. * More street outreach including social workers and psychologists (non-sworn officers). * Long-term shelter options for families. * Expanding hours/temperature requirements at warming centers. * Don’t convert City-owned shelters. * More overnight shelters for families. * Skilled nursing facilities for those who can’t afford them. * **Additional Suggestions** * Safe locations to camp or park vehicle overnight. * Include wrap-around services in these locations. * More case managers at all shelter locations. * Better/more utilization of City resources and collaboration with other agencies. * Like coordinating with DMV to provide IDs remotely or via mobile station. * Facility where people can exchange needles, NARCAN is available, and all hygiene products are available. * Streamlining process to get people into permanent shelter. * Provide more “non-shelter.” Options for individuals experiencing homelessness (stigma of shelters). Permanent support housing. SECTION 1E-6: PUBLIC OUTREACH AND ENGAGEMENT ## Events #11-15: Community Workshops (February/March 2023) Five meetings were organized and facilitated by Every Neighborhood Partnership (ENP) and the Fresno Community Economic Development Partnership (CEDP) Community Development Corporations (CDC). A total of 131 members of the community attended the five meetings. Facilitators or City staff delivered a presentation of the Housing Element then community members were invited to participate in an activity to discuss the following four questions: Critical Housing Issues, Most Impacted Groups, Suggestions and Solutions, and Programs Missing from the Fresno Housing Element. All the meetings had the same presentation, but not all used the same format of asking questions. Hidalgo, Lowell, and Southwest had each question on a poster for participants to write their response on directly or via a post-it note. At the Southwest workshop, the last framing question was reworded to be Southwest specific, “What were the most significant housing issues in Southwest?” With this distinction, the methodology provided by these communities that engaged with the poster activity were much more concise. El Dorado’s outreach data was gathered through recorded staff notes that documented the community discussion. Highway City’s outreach data was taken from written notes from table discussion leaders and participant post-it notes recorded into a Word document. They had a very open discussion on housing issues, needs, and solutions in Fresno and their comments were placed into framing questions after the fact. This adds a level of subjectivity since the participants were not specifically asked the framing questions at the meeting. Figure 1E-6.4: One of the Five Community Workshops for the Housing Element Update <
> APPENDIX 1E: CITY OF FRESNO The comments collected at the events were grouped into common categories to organize and document every participant’s feedback. Then each category was scored based on frequency to track which concerns were the most prevalent and reoccurring. While the five communities chosen shared some glaring similarities the data also indicates there are also unique concerns between the way each community prioritized them. As an example, even though one community may not prioritize the unhoused population during question 2 of “impacted communities”, there was interest for providing housing to the unhoused population in response to question 3. Many responses were very passionate and offered multiple points that fit multiple categories. Which made it difficult to fit into one subject. This posed a challenge on whether to include the full comment as one "tallying point" or to break it up into multiple categories. Directing instructions to the public also affected response accuracy as sometimes participants answered all framing questions in one comment and placed it separately from the directed framing question. These factors, together with the potential for a degree of human error, may impact how the values are calculated slightly, but the results still represent the main concerns of the community proportionally. ### Summary of Feedback The high-level themes are placed in order by the total number of comments provided in parenthesis, from high to low. The numbers provided represent the frequency of the responses provided. * **Critical Housing Issues** * Lack of affordable housing (50) * Rental instability and barriers (36) * Infrastructure needed (19) * Lack of equity, representation, and communication (15) * Housing ownership and programs to assist (12) * Homelessness (10) * Low density urban sprawl (4) * Lack of amenities nearby (3) * Health impacts of housing next to industrial developments (2) * **Most Impacted Groups** * Low-income (23) * Renters (18) * Homeless (16) * Age (15) – students, seniors, youth, and multi-generation * Household Type (13) – single, families, single parent families, and long-time residents of Fresno * Undocumented or Immigrants (10) * Ethnicity (7) – Minorities, BIPOC, and single white female * Disabled (7) SECTION 1E-6: PUBLIC OUTREACH AND ENGAGEMENT * Middle-Income (5) * Gender (5) – women and single mothers * Suggestions and Solutions * Build new buildings and repurpose/restore old ones (42) * Establish rent controls, tenant assistance and protections, and reduce barriers (28) * Provide financial assistance and incentives (25) * Create new policies and programs (20) * Build new and fix existing infrastructure in existing neighborhoods (18) * Engage in research and education (13) * Create community first buying options (9) * Pursue equity and equal representation (7) * Develop partnerships (6) * Rezone to create more opportunity for housing (6) * Increase code enforcement and safety (6) * Address homelessness (1) * Recommended Programs for the Fresno Housing Element * Establish programs for home and utility improvements (7) * Provide rental assistance (4) * Improve tax practices to support housing (4) * Provide financial assistance and incentives (3) * Invest in the community (3) * Promote walkable and safe environments (2) * Provide education (2) * Seek grant funding (2) APPENDIX 1E: CITY OF FRESNO # Events #16-21: Community Workshops on the Public Review Draft (July/August 2023) City staff organized, facilitated, and assisted with public outreach and engagement for six community workshops in July and August 2023 to receive input on the Public Review Draft Housing Element. Five of these meetings were held in collaboration with ENP and the CEDP CDCs. To expand the participation beyond the CEDP boundaries, City staff sent out four citywide email blasts with a reach of 27,000 resident subscribers with an average open rate of 60 percent. Four social media posts were also shared with 33,000 city-based followers. A total of 166 members of the community attended the six meetings which took place during the 30-day public comment period (July 17 to August 16) on July 20, July 22, July 28, August 3, August 8, and August 9. City staff provided a high level summary of the draft Housing Element, focusing on the actions and programs outlined in the document and how the programs relate to the community’s input from earlier workshops. There were group and breakout discussions where participants were asked to provide feedback on the programs provided in the Housing Element, to share thoughts, suggestions, and solutions to critical housing issues facing residents, and to share any other general comments. The City received almost 200 comments at the various workshops. These comments are summarized below. ### Figure 1E-6.5: One of the Six Community Workshops for the Draft Housing Element Update <
> SECTION 1E-6: PUBLIC OUTREACH AND ENGAGEMENT # Summary of Feedback The comments collected at the workshops were grouped into common categories to organize and document every participant’s feedback. The high-level themes are placed in order by the total number of comments provided in parenthesis, from high to low. The numbers provided represent the frequency of the responses provided. * **Most Popular Suggestions (total number of comments made):** * Provide rent control, assistance, and protection (14) * Opposition to **Program 2** - Variety of Housing Opportunities in High Resource Areas, and revise applicability to growth areas only (11) * Provide street paving, lighting, and sidewalk improvements (11) * Increase assistance to and opportunities for people struggling with homelessness (9) * Improve/diversify public outreach (6) * Provide homebuyers assistance and funding for undocumented/non-resident with ITIN (6) * No to urban sprawl (5) * Opposition to **Program 3** - Encourage and Facilitate Accessory Dwelling Units, in established neighborhoods (5) * Support for **Program 3** - Encourage and Facilitate Accessory Dwelling Units, and expand incentives/add funding for residents to develop ADUs (5) * Reduce or eliminate on street "no parking" hours (4) * Guarantee Section 8 voucher holders have place to rent (3) * Improve/increase housing regulations (3) * Increase community amenities investment (3) * Add inclusionary zoning program (2) * Add workforce housing program and funding (2) * Provide affordable housing (2) * Provide amenities in established neighborhoods north of Herndon (2) * Support for mixed-income housing in neighborhoods (2) * Support for **Program 29** - Opportunity to Purchase Act, and add non-Fresno resident property restrictions (2) * **Support for the Housing Element Action Plan Programs:** * Support for all Housing Element Programs * Support for **Program 2** - Variety of Housing Opportunities in High Resource Areas * Support for **Program 16** - Community Land Trust * Support for **Program 22** - Housing Rehabilitation, and include more than senior housing * Support for **Program 23** - Comprehensive Code Enforcement, and fine residents who don't maintain a clean front year and patio * Support for **Program 24** - Special Needs Housing, and expand emphasis on elderly assistance * Support for **Program 25** - Development Code Amendments for Compliance with State Law and to Reduce Barriers to Housing Development - Support for **Program 26** - Fair Housing Services - Support for **Program 28** - Reduce or Waive Fees for Vehicle Miles Travelled (VMT), and modify for infill only - Support for **Program 30** - Mobile Home Parks, and add mobile homes built prior to 1980 - Support for **Program 31** - Eviction Protection Program, and expand funding * **Request to Add to the Housing Element Action Plan Programs:** * Add educational training program for small scale developer and City resource access * Add farmworker housing program * Add homeless Tiny Home Village development program * Add large foreign company property restrictions * Add program for new homes for Veterans like what Clovis has done on Sunnyside Avenue * Add SB10 Overlay program * Allow more than one ADU on a property * Assess the number of at-risk of homeless youth and meet their housing needs * City take/purchase slumlord apartments * Clarify rent protection strategies * Conduct Zoning and lending practices study * Establish a rent remediation board * Force large scale developers to sell property to individual homeowners * Implement Fair Housing * Improve oversight of low-income rental units * Improve streamlining of affordable housing * Increase landlord resources * Partner housing programs with employment resources * Provide City liaison to help small/local developers * Provide Community Benefit Agreements * Provide homebuyers assistance and funding for farmers * Provide incentives to investors * Provide local development incentives and funding for affordable housing development * Provide property owner accountability * Recruit developers * Reduce fees and improve residential permitting experience * Request community amenities built around affordable housing * Request demolition of dilapidated homes * Start a safe parking program like San Diego * Vacant land suggestions include build affordable housing, incentivize housing development, and charge an incremental fee * **Suggestions Provided Beyond the Scope of the Housing Element:** * Expand Neighborhood and Placemaking * Improve parking regulations SECTION 1E-6: PUBLIC OUTREACH AND ENGAGEMENT * Improve water quality * Increase energy conservation * Provide cleaner neighborhoods * Provide Code Enforcement reporting protection * Provide design standards, infrastructure, and amenities * Provide immigration assistance * Require property owners to improve look of apartment complexes * **Support for Different Housing Types:** * Support for adaptive reuse * Support for live/work units * Support for missing middle housing * Support for mixed-use development APPENDIX 1E: CITY OF FRESNO # Climate Adaptation/Environmental Justice Workshops (April-June 2024) A series of workshops were held across the City as part of the City’s Climate Adaptation-Environmental Justice planning. These workshops included discussion and feedback on fair housing and civic engagement, as well as other typical climate adaptation and environmental justice topics. The workshops were held in or near the R/ECAP neighborhoods described in Chapter 3, or were attended by residents from R/ECAPS. They were often co-hosted by non-profit organizations that serve the neighborhood. Information about the workshops is listed below. These workshops were also listed in the outreach summaries for each of the R/ECAPs in Chapter 3: * April 23, 2024, Co-Host: Fresno Interdenominational Refugee Ministries (FIRM) * Location: FIRM Offices/1940 N. Fresno Street, Fresno, CA 93703 * McLane R/ECAP * June 1, 2024, Co-Host: Fresno State Office of Sustainability * Location: Fresno State, 5244 N Jackson Ave, Fresno, CA 93740 * Near El Dorado Park R/ECAP * June 18, 2024: Legacy Commons/Fresno Housing * Location: Legacy Commons, 2255 S. Plumas Ave, Fresno, CA 93706 * Southwest Fresno R/ECAP * June 29, 2024, Co-Host EAH * Location: Summer Park Apartments, 1275 S. Winery Ave, Fresno, CA 93727 * Central Southeast Specific Plan R/ECAP ## Summary of Feedback Feedback indicated the following priorities among the participants: ### Fair Housing * **Encourage a Variety of Affordable Housing Options.** Facilitate the development of new-income-restricted affordable housing, including senior, workforce, student housing, and accessory dwelling units * **Tenant Protections.** Create protections for tenants who report violations and may experience retaliation * **Land Use.** Prohibit the development of new uses that produce high amounts of truck traffic, particulate matter, noise and odors adjacent to existing neighborhoods; and prohibit the development of new residential uses adjacent to existing industrial uses. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-6-17 SECTION 1E-6: PUBLIC OUTREACH AND ENGAGEMENT Programs 2, 3, 16 and 24 address the first bullet; Program 34 addresses the second one. Regarding the third bullet: Changes were made to Program 17, Surplus Public Lands, to remove any inconsistencies in land use. In addition, Program 27, Environmental Justice, responds to this concern. ### Civic Engagement * **Increase Transparency and Efficacy.** Increase access to information about proposed projects, allow for feedback to be received through a variety of mediums, and improve communication on how feedback was received and considered. * **Implement Varied Community Forums.** Provide community members with varied platforms and opportunities to provide feedback and maximize participation, such as through conducting neighborhood-based meetings. Changes were made to Program 29, Equitable Engagement, to address these concerns. ### Summary of Revisions Made to Address Feedback on the Public Review Draft In addition to feedback received during the community workshops, the City also received a number of public comment letters on the Public Review Draft Housing Element, which can be found in Section 1E-8, Public Comments Received on the Housing Element. The City reviewed all of the comment letters and workshop comments received, as well as letters directed at the regional level to the Multi-Jurisdictional Housing Element. This feedback helped inform revisions made to the Public Review Draft before submitting to the California Department of Housing and Community Development (HCD) for State-mandated review. To help the reader easily identify revisions made, a track changed version of the draft Housing Element was also released and made available on the City’s website and the Multi-Jurisdictional Housing Element website. Below is a high-level summary of revisions made, by chapter, to the Public Review Draft to address public comments. * **1E-1: Action Plan.** Added an introduction to the Implementation Programs section, with a list of programs, by goal. Revised, modified, and added policies and programs to clarify intent, add additional commitments, and/or clarify objectives and timeframes: Addressed comments related to providing additional commitments regarding Accessory Dwelling Units (ADUs), to clarify timeframes for outreach in annual reporting, to include strategies to build and support the local construction workforce, to address housing rehabilitation needs of the community, to address home repair needs of residents in mobile home parks, and to expand/define outreach commitments to reach lower-income areas and residents in various programs. * **1E-2: Sites Inventory.** Supplemented the Methodology section to include a recent example of a large site development in the city. Added an environmental constraints and hazards section with a description of relevant environmental constraints and hazards and how it relates to the sites inventory. APPENDIX 1E: CITY OF FRESNO * **1E-3: Local Assessment of Fair Housing.** Supplemented various sections to address comments and provide additional context, data, and local knowledge including the Patterns of Integration and Segregation, Disproportionate Housing Needs and Displacement Risk, Access to Opportunity, and Other Relevant Factors and Local Knowledge sections. Updated and refined the list of contributing factors to reflect new information added and changes made to programs. * **1E-4: Constraints.** Updated chapter to reflect changes made to programs and expanded the discussion of parking requirements in the Parking section. * **1E-7: Detailed Sites Inventory Tables.** Added a column to the vacant and nonvacant sites inventory tables to identify environmental constraints. ## Summary of Revisions Made During HCD Review Process The City revised the Public Review Draft and submitted the revised Housing Element to HCD on November 3, 2023. On February 1, 2024, the City received a comment letter from HCD. From February through November 2024, City staff and the consultants reviewed the comments closely and made substantial changes to the Draft Housing Element. The City met with HCD in person and via phone calls to discuss comments and submitted additional revisions to HCD in August, October, and November 2024. During the HCD review process, the City received comment letters from Leadership Counsel for Justice and Accountability and one comment from Self Help Housing. Themes from the letters included housing constraints and request for more ministerial approval pathways, tenant protections, conservation of existing affordable housing and mobile homes, strengthening fair housing and environmental justice programs, and encouraging more affordable housing in high resource areas. The Housing Element team reviewed each of the letters and incorporated responses with the revisions made in response to the HCD comment letter. ## Discussions with Affordable Housing Partners (October-Nov. 2024) Prior to finalizing the Housing Element, the City also met with advocates and local affordable housing developers such as Self Help Enterprises, Habitat for Humanity, the Leadership Council for Justice and Accountability, and Fresno Housing to review the Action Plan and obtain any additional feedback. Concerns mainly focused on streamlining the entitlement and building permit processes and further defining roles regarding community land trusts. As a result of these conversations, revisions were made to the following programs: * **Program 4:** Streamline Development Review Process * **Program 11:** Incentives for Affordable Housing * **Program 14:** Partnerships with Affordable Housing Developers * **Program 16:** Community Land Trust * **Program 19:** Home Buyer Assistance * **Program 33:** Mobile Home Parks FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-6-19 SECTION 1E-6: PUBLIC OUTREACH AND ENGAGEMENT * Program 34: Eviction Protection Program ## Summary of Changes Changes made to Housing Element Programs in response to these comments include but are not limited to: removing two sites from the inventory based on adjacency to existing industrial uses; increasing commitments in Program 2: Variety of Housing Opportunities in High Resource Areas; additional incentives in Program 3: Encourage and Facilitate Accessory Dwelling Units and Small Homes; further streamlining entitlement processing timelines in Program 4: Streamline Development Review Process; adding incentives for large site development, which are often located in high resource areas, in Program 5: Large and Small Lot Development; adding more incentives and firmer commitments for affordable housing in Program 11: Incentives for Housing Development; modifying Program 14: Partnerships with Affordable Housing Developers to include outreach to lower-income and special needs households; adding commitments to Program 17: Surplus Public Lands; adding commitments to Program 25: Development Code Amendments for Compliance with State Law and to Reduce Barriers to Housing Development; significant revisions to Program 27 – Environmental Justice and Program 28 – Equitable Community Investments to provide more detailed commitments; addressing weatherization needs for mobile home parks in Program 33 – Mobile Home Parks; adding commitments to Program 36: Homeless Assistance, and expanding tenant outreach in Program 37: At-Risk Housing. Comments received on the Housing Element can be found in Section 1E-8, Public Comments Received on the Housing Element. ## Planning Commission and City Council Study Sessions (September 2022 and July 2023) A study session was held with the City Council on September 29, 2022 to discuss the Housing Element Update and process. The study session was open to the public and held in person, with a livestream option to reach members of the public who could not attend in person. CCRH staff supported City staff and presented an overview of the Housing Element update process and required contents of the element, discussed early strategies to meet the City’s RHNA, reviewed new state laws, and solicited feedback from the City Council and community members on these strategies and other housing needs in Fresno. Commentary was limited and no public comment related to fair housing was received at the meeting; instead, council members expressed concern regarding the implications of new and changing housing legislation on small cities with limited financial resources. After release of the Public Review Draft Housing Element, the City held study sessions with the Planning Commission on July 19, 2023, and City Council on July 20, 2023, to review the plan and solicit feedback before submitting to HCD for State-mandated review. These meetings were open to the public and held in person, with a livestream option available to reach those who could not attend in person. Clarifying questions were asked during both study sessions. No public comments were received at the meetings. # Regional Focus Groups (October/November 2022) Two regional focus groups were held as part of the Housing Element development process to receive a broad range of input from local and regional stakeholders including staff, community organizations and non-profits, and project consultants. Stakeholders were presented with information about the Housing Element process, particularly sections regarding community needs and fair housing, and were given the opportunity to weigh in on community needs. The first Regional Stakeholder Focus Group Meeting was held on Tuesday October 25th from 9:30 to 11:30am and the second Regional Stakeholder Focus Group Meeting was held on Tuesday November 15th from 9:30 to 11:30am. Stakeholders described the rising cost of housing, the shortage of affordable housing available in the city, multifamily or single-family unit types, as well as the economic disadvantages to market rate developers to build affordable housing. Some key topics that came up as regional housing issues: corporate acquisition of mobile home parks, over-reliance on commercially zoned property to accommodate RHNA (not much higher density zoning in the County relative to commercial), outdated community plans hindering development, and difficulties securing funding for new housing in low resource areas. There was also a fair amount of discussion on the need for more outreach and education to increase awareness/accessibility of existing assistance programs, and financial literacy to help low-income residents better compete for affordable housing/home ownership opportunities. # Regional and Local Stakeholder Consultations (Summer/Fall 2022) Consultations were conducted with service providers and other stakeholders who represent and/or provide services to different socioeconomic groups in the Fresno County region to obtain input on housing needs and programs. Throughout the summer and fall of 2022, several interviews were conducted with stakeholders who work in areas such as housing, homelessness, and other social services in Fresno and throughout the Fresno County area. The following organizations and stakeholders provided input and below is a summary of the feedback received. ## Fair Housing Council of Central CA Regional outreach efforts for the Multi-Jurisdictional Housing Element included interviewing the Fair Housing Council of Central California (FHCCC), a non-profit, civil rights organization dedicated to the elimination of discrimination in housing and the expansion of housing opportunities for all persons. FHCCC provides a multifaceted program of private enforcement, education and outreach, research and advocacy to affirmatively further the goal of equal housing opportunity in the San Joaquin Valley. SECTION 1E-6: PUBLIC OUTREACH AND ENGAGEMENT In response to the request for input, FHCC noted that the most common fair housing issues reported throughout Fresno County are discrimination on the bases of disability and race. FHCC emphasized a need for more government involvement in enforcement of fair housing laws. Currently, affordable housing options are often concentrated in specific neighborhoods. When developers are encouraged to continue to build affordable units in these areas as a result of zoning or other government regulations, this results in either intentional or unintentional segregation based on income. When asked about opportunities for local governments to actively improve outreach regarding fair housing and to combat existing issues, FHCC identified several opportunities including local rent controls to manage affordability and reduce displacement risk, code enforcement to ensure a safe and habitable housing stock, funding fair housing groups such as FHCC to enforce fair housing laws, and adjusting regulations or encouraging development of a variety of unit types and sizes throughout the jurisdiction to promote mobility and integration. Further, they expressed concern about the aging multifamily housing stock becoming uninhabitable due to physical conditions. However, given the shortage of affordable housing in the region, FHCC noted that many units that have already physically deteriorated are still occupied, posing a risk to occupants. Discrimination by landlords or agents as well as deliberate segregation has resulted in fair housing concerns, particularly for protected and special needs populations, such as persons with disabilities and lower-income households. ### Fresno Housing Authority There are two divisions of the Housing Authority operating within the region; one is for the City of Fresno and a separate authority for the rest of the County. Two representatives from the Fresno County Housing Authority were interviewed as part of regional outreach for the Multi-Jurisdictional Housing Element update. The representatives noted that there is tremendous demand for housing in all communities in Fresno County. The last time the Section 8 waiting list opened they received more than 50,000 applications. Recently, when a 60-unit development in Clovis opened, they received more than 10,000 applications. When a project in downtown Fresno opened, they received 4,000 applications within a two-week period. Rents are high, which is challenging for residents but good for developers. The region needs more housing opportunities for people experiencing homelessness but in rural and unincorporated communities, lack of water and sewer capacity are major concerns for additional housing development altogether. Representatives noted that entitlement processing timelines have been a barrier to development for the Housing Authority. There is also a lack of capacity among agencies that provide services in rural and unincorporated areas. This is especially challenging for special needs populations that need mental health services. The Housing Authority is following the State’s lead in providing housing in high opportunity areas. There are lots of incentives to do this to compete for tax credits and other state funding programs. APPENDIX 1E: CITY OF FRESNO # Fresno Madera Continuum of Care The Fresno Madera Continuum of Care (FMCoC) is a collaborative of agencies that work together to provide homeless services; however, FMCoC is not a legal entity and does not provide direct services. A representative from the FMCoC provided input on housing needs and programs for the Housing Element. At present, the representative noted that the biggest concern is that there is insufficient low-income housing for those who are homeless (or at risk of becoming homeless). Many people in the region are on a fixed income, including disability or social security, and cannot afford housing. # Llaves De Tu Casa The Llaves De Tu Casa Iniciativa is a financial education program open to all County of Fresno residents but with a focus on increasing Latino homeownership rates. The partners driving the initiative are NAHREP (National Association of Hispanic Real Estate Professionals) Fresno, the City of Fresno, Federal Home Loan Bank (FHLBank) of San Francisco, Self-Help Enterprises, and Union Bank. As a follow-up to the regionwide stakeholder focus groups held in October and November 2022, a collection of members from the Llaves de tu Casa Iniciativa (LDTC) met on December 13, 2022, to respond to several stakeholder interview questions. The opportunities for future housing in the region that the initiative members identified included the initiative’s ability to provide homeownership education virtually and in partnership with other local organizations. There has been a lack of financial literacy in the community along with challenges in using technology and language barriers. The initiative members expressed concerns about affordability, including the location of affordable housing in undesirable areas. Upzoning single-family zoning would create more opportunities for the development of multifamily housing in more desirable locations. Some funding is only available in certain areas, which can exacerbate existing patterns of segregation and close proximity to industrial uses. They also expressed concern about investors displacing community members in order to establish short-term rentals while community members live in hotels. The State’s mandate to install solar panels on new homes was also cited as an additional cost that will drive up the buyers’ or renters’ cost. The gap between ownership housing affordability and program income limits was identified as a barrier to accessing housing. Moderate-income households earn too much to qualify for housing assistance, but those who qualify cannot afford the housing available. In addition to a lack of multifamily rental housing, there aren’t enough condo buildings in the region, which could present another affordable homeownership strategy. The establishment of land trusts was also identified as a potential strategy for increasing affordability, as well as donations of land from municipalities. # Northern California Carpenters Regional Council (NCCRC) The Northern California Carpenters Regional Council (NCRCC), also known as the Nor Cal Carpenters Union, is a labor union representing carpenters and other construction trade workers in Northern California. It provides members with training, apprenticeship programs, benefits, and collective bargaining agreements to ensure fair wages and working conditions. The Nor Cal Carpenters Union has a number of committees working for equal rights for all members including women, minorities and veterans, and work to build empowerment and mutual support. A representative from the union provided input on housing needs and programs for the Housing Element update. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-6-23 SECTION 1E-6: PUBLIC OUTREACH AND ENGAGEMENT The union representative acknowledged that labor unions have not been strong housing advocates in the past, but they are trying to change that dynamic as the housing crisis across the state has created more sense of urgency which is an opportunity for NCCRC because more housing production means more construction jobs for the Fresno community. At present, NCCRC is concerned that there is a shortage of labor supply to meet that housing need. COVID has had a significant effect on office building construction and NCCRC noted this as an opportunity for construction workers to pivot to residential building, if more favorable working conditions are instituted. Currently, many of the union’s members are not a part of residential development because the working conditions are not good. Even with the prevailing wage requirements for affordable housing, NCCRC insinuated that developers are able to work around these requirements to reduce their costs. This is a statewide issue, but the problem is even more pronounced in Fresno, for example, construction workers are 3.9 percent of the total labor force. California-wide construction industry/trades workers are meanwhile 4.3 percent of the total labor force. So, by California standards Fresno does not have, in relative terms, an abundant supply of construction workers. NCCRC would like to see the shortage of labor (both statewide and in Fresno County) identified as a constraint in the Housing Element rather than the cost of labor and would like the Housing Element to include policy language related to a local hiring preference. ### Leadership Counsel for Justice and Accountability The Leadership Counsel for Justice and Accountability (Leadership Counsel) advocates at the local, regional, and statewide levels on the overlapping issues of land use, transportation, climate change, safe and affordable drinking water, housing, environmental justice, equitable investment, and government accountability. Based in the San Joaquin and Eastern Coachella Valleys, Leadership Counsel services include community organizing, research, legal representation, and policy advocacy. Representatives of Leadership Counsel expressed concern about the ongoing sprawl in the city. Stakeholders advocated for investment in existing communities that don’t have fair access to clean drinking water. Leadership Counsel strongly urges for actions to affirmatively further fair housing (AFFH) and incorporate into programs. Representatives noted that there is a need for more affordable housing and that the City is not making enough progress toward meeting the very low- and low-income RHNA. Leadership Counsel representatives noted that unmet needs include infrastructure, access to parks, medical centers, roads, transit, schools, etc. Regarding housing conditions, Leadership Counsel representatives noted aging mobile homes and general stock that is not maintained resulting in poor conditions. Leadership Counsel encourages the Housing Element to incorporate policies and programs from the City’s recently published Anti-Displacement report. Specific suggestions included long-term rental assistance, tenant protections from landlord retaliation, inclusionary zoning requirements, addressing prior evictions on rental applications, and criminal records on housing applications. APPENDIX 1E: CITY OF FRESNO # Central Valley Urban Institute Central Valley Urban Institute (CVUI) is an advocacy organization working throughout the San Joaquin Valley. The organization’s goal is to build economic and social mobility for low-income communities. CVUI indicated that opportunities for this Housing Element cycle are to increase affordable housing stock production, particularly within infill areas and brownfields as well as to increase homeownership through programs like the downpayment assistance program. CVUI expressed concerns about high building costs, lack of financing, and poor leadership in the area. Regarding housing needs, CVUI described that community members want intergenerational housing, middle-income housing, and “missing-middle” sized housing. Homelessness was also a primary concern, particularly among college-aged youth. In addition, CVUI noted that there are inadequate opportunities for homeownership or adequate rental housing. The largest barriers are access to credit, lack of financial education, and existing housing cost burden. There is also a lack of investment in programs that serve low to moderate-income communities. # Law Office of Patience Milrod – Civil Rights Attorney Patience Milrod, a civil rights attorney in the Fresno area, was interviewed to provide feedback on the FCOG Housing Element update. Ms. Milrod supports the continued attention to inclusionary housing and has concerns about the passive language of “facilitate” and “encourage” that have been common in past Housing Elements. She identified poor housing conditions and was adamant about bolstering code enforcement efforts to improve housing quality. With more aggressive code enforcement in place, she suggested that some landlords may decide that the cost of maintaining their property isn’t worthwhile and may choose to sell to a community land trust or Habitat for Humanity rather than entering receivership. According to Ms. Milrod, the biggest barrier to finding affordable, decent housing in the region is that lower-cost housing tends to also be low quality or ill maintained. Ms. Milrod offered several suggestions for the Housing Element including: * Inclusionary housing * Code Enforcement * Community Land Trusts * Mobile home parks protections. * Work with nonprofits to ensure that they are able to buy before properties go into receivership. * Instead of “facilitate and encourage” we need specific programs and timelines and responsible parties. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-6-25 SECTION 1E-6: PUBLIC OUTREACH AND ENGAGEMENT # BIA of Fresno/Madera Counties The Building Industry Association of Fresno/Madera Counties (BIA) is an industry organization that represents builders, developers, subcontractors, and affiliated businesses in the residential, commercial, and industrial building industry throughout the region. BIA identified that the biggest opportunities for housing in the region are increased demand, downpayment assistance and homeowner maintenance programs. BIA expressed concerns about local regulations, including the City of Fresno’s Zoning and Development Code. BIA members say that it’s hard to get a project through the City’s processes, specifically noting convoluted processes, and mitigation measures that go beyond requirements of the California Environmental Quality Act (CEQA). BIA estimates Fresno’s processes take six months to a year. This is compared to two months in the City of Clovis. In part because everything has to go through City Attorney’s office – even standard agreements. When there is an issue with the agreement, project has to go back to council to fix it. Whereas, there is a delegated authority in other cities. BIA acknowledged that streamlining tools have helped a little, but not enough. The concern is that the development areas west of Highway 99 are generally rural residential composed of parcels with multiple property owners, annexation limitations, and infrastructure constraints. For market rate housing, the BIA noted that the statewide shift to all-electric utilities rather than gas is a concern because of vehicle miles traveled (VMT) regulations. Across the FCOG region, public transit isn’t reliable, and a car is necessary to get around. Builders have to pay a fee to get around the cost of mitigating car miles unless city councils can make a finding of an unavoidable impact. For affordable housing, the prevailing wage requirements are a barrier to development due to the increased cost. Infrastructure costs also affect both types of projects. Streamlining tools help control costs, but not enough. A lack of local water access is also a barrier to development. BIA expressed concern that the State assigned the RHNA without this in mind because there may not be enough water access to support the housing development that the State is looking to see. In BIA’s experience, apartments are in demand but single-family homes are in the greatest demand. There is a lot of demand for low-income housing projects, but these aren’t financially viable for developers without government subsidy. However, including government subsidy in projects increases the overall cost to build, as it triggers prevailing-wage requirements. A recent affordable development in the City of Fresno at Blackstone Avenue and McKinley Avenue cost around $400,000 per unit to build. # Resources for Independence Central Valley Resources for Independence, Central Valley (RICV) is 1 of 28 Centers for Independent Living in California. Independent Living Centers, like RICV, are community-benefit, nonprofit organization run by and for persons with disabilities. RICV provides a foundation of core consumer-controlled, community-based, cross-disability and person-focused programs and assistance. A representative from RICV provided written feedback on housing needs and programs for the Housing Element. The representative expressed concern about laws in the City of Fresno that prevent homeless community members from camping or living in their cars. Homelessness is increasing, but the City is investing resources in enforcing these laws rather than providing assistance. There is funding to move homeless people around, but not to improve anyone’s living situation. APPENDIX 1E: CITY OF FRESNO Additionally, affordability limits are causing challenges for residents to qualify for affordable housing. Community members with disabilities in Fresno experience additional challenges trying to find homes that have necessary accessibility features. For renters, these improvements may be more challenging to implement, and those who use service or support animals may experience discrimination against pets. Homeowners with disabilities end up needing to make expensive home improvements in order to make their homes accessible for themselves. RICV also noted stated that there is a lack of diversity in the housing stock and that the region needs more townhomes, condominiums, and entry level housing options. Higher density housing near transit or major transportation corridors can provide more opportunities for ADA housing accommodations and designs. Regarding equity and fair housing, RICV identified access to credit and credit checks as a barrier to fair housing choice and/or equitable access to opportunity. In addition, RICV described language barriers as a barrier when it comes to applying for housing and not being able to get information or communication with property management. Generally, the lack of affordability for lower income households is the largest concern as rental housing can require deposit and/or income requirements that are unattainable. ### Noticing Per California Government Code Section 65585, the draft Housing Element was made available for public comment for 30 days. The draft was made available on the City’s website and was noticed to residents through the same methods as the Planning Commission and City Council meetings. Additional direct noticing was sent to local housing advocate groups. FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-6-27 SECTION 1E-6: PUBLIC OUTREACH AND ENGAGEMENT This page intentionally left blank. Section 1E-6: Public Outreach and Engagement ....................................................................................... 1 Community Workshops and Meetings ................................................................................................ 1 Summary of Revisions Made During HCD Review Process ............................................................... 19 Planning Commission and City Council Study Sessions (September 2022 and July 2023) ................. 20 Regional Focus Groups (October/November 2022) ............................................................................ 21 Regional and Local Stakeholder Consultations (Summer/Fall 2022) .................................................. 21 Noticing ............................................................................................................................................. 27 # SECTION 1E-7: DETAILED SITES INVENTORY TABLES Table 1E-7.1: Capacity on Vacant Sites, City of Fresno, September 2024 | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1 | 57907541 | | 49.44 | Residential - Medium Low Density | RS-4 | 4.8 | 237 | Above Moderate | YES | | | 2 | 57907542 | | 11.45 | Residential - Medium Low Density | RS-4 | 4.8 | 55 | Above Moderate | YES | | | 3 | 57907540 | | 4.02 | Residential - Medium Low Density | RS-4 | 4.8 | 19 | Above Moderate | YES | | | 5 | 57939055S | | 14.00 | Residential - Medium Low Density | RS-4 | 4.8 | 67 | Above Moderate | YES | FEMA 100-year flood zone | | 6 | 57907547 | | 3.59 | Residential - Medium Low Density | RS-4 | 4.8 | 17 | Above Moderate | NO | | | 7 | 57939062S | | 15.87 | Residential - Low Density | RS-3 | 3.3 | 53 | Above Moderate | YES | FEMA 100-year flood zone | | 8 | 57939063S | | 39.93 | Residential - Medium Density | RS-5 | 8.4 | 335 | Above Moderate | YES | | | 9 | 57939006S | | 2.65 | Residential - Medium Density | RS-5 | 8.4 | 22 | Above Moderate | NO | | | 10 | 57939047S | | 9.07 | Residential - Low Density | RS-3 | 3.3 | 30 | Above Moderate | NO | FEMA 100-year flood zone | | 11 | 57939064S | | 2.95 | Residential - Medium Low Density | RS-4 | 4.8 | 14 | Above Moderate | NO | | | 14 | 57937003S | 2458 E COPPER RIDGE DR | 0.46 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | NO | | | 15 | 57937004S | 2442 E COPPER RIDGE DR | 0.53 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | NO | | | 16 | 57937005S | 2426 E COPPER RIDGE DR | 0.34 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | NO | | | 17 | 57937025S | 2409 E SPEY VALLEY DR | 2.05 | Residential - Low Density | RS-3 | 3.3 | 7 | Above Moderate | NO | | | 18 | 57926016S | 2230 E SPEY VALLEY DR | 1.54 | Residential - Low Density | RS-3 | 3.3 | 5 | Above Moderate | NO | | | 19 | 57926015S | 2209 E SPEY VALLEY DR | 0.82 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | NO | | | 20 | 57939001S | | 4.92 | Residential - Medium Density | RS-5 | 8.4 | 41 | Above Moderate | YES | | | 23 | 57926007S | 11286 N GLASGOW DR | 0.59 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 24 | 57926006S | 11289 N GLASGOW DR | 0.52 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 25 | 57927010S | 2192 E STRATHSPEY WAY | 0.49 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 26 | 57927008S | 2167 E STRATHSPEY WAY | 0.48 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 27 | 57927002S | 11215 N GLASGOW DR | 0.53 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 28 | 57927004S | 2163 E ABERDEEN WAY | 0.73 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 29 | 57922071S | | 4.59 | Residential - Urban Neighborhood | RM-2 | 18.0 | 83 | Lower | NO | | | | 57922033S | | | | | | | | NO | | | 30 | 57915019S | 11363 N SANDHAVEN AVE | 0.50 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 31 | 57940129S | 11333 N ALICANTE DR | 2.00 | Residential - Urban Neighborhood | RM-2 | 18.0 | 36 | Lower | NO | | | 32 | 57941055S | | 2.54 | Residential - Urban Neighborhood | RM-2 | 18.0 | 46 | Lower | YES | | | 33 | 57942028S | 11563 N VIA CAMPAGNA DR | 0.12 | Residential - Medium High Density | RM-1 | 13.6 | 1 | Moderate | YES | | | 34 | 57942029S | 11569 N VIA CAMPAGNA DR | 0.12 | Residential - Medium High Density | RM-1 | 13.6 | 1 | Moderate | YES | | | 35 | 57942030S | 11575 N VIA CAMPAGNA DR | 0.19 | Residential - Medium High Density | RM-1 | 13.6 | 1 | Moderate | YES | | | 36 | 57942031S | 11568 N VIA CAMPAGNA DR | 0.18 | Residential - Medium High Density | RM-1 | 13.6 | 1 | Moderate | YES | | | 37 | 57938202S | 1955 E PIN HIGH DR | 0.17 | Residential - Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 38 | 57938203S | 1967 E PIN HIGH DR | 0.17 | Residential - Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 39 | 57945032S | 11739 N TURF DR | 0.18 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 40 | 57945010S | 11793 N CHAMPIONS DR | 0.18 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 42 | 57945023S | 11702 N LINKS DR | 0.17 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 43 | 57918005S | 11634 N DEVONSHIRE AVE | 0.37 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 44 | 57918006S | 11598 N DEVONSHIRE AVE | 0.41 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 45 | 57917008S | 11572 N DEVONSHIRE AVE | 0.50 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 46 | 57819019S | 2552 E SARAZEN AVE | 0.38 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 47 | 57819003S | 2537 E PRESTWICK AVE | 0.34 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 48 | 57727041 | 1809 E HOGAN AVE | 0.37 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 49 | 57727046 | 10834 N MERIDIAN AVE | 0.34 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 50 | 57727045 | 1937 E HOGAN AVE | 0.44 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 51 | 57814041S | 2047 E AJIT LN | 0.36 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 52 | 57814042S | 2071 E AJIT LN | 0.37 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 53 | 57814043S | 2093 E AJIT LN | 0.38 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 54 | 57801005 | | 2.33 | Residential - Low Density | RS-3 | 3.3 | 8 | Above Moderate | YES | | | 55 | 57624118S | 922 E RIDGECREST DR | 0.28 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 56 | 57624125S | 10780 N HAMPSHIRE DR | 0.26 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 57 | 57724403S | 1067 E TURNBERRY AVE | 0.33 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 58 | 57724409S | 1163 E TURNBERRY AVE | 0.33 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 59 | 57720027S | 1297 E CARLYLE WAY | 0.45 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 60 | 40263122 | 204 W BLUFF AVE | 0.53 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 61 | 40260215 | 251 W HUBERT CT | 0.31 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 62 | 40261004 | 207 W BRIER CIR | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 63 | 40108204 | 9201 N STONERIDGE LN | 0.20 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 64 | 40355229S | | 0.45 | Residential - Medium Low Density | RS-4 | 4.8 | 2 | Above Moderate | YES | | | 65 | 40302208 | 8645 N MAPLE AVE | 2.63 | Residential - Medium Low Density | RS-4 | 4.8 | 13 | Above Moderate | NO | | | 66 | 40402102 | | 4.52 | Residential - Urban Neighborhood | RM-2 | 18.0 | 81 | Lower | YES | | | 67 | 40408301 | | 0.20 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 68 | 408153X54 | | 0.62 | Residential - Medium Density | RS-5 | 8.4 | 5 | Above Moderate | YES | | | 69 | 30363021 | 131 W NEES AVE | 1.64 | Residential High Density | RM-3 | 36.0 | 55 | Lower | YES | | | 70 | 30303133 | 7388 N INGRAM AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 71 | 30303110 | | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 72 | 30307101 | | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 73 | 30307102 | 481 W MINARETS AVE | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 74 | 30311125 | 445 W SPRUCE AVE | 0.22 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 75 | 30311216 | | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 76 | 30314102 | 7078 N INGRAM AVE | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 77 | 30314103 | | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 78 | 30314115 | 440 W BEECHWOOD AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 79 | 30314324S | 350 W BEECHWOOD AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 80 | 30311310 | 311 W SPRUCE AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 81 | 30307334 | 352 W BIRCH AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 82 | 30307343 | | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 83 | 30303404 | | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 84 | 30304139 | 269 W ALLUVIAL AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 85 | 30304242 | 263 W PINEDALE AVE | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 86 | 30308115 | 7287 N SAN PABLO AVE | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 87 | 30308121 | | 0.22 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 88 | 30315105 | 261 W FIR AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 89 | 30315124 | | 0.22 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 90 | 30316601 | 25 W BEECHWOOD AVE | 0.15 | Corridor - Center Mixed Use | CMX | 37.50 | 6 | Above Moderate | NO | | | 91 | 30316149 | | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 92 | 30316147 | 57 W FIR AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 93 | 30316146 | 69 W FIR AVE | 0.22 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | NO | | | 94 | 30309242 | | 0.22 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 95 | 30309245 | 130 W SPRUCE AVE | 0.29 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 96 | 30309231 | 163 W BIRCH AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 97 | 30309171 | | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 98 | 30305211 | 102 W MINARETS AVE | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 99 | 30305308 | | 0.15 | Corridor - Center Mixed Use | CMX | 37.50 | 6 | Above Moderate | YES | | | 100 | 30305417 | 7328 N SUGAR PINE AVE | 0.14 | Corridor - Center Mixed Use | CMX | 37.50 | 5 | Above Moderate | YES | | | 101 | 30305418 | | 0.28 | Corridor - Center Mixed Use | CMX | 37.50 | 10 | Above Moderate | YES | | | 102 | 30305406 | 7315 N BLACKSTONE AVE | 0.30 | Corridor - Center Mixed Use | CMX | 37.50 | 11 | Above Moderate | NO | | | 103 | 30306225 | | 0.69 | Corridor - Center Mixed Use | CMX | 37.50 | 26 | Lower | YES | | | | 30306226 | 51 E PINEDALE AVE | | | | | | | | | | | 30306209 | 67 E PINEDALE AVE | | | | | | | | | | | 30306210 | 75 E PINEDALE AVE | | | | | | | | | | | 30306208 | 57 E PINEDALE AVE | | | | | | | | | | 104 | 30320127 | 7354 N ABBY ST | 7.76 | Commercial - Regional | CR | 40.00 | 260 | Lower | NO | | | 105 | 40535095S | | 2.02 | Residential Low Density | RS-2 | 2.0 | 4 | Above Moderate | YES | | | 106 | 40552309S | 2016 W ALLUVIAL AVE | 0.69 | Residential Low Density | RS-2 | 2.0 | 1 | Above Moderate | YES | | | 107 | 40551012S | 7512 N HIGHGROVE LN | 0.46 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 108 | 40551011S | 7536 N HIGHGROVE LN | 0.51 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 109 | 40558044 | 2227 W THOMASON PL | 0.61 | Residential Low Density | RS-2 | 2.0 | 1 | Above Moderate | YES | | | 110 | 40558045 | 2221 W THOMASON PL | 1.64 | Residential Low Density | RS-2 | 2.0 | 3 | Above Moderate | NO | | | 111 | 40505016 | 7439 N SEQUOIA DR | 0.96 | Residential Low Density | RS-1 | 0.8 | 1 | Above Moderate | YES | | SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 112 | 50028001S | 7379 N VAN NESS BLVD | 1.16 | Residential Low Density | RS-1 | 0.8 | 1 | Above Moderate | YES | | | 113 | 40720402 | 6559 N MAROA AVE | 2.56 | Residential - Medium High Density | RM-1 | 13.6 | 35 | Moderate | YES | | | 114 | 40717310 | 157 W MENLO AVE | 0.21 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 119 | 41707056 | | 0.66 | Residential - Medium Density | RS-5 | 8.4 | 6 | Above Moderate | YES | | | 120 | 41714021 | 614 W SAN JOSE AVE | 1.05 | Regional Mixed-Use | RMX | 45.0 | 47 | Lower | NO | | | 121 | 41723120 | 575 W SAN JOSE AVE | 2.29 | Regional Mixed-Use | RMX | 45.0 | 103 | Lower | NO | | | 122 | 41845014 | | 5.52 | Regional Mixed-Use | RMX | 45.0 | 248 | Lower | NO | | | 124 | 41806054 | 83 E BARSTOW AVE | 2.36 | Regional Mixed-Use | RMX | 45.0 | 106 | Lower | YES | | | 125 | 41808085 | | 1.81 | Regional Mixed-Use | RMX | 45.0 | 82 | Lower | YES | | | 126 | 41808082 | | 2.36 | Regional Mixed-Use | RMX | 45.0 | 106 | Lower | YES | | | 128 | 42509103 | | 0.34 | Corridor - Center Mixed Use | CMX | 37.50 | 13 | Above Moderate | YES | | | 129 | 42509213 | 63 W SHAW AVE | 2.25 | Corridor - Center Mixed Use | CMX | 37.50 | 84 | Lower | NO | | | 130 | 41806052 | 251 BARSTOW AVE | 3.30 | Residential - Medium High Density | RM-1 | 13.6 | 45 | Moderate | NO | | | 131 | 41820145 | | 0.61 | Corridor - Center Mixed Use | CMX | 37.50 | 23 | Lower | YES | | | 133 | 41818322 | 488 E SAN JOSE AVE | 0.23 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 134 | 41809131 | 659 E KEATS AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 135 | 41809134 | 687 E KEATS AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 136 | 41809118 | | 2.34 | Corridor - Center Mixed Use | CMX | 37.50 | 88 | Lower | YES | | | 137 | 41809124 | 1066 E SHAW FR | 1.16 | Corridor - Center Mixed Use | CMX | 37.50 | 43 | Lower | NO | | | 138 | 42707140 | | 0.29 | Corridor - Center Mixed Use | CMX | 37.50 | 11 | Above Moderate | YES | | | 139 | 41814108 | | 0.23 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 140 | 41814502 | 1315 E PORTALS AVE | 0.22 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 141 | 41816102S | 1319 E SAN RAMON AVE | 0.18 | Residential High Density | RM-3 | 36.0 | 1 | Above Moderate | YES | | | 142 | 41816106S | 1357 E SAN RAMON AVE | 0.18 | Open Space - Community Park | RM-3 | 36.0 | 1 | Above Moderate | NO | | | 143 | 41816306S | 1470 E BULLDOG LN | 0.79 | Residential High Density | RM-3 | 36.0 | 27 | Lower | YES | | | 144 | 43012039 | | 0.37 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 145 | 43012042 | 4341 E SAN GABRIEL AVE | 0.34 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 146 | 43011050 | 4527 E ALAMOS AVE | 0.40 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | | 4651 N BARTON AVE | 0.33 | 1 | Above Moderate | | | | 147 | 43009043 | | 0.37 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | | 43015015 | | 0.26 | 4.8 | 1 | Above Moderate | | | | 148 | 43016121 | 4561 N ARCHIE AVE | 0.23 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 149 | 43032226 | | 0.21 | Corridor - Center Mixed Use | CMX | 37.50 | 8 | Above Moderate | YES | | | 150 | 43038131 | 4516 N CHESTNUT AVE | 1.12 | Residential - Medium High Density | RM-1 | 13.6 | 15 | Moderate | YES | | | 151 | 43039135 | | 0.95 | Residential - Medium Density | RS-5 | 8.4 | 8 | Above Moderate | YES | | | 152 | 43021007 | 4783 E AUSTIN WAY | 0.90 | Residential - Medium High Density | RM-1 | 13.6 | 12 | Moderate | YES | | | 153 | 42517217 | 4819 N BLACKSTONE AVE | 0.69 | Corridor - Center Mixed Use | CMX | 37.50 | 26 | Lower | YES | | | 154 | 42708120 | | 0.79 | Corridor - Center Mixed Use | CMX | 37.50 | 30 | Lower | YES | | APPENDIX 1E: CITY OF FRESNO | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 160 | 42609220 | 4528N GLENN FR | 0.31 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 163 | 42633123 | 4268 N MAROA AVE | 0.29 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 164 | 42823318 | 1929 E ASHLAN AVE | 0.18 | Corridor - Center Mixed Use | CMX | 37.50 | 1 | Above Moderate | NO | | | 165 | 43602210 | | 0.18 | Regional Mixed-Use | RMX | 45.0 | 1 | Above Moderate | YES | | | 166 | 43602228 | | 0.31 | Regional Mixed-Use | RMX | 45.0 | 14 | Above Moderate | YES | | | 167 | 43619308T | | 0.14 | Regional Mixed-Use | RMX | 45.0 | 6 | Above Moderate | YES | | | 168 | 43627015 | 2111 E DAKOTA AVE | 0.71 | Regional Mixed-Use | RMX | 45.0 | 32 | Lower | NO | | | 169 | 43613217 | 2920 E JOAQUIN PL | 0.30 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 170 | 43621107 | | 0.23 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 171 | 43621322 | 3944 N ANGUS ST | 0.22 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 172 | 43621314 | | 0.18 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 173 | 43621316 | | 0.16 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 174 | 43621317 | | 0.17 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 175 | 43621319 | | 0.23 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 176 | 43621320 | | 0.15 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 178 | 43608072 | | 0.40 | Residential - Medium High Density | RM-1 | 13.6 | 5 | Moderate | YES | | | 179 | 43722116 | 3436 N FIRST ST | 1.38 | Residential - Medium Density | RS-5 | 8.4 | 12 | Above Moderate | YES | | | 180 | 43633017 | 4112 E SAGINAW WAY | 1.91 | Residential - Medium Density | RS-5 | 8.4 | 16 | Above Moderate | YES | | | 182 | 44704124 | 4544 E SHIELDS AVE | 0.14 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 287 | 45603034T | 5471 E BELMONT AVE | 4.17 | Residential - Medium High Density | RM-1 | 13.6 | 57 | Moderate | YES | | | 288 | 45603044 | | 5.51 | Corridor - Center Mixed Use | CMX | 37.50 | 206 | Lower | YES | | | 289 | 45603037 | | 1.47 | Corridor - Center Mixed Use | CMX | 37.50 | 55 | Lower | YES | | | 290 | 46218211
46218205 | | 0.64 | Corridor - Center Mixed Use | CMX | 37.50 | 24 | Lower | YES | | | 292 | 46202029 | 169 N CLOVIS AVE | 2.46 | Corridor - Center Mixed Use | CMX | 37.50 | 92 | Lower | YES | | | 293 | 46228034 | 5483 E TULARE ST | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 302 | 46303025 | 360 S CLOVIS AVE | 4.41 | Corridor - Center Mixed Use | CMX | 37.50 | 165 | Lower | NO | | | 303 | 31322133
31322131 | | 0.62 | Corridor - Center Mixed Use | CMX | 37.50 | 23 | Lower | YES | | | 304 | 31332107T | | 0.45 | Residential - Medium Low Density | RS-4 | 4.8 | 2 | Above Moderate | YES | | | 305 | 31379825 | | 0.32 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 307 | 31324082 | | 1.99 | Corridor - Center Mixed Use | CMX | 37.50 | 74 | Lower | YES | | | 308 | 31380111
31306011 | | 3.61 | Residential - Medium Density | RS-5 | 8.4 | 30 | Above Moderate | YES | | | 309 | 31381028
31306010 | 5913 E TULARE ST | 3.12 | Residential - Medium Density | RS-5 | 8.4 | 26 | Above Moderate | YES | | | 310 | 31306008 | 5935 E TULARE ST | 0.67 | Residential - Medium Density | RS-5 | 8.4 | 6 | Above Moderate | YES | | | 313 | 47403066 | | 6.75 | Corridor - Center Mixed Use | CMX | 37.50 | 212 | Lower | YES | | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 | 1E-7-5 SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 314 | 47408018 | 1117 S CLOVIS AVE | 1.69 | Residential - Medium Density | RS-5 | 8.4 | 14 | Above Moderate | YES | | | 382 | 31616053 | | 2.32 | Residential - Urban Neighborhood | RM-2 | 18.0 | 42 | Lower | YES | | | 384 | 31602267 | | 11.99 | Residential - Medium Density | RS-5 | 8.4 | 101 | Above Moderate | YES | | | 385 | 31602268 | | 11.34 | Residential - Medium Density | RS-5 | 8.4 | 95 | Above Moderate | YES | | | 386 | 31612261 | | 4.28 | Residential - Urban Neighborhood | RM-2 | 18.0 | 77 | Lower | NO | | | 388 | 31602201 | 2149 S CLOVIS AVE | 6.48 | Residential - Medium Low Density | RS-4 | 4.8 | 31 | Above Moderate | YES | | | 389 | 31612001 | | 1.11 | Residential - Medium Low Density | RS-4 | 4.8 | 5 | Above Moderate | YES | | | 390 | 48110014 | | 1.16 | Residential - Medium Low Density | RS-4 | 4.8 | 6 | Above Moderate | NO | | | 391 | 48147041 | | 4.49 | Residential - Medium Density | RS-5 | 8.4 | 38 | Above Moderate | YES | | | 392 | 48113026 | | 5.96 | Residential - Medium High Density | RM-1 | 13.6 | 81 | Moderate | YES | | | 393 | 48113026 | | 5.02 | Residential - Medium Density | RS-5 | 8.4 | 42 | Above Moderate | YES | | | 394 | 48105003 | 2551 S MINNEWAWA AVE | 23.18 | Residential - Medium High Density | RM-1 | 13.6 | 315 | Moderate | YES | | | 396 | 48150109S | 5231 E GARRETT AVE | 0.15 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 397 | 48150108S | 5227 E GARRETT AVE | 0.15 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 398 | 48150107S | 5223 E GARRETT AVE | 0.15 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 399 | 48102060S | 2358 S ADRIAN AVE | 6.39 | Residential - Medium Density | RS-5 | 8.4 | 54 | Above Moderate | YES | FEMA 100-year flood zone | | 400 | 48102060S | 2358 S ADRIAN AVE | 5.49 | Residential - Medium Low Density | RS-4 | 4.8 | 26 | Above Moderate | YES | FEMA 100-year flood zone | | 403 | 48137501S | 2286 S MINNEWAWA AVE | 0.46 | Residential Low Density | RS-2 | 2.0 | 1 | Above Moderate | YES | | | 404 | 48149352S | 2178 S MINNEWAWA AVE | 0.47 | Residential Low Density | RS-2 | 2.0 | 1 | Above Moderate | YES | | | 405 | 47310307 | 5386 E ORLEANS AVE | 0.56 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 406 | 47310404 | 5369 E ORLEANS AVE | 0.38 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 407 | 47309403 | 5366 E TOWNSEND AVE | 0.46 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 408 | 47309310 | 5387 E TOWNSEND AVE | 0.63 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 409 | 47309307 | 5368 E BUTLER AVE | 0.55 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | NO | | | 410 | 47309315S | 5348 E BUTLER AVE | 0.41 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 411 | 47309316S | 5338 E BUTLER AVE | 0.41 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 412 | 47309317S | 5328 E BUTLER AVE | 0.41 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 413 | 47213030 | 5433 E BUTLER AVE | 0.55 | Residential Low Density | RS-2 | 2.0 | 1 | Above Moderate | YES | | | 414 | 47219035 | 5243 E LIBERTY AVE | 0.60 | Residential - Medium High Density | RM-1 | 13.6 | 8 | Moderate | YES | | | 416 | 46310017 | 145 S PEACH AVE | 0.65 | Residential - Medium Low Density | RS-4 | 4.8 | 3 | Above Moderate | YES | | | 417 | 46318104 | 5032 E HUNTINGTON AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 418 | 46305046 | | 1.47 | Corridor - Center Mixed Use | CMX | 37.50 | 55 | Lower | YES | | | 420 | 47217101 | 933 S WILLOW AVE | 0.92 | Corridor - Center Mixed Use | CMX | 37.50 | 35 | Lower | YES | | | | 47217102 | 957 S WILLOW AVE | | | | | | | | | | | 47216112 | 901 S WILLOW AVE | | | | | | | | | | 421 | 47217208 | 5044 E ALTA AVE | 0.45 | Corridor - Center Mixed Use | CMX | 37.50 | 17 | Above Moderate | YES | | | 422 | 48102047 | 2122 S PEACH AVE | 38.05 | Residential - Medium Density | RS-5 | 8.4 | 320 | Above Moderate | YES | | | 426 | 48112004 | 2575 S KAREN AVE | 17.22 | Residential - Medium Density | RS-5 | 8.4 | 145 | Above Moderate | YES | | | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 427 | 48109026 | | 3.86 | Residential - Medium Density | RS-5 | 8.4 | 32 | Above Moderate | YES | | | 428 | 48109024 | 2449 S WILLOW AVE | 5.79 | Residential - Medium Density | RS-5 | 8.4 | 49 | Above Moderate | YES | | | 430 | 48111005 | 4865 E JENSEN AVE | 6.27 | Residential - Medium High Density | RM-1 | 13.6 | 85 | Moderate | YES | FEMA 100-year flood zone | | 432 | 48108032 | 4958 E CHURCH AVE | 4.75 | Residential - Medium Density | RS-5 | 8.4 | 40 | Above Moderate | YES | | | 433 | 47320037 | | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 434 | 47204025 | | 0.64 | Neighborhood Mixed-Use | NMX | 32.0 | 21 | Lower | YES | | | 435 | 46312021 | | 0.99 | Residential - Medium Density | RS-5 | 8.4 | 8 | Above Moderate | NO | | | 436 | 46317121 | 4846 E HUNTINGTON AVE | 0.22 | Residential - Medium High Density | RM-1 | 13.6 | 3 | Moderate | NO | | | 437 | 46312030 | | 0.18 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 439 | 48003035 | 2536 S MAPLE AVE | 1.90 | Residential - Medium Density | RS-5 | 8.4 | 16 | Above Moderate | YES | | | 440 | 48003018 | 2534 S MAPLE AVE | 0.96 | Residential - Medium Density | RS-5 | 8.4 | 8 | Above Moderate | YES | | | 441 | 48035314 | 2569 S HOLLOWAY AVE | 0.51 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | YES | | | 442 | 48035231 | 2553 S ROWELL AVE | 0.37 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 443 | 48032110 | | 1.16 | Residential - Medium Density | RS-5 | 8.4 | 10 | Above Moderate | YES | | | 444 | 48024504 | | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 445 | 48712401 | 4120 E CALWA AVE | 0.25 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 446 | 48022037 | 3633 E EUGENIA AVE | 0.61 | Residential - Medium Density | RS-5 | 8.4 | 5 | Above Moderate | YES | | | 447 | 48012012 | | 1.20 | Residential - Medium Density | RS-5 | 8.4 | 10 | Above Moderate | YES | | | 448 | 48008003 | 4737 E FLORENCE AVE | 9.31 | Residential - Medium Density | RS-5 | 8.4 | 78 | Above Moderate | NO | | | 450 | 48020121 | 4643 E CHURCH AVE | 0.18 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 451 | 47129111 | 2080 S CHANCE AVE | 0.56 | Residential - Medium Density | RS-5 | 8.4 | 5 | Above Moderate | YES | | | 47134001 | 4308 E WOODWARD AVE | 2.27 | Residential - Medium High Density | RM-1 | 13.6 | 31 | Moderate | | | | 452 | 47130243 | 2074 S HAYSTON AVE | 0.57 | Residential - Medium Density | RS-5 | 8.4 | 5 | Above Moderate | YES | | | 453 | 47130245 | 2040 S HAYSTON AVE | 0.38 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 455 | 47130206 | 4596 E WOODWARD AVE | 0.35 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 456 | 47122045 | 4551 E WOODWARD AVE | 0.80 | Residential - Medium Density | RS-5 | 8.4 | 7 | Above Moderate | YES | | | 457 | 47122005 | 4576 E HAMILTON AVE | 0.96 | Residential - Medium High Density | RM-1 | 13.6 | 13 | Moderate | YES | | | 458 | 47017425 | 4796 E ALTA AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 459 | 47009104 | 4736 E KINGS CANYON RD | 0.14 | Corridor - Center Mixed Use | CMX | 37.50 | 5 | Above Moderate | NO | | | 460 | 47008106 | 4648 E KINGS CANYON RD | 0.37 | Corridor - Center Mixed Use | CMX | 37.50 | 14 | Above Moderate | YES | | | 462 | 46129331 | 650 S SIERRA VISTA AVE | 0.38 | Corridor - Center Mixed Use | CMX | 37.50 | 14 | Above Moderate | YES | | | 463 | 46130107 | 618 S WHITNEY AVE | 0.23 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | NO | | | 464 | 46130217 | 4723 E KINGS CANYON RD | 0.23 | Corridor - Center Mixed Use | CMX | 37.50 | 9 | Above Moderate | YES | | | 465 | 46130309 | 4755 E KINGS CANYON RD | 0.31 | Corridor - Center Mixed Use | CMX | 37.50 | 12 | Above Moderate | YES | | | 467 | 46130319 | 556 S DEARING AVE | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 468 | 46123413 | 515 S DEARING AVE | 0.23 | Residential - Urban Neighborhood | RM-2 | 18.0 | 4 | Above Moderate | YES | | | 469 | 46123303 | 422 S DEARING AVE | 0.42 | Residential - Urban Neighborhood | RM-2 | 18.0 | 8 | Above Moderate | YES | | | 470 | 46122410 | 533 S SIERRA VISTA AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 471 | 46122136 | | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 472 | 46032339 | 4645 E TULARE ST | 0.34 | Neighborhood Mixed-Use | NMX | 32.0 | 11 | Above Moderate | YES | | | 473 | 46017227 | 369 N CHESTNUT AVE | 0.33 | Neighborhood Mixed-Use | NMX | 32.0 | 11 | Above Moderate | NO | | | 474 | 46009202 | 4770 E BELMONT AVE | 0.32 | Neighborhood Mixed-Use | NMX | 32.0 | 10 | Above Moderate | NO | | | 476 | 46009119 | 4705 E MADISON AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 477 | 45432414 | 4675 E BELMONT AVE | 0.35 | Neighborhood Mixed-Use | NMX | 32.0 | 11 | Above Moderate | YES | | | 478 | 45433102 | 4714 E TURNER AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 479 | 45432107 | 685 N BACKER AVE | 0.74 | Residential - Medium Density | RS-5 | 8.4 | 6 | Above Moderate | NO | | | 481 | 45624122 | 4831 E TYLER AVE | 0.66 | Residential - Medium Density | RS-5 | 8.4 | 6 | Above Moderate | YES | | | 482 | 45409102 | | 0.20 | Residential - Medium High Density | RM-1 | 13.6 | 3 | Moderate | YES | | | 483 | 45325112 | | 0.31 | Residential - Medium High Density | RM-1 | 13.6 | 4 | Moderate | YES | | | 504 | 44608213 | 4167 E UNION AVE | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 505 | 44730322 | 4561 E MCKINLEY AVE | 0.31 | Residential - Medium High Density | RM-1 | 13.6 | 4 | Moderate | YES | | | 506 | 45322314 | 4435 E LAMONA AVE | 0.23 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 507 | 45322316 | 1360 N ROWELL AVE | 0.25 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 509 | 45423334 | 4537 E TURNER AVE | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 510 | 45431324 | | 0.34 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 511 | 45431327 | 4545 E BELMONT AVE | 0.37 | Neighborhood Mixed-Use | NMX | 32.0 | 12 | Above Moderate | YES | | | 515 | 46007104 | | 0.12 | Neighborhood Mixed-Use | NMX | 32.0 | 4 | Above Moderate | NO | | | 517 | 45430325 | 4345 E BELMONT AVE | 0.40 | Neighborhood Mixed-Use | NMX | 32.0 | 13 | Above Moderate | YES | | | 518 | 45422324 | 720 N CEDAR AVE | 0.59 | Residential - Medium Density | RS-5 | 8.4 | 5 | Above Moderate | YES | | | 519 | 46007419 | 4565 E GRANT AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 520 | 46107429 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 521 | 46107325 | 4550 E TULARE ST | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 522 | 46107125 | 4510 E TULARE ST | 0.11 | Neighborhood Mixed-Use | NMX | 32.0 | 4 | Above Moderate | NO | | | 523 | 46030316 | 4313 E TULARE ST | 0.29 | Neighborhood Mixed-Use | NMX | 32.0 | 9 | Above Moderate | NO | | | 524 | 47007109 | | 0.24 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 525 | 47007306 | | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 527 | 47106215 | | 0.29 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 528 | 47106229 | | 0.17 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 529 | 47027305 | | 0.19 | Neighborhood Mixed-Use | NMX | 32.0 | 6 | Above Moderate | YES | | | 530 | 47013136 | | 0.30 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 531 | 47013309 | | 0.18 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 534 | 47005301 | | 0.19 | Neighborhood Mixed-Use | NMX | 32.0 | 6 | Above Moderate | YES | | | | 47005201T | 3702 E VENTURA ST | 0.29 | Neighborhood Mixed-Use | NMX | 32.0 | | | | | | 535 | 47005202T | 3754 E VENTURA ST | 3.35 | Neighborhood Mixed-Use | NMX | 32.0 | 109 | Lower | YES | | | | 47005203T | 3745 E EL MONTE WAY | 0.26 | Residential - Medium Density | RS-5 | 8.4 | | | | | | 538 | 47005105 | | 0.23 | Neighborhood Mixed-Use | NMX | 32.0 | 7 | Above Moderate | YES | | | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 539 | 47005115 | 745 S ORANGE AVE | 0.21 | Neighborhood Mixed-Use | NMX | 32.0 | 7 | Above Moderate | YES | | | 540 | 46126510 | 3849 E VENTURA ST | 0.17 | Neighborhood Mixed-Use | NMX | 32.0 | 6 | Above Moderate | YES | | | 541 | 46126511 | 3839 E VENTURA ST | 0.35 | Neighborhood Mixed-Use | NMX | 32.0 | 11 | Above Moderate | YES | | | 542 | 46126513 | 3811 E VENTURA ST | 0.21 | Neighborhood Mixed-Use | NMX | 32.0 | 7 | Above Moderate | YES | | | 543 | 46126410 | | 0.17 | Neighborhood Mixed-Use | NMX | 32.0 | 6 | Above Moderate | YES | | | 544 | 47126520 | 2060 S FIFTH ST | 0.26 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 545 | 47126519 | | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 546 | 47126508 | | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 547 | 47125308 | | 0.34 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 548 | 47125306 | | 0.20 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 549 | 47125304 | | 0.20 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 550 | 47125303 | | 0.20 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 551 | 47125302 | 2010 S HAZELWOOD BLVD | 0.40 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 552 | 47118205 | | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 553 | 47111509 | 3361 E HAMILTON AVE | 0.11 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 554 | 47110306 | 1645 S THIRD ST | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 555 | 47104103 | 3366 E BUTLER AVE | 0.17 | Neighborhood Mixed-Use | NMX | 32.0 | 6 | Above Moderate | NO | | | 556 | 47104102 | | 0.17 | Neighborhood Mixed-Use | NMX | 32.0 | 6 | Above Moderate | YES | | | 557 | 47026219 | 3403 E BUTLER AVE | 0.15 | Neighborhood Mixed-Use | NMX | 32.0 | 5 | Above Moderate | YES | | | 558 | 47025403 | 3350 E LYELL AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 559 | 47003206 | | 0.68 | Residential - Medium Density | RS-5 | 8.4 | 6 | Above Moderate | YES | | | 560 | 47003121 | 3144 E VENTURA ST | 0.47 | Neighborhood Mixed-Use | NMX | 32.0 | 15 | Above Moderate | YES | | | 561 | 46813116 | 3067 E EL MONTE WAY | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 562 | 46813105 | | 0.63 | Neighborhood Mixed-Use | NMX | 32.0 | 20 | Lower | YES | | | | 46813104 | 3000 E VENTURA ST | | | | | | | | | | | 46813103 | 2996 E VENTURA ST | | | | | | | | | | 563 | 46814007 | 746 S HAZELWOOD BLVD | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 564 | 46814009 | 760 S HAZELWOOD BLVD | 0.30 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 565 | 46125415 | | 0.17 | Neighborhood Mixed-Use | NMX | 32.0 | 1 | Above Moderate | NO | | | 566 | 46125407 | 3452 E MONO ST | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 567 | 46839063 | 2948 E TULARE ST | 0.55 | Neighborhood Mixed-Use | NMX | 32.0 | 18 | Lower | YES | | | | 46839055S | | | | | | | | | | | 568 | 46026612 | 3333 E TULARE ST | 0.14 | Neighborhood Mixed-Use | NMX | 32.0 | 5 | Above Moderate | NO | | | 570 | 46028202 | 3810 E ILLINOIS AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 571 | 46029609 | 4155 E TULARE ST | 0.52 | Neighborhood Mixed-Use | NMX | 32.0 | 17 | Lower | YES | | | 572 | 46029720 | | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | | 46029710 | | | | | | | | | | | 573 | 46005248 | 4175 E MADISON AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 574 | 46004217 | 3870 E BELMONT AVE | 0.39 | Neighborhood Mixed-Use | NMX | 32.0 | 12 | Above Moderate | YES | | | 575 | 45428161 | 3883 E WHITE AVE | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 576 | 45928407 | 3042 E NEVADA AVE | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 577 | 45919406 | 3040 E WASHINGTON AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 578 | 45919225 | 3079 E WASHINGTON AVE | 0.27 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | NO | | | 579 | 45919201 | 3004 E GRANT AVE | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 580 | 45919126 | 2951 E WASHINGTON AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 581 | 45910405 | 3028 E MADISON AVE | 0.11 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 582 | 45910433 | 409 N FIRST ST | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 583 | 45910226 | 3081 E MADISON AVE | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 584 | 46010103 | 3150 E GRANT AVE | 0.18 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 585 | 45233516 | 3065 E BELMONT AVE | 0.15 | Neighborhood Mixed-Use | NMX | 32.0 | 5 | Above Moderate | NO | | | 586 | 45426135 | 538 N FIRST ST | 0.23 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | NO | | | 587 | 45426143 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 588 | 45418510 | | 0.22 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 589 | 45418125 | 702 N FIRST ST | 0.09 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 590 | 45418124 | 714 N FIRST ST | 0.11 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 591 | 45418122 | | 0.11 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 592 | 45418130 | 739 N SECOND ST | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 593 | 45418226 | 3228 E HARVEY AVE | 0.08 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 594 | 45418221 | 3232 E HARVEY AVE | 0.07 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 595 | 45418313 | 736 N FISHER ST | 0.12 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 596 | 45418421 | 738 N THIRD ST | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 597 | 45418408 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 598 | 45418413 | 720 N THIRD ST | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 599 | 45426321 | 618 N FISHER ST | 0.30 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | NO | | | 600 | 45426215 | 3201 E BELMONT AVE | 0.14 | Neighborhood Mixed-Use | NMX | 32.0 | 5 | Above Moderate | YES | | | 602 | 45427122 | 616 N BOND ST | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 603 | 45419405 | 717 N MILLBROOK AVE | 0.18 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 604 | 45420417 | 3859 E TURNER AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 605 | 45405428 | 1035 N CEDAR AVE | 0.50 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | YES | | | 606 | 45405218 | 1102 N ELEVENTH ST | 0.09 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 607 | 45405233 | | 0.11 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 608 | 45329238 | 1249 N CEDAR AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 609 | 45404228 | | 0.47 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | YES | | | 610 | 45328223 | | 0.64 | Residential - Medium Density | RS-5 | 8.4 | 5 | Above Moderate | YES | | | 611 | 45320101 | 3746 E FLORADORA AVE | 0.44 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | YES | | | 612 | 45312122 | | 0.30 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 613 | 45305120 | | 0.90 | Residential - Medium Density | RS-5 | 8.4 | 8 | Above Moderate | YES | | | 614 | 45124226 | 1361 N FIRST ST | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 615 | 45310222 | 3255 E PINE AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 616 | 44519211 | 2707 N FRESNO ST | 0.37 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 617 | 44505112 | 2819 E SIMPSON AVE | 0.22 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | NO | | | 618 | 43516225 | 1142 E GARLAND AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 619 | 43517302 | 1314 E FEDORA AVE | 0.21 | Residential - Medium High Density | RM-1 | 13.6 | 3 | Moderate | YES | | | 620 | 43517308 | 1422 E FEDORA AVE | 0.69 | Residential - Medium High Density | RM-1 | 13.6 | 9 | Moderate | YES | FEMA 100-year flood zone | | 621 | 4354210 | | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 622 | 43533301 | | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 623 | 44310204 | 1526 E SHIELDS AVE | 0.50 | Neighborhood Mixed-Use | NMX | 32.0 | 16 | Lower | YES | | | | 44310203 | 1518 E SHIELDS AVE | | | | | | | | | | | 44310202 | 1510 E SHIELDS AVE | | | | | | | | | | | 44310201 | 1502 E SHIELDS AVE | | | | | | | | | | 624 | 44310217 | 1519 E SIMPSON AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 625 | 44309223 | 1103 E SIMPSON AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 629 | 44318222 | 2915 N BLACKSTONE AVE | 0.25 | Neighborhood Mixed-Use | NMX | 32.0 | 8 | Above Moderate | YES | | | 631 | 44333623 | | 0.35 | Residential - Medium High Density | RM-1 | 13.6 | 5 | Moderate | YES | | | 632 | 44409110 | 1433 E VASSAR AVE | 0.14 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 633 | 44409205 | 1605 E VASSAR AVE | 2.73 | Neighborhood Mixed-Use | NMX | 32.0 | 87 | Lower | YES | | | | 44409204 | 1538 E CLINTON AVE | | | | | | | | | | | 44409228 | 1533 E VASSAR AVE | | | | | | | | | | 634 | 44409220 | | 0.21 | Neighborhood Mixed-Use | NMX | 32.0 | 7 | Above Moderate | NO | | | 635 | 44409301 | 2240 N SAN PABLO AVE | 0.16 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 636 | 44409310 | 1405 E YALE AVE | 0.13 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 637 | 44408607 | 2221 N SAN PABLO AVE | 0.15 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 638 | 44408514 | 1143 E YALE AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 639 | 44624203 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 640 | 45123103 | 2556 E FLORADORA AVE | 0.16 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 641 | 45208112 | 2525 E CLAY AVE | 0.18 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 642 | 45216513 | | 0.15 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 643 | 45223221 | | 1.14 | Residential - Medium High Density | RM-1 | 13.6 | 15 | Moderate | YES | | | 644 | 45222616 | 2012 E HARVEY AVE | 0.43 | Residential - Medium High Density | RM-1 | 13.6 | 6 | Moderate | YES | | | 645 | 45215522 | 2215 E LEWIS AVE | 0.15 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 646 | 45215512 | | 0.15 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 647 | 45206602 | 2012 E CLAY AVE | 0.15 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 648 | 45207304 | 2224 E WEBSTER AVE | 0.15 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | NO | | | 649 | 45222406 | | 0.16 | Neighborhood Mixed-Use | NMX | 32.0 | 5 | Above Moderate | YES | | SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 651 | 45214608 | 1918 E LEWIS AVE | 0.15 | Neighborhood Mixed-Use | NMX | 32.0 | 5 | Above Moderate | YES | | | 652 | 45214601 | 848 N ABBY ST | 0.20 | Neighborhood Mixed-Use | NMX | 32.0 | 6 | Above Moderate | YES | | | 654 | 45214302 | 1925 E LEWIS AVE | 0.24 | Neighborhood Mixed-Use | NMX | 32.0 | 8 | Above Moderate | YES | | | 655 | 45206207 | 1906 E OLIVE AVE | 0.13 | Neighborhood Mixed-Use | NMX | 32.0 | 4 | Above Moderate | YES | | | 656 | 45129633 | 1150 N ABBY ST | 0.27 | Neighborhood Mixed-Use | NMX | 32.0 | 9 | Above Moderate | YES | | | 660 | 45205308 | 1556 E OLIVE AVE | 0.17 | Commercial - Main Street | CMS | 24.00 | 4 | Above Moderate | NO | | | 661 | 45205111 | 1047 N DELPHIA AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 662 | 45221112 | 837 N GLENN AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 663 | 45221112 | 604 N SAN PABLO AVE | 0.60 | Residential - Medium Density | RS-5 | 8.4 | 5 | Above Moderate | YES | | | 664 | 45905119S | | 0.29 | Commercial - Main Street | CMS | 24.00 | 7 | Above Moderate | YES | | | 665 | 45228216 | | 0.19 | Commercial - Main Street | CMS | 24.00 | 4 | Above Moderate | YES | | | 666 | 45228221 | | 0.18 | Commercial - Main Street | CMS | 24.00 | 4 | Above Moderate | YES | | | 667 | 45220707 | 712 N VAN NESS AVE | 0.18 | Commercial - Main Street | CMS | 24.00 | 4 | Above Moderate | YES | | | 668 | 45227304 | 510 N YOSEMITE AVE | 0.27 | Commercial - Main Street | CMS | 24.00 | 6 | Above Moderate | NO | FEMA 100-year flood zone | | 669 | 45219411 | 821 E THOMAS AVE | 0.10 | Commercial - Main Street | CMS | 24.00 | 2 | Above Moderate | NO | FEMA 100-year flood zone | | 670 | 45211212 | | 0.14 | Commercial - Main Street | CMS | 24.00 | 3 | Above Moderate | YES | | | 674 | 45127111 | 1201 N VAN NESS AVE | 0.21 | Commercial - Main Street | CMS | 24.00 | 5 | Above Moderate | NO | | | 678 | 45112220 | 1458 N VAN NESS AVE | 0.14 | Commercial - Main Street | CMS | 24.00 | 3 | Above Moderate | NO | | | 679 | 44405201 | | 0.73 | Residential - Medium Density | RS-5 | 8.4 | 6 | Above Moderate | YES | | | 680 | 44405202 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 681 | 45103107 | 1541 N FERGER AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 682 | 45125111 | 315 E OLIVE AVE | 0.47 | Commercial - Main Street | CMS | 24.00 | 11 | Above Moderate | YES | | | 683 | 45219113 | 712 N ECHO AVE | 0.34 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 684 | 45226411 | 563 E BELMONT AVE | 0.40 | Commercial - Main Street | CMS | 24.00 | 10 | Above Moderate | YES | | | 685 | 45904101 | 706 E BELMONT AVE | 0.47 | Commercial - Main Street | CMS | 24.00 | 11 | Above Moderate | YES | | | 687 | 45912217 | 303 N BROADWAY | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 688 | 45912118 | 341 N ECHO AVE | 0.43 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | YES | FEMA 100-year flood zone | | 689 | 45911211 | 255 N FERGER AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 690 | 45226206 | 605 N WILSON AVE | 0.18 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 691 | 45027403 | 631 N PALM AVE | 0.24 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 704 | 45020319 | 111 E ALHAMBRA AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 706 | 45020104 | 24 E OLIVE AVE | 0.15 | Commercial - Main Street | CMS | 24.00 | 4 | Above Moderate | NO | | | 707 | 45022201 | 994 N ADOLINE AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 708 | 45021106T | 929 N FRUIT AVE | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 714 | 45015401T | 761 W HAMMOND AVE | 0.16 | Residential - High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 715 | 44411307 | 745 W CAMBRIDGE AVE | 0.45 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | YES | | | 716 | 43526422 | 1022 W SHIELDS AVE | 0.16 | Residential - High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 717 | 44201002U | | 1.73 | Residential - High Density | RM-1 | 13.6 | 23 | Moderate | YES | | | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 718 | 43308001 | 3282 N MARKS AVE | 0.84 | Residential - Medium Density | RS-5 | 8.4 | 7 | Above Moderate | YES | | | 719 | 43321033 | 3312 N MARKS AVE | 1.21 | Residential - Medium Density | RS-5 | 8.4 | 10 | Above Moderate | YES | | | 720 | 43321014 | 2510 W GARLAND AVE | 0.37 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 721 | 43321008 | 2535 W DAKOTA AVE | 0.25 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 722 | 43322006 | 2317 W DAKOTA AVE | 1.00 | Residential - Medium Density | RS-5 | 8.4 | 8 | Above Moderate | YES | | | 724 | 43323006 | 1785 W DAKOTA AVE | 0.58 | Residential - Medium High Density | RM-1 | 13.6 | 8 | Moderate | YES | | | 725 | 43402081 | 1101 W ASHLAN AVE | 6.00 | Residential - Medium High Density | RM-1 | 13.6 | 82 | Moderate | YES | | | 726 | 43402057 | 505 W ASHLAN AVE | 0.70 | Residential - Medium High Density | RM-1 | 13.6 | 10 | Moderate | YES | | | 727 | 42628102 | 727 W SWIFT AVE | 0.38 | Residential - Medium Low Density | RS-4 | 4.8 | 2 | Above Moderate | YES | | | 728 | 42504136 | 4942 N FRUIT AVE | 0.34 | Residential - Medium High Density | RM-1 | 13.6 | 5 | Moderate | YES | | | 729 | 42406201 | 2171 W SHAW AVE | 0.52 | Corridor - Center Mixed Use | CMX | 37.50 | 19 | Lower | YES | | | 730 | 42450126 | 4505 N EMERSON AVE | 3.66 | Residential - Medium High Density | RM-1 | 13.6 | 50 | Moderate | YES | | | 731 | 41533131 | | 0.35 | Residential - Medium Low Density | RS-4 | 4.8 | 2 | Above Moderate | YES | | | 732 | 42464010 | 3441 W SHAW AVE | 0.25 | Regional Mixed-Use | RMX | 45.0 | 11 | Above Moderate | YES | | | 733 | 42466004 | 3471 W SHAW AVE | 0.22 | Regional Mixed-Use | RMX | 45.0 | 10 | Above Moderate | YES | | | 734 | 42466007 | 3421 W SHAW AVE | 0.24 | Regional Mixed-Use | RMX | 45.0 | 11 | Above Moderate | YES | | | 735 | 42466005 | 3425 W SHAW AVE | 0.22 | Regional Mixed-Use | RMX | 45.0 | 10 | Above Moderate | YES | | | 736 | 42466002 | 3477 W SHAW AVE | 0.24 | Regional Mixed-Use | RMX | 45.0 | 11 | Above Moderate | YES | | | 740 | 41504440 | | 0.85 | Regional Mixed-Use | RMX | 45.0 | 38 | Lower | YES | | | 742 | 41502817U | | 6.98 | Residential - Medium High Density | RM-1 | 13.6 | 95 | Moderate | YES | | | 743 | 41568539 | 5616 N BRAWLEY AVE | 0.47 | Residential - Medium High Density | RM-1 | 13.6 | 6 | Moderate | YES | | | 744 | 41568527 | | 0.34 | Residential - Medium High Density | RM-1 | 13.6 | 5 | Moderate | YES | | | 745 | 40613314S | 6049 N SAN PEDRO AVE | 0.13 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 747 | 40642126S | 6712 N SELLAND AVE | 0.28 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 748 | 50113410S | 3608 W FIR AVE | 0.33 | Residential - Medium Low Density | RS-4 | 4.8 | 2 | Above Moderate | YES | | | 749 | 50727722 | 6430 N PIMA AVE | 0.27 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 750 | 50727719 | 6435 N PIMA AVE | 0.27 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 751 | 50727718 | 6413 N PIMA AVE | 0.28 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 752 | 50922001S | 5463 N GATES AVE | 0.21 | Residential - Medium High Density | RM-1 | 13.6 | 3 | Moderate | YES | | | 754 | 50812013S | 5123 W MISSION AVE | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 755 | 50812010S | 5179 W MISSION AVE | 0.42 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | YES | | | 756 | 50812006S | 5227 W MISSION AVE | 0.40 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 757 | 50808233S | 5130 N BARCUS AVE | 0.22 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 759 | 50808209S | 5226 N MARKET ST | 0.85 | Residential - Medium Density | RS-5 | 8.4 | 7 | Above Moderate | YES | | | 760 | 50807011S | 5160 N POLK AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 761 | 50810121S | 5293 N MARKET ST | 0.43 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | YES | | | 767 | 50613004S | 6507 N POLK AVE | 3.91 | Residential - Urban Neighborhood | RM-2 | 18.0 | 70 | Lower | NO | | SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 768 | 50613039 | | | | | | 0 | Moderate | | | | | 50613039 | Near W Sierra Ave & N Vista Ave | 10.48 | Residential - Urban Neighborhood | RM-2 | 18.0 | 0 | Above Moderate | YES | | | | 50613039 | | | | | | 189 | Lower | | | | 769 | 50613039 | | 5.05 | Residential - Urban Neighborhood | RM-2 | 18.0 | 91 | Lower | NO | | | 775 | 50234301S | 7710 N DANTE AVE | 0.38 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 776 | 50206210 | 4996 W PINEDALE AVE | 0.22 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 777 | 50302011 | | 11.20 | Residential - Medium High Density | RM-1 | 13.6 | 152 | Moderate | YES | | | 780 | 50409209 | N Hayes Ave near W Herndon Ave | 13.10 | Residential - Urban Neighborhood | RM-2 | 18.0 | 0 | Moderate | | | | | | | | | | | 0 | Above Moderate | YES | | | | | | | | | | 236 | Lower | | | | 781 | 50409220 | | 5.30 | Residential - Urban Neighborhood | RM-2 | 18.0 | 95 | Lower | YES | | | 785 | 50409253S | | 5.43 | Commercial - Regional | CR | 40.00 | 217 | Lower | YES | | | 786 | 50412301S | | 0.17 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 787 | 50412309S | 7110 N EVEREST AVE | 0.17 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 788 | 50412110S | 7010 N VAN BUREN AVE | 0.17 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 789 | 50412106S | 7050 N VAN BUREN AVE | 0.17 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 800 | 50411201 | 7075 N VAN BUREN AVE | 0.17 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 801 | 50410113 | 6980 N WEBER AVE | 0.17 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 802 | 50410111 | 6968 N WEBER AVE | 0.26 | Residential - Medium High Density | RM-1 | 13.6 | 4 | Moderate | YES | | | 803 | 50410404 | 6975 N WEBER AVE | 0.17 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 804 | 50410410 | 6983 N WEBER AVE | 0.13 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | NO | | | 805 | 50410416 | | 0.21 | Residential - Medium High Density | RM-1 | 13.6 | 3 | Moderate | NO | | | 806 | 50408152S | | 4.73 | Residential - Medium High Density | RM-1 | 13.6 | 64 | Moderate | NO | | | 807 | 50525003 | 7250 W MORRIS AVE | 0.36 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 809 | 50522058 | | 0.71 | Residential - Medium Low Density | RS-4 | 4.8 | 3 | Above Moderate | YES | | | 810 | 50522059 | | 0.64 | Residential - Medium Low Density | RS-4 | 4.8 | 3 | Above Moderate | YES | | | 811 | 50507042S | | 1.15 | Residential - Medium Density | RS-5 | 8.4 | 10 | Above Moderate | YES | | | 812 | 50507005S | | 1.14 | Residential - Medium Density | RS-5 | 8.4 | 10 | Above Moderate | YES | | | 813 | 50530320S | 7420 W SAN RAMON AVE | 0.22 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 814 | 50530319S | 7436 W SAN RAMON AVE | 0.25 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 815 | 50530318S | 7452 W SAN RAMON AVE | 0.32 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 816 | 50506008 | 6785 W BARSTOW FR | 13.26 | Residential - Medium High Density | RM-1 | 13.6 | 90 | Moderate | YES | | | 817 | 50506008 | 6785 W BARSTOW FR | 16.98 | Corridor - Center Mixed Use | CMX | 37.50 | 115 | Moderate | | | | | | | | | | | 38 | Above Moderate | YES | | | | | | | | | | 38 | Lower | | | | 818 | 50506008 | 6785 W BARSTOW FR | 7.80 | Corridor - Center Mixed Use | CMX | 37.50 | 53 | Moderate | | | | | | | | | | | 18 | Above Moderate | YES | | | | | | | | | | 18 | Lower | | | | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 819 | 50506074 50506066 | W Scott Ave near W Barstow Ave | 24.05 | Residential - Urban Neighborhood | RM-2 | 18.0 | 130 | Moderate | YES | | | | | | | | | | 43 | Above Moderate | | | | | | | | | | | 43 | Lower | | | | 820 | 50506070 | End of N Ensanada Ave | 0.45 | Residential - Urban Neighborhood | RM-2 | 18.0 | 2 | Moderate | YES | | | | | | | | | | 1 | Above Moderate | | | | | | | | | | | 1 | Lower | | | | 826 | 50506024 | 6130 W SHAW AVE | 3.30 | Corridor - Center Mixed Use | CMX | 37.50 | 0 | Moderate | YES | | | | | | | | | | 0 | Above Moderate | | | | | | | | | | | 37 | Lower | | | | 827 | 50506068 | 6010 W SHAW AVE | 5.15 | Corridor - Center Mixed Use | CMX | 37.50 | 0 | Moderate | YES | | | | | | | | | | 0 | Above Moderate | | | | | | | | | | | 58 | Lower | | | | 828 | 50506067 | End of W Keats Ave | 9.20 | Corridor - Center Mixed Use | CMX | 37.50 | 0 | Moderate | YES | | | | | | | | | | 0 | Above Moderate | | | | | | | | | | | 103 | Lower | | | | 830 | 50803025 | N Island Waterpark Dr at canal | 13.27 | Regional Mixed-Use | RMX | 45.0 | 107 | Moderate | YES | | | | | | | | | | 36 | Above Moderate | | | | | | | | | | | 36 | Lower | | | | 831 | 50803004 | 5708 W SHAW AVE | 5.56 | Regional Mixed-Use | RMX | 45.0 | 0 | Moderate | YES | | | | | | | | | | 0 | Above Moderate | | | | | | | | | | | 75 | Lower | | | | 832 | 51024012 | 5373 W FAIRMONT AVE | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 833 | 51024011 | 5383 W FAIRMONT AVE | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 834 | 51013033S | | 0.12 | Residential - Urban Neighborhood | RM-2 | 18.0 | 2 | Above Moderate | NO | | | 835 | 51051322 | 5431 W ACACIA AVE | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 836 | 51051320 | 5447 W ACACIA AVE | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 837 | 51051318 | 5463 W ACACIA AVE | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 838 | 51011034 | 5703 W SHAW AVE | 1.51 | Residential - Urban Neighborhood | | 18.0 | 27 | Lower | YES | | | | 51011029 | 5705 W SHAW AVE | | | | | | | | | | | 51011030 | 5707 W SHAW AVE | | | | | | | | | | | 51011031 | | | | | | | | | | | | 51004011 | 5711 W SHAW AVE | | | | | | | | | | 839 | 51011037 | 5753 W SHAW AVE | 0.14 | Residential - Urban Neighborhood | RM-2 | 18.0 | 3 | Above Moderate | YES | | | 840 | 51011025 | 5751 W SHAW AVE | 0.23 | Residential - Urban Neighborhood | RM-2 | 18.0 | 4 | Above Moderate | YES | | | 841 | 51011024 | 5747 W SHAW AVE | 0.27 | Residential - Urban Neighborhood | RM-2 | 18.0 | 5 | Above Moderate | YES | | | 842 | 51004013 | 5729 W SHAW AVE | 0.50 | Residential - Urban Neighborhood | RM-2 | 18.0 | 9 | Lower | YES | | | 843 | 51004007 | 5727 W SHAW AVE | 0.25 | Residential - Urban Neighborhood | RM-2 | 18.0 | 5 | Above Moderate | YES | | | 844 | 51004009 | 5715 W SHAW AVE | 0.37 | Residential - Urban Neighborhood | RM-2 | 18.0 | 7 | Above Moderate | YES | | SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 845 | 51004008 | 5717 W SHAW AVE | 0.49 | Residential - Urban Neighborhood | RM-2 | 18.0 | 9 | Above Moderate | YES | | | 846 | 51011015 | 5811 W SHAW AVE | 0.08 | Residential - Urban Neighborhood | RM-2 | 18.0 | 1 | Above Moderate | NO | | | 847 | 51011009 | 5863 W SHAW AVE | 0.13 | Residential - Urban Neighborhood | RM-2 | 18.0 | 2 | Above Moderate | YES | | | 848 | 51011008 | 5869 W SHAW AVE | 1.27 | Residential - Urban Neighborhood | RM-2 | 18.0 | 23 | Lower | YES | | | 849 | 51011006 | 5871 W SHAW AVE | 3.37 | Residential - Urban Neighborhood | RM-2 | 18.0 | 52 | Lower | YES | | | | 51011032 | 5861 W SHAW AVE | | | | | | | | | | | 51011033 | | | | | | | | | | | | 51011035 | 5875 W SHAW AVE | | | | | | | | | | | 51011005 | 5873 W SHAW AVE | | | | | | | | | | 850 | 51004038 | | 1.62 | Residential - Urban Neighborhood | RM-2 | 18.0 | 29 | Lower | NO | | | 851 | 510540X1 | | 4.99 | Residential - Urban Neighborhood | RM-2 | 18.0 | 90 | Lower | NO | | | | 51054009 | | | | | | | | | | | | 51054013 | | | | | | | | | | | | 51054013 | | | | | | | | | | | | 51054012 | | | | | | | | | | | | 51054008 | | | | | | | | | | | | 51054018 | | | | | | | | | | | | 510540X2 | | | | | | | | | | | | 51054016 | | | | | | | | | | | | 51054010 | | | | | | | | | | | | 51054002 | | | | | | | | | | | | 51054007 | | | | | | | | | | | | 51054003 | | | | | | | | | | | | 51054011 | | | | | | | | | | | | 51054015 | | | | | | | | | | | | 51054001 | | | | | | | | | | | 855 | 51203103 | | 1.67 | Regional Mixed-Use | RMX | 45.0 | 75 | Lower | YES | | | 856 | 51203102 | | 1.67 | Regional Mixed-Use | RMX | 45.0 | 75 | Lower | YES | | | 857 | 51209402 | 4715 N BRYAN AVE | 0.39 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 858 | 51002201S | | 4.76 | Residential - Urban Neighborhood | RM-2 | 18.0 | 86 | Lower | YES | | | 859 | 51002244 | | 0.88 | Residential - Medium Density | RS-5 | 8.4 | 7 | Above Moderate | YES | | | 987 | 51135201ST | | 0.26 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 988 | 51102301 | 5677 W DAKOTA AVE | 14.57 | Residential - Urban Neighborhood | RM-2 | 18.0 | 0 | Moderate | YES | | | | | | | | | | 0 | Above Moderate | | | | | | | | | | | 262 | Lower | | | | 989 | 51101107 | 5555 W ASHLAN AVE | 9.77 | Residential - Medium Density | RS-5 | 8.4 | 82 | Above Moderate | YES | | | 990 | 51107410 | 3916 N CONSTANCE AVE | 2.12 | Residential - Medium Low Density | RS-4 | 4.8 | 10 | Above Moderate | YES | | | 991 | 51121412 | 4794 W FLINT WAY | 12.33 | Residential - Medium Low Density | RS-4 | 4.8 | 59 | Above Moderate | YES | | | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 992 | 51117120 | | 4.94 | Residential - Medium Density | RS-5 | 8.4 | 42 | Above Moderate | YES | | | 993 | 51125002 | 3572 N BLYTHE AVE | 4.85 | Residential - Medium High Density | RM-1 | 13.6 | 66 | Moderate | YES | | | 994 | 51136324 | 3540 N BLYTHE AVE | 2.34 | Residential - Medium High Density | RM-1 | 13.6 | 32 | Moderate | YES | | | 995 | 51124033 | 3953 N PARKWAY DR | 9.47 | Residential - Medium High Density | RM-1 | 13.6 | 129 | Moderate | YES | | | 996 | 51124036 | | 1.94 | Residential - Medium High Density | RM-1 | 13.6 | 26 | Moderate | YES | | | 997 | 43305006 | 3714 W DAKOTA FR | 1.07 | Residential - Medium Density | RS-5 | 8.4 | 9 | Above Moderate | YES | | | 998 | 51103142S | | 15.38 | Residential - Medium Density | RS-5 | 8.4 | 129 | Above Moderate | YES | | | 999 | 51103160S | | 0.20 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | NO | | | 1000 | 43309024S | | 3.06 | Residential - Medium High Density | RM-1 | 13.6 | 42 | Moderate | YES | | | 1001 | 43303207 | | 7.26 | Residential - Medium High Density | RM-1 | 13.6 | 99 | Moderate | YES | | | 1002 | 43309021S | 3484 W SHIELDS AVE | 2.21 | Residential - Medium Density | RS-5 | 8.4 | 19 | Above Moderate | YES | | | 1003 | 44203007 | 3409 W SHIELDS AVE | 2.19 | Residential - Medium High Density | RM-1 | 13.6 | 30 | Moderate | YES | | | 1004 | 44204018 | 3375 W SHIELDS AVE | 2.20 | Residential - Medium Density | RS-5 | 8.4 | 18 | Above Moderate | YES | | | 1005 | 44204002 | | 9.70 | Residential - Medium Density | RS-5 | 8.4 | 81 | Above Moderate | YES | | | 1006 | 31230032 | 4176 W CORNELL AVE | 0.20 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 1007 | 31253503 | | 0.35 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1008 | 31254127 | 4377 W HARVARD AVE | 0.41 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1009 | 44206033 | 3508 W CLINTON AVE | 4.64 | Residential - Medium High Density | RM-2 | 18.0 | 83 | Lower | NO | | | 1010 | 31208226 | | 1.24 | Residential - Medium Density | RS-5 | 8.4 | 10 | Above Moderate | YES | | | 1011 | 31208224 | | 13.68 | Residential - Medium Density | RS-5 | 8.4 | 108 | Above Moderate | YES | | | 1012 | 31260424 | 4657 W UNIVERSITY AVE | 0.12 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1013 | 31260423 | 4665 W UNIVERSITY AVE | 0.11 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1014 | 31208136 | 2348 N CORNELIA AVE | 2.03 | Residential Low Density | RE | 0.1 | 1 | Above Moderate | YES | | | 1015 | 31265010S | 5545 W HAMMOND AVE | 0.18 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 1027 | 44202232 | | 3.89 | Residential - Medium Density | RS-5 | 8.4 | 33 | Above Moderate | YES | | | 1028 | 44207132 | | 2.07 | Residential - Medium Low Density | RS-4 | 4.8 | 10 | Above Moderate | YES | | | 1029 | 44209051 | 2827 W CLINTON AVE | 4.38 | Residential - Medium Density | RS-5 | 8.4 | 37 | Above Moderate | NO | | | 1030 | 44209050 | 2755 W CLINTON AVE | 0.61 | Residential - Medium Density | RS-5 | 8.4 | 5 | Above Moderate | YES | | | 1031 | 44209047 | | 0.51 | Neighborhood Mixed-Use | NMX | 32.0 | 16 | Lower | YES | | | 1034 | 44211120 | | 1.75 | Neighborhood Mixed-Use | NMX | 32.0 | 56 | Lower | YES | | | 1035 | 44902010 | | 8.88 | Residential - Low Density | RS-3 | 3.3 | 30 | Above Moderate | YES | | | 1036 | 44909033S | | 9.03 | Residential Medium High Density | RM-MH | 8.5 | 77 | Moderate | YES | | | 1037 | 44919209 | 2214 W HEDGES AVE | 0.47 | Residential - Low Density | RS-3 | 3.3 | 2 | Above Moderate | NO | | | 1038 | 44923128 | 1811 W HEDGES AVE | 1.17 | Neighborhood Mixed-Use | NMX | 32.0 | 37 | Lower | YES | | | 1039 | 44923127 | 1824 W OLIVE AVE | 1.26 | Neighborhood Mixed-Use | NMX | 32.0 | 40 | Lower | YES | | 1041 | 44926001 | 2035 W OLIVE AVE | 4.27 | Neighborhood Mixed-Use | NMX | 32.0 | 137 | Lower | YES | | | 1043 | 44931218 | | 0.23 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 1044 | 44926037 | 1028 N CRYSTAL AVE | 0.33 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1045 | 44931228 | 937 N CRYSTAL AVE | 0.44 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 1046 | 44932118 | | 0.85 | Neighborhood Mixed-Use | NMX | 32.0 | 27 | Lower | YES | | | 1055 | 44934104 | | 0.25 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 1056 | 44934110 | 549 N PARKVIEW DR | 0.24 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 1058 | 44934206 | 624 N PARKVIEW DR | 0.24 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | NO | | | 1059 | 44934202 | | 0.27 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 1060 | 44934203 | | 0.30 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 1061 | 45814108 | | 0.67 | Residential - Medium Density | RS-5 | 8.4 | 6 | Above Moderate | YES | | | 1062 | 45811207 | 1001 W BELMONT AVE | 0.09 | Neighborhood Mixed-Use | NMX | 32.0 | 3 | Above Moderate | NO | | | 1063 | 45811205 | 461 N DURANT WAY | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1065 | 45811402 | 450 N TEILMAN AVE | 3.51 | Neighborhood Mixed-Use | NMX | 32.0 | 112 | Lower | YES | | | 1066 | 45812119 | 719 W BELMONT AVE | 0.44 | Neighborhood Mixed-Use | NMX | 32.0 | 14 | Above Moderate | NO | | | 1067 | 45812106 | 443 N DELNO AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1068 | 45814415 | 823 W NAPA AVE | 0.28 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1069 | 45813117 | 327 BELMONT AVE | 4.05 | Residential - Medium Density | RS-5 | 8.4 | 34 | Above Moderate | NO | | | 1070 | 45813204 | 459 N WESLEY AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1071 | 45816103 | | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1072 | 45816114 | | 0.24 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1073 | 45816106 | 343 W FRANKLIN AVE | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1074 | 45816107 | | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1075 | 45816112 | 355 N ARTHUR AVE | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1085 | 46402024 | 2106 W KEARNEY BLVD | 2.00 | Residential - Medium Low Density | RS-4 | 4.8 | 10 | Above Moderate | YES | | | 1086 | 45808059 | 2540 W WHITES BRIDGE AVE | 3.30 | Commercial - Regional | CR | 40.00 | 112 | Lower | NO | | | 1087 | 45808055 | 2510 W WHITES BRIDGE AVE | 3.32 | Commercial - Regional | CR | 40.00 | 113 | Lower | NO | | | 1088 | 45808027 | 2280 W WHITES BRIDGE AVE | 8.11 | Commercial - Regional | CR | 40.00 | 324 | Lower | NO | | | 1089 | 45808060 | 2137 W EL DORADO ST | 1.44 | Commercial - Regional | CR | 40.00 | 58 | Lower | NO | | | 1090 | 45808033 | 618 S HUGHES AVE | 1.91 | Commercial - Regional | CR | 40.00 | 76 | Lower | NO | | | 1091 | 46404007 | 733 S HUGHES AVE | 8.91 | Residential - Medium Density | RS-5 | 8.4 | 75 | Above Moderate | YES | | | 1092 | 46404054 | 770 S SEQUOIA DR | 2.58 | Residential - Medium Density | RS-5 | 8.4 | 22 | Above Moderate | YES | | | 1093 | 46404039 | 1849 W WHITES BRIDGE AVE | 0.74 | Residential - Medium Density | RS-5 | 8.4 | 6 | Above Moderate | YES | | | 1095 | 46404042 | | 1.85 | Residential - Medium Low Density | RS-4 | 4.8 | 9 | Above Moderate | YES | | | 1096 | 46404059T | | 0.98 | Residential - Medium Low Density | RS-4 | 4.8 | 5 | Above Moderate | YES | | | 1097 | 46404073T | | 2.32 | Residential - Medium Low Density | RS-4 | 4.8 | 11 | Above Moderate | YES | | | 1098 | 46431210T | 1108 S ROEDING DR | 0.18 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 1099 | 46431211T | 1122 S ROEDING DR | 0.23 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 1100 | 46431212T | 1136 S ROEDING DR | 0.24 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 1101 | 46431213T | 1150 S WEST AVE | 0.46 | Residential - Medium Low Density | RS-4 | 4.8 | 2 | Above Moderate | YES | | | 1102 | 46431214T | 1164 S WEST AVE | 0.39 | Residential - Medium Low Density | RS-4 | 4.8 | 2 | Above Moderate | YES | | | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1103 | 46427237T | 1212 S WEST AVE | 1.05 | Residential - Medium Low Density | RS-4 | 4.8 | 5 | Above Moderate | YES | | | 1104 | 46427238 | | 0.80 | Residential - Medium Low Density | RS-4 | 4.8 | 4 | Above Moderate | YES | | | 1105 | 46427238 | | 1.10 | Residential - Low Density | RS-3 | 3.3 | 4 | Above Moderate | YES | | | 1113 | 46407009 | 1705 W KEARNEY BLVD | 2.76 | Residential - Low Density | RS-2 | 2.0 | 6 | Above Moderate | NO | | | 1114 | 46407009 | 1705 W KEARNEY BLVD | 5.29 | Residential - Medium Density | RS-5 | 8.4 | 44 | Above Moderate | NO | | | 1115 | 46407005 | 1604 S CRYSTAL AVE | 4.53 | Residential - Medium Density | RS-5 | 8.4 | 38 | Above Moderate | NO | | | 1116 | 46426042 | | 0.24 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 1117 | 46426040 | | 0.23 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 1120 | 46430029 | | 0.73 | Residential - Medium Low Density | RS-4 | 4.8 | 4 | Above Moderate | YES | | | 1121 | 46430020 | | 0.13 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 1122 | 46430022 | | 0.39 | Residential - Medium Low Density | RS-4 | 4.8 | 2 | Above Moderate | YES | | | 1123 | 46410215 | | 1.25 | Corridor - Center Mixed Use | CMX | 37.50 | 47 | Lower | YES | | | 1124 | 46410208T | 2022 S WEST AVE | 0.44 | Corridor - Center Mixed Use | CMX | 37.50 | 10 | Above Moderate | YES | | | 1125 | 46419207 | | 0.18 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1126 | 46417210 | 714 W VALENCIA AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1127 | 46420011 | | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1129 | 47704075ST | 901 W ATCHISON CT | 1.19 | Residential - Urban Neighborhood | RM-2 | 18.0 | 21 | Lower | YES | | | 1130 | 47704075ST | 901 W ATCHISON CT | 4.91 | Residential - Urban Neighborhood | RM-2 | 18.0 | 88 | Lower | YES | | | 1131 | 47704073T | 555 W CALIFORNIA AVE | 8.06 | Corridor - Center Mixed Use | CMX | 37.50 | 302 | Lower | YES | | | 1132 | 47704052 | | 0.36 | Corridor - Center Mixed Use | CMX | 37.50 | 14 | Above Moderate | YES | | | 1134 | 47704049 | | 1.80 | Corridor - Center Mixed Use | CMX | 37.50 | 68 | Lower | YES | | | 1135 | 47711109ST | 2141 S FRUIT AVE | 3.59 | Corridor - Center Mixed Use | CMX | 37.50 | 154 | Lower | YES | Brownfield | | | 47711110T | | 0.52 | | | | | | | | | 1136 | 47711303 | 333 W CHURCH RD | 0.85 | Corridor - Center Mixed Use | CMX | 37.50 | 32 | Lower | YES | | | 1137 | 47711302 | 403 W CHURCH RD | 0.40 | Corridor - Center Mixed Use | CMX | 37.50 | 15 | Above Moderate | YES | | | 1138 | 47711301 | 433 W CHURCH RD | 0.79 | Corridor - Center Mixed Use | CMX | 37.50 | 30 | Lower | YES | | | 1139 | 47713101 | 2233 S FRUIT AVE | 0.65 | Corridor - Center Mixed Use | CMX | 37.50 | 24 | Lower | YES | | | 1140 | 47713102 | | 0.83 | Corridor - Center Mixed Use | CMX | 37.50 | 31 | Lower | YES | | | 1141 | 47713112 | | 0.18 | Corridor - Center Mixed Use | CMX | 37.50 | 7 | Above Moderate | YES | | | 1142 | 47713104 | 403 W LORENA AVE | 0.19 | Corridor - Center Mixed Use | CMX | 37.50 | 7 | Above Moderate | YES | | | 1143 | 47713105 | 335 W LORENA AVE | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1144 | 47711207 | 130 W ATCHISON ST | 0.62 | Residential - Medium Density | RS-5 | 8.4 | 5 | Above Moderate | YES | | | 1145 | 47711405 | 215 W ATCHISON ST | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1146 | 47711411 | 2152 S THORNE AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1147 | 47713418 | 106 W FLORENCE AVE | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1148 | 47713419 | 102 W FLORENCE AVE | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1149 | 47712101 | | 0.28 | Neighborhood Mixed-Use | NMX | 32.0 | 9 | Above Moderate | YES | | | 1150 | 47712102 | | 0.36 | Neighborhood Mixed-Use | NMX | 32.0 | 11 | Above Moderate | YES | | SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1151 | 47712113T | 33 E ATCHISON ST | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1152 | 47712104 | 64 E CALIFORNIA AVE | 0.18 | Neighborhood Mixed-Use | NMX | 32.0 | 6 | Above Moderate | YES | | | 1153 | 47712105T | | 0.18 | Neighborhood Mixed-Use | NMX | 32.0 | 12 | Above Moderate | YES | | | | 47712106T | | 0.19 | | | | | | | | | 1155 | 477121306 | 64 E ATCHISON ST | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1156 | 47712313 | 45 E LORENA AVE | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1157 | 47714102 | | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1158 | 47714116 | | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1163 | 47714534 | 50 E GEARY ST | 0.42 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | YES | | | 1167 | 47712436 | 122 E CALIFORNIA AVE | 0.65 | Neighborhood Mixed-Use | NMX | 32.0 | 21 | Lower | YES | | | 1168 | 47716116 | 46 E FLORENCE AVE | 3.40 | Residential - Low Density | RS-3 | 3.3 | 11 | Above Moderate | NO | | | 1169 | 47716111 | | 0.36 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 1170 | 47718101 | 47 E CHURCH AVE | 0.38 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 1171 | 47718102 | | 0.20 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 1172 | 47718103 | 43 E CHURCH AVE | 0.20 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 1173 | 47718104 | | 0.20 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 1174 | 47718105S | 136 E CHURCH AVE | 0.21 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 1175 | 47718106 | | 0.31 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 1176 | 47718107 | | 0.41 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 1177 | 47718112 | 2365 S THORNE AVE | 0.15 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 1178 | 47706003 | 65 E CHURCH AVE | 9.53 | Residential - Low Density | RS-3 | 3.3 | 32 | Above Moderate | YES | | | 1180 | 47718202 | 2364 S WALNUT AVE | 0.41 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1181 | 47718205 | 2380 S WALNUT AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1182 | 47718206 | 2378 S WALNUT AVE | 0.12 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1183 | 47718217 | 115 E CHURCH AVE | 0.47 | Residential - Low Density | RS-3 | 3.3 | 2 | Above Moderate | YES | | | 1184 | 47718207 | 2382 S WALNUT AVE | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1194 | 47719102S | 231 W GROVE AVE | 0.37 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1195 | 47719207S | | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1196 | 47719208S | 11 E BYRD AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1197 | 47719205 | 25 E BYRD AVE | 0.30 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1198 | 47719403 | 40 E BYRD AVE | 0.31 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1199 | 47719401 | 10 E BYRD AVE | 0.30 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1200 | 47719310 | 248 W KAVILAND AVE | 0.36 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1201 | 47721115 | 253 W KAVILAND AVE | 0.18 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1202 | 47721109 | 234 W GARRETT AVE | 0.36 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1203 | 47721204 | 37 E GARRETT AVE | 0.31 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1204 | 47722259 | | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1206 | 47722254 | | 0.22 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1207 | 47722271 | 265 E JENSEN AVE | 0.28 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1208 | 47722103 | 130 E KAVILAND AVE | 0.23 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1209 | 47720052 | 182 E BYRD AVE | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1210 | 47720015 | 2520 S WALNUT AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1211 | 47720011 | | 0.18 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1212 | 47915103 | 330 E GROVE AVE | 0.18 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1213 | 47915112 | 357 E BYRD AVE | 0.36 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1214 | 47915117 | 341 E BYRD AVE | 0.18 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1215 | 47915204 | 370 E BYRD AVE | 0.18 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1216 | 47915217 | 410 E BYRD AVE | 0.37 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1217 | 47915221 | | 0.18 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1218 | 47919119 | 408 E KAVILAND AVE | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1219 | 47919113 | | 0.36 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | NO | | | 1220 | 47919209 | | 0.39 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1221 | 47904032 | 756 E JENSEN AVE | 1.18 | Commercial - Regional | CR | 40.00 | 47 | Lower | YES | | | 1229 | 32813102 | 2958 S NEWMAN AVE | 0.07 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 1230 | 32813104 | 2962 S NEWMAN AVE | 0.15 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 1231 | 32813110 | 2980 S NEWMAN AVE | 0.15 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 1232 | 32813128 | | 0.52 | Residential - Medium Low Density | RS-4 | 4.8 | 2 | Above Moderate | YES | | | 1233 | 32813222 | 2953 S NEWMAN AVE | 0.14 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 1234 | 32813221 | 2957 S NEWMAN AVE | 0.07 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 1235 | 32813204 | 2962 S HARDT AVE | 0.15 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 1236 | 32813205 | 2968 S HARDT AVE | 0.15 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 1237 | 32813214 | 2981 S NEWMAN AVE | 0.12 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 1238 | 32813213 | 2987 S NEWMAN AVE | 0.17 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 1239 | 32813226 | 2993 S NEWMAN AVE | 0.29 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 1240 | 32813314 | 2955 S HARDT AVE | 0.22 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 1241 | 32813313 | 2959 S HARDT AVE | 0.15 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 1242 | 32813303 | 2972 S WALNUT AVE | 0.15 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 1243 | 32813304 | 2978 S WALNUT AVE | 0.15 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 1244 | 32813310 | 2973 S HARDT ST | 0.07 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 1245 | 32818110 | 739 E SAMSON AVE | 0.46 | Residential - Medium Low Density | RS-4 | 4.8 | 2 | Above Moderate | YES | | | 1246 | 32818108 | 739 E SAMSON AVE | 0.46 | Residential - Medium Low Density | RS-4 | 4.8 | 2 | Above Moderate | YES | | | 1247 | 32818111 | 2908 S MARTIN LUTHER KING JR BLVD | 3.19 | Residential - Medium Low Density | RS-4 | 4.8 | 15 | Above Moderate | YES | | | 1248 | 32818101 | 2902 S MARTIN LUTHER KING JR BLVD | 0.31 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 1249 | 32816118 | | 0.19 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1250 | 32816111 | 837 E HARDY AVE | 0.19 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 1251 | 32816310 | 2990 S MARTIN LUTHER KING JR BLVD | 0.14 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 1252 | 32818203 | 2918 S WELLER ST | 0.24 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1253 | 32818216 | 2927 S MARTIN LUTHER KIN JR BLVD | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1254 | 32818506 | 1030 E CHESTER AVE | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1255 | 32817201 | | 0.27 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1256 | 32817105 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1257 | 32817127 | | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1258 | 32817208 | | 0.22 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1259 | 32916106 | | 0.34 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1260 | 32916124 | 348 W ALMY AVE | 0.50 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | YES | | | 1261 | 32916123 | 338 W ALMY AVE | 0.99 | Residential - Medium Density | RS-5 | 8.4 | 8 | Above Moderate | YES | | | 1262 | 32916122 | 304 W ALMY AVE | 0.47 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | | | | 1263 | 32916121 | | 0.40 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1264 | 32916143 | | 0.48 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | YES | | | 1265 | 32916118 | | 0.35 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1266 | 32916201 | 3078 S FIG AVE | 0.34 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1267 | 32916222 | 379 W ALMY AVE | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1268 | 32920038 | 276 W ROY AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1269 | 32817309 | 2985 S CLARA AVE | 0.39 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | NO | | | 1270 | 32815017 | 32817311 | | 0.11 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1271 | 32815021 | | 0.49 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | YES | | | 1272 | 32815022 | | 0.73 | Residential - Medium Density | RS-5 | 8.4 | 6 | Above Moderate | NO | | | 1273 | 32815012 | 92 W NORTH AVE | 0.94 | Residential - Medium Density | RS-5 | 8.4 | 8 | Above Moderate | NO | | | 1274 | 32815043 | | 0.68 | Neighborhood Mixed-Use | NMX | 32.0 | 22 | Lower | NO | | | 1277 | 47904014 | | 5.27 | Residential - Medium Density | RS-5 | 8.4 | 44 | Above Moderate | YES | | | 1278 | 47927001 | 1309 E ANNADALE AVE | 4.78 | Residential - Medium Density | RS-5 | 8.4 | 40 | Above Moderate | YES | | | 1280 | 47904026 | | 3.37 | Residential - Medium Density | RS-5 | 8.4 | 24 | Above Moderate | YES | | | 1281 | 47923123 | | 0.25 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1282 | 47916412 | 1245 E KAVILAND AVE | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1283 | 47916322 | | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1284 | 47902052 | | 5.12 | Residential - Medium Density | RS-5 | 8.4 | 43 | Above Moderate | YES | | | 1285 | 47902035 | 2582 S ELM AVE | 2.36 | Corridor - Center Mixed Use | CMX | 37.50 | 88 | Lower | YES | | | 1286 | 47902036 | | 2.44 | Corridor - Center Mixed Use | CMX | 37.50 | 5 | Above Moderate | YES | | | | 47921109 | | | | | | 86 | Lower | NO | | | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1287 | 47902033 | 2512 S ELM AVE | 0.41 | Corridor - Center Mixed Use | CMX | 37.50 | 26 | Above Moderate | YES | | | | 47921110 | 2579 S ELM AVE | 0.28 | | | | | | | | | 1290 | 47917115 | | 0.14 | Corridor - Center Mixed Use | CMX | 37.50 | 5 | Above Moderate | NO | | | 1292 | 47921514 | 2015 E JENSEN AVE | 0.74 | Residential - Medium Density | RS-5 | 8.4 | 6 | Above Moderate | YES | | | 1294 | 47912116 | | 0.14 | Corridor - Center Mixed Use | CMX | 37.50 | 5 | Above Moderate | NO | | | 1295 | 47912120 | | 0.14 | Corridor - Center Mixed Use | CMX | 37.50 | 5 | Above Moderate | NO | | | 1296 | 47912117 | | 0.14 | Corridor - Center Mixed Use | CMX | 37.50 | 5 | Above Moderate | NO | | | 1297 | 47909403 | | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1298 | 47902049 | | 18.87 | Residential - Medium Density | RS-5 | 8.4 | 159 | Above Moderate | YES | | | 1299 | 47811328 | | 0.42 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | YES | | | 1300 | 47817312 | | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1301 | 47818109 | 2328 S EUNICE AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1302 | 47818201 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1303 | 47818237 | 2317 S EUNICE AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1304 | 47818236 | 2321 S EUNICE AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1305 | 47818202 | | 0.26 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1306 | 47818306 | | 0.35 | Neighborhood Mixed-Use | NMX | 32.0 | 11 | Above Moderate | YES | | | 1307 | 47818312 | | 1.14 | Residential - Medium Density | RS-5 | 8.4 | 10 | Above Moderate | YES | | | 1308 | 47818317 | 2346 S ELM AVE | 2.36 | Neighborhood Mixed-Use | NMX | 32.0 | 76 | Lower | YES | | | 1309 | 47825402 | 2356 S ELM AVE | 0.50 | Neighborhood Mixed-Use | NMX | 32.0 | 16 | Lower | YES | | | 1310 | 47825313 | 2392 S GENEVA AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1311 | 47825405 | | 0.44 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | YES | | | 1312 | 47826135 | | 0.69 | Neighborhood Mixed-Use | NMX | 32.0 | 22 | Lower | YES | | | 1313 | 47819132 | 2345 S ELM AVE | 0.17 | Neighborhood Mixed-Use | NMX | 32.0 | 6 | Above Moderate | YES | | | 1314 | 47819120 | | 0.11 | Neighborhood Mixed-Use | NMX | 32.0 | 4 | Above Moderate | NO | | | 1315 | 47819124 | | 0.11 | Neighborhood Mixed-Use | NMX | 32.0 | 3 | Above Moderate | NO | | | 1316 | 47819122 | 2305 S ELM AVE | 0.59 | Neighborhood Mixed-Use | NMX | 32.0 | 19 | Lower | YES | | | 1317 | 47827428 | | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | FEMA 100-year flood zone | | 1318 | 47820326 | | 4.14 | Residential - Medium Density | RS-5 | 8.4 | 35 | Above Moderate | NO | FEMA 100-year flood zone | | 1319 | 47816105 | 2521 E FLORENCE AVE | 0.20 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1320 | 47816104 | 2291 S CHERRY AVE | 0.26 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | FEMA 100-year flood zone | | 1321 | 47816102 | 2261 S CHERRY AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | FEMA 100-year flood zone | | 1322 | 47816101 | | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | FEMA 100-year flood zone | | 1323 | 47815414 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | FEMA 100-year flood zone | | 1324 | 47815413 | | 0.27 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | FEMA 100-year flood zone | | 1325 | 47815308 | 2250 S NICHOLAS AVE | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1326 | 47815326 | | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1327 | 47815332 | 2301 E FLORENCE AVE | 0.30 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1328 | 47815228 | 2414 S ROSE AVE | 0.29 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1329 | 47809305 | 2167 S ROSE AVE | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1330 | 47809512 | 2038 E CALIFORNIA AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1331 | 47809513 | | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1332 | 47808323 | 2108 S LOTUS AVE | 0.22 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1333 | 46713417 | | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1334 | 46713401 | | 0.34 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | NO | | | 1335 | 46713414 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1336 | 46713611 | | 0.48 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | YES | | | 1337 | 46713513 | | 0.54 | Residential - Medium Density | RS-5 | 8.4 | 5 | Above Moderate | YES | | | 1338 | 46713509 | | 0.22 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | NO | | | 1339 | 46713303 | 245 F ST | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1340 | 46713202 | | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1341 | 47814106 | | 0.11 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1343 | 47813424 | 2226 S ELM AVE | 0.23 | Neighborhood Mixed-Use | NMX | 32.0 | 7 | Above Moderate | YES | | | 1344 | 47813406 | 2240 S ELM AVE | 0.19 | Neighborhood Mixed-Use | NMX | 32.0 | 6 | Above Moderate | YES | | | 1345 | 47813407 | | 0.38 | Neighborhood Mixed-Use | NMX | 32.0 | 12 | Above Moderate | YES | | | 1346 | 47807219 | 2186 S IVY AVE | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1347 | 46730154 | 1003 SANTA CLARA ST | 0.12 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1348 | 46730169 | 1031 SANTA CLARA ST | 0.10 | Neighborhood Mixed-Use | NMX | 32.0 | 3 | Above Moderate | NO | | | 1349 | 46717215 | 538 B ST | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1350 | 46717210 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1351 | 46717219 | | 0.26 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1352 | 46712510 | 504 C ST | 0.22 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1353 | 46712514 | 532 C ST | 0.27 | Neighborhood Mixed-Use | NMX | 32.0 | 9 | Above Moderate | YES | | | 1354 | 46716603 | 745 B ST | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1355 | 46716508 | 801 B ST | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1356 | 46711605 | 734 C ST | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1357 | 46711606 | 736 C ST | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1358 | 46711607 | 738 C ST | 0.09 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1359 | 46711501 | | 0.37 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1360 | 46711411 | | 0.30 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1361 | 46716101 | 1138 TULARE ST | 0.34 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1362 | 46716402 | 949 B ST | 0.34 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1363 | 46716404 | 929 B ST | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1364 | 46716406 | 913 B ST | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | APPENDIX 1E: CITY OF FRESNO | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | | 46724601T | 731 E CALIFORNIA AVE | 0.24 | Neighborhood Mixed-Use | NMX | 32.0 | 93 | Lower | NO | | | | 46724506T | 537 INYO ST | 0.18 | | | | | | YES | | | | 46724505T | 811 WATERMAN AVE | 0.09 | | | | | | NO | | | | 46724504T | 813 WATERMAN AVE | 0.09 | | | | | | NO | | | | 46724503T | | 0.17 | | | | | | NO | | | | 46724510T | 842 KLETTE AVE | | | | | | | | | | | 46724508T | | | | | | | | | | | 1365 | 46724512T | 864 KLETTE AVE | 1.33 | | | | | | YES | | | | 46724509T | | | | | | | | | | | | 46724511T | 854 KLETTE AVE | | | | | | | | | | | 46724507T | 661 E CALIFORNIA AVE | | | | | | | | | | | 46726203T | | | | | | | | | | | | 46726202T | 851 KLETTE AVE | 0.69 | | | | | | YES | | | | 46726201T | | | | | | | | | | | | 46726204T | 601 E CALIFORNIA AVE | 0.14 | | | | | | YES | | | 1380 | 46724416 | 514 TULARE ST | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1381 | 46723611 | 1020 WATERMAN AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1382 | 46723613 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1383 | 46723317 | 716 MARIPOSA ST | 0.06 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1384 | 46718707 | 831 TULARE ST | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1385 | 46718714 | 1060 COLLINS AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1386 | 46718609T | 1128 COLLINS AVE | 0.34 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1387 | 46718620 | 1143 MAYOR AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1388 | 46718418 | 924 MARIPOSA ST | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1389 | 46718414 | 1028 MAYOR AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1390 | 46715602 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1391 | 46715507T | 1107 B ST | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1392 | 46715508 | | 0.11 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1393 | 46715516 | | 0.26 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1394 | 46715504 | 1129 B ST | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1396 | 46715211 | 1122 B ST | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1397 | 46715221 | 1160 FRESNO ST | 0.50 | Neighborhood Mixed-Use | NMX | 32.0 | 16 | Lower | NO | | | | 46715204 | 1143 C ST | | | | | | | | | | 1398 | 46715301 | | 0.70 | Neighborhood Mixed-Use | NMX | 32.0 | 22 | Lower | YES | | | | 46715303 | | | | | | | | | | | | 46715302 | | | | | | | | | | | 1399 | 46715307 | 1109 TULARE ST | 0.35 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | NO | | | 1400 | 46710601 | | 0.32 | Neighborhood Mixed-Use | NMX | 32.0 | 10 | Above Moderate | YES | | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-7-25 SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1405 | 46521410 | 15 E TUOLUMNE ST | 0.12 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1406 | 46521408 | | 0.08 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1407 | 46521503 | | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1408 | 46525105 | | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1409 | 46715425 | 1260 A ST | 0.22 | Neighborhood Mixed-Use | NMX | 32.0 | 7 | Above Moderate | YES | | | 1410 | 46715414 | 1246 A ST | 0.13 | Neighborhood Mixed-Use | NMX | 32.0 | 4 | Above Moderate | YES | | | 1411 | 46715422 | | 0.09 | Neighborhood Mixed-Use | NMX | 32.0 | 3 | Above Moderate | NO | | | 1413 | 46517601 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1414 | 46517502 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1415 | 46517211 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1416 | 46517215 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1417 | 46517216 | | 0.35 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1418 | 46517421T | 1511 B ST | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1419 | 46517422T | 1515 B ST | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1420 | 46517413 | 1540 A ST | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1421 | 46516518 | 1625 B ST | 0.26 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1422 | 46516428 | | 0.12 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1424 | 46516107 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1425 | 46512503 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1426 | 46512516 | 1738 C ST | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1427 | 46512517 | 1730 C ST | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1428 | 46512539 | | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1430 | 46521301 | 206 E SAN JOAQUIN ST | 0.24 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1431 | 46519510 | 129 E SAN JOAQUIN ST | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1432 | 46519516 | 121 E SAN JOAQUIN ST | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1433 | 46412207 | 120 W CHANDLER AVE | 0.36 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1434 | 46411318 | 824 S THORNE AVE | 0.54 | Residential - Medium Density | RS-5 | 8.4 | 5 | Above Moderate | YES | | | 1435 | 46411314 | 129 W AMADOR ST | 0.25 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1436 | 46411313T | 130 W LEMON AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1437 | 46411310 | 146 W LEMON AVE | 0.37 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1438 | 46411311 | 241 W AMADOR ST | 0.67 | Residential - Medium Density | RS-5 | 8.4 | 6 | Above Moderate | YES | | | 1439 | 46411107 | 311 W WHITES BRIDGE AVE | 0.18 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1441 | 46519303 | 216 E AMADOR ST | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1442 | 46518613 | 211 E AMADOR ST | 0.16 | Neighborhood Mixed-Use | NMX | 32.0 | 5 | Above Moderate | YES | | | 1443 | 46518612 | 217 E AMADOR ST | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1444 | 46518604 | 228 E WHITES BRIDGE AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1445 | 46518605 | 236 E WHITES BRIDGE AVE | 0.23 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1446 | 46518515 | 748 S MODOC ST | 0.16 | Neighborhood Mixed-Use | NMX | 32.0 | 5 | Above Moderate | YES | | APPENDIX 1E: CITY OF FRESNO | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1447 | 46518409 | 47 E AMADOR ST | 0.16 | Neighborhood Mixed-Use | NMX | 32.0 | 5 | Above Moderate | NO | | | 1448 | 46518415 | 26 E WHITES BRIDGE AVE | 0.23 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1449 | 46518312 | 225 E WHITES BRIDGE AVE | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1450 | 46518208 | 153 E WHITES BRIDGE AVE | 0.13 | Neighborhood Mixed-Use | NMX | 32.0 | 4 | Above Moderate | YES | | | 1451 | 46518107 | 43 E WHITES BRIDGE AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1452 | 46518108 | 35 E WHITES BRIDGE AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1453 | 46518109 | 27 E WHITES BRIDGE AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1454 | 46518110 | 19 E WHITES BRIDGE AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1455 | 46518103 | 34 E ONEIL AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1456 | 46518205 | 142 E ONEIL AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1457 | 45822011 | 550 S THORNE AVE | 1.38 | Residential - Medium Density | RS-5 | 8.4 | 12 | Above Moderate | YES | | | 1458 | 45822028 | | 0.43 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | YES | | | 1460 | 45821218 | 148 W EL DORADO ST | 0.20 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1461 | 45821221 | 222 W EL DORADO ST | 0.25 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1462 | 45821222 | 228 W EL DORADO ST | 0.49 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | YES | | | 1463 | 45821226 | | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1464 | 45821227 | 328 W EL DORADO ST | 0.42 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1465 | 45821229 | 410 W EL DORADO ST | 0.57 | Residential - Medium Density | RS-5 | 8.4 | 5 | Above Moderate | YES | | | 1466 | 45821230 | 441 S FRUIT AVE | 0.30 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1467 | 45821233 | 421 S FRUIT AVE | 1.14 | Residential - Medium Density | RS-5 | 8.4 | 10 | Above Moderate | YES | | | 1468 | 45821242 | 407 W DUNN AVE | 2.29 | Residential - Medium Density | RS-5 | 8.4 | 19 | Above Moderate | NO | | | 1469 | 45821238 | | 0.25 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1470 | 45821211 | 145 W DUNN AVE | 0.22 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1471 | 45821166 | 144 E DUNN AVE | 0.07 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1472 | 45821178 | | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1473 | 45821168 | 232 W DUNN AVE | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1474 | 45821170 | | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1475 | 45821158 | | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1476 | 45821156 | 316 W DUNN AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1477 | 45821185 | | 0.12 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1478 | 45821173 | 412 W DUNN AVE | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1479 | 46510605 | 25 E DUNN AVE | 0.34 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 1480 | 46510602 | | 0.07 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1481 | 46510701 | 345 S PLUMAS ST | 0.25 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1489 | 46706124T | 1535 FRESNO ST | 0.34 | Downtown Neighborhood | DTN | 76.0 | 25 | Above Moderate | YES | | | 1490 | 46706123T | | 0.12 | Downtown Neighborhood | DTN | 76.0 | 9 | Above Moderate | YES | | | 1492 | 46706211T | 1526 FRESNO ST | 0.26 | Downtown Neighborhood | DTN | 76.0 | 20 | Above Moderate | YES | | | 1496 | 46710305 | | 0.21 | Downtown Neighborhood | DTN | 76.0 | 16 | Above Moderate | YES | | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-7-27 SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1498 | 46706611 | 1427 TULARE ST | 0.17 | Downtown Neighborhood | DTN | 76.0 | 13 | Above Moderate | YES | | | 1500 | 46706613 | 1047 F ST | 0.13 | Downtown Neighborhood | DTN | 76.0 | 10 | Above Moderate | NO | | | 1503 | 46706333 | 1042 F ST | 0.09 | Downtown Neighborhood | DTN | 76.0 | 7 | Above Moderate | NO | | | 1504 | 46706332 | | 0.04 | Downtown Neighborhood | DTN | 76.0 | 3 | Above Moderate | YES | | | 1505 | 46706330 | 1033 CHINA ALY | 0.09 | Downtown Neighborhood | DTN | 76.0 | 7 | Above Moderate | NO | | | 1506 | 46706329 | | 0.17 | Downtown Neighborhood | DTN | 76.0 | 13 | Above Moderate | YES | | | 1507 | 46706328 | | 0.03 | Downtown Neighborhood | DTN | 76.0 | 2 | Above Moderate | NO | | | 1508 | 46706326 | 1020 F ST | 0.04 | Downtown Neighborhood | DTN | 76.0 | 3 | Above Moderate | NO | | | 1509 | 46706325 | 1016 F ST | 0.17 | Downtown Neighborhood | DTN | 76.0 | 13 | Above Moderate | YES | | | 1511 | 46706320 | | 0.02 | Downtown Neighborhood | DTN | 76.0 | 1 | Above Moderate | NO | | | 1514 | 46706304 | | 0.04 | Downtown Neighborhood | DTN | 76.0 | 3 | Above Moderate | NO | | | 1515 | 46706344 | 1034 CHINA ALY | 0.27 | Downtown Neighborhood | DTN | 76.0 | 21 | Above Moderate | YES | | | 1516 | 46706339 | | 0.11 | Downtown Neighborhood | DTN | 76.0 | 9 | Above Moderate | NO | | | 1517 | 46706311 | | 0.09 | Downtown Neighborhood | DTN | 76.0 | 7 | Above Moderate | NO | | | 1518 | 46706312 | 1022 CHINA ALY | 0.26 | Downtown Neighborhood | DTN | 76.0 | 20 | Above Moderate | YES | | | 1519 | 46706335 | | 0.14 | Downtown Neighborhood | DTN | 76.0 | 11 | Above Moderate | YES | | | 1522 | 46707412 | 950 E ST | 0.52 | Downtown Neighborhood | DTN | 76.0 | 39 | Lower | YES | | | | 46707411 | | | | | | | | | | | 1528 | 46707202 | 811 G ST | 1.21 | Downtown Neighborhood | DTN | 76.0 | 92 | Lower | YES | | | 1529 | 46707316T | 730 F ST | 0.60 | Downtown Neighborhood | DTN | 76.0 | 46 | Lower | YES | | | 1530 | 46707305T | 723 G ST | 0.09 | Downtown Neighborhood | DTN | 76.0 | 7 | Above Moderate | YES | | | 1531 | 46707306T | | 0.18 | Downtown Neighborhood | DTN | 76.0 | 13 | Above Moderate | YES | | | 1537 | 46708123 | | 0.05 | Downtown Neighborhood | DTN | 76.0 | 4 | Above Moderate | NO | | | 1539 | 46712118 | | 0.08 | Downtown Neighborhood | DTN | 76.0 | 6 | Above Moderate | YES | | | 1540 | 46712117 | 615 E ST | 0.60 | Downtown Neighborhood | DTN | 76.0 | 46 | Lower | YES | | | | 46712115 | | | | | | | | | | | | 46712113 | 637 E ST | | | | | | | | | | | 46712112 | 625 E ST | | | | | | | | | | 1552 | 46827717 | 101 VAN NESS AVE | 0.70 | Downtown Neighborhood | DTN | 76.0 | 53 | Lower | NO | | | 1553 | 46823527 | | 1.20 | Downtown Neighborhood | DTN | 76.0 | 91 | Lower | NO | | | 1554 | 46827423 | | 0.17 | Downtown Neighborhood | DTN | 76.0 | 13 | Above Moderate | NO | | | 1555 | 46827109 | 2115 MONTEREY ST | 0.25 | Downtown Neighborhood | DTN | 76.0 | 19 | Above Moderate | NO | | | 1556 | 46827104 | 343 L ST | 0.12 | Downtown Neighborhood | DTN | 76.0 | 9 | Above Moderate | NO | | | 1557 | 46827105 | 333 L ST | 0.17 | Downtown Neighborhood | DTN | 76.0 | 13 | Above Moderate | NO | | | 1558 | 46823413 | 351 M ST | 0.08 | Downtown Neighborhood | DTN | 76.0 | 6 | Above Moderate | NO | | | 1559 | 46823113 | | 0.17 | Downtown Neighborhood | DTN | 76.0 | 13 | Above Moderate | NO | | | 1560 | 46830504 | 1804 SAN BENITO ST | 0.25 | Downtown Neighborhood | DTN | 76.0 | 19 | Above Moderate | NO | | | 1562 | 46705013ST | 555 H ST | 1.47 | Downtown Neighborhood | DTN | 76.0 | 111 | Lower | YES | | | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1563 | 46829506 | 550 H ST | 0.62 | Downtown Neighborhood | DTN | 76.0 | 47 | Lower | YES | | | 1565 | 46829205 | 514 BROADWAY | 0.41 | Downtown Neighborhood | DTN | 76.0 | 31 | Above Moderate | YES | | | 1568 | 46829301 | 461 FULTON ST | 0.19 | Downtown Neighborhood | DTN | 76.0 | 14 | Above Moderate | NO | | | 1569 | 46829319 | 447 FULTON ST | 0.07 | Downtown Neighborhood | DTN | 76.0 | 6 | Above Moderate | NO | | | 1571 | 46826209 | 511 L ST | 0.17 | Downtown General | DTG | 83.0 | 14 | Above Moderate | YES | | | 1573 | 46822212T | 550 M ST | 0.30 | Downtown General | DTG | 83.0 | 25 | Above Moderate | YES | | | 1574 | 46822215T | 525 N ST | 0.26 | Downtown General | DTG | 83.0 | 50 | Lower | YES | | | | 46822216T | 505 N ST | 0.34 | | | | | | | | | 1576 | 46822301T | 461 N ST | 0.17 | Downtown General | DTG | 83.0 | 36 | Above Moderate | NO | | | | 46822302T | 453 N ST | 0.09 | | | | | | | | | | 46822319T | | 0.17 | | | | | | | | | 1580 | 46819213T | 2504 VENTURA ST | 0.15 | Downtown General | DTG | 83.0 | 79 | Lower | YES | | | | 46819214T | 2518 VENTURA ST | 0.30 | | | | | | | | | | 46819236 | 530 O ST | 0.06 | | | | | | | | | | 46819237 | 534 O ST | 0.19 | | | | | | | | | | 46819222 | 2526 VENTURA ST | 0.14 | | | | | | | | | | 46819227 | 2534 VENTURA ST | 0.12 | | | | | | | | | 1590 | 46821220 | 800 M ST | 0.74 | Downtown General | DTG | 83.0 | 61 | Lower | YES | | | 1594 | 46826117 | | 0.17 | Downtown General | DTG | 83.0 | 14 | Above Moderate | YES | | | 1595 | 46826111 | | 0.17 | Downtown General | DTG | 83.0 | 14 | Above Moderate | YES | | | 1602 | 46828607 | 702 H ST | 0.17 | Downtown Neighborhood | DTN | 76.0 | 13 | Above Moderate | YES | | | 1605 | 46825401 | 2030 TULARE ST | 0.52 | Downtown Core | DTC | 90.0 | 46 | Lower | YES | | | | 46825402 | 2060 TULARE ST | | | | | | | | | | 1613 | 46620518T | 1408 H ST | 0.29 | Downtown Core | DTC | 90.0 | 26 | Above Moderate | NO | | | 1621 | 46611308 | 2301 FRESNO ST | 0.59 | Downtown General | DTG | 83.0 | 49 | Lower | YES | | | 1625 | 46608122 | 2528 TUOLUMNE ST | 0.34 | Downtown Neighborhood | DTN | 76.0 | 26 | Above Moderate | YES | | | 1627 | 46608104 | 1333 P ST | 0.17 | Downtown Neighborhood | DTN | 76.0 | 13 | Above Moderate | YES | | | 1628 | 46605512 | | 0.17 | Downtown Neighborhood | DTN | 76.0 | 13 | Above Moderate | YES | | | 1629 | 46605509 | 2615 MERCED ST | 0.11 | Downtown Neighborhood | DTN | 76.0 | 9 | Above Moderate | NO | | | 1631 | 46605607 | 2627 FRESNO ST | 0.21 | Downtown General | DTG | 83.0 | 17 | Above Moderate | YES | | | 1636 | 46607101 | 75 N BLACKSTONE AVE | 0.17 | Downtown Neighborhood | DTN | 76.0 | 13 | Above Moderate | YES | | | 1637 | 46607406 | 1509 O ST | 0.34 | Downtown Neighborhood | DTN | 76.0 | 26 | Above Moderate | YES | | | 1638 | 45932702 | 2415 CALAVERAS ST | 0.70 | Downtown Neighborhood | DTN | 76.0 | 53 | Lower | YES | | | | 45932701 | 1660 N ST | | | | | | | | | | 1643 | 46614209 | 1528 VAN NESS AVE | 0.34 | Downtown Neighborhood | DTN | 76.0 | 26 | Above Moderate | YES | | | 1651 | 46613418 | 2024 AMADOR ST | 0.17 | Downtown Neighborhood | DTN | 76.0 | 13 | Above Moderate | YES | | | 1653 | 46613213 | 1762 VAN NESS AVE | 0.26 | Downtown Neighborhood | DTN | 76.0 | 20 | Above Moderate | YES | | | 1654 | 46610332 | 14 N PARK AVE | 0.28 | Downtown Neighborhood | DTN | 76.0 | 22 | Above Moderate | YES | | SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1656 | 46613328 | 1845 VAN NESS AVE | 0.33 | Downtown Neighborhood | DTN | 76.0 | 25 | Above Moderate | YES | | | 1661 | 45825012 | 101 N ROOSEVELT AVE | 1.04 | Neighborhood Mixed-Use | NMX | 32.0 | 33 | Lower | YES | | | 1663 | 45920007 | | 0.22 | Neighborhood Mixed-Use | NMX | 32.0 | 7 | Above Moderate | YES | | | 1664 | 45929219 | | 0.29 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1665 | 45922122S | 252 N BROADWAY | 0.16 | Neighborhood Mixed-Use | NMX | 32.0 | 5 | Above Moderate | YES | | | 1666 | 45930120 | 140 N BROADWAY | 0.14 | Neighborhood Mixed-Use | NMX | 32.0 | 4 | Above Moderate | YES | | | 1668 | 45930236 | 181 N FULTON ST | 0.24 | Neighborhood Mixed-Use | NMX | 32.0 | 8 | Above Moderate | YES | | | 1669 | 45913218 | | 0.06 | Residential - Medium Density | RS-5 | 8.4 | 0 | Above Moderate | NO | | | 1670 | 45930328 | | 0.39 | Neighborhood Mixed-Use | NMX | 32.0 | 12 | Above Moderate | YES | | | 1671 | 45930312 | | 0.12 | Neighborhood Mixed-Use | NMX | 32.0 | 4 | Above Moderate | NO | | | 1672 | 45930604 | 943 E DIVISADERO ST | 0.11 | Neighborhood Mixed-Use | NMX | 32.0 | 3 | Above Moderate | NO | | | 1673 | 45931126 | 106 N VAN NESS AVE | 0.19 | Neighborhood Mixed-Use | NMX | 32.0 | 6 | Above Moderate | YES | | | 1674 | 45905120 | 1045 E FRANKLIN AVE | 0.12 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1675 | 45914501 | 380 N POPLAR AVE | 0.20 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | NO | | | 1676 | 45932113 | 208 N SAN PABLO AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1677 | 45931809 | 1325 E DIVISADERO ST | 0.37 | Neighborhood Mixed-Use | NMX | 32.0 | 12 | Above Moderate | YES | | | 1678 | 45932103 | 121 N GLENN AVE | 0.27 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1679 | 45932506 | 25 N CALAVERAS ST | 0.21 | Neighborhood Mixed-Use | NMX | 32.0 | 7 | Above Moderate | YES | | | 1682 | 45915319 | 382 N CALAVERAS ST | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1685 | 45916104 | 357 N ABBY ST | 0.16 | Corridor - Center Mixed Use | CMX | 37.50 | 6 | Above Moderate | NO | | | 1686 | 45907107 | 437 N ABBY ST | 0.12 | Corridor - Center Mixed Use | CMX | 37.50 | 4 | Above Moderate | NO | | | 1688 | 45229315 | | 0.17 | Neighborhood Mixed-Use | NMX | 32.0 | 6 | Above Moderate | YES | | | 1689 | 45229425 | | 0.05 | Residential - Medium Density | RS-5 | 8.4 | 0 | Above Moderate | NO | | | 1690 | 45229426 | | 0.05 | Residential - Medium Density | RS-5 | 8.4 | 0 | Above Moderate | NO | | | 1692 | 45230130 | 534 N BLACKSTONE AVE | 0.71 | Corridor - Center Mixed Use | CMX | 37.50 | 27 | Lower | YES | | | | 45230127 | 1731 E BELMONT AVE | | | | | | | | | | | 45230125 | | | | | | | | | | | | 45230126 | 1737 E BELMONT AVE | | | | | | | | | | 1693 | 45230226 | | 0.06 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1694 | 45230211 | 1931 E WHITE AVE | 0.09 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1695 | 45907204 | 457 N EFFIE ST | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1696 | 45916305 | 361 N DIANA ST | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1697 | 45925319 | 266 N EFFIE ST | 0.09 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1698 | 45925318 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1699 | 45925317 | 256 N EFFIE ST | 0.09 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1700 | 45925214 | | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1701 | 45925312 | 214 N EFFIE ST | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1702 | 45925311 | 202 N EFFIE ST | 0.18 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1703 | 45925306 | | 0.18 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1704 | 45925310 | 1931 E ILLINOIS AVE | 0.18 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1705 | 45933302 | 175 N DIANA ST | 0.26 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | NO | | | 1706 | 45933303 | | 0.26 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1707 | 45933321 | 129 N DIANA ST | 0.24 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 1708 | 45925405 | 257 N CLARK ST | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1710 | 45916401U | | 1.72 | Residential - Medium Density | RS-5 | 8.4 | 14 | Above Moderate | YES | | | 1711 | 45917134 | | 0.06 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1712 | 45917105 | 359 N VALERIA ST | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1713 | 45907413U | | 1.59 | Residential - Medium Density | RS-5 | 8.4 | 13 | Above Moderate | YES | | | 1714 | 45907416 | 2020 E BELMONT AVE | 0.22 | Neighborhood Mixed-Use | NMX | 32.0 | 7 | Above Moderate | YES | | | 1715 | 45908103 | 469 N VALERIA ST | 0.13 | Neighborhood Mixed-Use | NMX | 32.0 | 4 | Above Moderate | YES | | | 1716 | 45908231 | | 0.30 | Neighborhood Mixed-Use | NMX | 32.0 | 10 | Above Moderate | YES | | | 1718 | 45231101 | 2060 E THOMAS AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1719 | 45231302 | 2320 E THOMAS AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1720 | 45231309 | 639 N FRESNO ST | 0.13 | Neighborhood Mixed-Use | NMX | 32.0 | 4 | Above Moderate | NO | | | 1721 | 45917324 | 359 N FRESNO ST | 0.11 | Neighborhood Mixed-Use | NMX | 32.0 | 4 | Above Moderate | NO | | | 1722 | 45917326 | 331 N FRESNO ST | 0.14 | Neighborhood Mixed-Use | NMX | 32.0 | 4 | Above Moderate | YES | | | 1723 | 45917340 | 317 N FRESNO ST | 0.31 | Neighborhood Mixed-Use | NMX | 32.0 | 10 | Above Moderate | YES | | | 1724 | 45224419 | 704 N FRESNO ST | 0.35 | Neighborhood Mixed-Use | NMX | 32.0 | 11 | Above Moderate | YES | | | 1725 | 45232415 | 530 N FRESNO ST | 0.17 | Neighborhood Mixed-Use | NMX | 32.0 | 5 | Above Moderate | YES | | | 1728 | 45910133 | 2902 E BELMONT AVE | 0.09 | Neighborhood Mixed-Use | NMX | 32.0 | 3 | Above Moderate | NO | | | 1729 | 45909322 | | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1730 | 45927414 | 261 N ANGUS ST | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1731 | 45927106 | 267 N U ST | 0.12 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1734 | 45927116 | 212 N FRESNO ST | 0.14 | Neighborhood Mixed-Use | NMX | 32.0 | 4 | Above Moderate | YES | | | 1735 | 45927214 | 217 N MARIPOSA ST | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 1736 | 45935134 | | 0.17 | Neighborhood Mixed-Use | NMX | 32.0 | 6 | Above Moderate | YES | | | 1737 | 46604311 | 1045 U ST | 0.55 | Downtown Neighborhood | DTN | 76.0 | 41 | Lower | YES | | | 1738 | 46604201 | 1050 S ST | 0.36 | Downtown Neighborhood | DTN-AH | 32.0 | 11 | Above Moderate | YES | | | 1739 | 46603505 | 2831 MARIPOSA ST | 0.25 | Downtown Neighborhood | DTN-AH | 32.0 | 8 | Above Moderate | YES | | | 1742 | 31025012 | 6512 E CLINTON AVE | 2.97 | Residential Low Density | RS-1 | 0.8 | 2 | Above Moderate | YES | | | 1744 | 51222418 | 4405 N HAYES AVE | 0.87 | Residential - Medium Density | RS-5 | 8.4 | 7 | Above Moderate | YES | | | 1745 | 57907546 | | 13.34 | Residential - Medium Low Density | RS-4 | 4.8 | 64 | Above Moderate | YES | | | 1746 | 46724102 | 617 KERN ST | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1747 | 46002323 | 3350 E BELMONT AVE | 0.12 | Neighborhood Mixed-Use | NMX | 32.0 | 4 | Above Moderate | NO | | | 1749 | 45202103 | 326 E OLIVE AVE | 0.11 | Commercial - Main Street | CMS | 24.00 | 3 | Above Moderate | NO | | | 1751 | 46823403 | | 0.17 | Downtown Neighborhood | DTN | 76.0 | 13 | Above Moderate | NO | | SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1753 | 45129228 | 1270 N ABBY ST | 0.32 | Neighborhood Mixed-Use | NMX | 32.0 | 10 | Above Moderate | NO | | | | 45129202 | | | | | | | | | | | | 45129201 | | | | | | | | | | | 1754 | 45921228 | 208 N ECHO AVE | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 0 | Above Moderate | NO | | | 1755 | 46005120 | 3931 E MADISON AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 0 | Above Moderate | NO | | | 1756 | 46013104 | 3924 E GRANT AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1757 | 42634219 | | 0.07 | Residential - Medium High Density | RM-1 | 13.6 | 1 | Moderate | NO | | | 1758 | 44417204 | 1522 E YALE AVE | 0.12 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | NO | | | 1759 | 44704218 | | 0.30 | Residential - Medium High Density | RM-1 | 13.6 | 4 | Moderate | NO | | | 1760 | 44705017 | | 0.11 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | NO | | | 1761 | 44904054 | 3015 W MCKINLEY AVE | 1.06 | Residential - Medium High Density | RM-1 | 13.6 | 14 | Moderate | NO | | | 1762 | 45224121 | 2552 E LEWIS AVE | 0.17 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 1763 | 45402204 | 3280 E OLIVE AVE | 0.11 | Residential - Medium High Density | RM-1 | 13.6 | 1 | Moderate | NO | | | 1764 | 4540220S | 3271 E CLAY AVE | 0.15 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | NO | | | 1765 | 45402324 | 3120 E CLAY AVE | 0.29 | Residential - Medium High Density | RM-1 | 13.6 | 4 | Moderate | NO | | | 1766 | 45402214 | 3323 E CLAY AVE | 0.15 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | NO | | | 1767 | 45402409 | 3322 E CLAY AVE | 0.15 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | NO | | | 1768 | 45402118 | 3131 E CLAY AVE | 0.15 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | NO | | | 1769 | 50733019 | 4099 W KADOTA AVE | 0.13 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | NO | | | 1770 | 50733043 | | 0.15 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | NO | | | 1771 | 51117107 | 4595 W ASHLAN AVE | 2.33 | Residential - Medium High Density | RM-1 | 13.6 | 32 | Moderate | NO | | | 1772 | 51117111 | 4515 W ASHLAN AVE | 2.30 | Residential - Medium High Density | RM-1 | 13.6 | 31 | Moderate | NO | | 1773 | 51124017S | 3601 N BRAWLEY DR | 2.08 | Residential - Medium High Density | RM-1 | 13.6 | 28 | Moderate | NO | | | 1775 | 44913010 | 1715 W DUDLEY AVE | 2.36 | Residential - Low Density | RS-3 | 3.3 | 8 | Above Moderate | NO | | | 1777 | 57414002 | 2204 N ARMSTRONG AVE | 2.44 | Residential - Low Density | RS-3 | 3.3 | 8 | Above Moderate | NO | | | 1784 | 32813219 | 2965 S NEWMAN AVE | 0.07 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 1785 | 32813218 | 2964 S NEWMAN AVE | 0.07 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 1786 | 32813217 | 2969 S NEWMAN AVE | 0.07 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 1787 | 32816309 | 2986 S MARTIN LUTHER KING JR BLVD | 0.12 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 1788 | 32816311 | | 0.08 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 1789 | 32816312 | 2996 S MARTIN LUTHER KING JR BLVD | 0.08 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 1790 | 32818104 | 2930 S MARTIN LUTHER KING JR BLVD | 0.18 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 1791 | 44203017 | 4650 N BRAWLEY AVE | 0.22 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 1792 | 45613120 | 712 N PEACH AVE | 0.28 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 1793 | 48025221 | 4665 E EUGENIA AVE | 0.14 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 1794 | 51102117 | 3207 N POLK AVE | 9.55 | Residential - Medium Low Density | RS-4 | 4.8 | 46 | Above Moderate | NO | | | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1795 | 30303333 | 389 W ALLUVIAL AVE | 0.22 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | NO | | | 1796 | 30304153 | | 0.08 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1797 | 30304149 | | 0.07 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1798 | 30304127 | 288 W PINEDALE AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1800 | 30307110 | | 0.06 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1801 | 30307105 | | 0.06 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1802 | 30307103 | | 0.06 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1803 | 30309253 | | 0.11 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1804 | 30312226 | | 0.12 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1805 | 30314223 | 413 W BEECHWOOD AVE | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1806 | 32916217 | 235 W ALMY AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1807 | 40805030 | | 2.20 | Residential - Medium Density | RS-5 | 8.4 | 18 | Above Moderate | NO | | | 1808 | 43026234 | | 0.12 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1809 | 43026239 | | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1810 | 43719126 | | 0.08 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1811 | 44405116T | | 0.12 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1812 | 44610118 | 2243 E CAMBRIDGE AVE | 0.09 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1813 | 44610423 | | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1814 | 44616323 | | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1815 | 44626217 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1816 | 45004425 | 1511 N FRUIT AVE | 0.31 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | NO | | | 1817 | 45104113 | | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1818 | 45130114 | 2245 E HAMMOND AVE | 0.09 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1819 | 45205503 | 1037 N GLENN AVE | 0.08 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1820 | 45218106 | 807 N FERGER AVE | 0.09 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1821 | 45220905 | 706 N POPLAR AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1822 | 45221329 | | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | NO | | | 1823 | 45228203 | 629 N COLLEGE AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1824 | 45314214 | 1450 N ARCHIE AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1825 | 45314215 | 1444 N ARCHIE AVE | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | NO | | | 1826 | 45320114 | 1323 N EIGHTH AVE | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1828 | 45418405 | 761 N BOND AVE | 0.09 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1829 | 45419302 | | 0.07 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1830 | 45419310 | 708 N FIFTH AVE | 0.09 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1831 | 45424411 | 719 N SIERRA VISTA AVE | 0.18 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | NO | | | 1832 | 45428139 | 3739 E WHITE AVE | 0.11 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1833 | 45623232 | | 0.41 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | NO | | | 1834 | 45811309 | 409 N TEILMAN AVE | 0.12 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1835 | 45815103 | 717 W FRANKLIN AVE | 0.08 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1836 | 45815112 | | 0.11 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1837 | 45908219 | | 0.11 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1838 | 45917126 | 378 N CLARK AVE | 0.11 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1839 | 45911208 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1840 | 45914410 | 359 N POPLAR AVE | 0.11 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1841 | 45918126 | 2630 E GRANT AVE | 0.09 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1842 | 45918423 | 2717 E MC KENZIE AVE | 0.11 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1843 | 4591238 | | 0.12 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1844 | 45927102 | 2526 E MC KENZIE AVE | 0.11 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1845 | 45933208 | 137 N EFFIE AVE | 0.08 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1846 | 45928414 | 3049 E ILLINOIS AVE | 0.09 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1847 | 45928424 | 219 N FIRST AVE | 0.09 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1848 | 45936117 | 2971 E IOWA AVE | 0.09 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1849 | 46002610 | 3353 E GRANT AVE | 0.12 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1852 | 46022718 | 4406 E BALL AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1853 | 46026205 | 3230 E ILLINOIS AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1854 | 46028406 | 3846 E IOWA AVE | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1855 | 46115114 | 4627 E HUNTINGTON AVE | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | NO | | | 1856 | 46121223 | 4561 E BALCH AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1857 | 46130202 | 548 S RECREATION AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1858 | 46225427 | 4921 E TULARE AVE | 0.61 | Residential - Medium Density | RS-5 | 8.4 | 5 | Above Moderate | NO | | | 1859 | 46327024 | 4960 E TULARE AVE | 0.63 | Residential - Medium Density | RS-5 | 8.4 | 5 | Above Moderate | NO | | | 1860 | 46308201 | 155 S WILLOW AVE | 0.43 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | NO | | | 1861 | 46313220 | 369 S WILLOW AVE | 0.61 | Residential - Medium Density | RS-5 | 8.4 | 5 | Above Moderate | NO | | | 1862 | 46318226 | 5030 E BALCH AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1863 | 46404049 | 1861 W WHITESBRIDGE AVE | 3.01 | Residential - Medium Density | RS-5 | 8.4 | 25 | Above Moderate | NO | | | 1864 | 46419214 | 1006 W WOODWARD AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1865 | 46517117 | 1122 CALAVERAS ST | 0.07 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1866 | 46519103 | 30 E AMADOR ST | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1867 | 46519615 | | 0.08 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1868 | 46521310 | 231 E STANISLAUS ST | 0.08 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1869 | 46521606 | 1130 S TRINITY ST | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1870 | 46711408 | | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1871 | 46713406 | 127 F ST | 0.09 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1872 | 47808338 | | 0.08 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1873 | 46813208 | 3070 E EL MONTE WAY | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1874 | 47007139 | 751 S CEDAR AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1875 | 47009233 | | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1876 | 47017223 | 4775 E ALTA AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1877 | 47110201 | 1606 S THIRD AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1878 | 47118510 | 1915 S HAZELWOOD BLVD | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1879 | 47706005 | 106 W CHURCH AVE | 4.29 | Residential - Medium Density | RS-5 | 8.4 | 36 | Above Moderate | NO | | | 1880 | 47809237 | | 0.07 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1881 | 47815419 | 2234 S CHERRY AVE | 0.05 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1882 | 47819106 | 2326 S POPPY AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1883 | 47826110 | | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1884 | 48023526 | 2428 S CEDAR AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1885 | 48035241 | | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1886 | 48035311 | | 0.07 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1887 | 48711221 | 2641 S NINTH AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1888 | 48712419 | 2681 S ELEVENTH AVE | 0.12 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1889 | 48713003 | 4024 E VINE AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1890 | 48713006 | 4107 E MASON AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 1891 | 50409212T | | 1.74 | Residential - Medium Density | RS-5 | 8.4 | 15 | Above Moderate | NO | | | 1892 | 57405003 | | 0.85 | Residential - Medium Density | RS-5 | 8.4 | 7 | Above Moderate | NO | | | 2213 | 57423808 | | 8.85 | Residential - Medium Density | RS-5 | 8.4 | 74 | Above Moderate | NO | | | 2251 | 31008103S | | 15.33 | Residential - Medium Density | RS-5 | 8.4 | 129 | Above Moderate | NO | | | 2253 | 57907534 | | 10.14 | Residential - Medium Low Density | RS-4 | 4.8 | 49 | Above Moderate | YES | | | 2255 | 57939045S | | 9.70 | Residential - Medium Low Density | RS-4 | 4.8 | 47 | Above Moderate | NO | FEMA 100-year flood zone | | 2256 | 57939062S | | 4.26 | Residential - Medium Density | RS-5 | 8.4 | 36 | Above Moderate | YES | | | 2257 | 57922049S | | 2.57 | Residential - Urban Neighborhood | RM-2 | 18.0 | 46 | Lower | NO | | | 2258 | 30316150 | | 0.23 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 2259 | 30316151 | | 0.27 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 2260 | 30316152 | | 0.22 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 2261 | 30316153 | | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2262 | 41808086 | | 1.55 | Regional Mixed-Use | RMX | 45.0 | 70 | Lower | YES | | | 2263 | 41808087 | | 1.31 | Regional Mixed-Use | RMX | 45.0 | 59 | Lower | YES | | | 2264 | 41808083 | | 1.47 | Regional Mixed-Use | RMX | 45.0 | 66 | Lower | YES | | | 2265 | 42517218 | 4819 N BLACKSTONE AVE | 0.80 | Corridor - Center Mixed Use | CMX | 37.50 | 30 | Lower | YES | | | 2267 | 45603038 | | 1.10 | Corridor - Center Mixed Use | CMX | 37.50 | 41 | Lower | YES | | | 2268 | 45603048 | | 5.33 | Corridor - Center Mixed Use | CMX | 37.50 | 200 | Lower | YES | | | 2269 | 31306007 | | 0.53 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | YES | | | 2270 | 47403072 | | 9.85 | Corridor - Center Mixed Use | CMX | 37.50 | 370 | Lower | YES | | | 2271 | 47403078 | | 8.46 | Corridor - Center Mixed Use | CMX | 37.50 | 317 | Lower | YES | | | 2272 | 48110016 | | 0.92 | Residential - Medium Low Density | RS-4 | 4.8 | 4 | Above Moderate | NO | | SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 2273 | 48149337S | 2206 S MINNEWAWA AVE | 0.46 | Residential Low Density | RS-2 | 2.0 | 1 | Above Moderate | YES | | | 2274 | 46305047 | | 0.96 | Corridor - Center Mixed Use | CMX | 37.50 | 36 | Lower | YES | | | 2275 | 46305048 | | 1.03 | Corridor - Center Mixed Use | CMX | 37.50 | 39 | Lower | YES | | | 2276 | 48102031 | 2108 S PEACH AVE | 0.24 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | NO | | | 2277 | 47320038 | 1624 S WILLOW AVE | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 2278 | 47204026 | | 0.64 | Neighborhood Mixed-Use | NMX | 32.0 | 21 | Lower | YES | | | 2279 | 47204027 | | 0.64 | Neighborhood Mixed-Use | NMX | 32.0 | 21 | Lower | YES | | | 2280 | 47204028 | | 0.64 | Neighborhood Mixed-Use | NMX | 32.0 | 21 | Lower | YES | | | 2281 | 48012016 | 3639 E EUGENIA AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2282 | 48012016 | | 1.52 | Residential - Medium Density | RS-5 | 8.4 | 13 | Above Moderate | YES | | | 2283 | 46130320 | 560 S DEARING AVE | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 2284 | 47106230 | 4140 E BUTLER AVE | 0.28 | Residential - Medium High Density | RM-1 | 13.6 | 4 | Moderate | YES | | | 2286 | 47125307 | 2054 S HAZELWOOD BLVD | 0.20 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 2287 | 47125305 | | 0.20 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 2288 | 46814010 | 778 S HAZELWOOD BLVD | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2289 | 45928426 | | 0.37 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 2290 | 45928427 | 3050 E NEVADA AVE | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2291 | 45426131 | | 0.19 | Residential - Medium Density | RS-5 | 8.4 | 4 | Above Moderate | YES | | | | 46010104 | | 0.21 | | | | | | | | | 2292 | 45418502 | 3116 E THOMAS AVE | 0.07 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2293 | 45418512 | 3106 E THOMAS AVE | 0.08 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2294 | 45418123 | 726 N FIRST ST | 0.11 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2295 | 45405234 | | 0.11 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2296 | 45328230 | 1304 N EIGHTH ST | 2.19 | Residential - Medium Density | RS-5 | 8.4 | 18 | Above Moderate | YES | | | 2297 | 44409312 | 2224 N SAN PABLO AVE | 0.16 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | YES | | | 2298 | 45216513 | | 0.54 | Residential - Medium High Density | RM-1 | 13.6 | 7 | Moderate | YES | | | 2299 | 45223223 | 2203 E HARVEY AVE | 0.35 | Residential - Medium High Density | RM-1 | 13.6 | 5 | Moderate | YES | | | 2300 | 45228217 | 540 N VAN NESS AVE | 0.19 | Commercial - Main Street | CMS | 24.00 | 4 | Above Moderate | YES | | | 2301 | 45219114 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2302 | 45912218 | 631 E MILDREDA AVE | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2303 | 43308002 | | 3.79 | Residential - Medium Density | RS-5 | 8.4 | 32 | Above Moderate | YES | | | 2304 | 42628103 | 4235 N DELNO AVE | 0.30 | Residential - Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 2305 | 40613315 | 6029 N SAN PEDRO AVE | 0.23 | Residential - Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 2306 | 40613316 | 6029 N SAN PEDRO AVE | 0.12 | Residential - Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 2309 | 50409221 | | 8.70 | Residential - Urban Neighborhood | RM-2 | 18.0 | 157 | Lower | YES | | | 2310 | 50410411 | 6979 N WEBER AVE | 0.13 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | NO | | | 2311 | 50411420 | 7015 N WEBER AVE | 0.13 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | NO | | | 2312 | 50411421 | 7003 N WEBER AVE | 0.13 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | NO | | | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 2313 | 50411426 | 7001 N WEBER AVE | 0.13 | Residential - Medium High Density | RM-1 | 13.6 | 2 | Moderate | NO | | | 2314 | 50507006S | | 1.37 | Residential - Medium Density | RS-5 | 8.4 | 12 | Above Moderate | YES | | | 2315 | 50803014 | North of W Shaw Ave, south of Island Waterpark | 22.38 | Corridor - Center Mixed Use | CMX | 37.50 | 151 | Moderate | YES | | | | | | | | | | 50 | Above Moderate | | | | | | | | | | | 50 | Lower | | | | 2316 | 50803026 | North of W Shaw Ave, south of Island Waterpark | 7.23 | Regional Mixed-Use | RMX | 45.0 | 0 | Moderate | NO | | | | | | | | | | 0 | Above Moderate | | | | | | | | | | | 98 | Lower | | | | 2317 | 50803005 | N Lola Ave at W Shaw Ave | 11.16 | Regional Mixed-Use | RMX | 45.0 | 90 | Moderate | YES | | | | | | | | | | 30 | Above Moderate | | | | | | | | | | | 30 | Lower | | | | 2318 | 51011016 | 5819 W SHAW AVE | 0.08 | Residential - Urban Neighborhood | RM-2 | 18.0 | 1 | Above Moderate | NO | | | 2319 | 51054029 | | | | | | | | | | | | 51054030 | | | | | | | | | | | | 51054028 | | 1.79 | Residential - Urban Neighborhood | RM-2 | 18.0 | 32 | Lower | YES | | | | 51054027 | | | | | | | | | | | | 51054031 | | | | | | | | | | | | 51054023 | | | | | | | | | | | 2320 | 51124037 | 3949 N PARKWAY DR | 8.47 | Residential - Medium High Density | RM-1 | 13.6 | 115 | Moderate | YES | | | 2321 | 43303208 | 3114 N VALENTINE AVE | 2.00 | Residential - Medium Density | RM-1 | 13.6 | 27 | Moderate | NO | | | 2322 | 44202246 | | 4.91 | Residential - Medium Density | RS-5 | 8.4 | 41 | Above Moderate | YES | | | 2323 | 44209048 | 2741 W CLINTON AVE | 0.69 | Neighborhood Mixed-Use | NMX | 32.0 | 22 | Lower | YES | | | 2324 | 44923129 | 1835 W HEDGES AVE | 1.16 | Neighborhood Mixed-Use | NMX | 32.0 | 37 | Lower | YES | | | 2325 | 44923135 | 1915 W HEDGES AVE | 1.16 | Neighborhood Mixed-Use | NMX | 32.0 | 37 | Lower | YES | | | 2326 | 44923134 | 1937 W HEDGES AVE | 1.18 | Neighborhood Mixed-Use | NMX | 32.0 | 38 | Lower | YES | | | 2327 | 44934109 | | 0.23 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 2328 | 44934204 | | 0.47 | Residential - Low Density | RS-3 | 3.3 | 2 | Above Moderate | YES | | | 2329 | 44934205 | | 0.23 | Residential - Low Density | RS-3 | 3.3 | 1 | Above Moderate | YES | | | 2330 | 45814110 | 303 N CHANNING WAY | 0.28 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 2331 | 45811206 | 453 N DURANT WAY | 0.25 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | NO | | | 2332 | 45813205 | 449 N WESLEY AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2333 | 45816104 | | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2334 | 45816116 | 414 N NAPA AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2335 | 45816122 | 424 W NAPA AVE | 0.20 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 2336 | 45816123 | 350 N FRUIT AVE | 0.15 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2337 | 45816124 | 360 N FRUIT AVE | 0.16 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2338 | 45816128 | 413 W FRANKLIN AVE | 0.18 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2339 | 45808034 | 2146 W WHITES BRIDGE AVE | 1.53 | Commercial - Regional | CR | 40.00 | 61 | Lower | NO | | SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 2340 | 46404055 | 850 S SEQUOIA DR | 2.97 | Residential - Medium Density | RS-5 | 8.4 | 25 | Above Moderate | YES | | | 2341 | 46420012 | 824 W CALIFORNIA AVE | 0.21 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | NO | | | 2343 | 47711304 | | 0.93 | Corridor - Center Mixed Use | CMX | 37.50 | 35 | Lower | YES | | | 2344 | 47711208 | | 0.23 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 2345 | 47711210 | 2122 S THORNE AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2346 | 47711211 | 146 W ATCHISON ST | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2347 | 47711425 | 221 W ATCHISON ST | 0.12 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2348 | 47718203 | 2368 S WALNUT AVE | 0.41 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 2349 | 47718212 | | 0.23 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 2350 | 47718219 | | 0.30 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 2351 | 47722260 | 225 E JENSEN AVE | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2352 | 32813103 | | 0.07 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 2353 | 32813109 | | 0.07 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 2354 | 32813206 | 2970 S HARDT AVE | 0.07 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 2355 | 32813207 | | 0.07 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 2356 | 32916145 | 362 W ALMY AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2357 | 32815044 | 2916 S ELM AVE | 1.32 | Neighborhood Mixed-Use | NMX | 32.0 | 42 | Lower | NO | | | 2358 | 32815045 | | 0.68 | Residential - Medium Density | RS-5 | 8.4 | 6 | Above Moderate | NO | | | 2359 | 47917116 | | 0.14 | Corridor - Center Mixed Use | CMX | 37.50 | 5 | Above Moderate | NO | | | 2361 | 47912121 | | 0.14 | Corridor - Center Mixed Use | CMX | 37.50 | 5 | Above Moderate | NO | | | 2362 | 47912122 | | 0.14 | Corridor - Center Mixed Use | CMX | 37.50 | 5 | Above Moderate | NO | | | 2363 | 47818215 | | 0.25 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 2364 | 47818319 | | 0.65 | Residential - Medium Density | RS-5 | 8.4 | 5 | Above Moderate | YES | | | 2365 | 47825401 | | 0.09 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2366 | 47819130 | 2341 S ELM AVE | 0.11 | Neighborhood Mixed-Use | NMX | 32.0 | 4 | Above Moderate | NO | | | 2367 | 46713203 | 321 F ST | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2368 | 47813425 | 2232 S ELM AVE | 0.16 | Neighborhood Mixed-Use | NMX | 32.0 | 5 | Above Moderate | YES | | | 2369 | 46730170 | 1029 SANTA CLARA ST | 0.09 | Neighborhood Mixed-Use | NMX | 32.0 | 3 | Above Moderate | NO | | | 2370 | 46730171 | 1027 SANTA CLARA ST | 0.10 | Neighborhood Mixed-Use | NMX | 32.0 | 3 | Above Moderate | NO | | | 2371 | 46717211 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2372 | 46711412 | 916 C ST | 0.29 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 2373 | 46711413 | | 0.28 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 2375 | 46521409 | 27 E TUOLUMNE ST | 0.08 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2376 | 46521502 | 112 E STANISLUAS ST | 0.08 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2377 | 46517503 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2378 | 46517212 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2379 | 46517213 | | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2381 | 46512540 | | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | APPENDIX 1E: CITY OF FRESNO | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 2382 | 46512541 | | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2383 | 46512542 | | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2384 | 46512543 | | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2385 | 46512544 | | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2386 | 46512545 | | 0.10 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2387 | 46512546 | | 0.18 | Residential - Medium Density | RS-5 | 8.4 | 2 | Above Moderate | YES | | | 2388 | 46411312 | 238 W LEMON AVE | 0.67 | Residential - Medium Density | RS-5 | 8.4 | 6 | Above Moderate | YES | | | 2389 | 45822012 | 608 S THORNE AVE | 1.38 | Residential - Medium Density | RS-5 | 8.4 | 12 | Above Moderate | YES | | | 2390 | 45821220 | 154 W EL DORADO ST | 0.38 | Residential - Medium Density | RS-5 | 8.4 | 3 | Above Moderate | YES | | | 2391 | 45821219 | 152 W EL DORADO ST | 0.12 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2392 | 45821180 | | 0.09 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2393 | 46710306 | | 0.22 | Downtown Neighborhood | DTN | 76.0 | 17 | Above Moderate | YES | | | 2394 | 46706327 | | 0.02 | Downtown Neighborhood | DTN | 76.0 | 1 | Above Moderate | NO | | | 2395 | 46706321 | | 0.03 | Downtown Neighborhood | DTN | 76.0 | 3 | Above Moderate | NO | | | 2396 | 46707307T | | 0.28 | Downtown Neighborhood | DTN | 76.0 | 21 | Above Moderate | YES | | | 2397 | 46827110 | | 0.17 | Downtown Neighborhood | DTN | 76.0 | 13 | Above Moderate | NO | | | 2398 | 46827121 | 347 L ST | 0.08 | Downtown Neighborhood | DTN | 76.0 | 6 | Above Moderate | NO | | | 2399 | 46823423 | 348 L ST | 0.18 | Downtown Neighborhood | DTN | 76.0 | 13 | Above Moderate | NO | | | 2400 | 45930121 | 146 N BROADWAY | 0.12 | Neighborhood Mixed-Use | NMX | 32.0 | 4 | Above Moderate | NO | | | 2401 | 45913220 | | 0.02 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2402 | 45930605 | 945 E DIVISADERO ST | 0.11 | Neighborhood Mixed-Use | NMX | 32.0 | 3 | Above Moderate | NO | | | 2403 | 45916121 | 1728 E GRANT AVE | 0.31 | Corridor - Center Mixed Use | CMX | 37.50 | 12 | Above Moderate | NO | | | 2404 | 45229316 | | 0.09 | Neighborhood Mixed-Use | NMX | 32.0 | 3 | Above Moderate | NO | | | 2405 | 45230227 | | 0.06 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2406 | 45933309 | 119 N DIANA ST | 0.11 | Neighborhood Mixed-Use | NMX | 32.0 | 4 | Above Moderate | NO | | | 2407 | 45933310 | 115 N DIANA ST | 0.11 | Neighborhood Mixed-Use | NMX | 32.0 | 4 | Above Moderate | NO | | | 2408 | 45917135 | | 0.02 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2409 | 45907403 | 459 N CLARK ST | 0.13 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2410 | 45908125 | | 0.06 | Neighborhood Mixed-Use | NMX | 32.0 | 2 | Above Moderate | NO | | | 2411 | 45927107 | 263 N U ST | 0.12 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2413 | 45613121 | 726 N PEACH AVE | 0.21 | Residential - Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 2414 | 45613122 | 712 N PEACH AVE | 0.11 | Residential - Low Density | RS-4 | 4.8 | 1 | Above Moderate | NO | | | 2415 | 30307111 | | 0.06 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2416 | 30307112 | | 0.06 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2417 | 30307106 | 463 W MINARETS AVE | 0.06 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2418 | 30307107 | 461 W MINARETS AVE | 0.06 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2419 | 30307104 | | 0.06 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2420 | 40805031 | | 0.91 | Residential - Medium Density | RS-5 | 8.4 | 8 | Above Moderate | NO | | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-7-39 SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Assumed Density (per acre) | Units | Income Level | In 5th Cycle Housing Element? | Environmental Constraint | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 2421 | 40805034 | 6507 N FRESNO ST | 22.28 | Residential - Medium Density | RS-5 | 8.4 | 187 | Above Moderate | NO | | | 2422 | 45933209 | 131 N EFFIE AVE | 0.09 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2423 | 46327025 | 127 S FINE AVE | 1.22 | Residential - Medium Density | RS-5 | 8.4 | 10 | Above Moderate | NO | | | 2424 | 47706006 | | 4.54 | Residential - Medium Density | RS-5 | 8.4 | 38 | Above Moderate | NO | | | 2460 | 47020227 | 3853 E LIBERTY AVE | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2461 | 47027215 | | 0.14 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | YES | | | 2471 | 46828612
46828610
46828609 | 702 H ST | 0.60 | Downtown Neighborhood | DTN | 76.0 | 46 | Lower | NO | | | 2472 | 47902043
47902044 | 2434 S ELM AVE | 6.73 | Corridor - Center Mixed Use | CMX | 37.5 | 253 | Lower | NO | | | 2474 | 45230604 | 2040 E WHITE AVE | 0.17 | Residential - Medium Density | RS-5 | 8.4 | 1 | Above Moderate | NO | | | 2475 | 31310124 | | 2.96 | Commercial - Regional | CR | | 240 | Moderate | NO | | | 2476 | 40303051 | E SHEPHERD AVE AND N CHANCE AVE | 2.77 | Residential - Urban Neighborhood | RM-2 | 18 | 50 | Lower | YES | | | 2477 | 50020027S
50020028S
50020029S | W HERNDON AVE AND N PROSPECT AVE | 3.78 | Residential - Urban Neighborhood | RM-2 | 18 | 68 | Lower | YES | | | 2482 | 43011050 | 4527 E ALAMOS AVE | 0.40 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | 2483 | 43009043 | | 0.37 | Residential - Medium Low Density | RS-4 | 4.8 | 1 | Above Moderate | YES | | | | | | | | | Total | 22,232 | | | | *Source: City of Fresno, Ascent, 2024.* APPENDIX 1E: CITY OF FRESNO ### Table 1E-7.2: Capacity on Underutilized Non-Vacant Sites, City of Fresno, September 2024 | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Max Density (per acre) | Assumed Density (per acre) | Development Likelihood | Lower-Income Units | Moderate-Income Units | Above-Moderate Income Units | Total | In 5th Cycle Housing Element? | Environmental Constraint | Existing Use | Non-Vacant Site Category | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 21 | 57939019S | 2254 E Copper Cl | 12.86 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 108 | 108 | NO | | Split zoned parcel. House on portion of parcel. Agriculture. | A | | 22 | 57939019S | 2254 E Copper Cl | 6.27 | Residential - Medium High Density | RM-1 | 16 | 13.6 | 100% | | 85 | | 85 | NO | | Split zoned parcel. Agriculture. | A | | 115 | 40710207 | 6353 N Blackstone Ave | 0.49 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | | | 18 | 18 | NO | | Surface parking lot | E | | 116 | 40914048 | | 0.36 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | | | 10 | 10 | YES | | Access constraints | C | | 117 | 40915051 | | 1.71 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | 64 | | | 64 | YES | | Church parking lot | E | | 123 | 41845013 | | 0.92 | Regional Mixed-Use | RMX | 90 | 45 | 100% | 41 | | | 41 | YES | | Parking lot, Racetrack. | E | | 127 | 41734223 | 20 W Shaw Ave | 10.65 | Regional Mixed-Use | RMX | 90 | 45 | 100% | 57 | 172 | 57 | 286 | YES | | Some vacant land within parcel; assortment of existing uses | D | | 155 | 42710137 | 4724 N Blackstone Ave | 1.77 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | 67 | | | 67 | NO | | Small Building; Large surface parking/paved area | D | | 156 | 42710117 | | 0.99 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | 37 | | | 37 | NO | | Paved | C | | 157 | 42717125 | 4678 N Blackstone Ave | 4.25 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | 159 | | | 159 | NO | | Over half of parcel is vacant | D | | 158 | 42533209 | 4631 N Blackstone Ave | 0.75 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | 28 | | | 28 | NO | | Back half parcel is vacant | D | | 159 | 42609216 | 4549 N Blackstone Ave | 1.16 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | 44 | | | 44 | NO | | Back half parcel is vacant | D | | 268 | 44503122 | 3034 N Blackstone Ave | 0.65 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | 21 | | | 21 | NO | | Paved | D | | 306 | 31324054 | | 1.42 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | 53 | | | 53 | NO | | Half of parcel is parking lot | E | | 311 | 47403075 | 5698 E Kings Canyon Rd | 0.33 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | | | 12 | 12 | YES | | Paved | C | | 312 | 47403054 | 5674 E Kings Canyon Rd | 2.83 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | 106 | | | 106 | YES | | Some of parcel paved | E | | 387 | 31602201 | 2149 S Clovis Ave | 10.32 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 50 | 50 | YES | | Residence on parcel | B | | 415 | 46306017 | 525 S Peach Ave | 2.42 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | 91 | | | 91 | YES | | Portion is paved parking | E | | 425 | 48112003 | 2534 S Peach Ave | 19.50 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 164 | 164 | YES | | Residence and Agriculture | A | | 429 | 48111020 | | 2.65 | Residential - Medium High Density | RM-1 | 16 | 13.6 | 100% | | 36 | | 36 | YES | FEMA 100-year flood zone | Agricultural structures on half of parcel | A | | 449 | 48008005 | 2200 S Chestnut Ave | 17.85 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 150 | 150 | YES | | Residence, Agriculture | A | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 | 1E-7-41 SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Max Density (per acre) | Assumed Density (per acre) | Development Likelihood | Lower-Income Units | Moderate-Income Units | Above-Moderate Income Units | Total | In 5th Cycle Housing Element? | Environmental Constraint | Existing Use | Non-Vacant Site Category | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 466 | 46130321 | 4741 E Kings Canyon Rd | 0.55 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | 21 | | | 21 | NO | | Paved parking, vacant pad | C | | 480 | 45424103 | 774 N Maple Ave | 2.12 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | 68 | | | 68 | YES | | Paved | C | | 508 | 45423205 | 4582 E Harvey Ave | 8.15 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | 261 | | | 261 | NO | | Paved, but most of parcel is vacant, building in corner | C | | 512 | 45431401 | 4555 E Belmont Ave | 0.69 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | 22 | | | 22 | NO | | half of parcel is vacant | D | | 513 | 46007227 | 4584 E Belmont Ave | 0.23 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | | | 7 | 7 | YES | | paved | C | | 516 | 46006203 | | 0.12 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | | | 4 | 4 | YES | | Paved, car storage | D | | 569 | 46027409 | 3449 E Tulare St | 0.60 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | 19 | | | 19 | YES | | Half of parcel vacant | D | | 601 | 45426213 | 3217 E Belmont Ave | 0.05 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | | | 2 | 2 | NO | | Portion paved | C | | 630 | 44518119 | 2736 N Blackstone Ave | 0.55 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | 18 | | | 18 | NO | | Surface parking | E | | 650 | 45222415 | 735 N Abby St | 0.24 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | | | 8 | 8 | YES | | Portion paved | C | | 653 | 45214117 | 902 N Blackstone Ave | 0.30 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | | | 10 | 10 | YES | | Paved | C | | 657 | 45129632 | 1206 N Effie St | 1.01 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | 32 | | | 32 | NO | FEMA 100-year flood zone | Paved | C | | 659 | 45113515 | 1407 N Blackstone Ave | 1.02 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | 33 | | | 33 | NO | | Portion of parcel is vacant | D | | 671 | 45211510 | 958 N Fulton St | 0.51 | Commercial - Main Street | CMS | 48 | 24 | 100% | 12 | | | 12 | NO | | Part of parcel is vacant | D | | 673 | 45204103 | 1145 N Van Ness Ave | 0.23 | Commercial - Main Street | CMS | 48 | 24 | 100% | | | 6 | 6 | NO | | Paved Parking | E | | 675 | 45126404 | 849 E Fern Ave | 0.41 | Commercial - Main Street | CMS | 48 | 24 | 100% | | | 10 | 10 | NO | | Part of parcel is vacant | D | | 677 | 45126315 | | 0.14 | Residential - Urban Neighborhood | RM-2 | 30 | 18 | 100% | | | 2 | 2 | NO | | Paved | C | | 686 | 45903304 | 540 E Belmont Ave | 0.14 | Commercial - Main Street | CMS | 48 | 24 | 100% | | | 3 | 3 | YES | | Paved, poor condition overgrown | C | | 703 | 45020302 | 108 E Olive Ave | 0.32 | Commercial - Main Street | CMS | 48 | 24 | 100% | | | 8 | 8 | NO | | Half of parcel vacant | D | | 705 | 45020224 | 48 E Olive Ave | 0.28 | Commercial - Main Street | CMS | 48 | 24 | 100% | | | 7 | 7 | NO | | Paved | C | | 723 | 43323003 | 1783 W Dakota Ave | 1.15 | Residential - Medium High Density | RM-1 | 16 | 13.6 | 100% | | 16 | | 16 | YES | | Old cement pads | C | | 737 | 42402202 | 3503 W Shaw Ave | 9.55 | Regional Mixed-Use | RMX | 90 | 45 | 100% | 430 | | | 430 | YES | FEMA 100-year flood zone | Large portion of parcel is vacant | D | | 738 | 41504449 | | 1.23 | Regional Mixed-Use | RMX | 90 | 45 | 100% | 55 | | | 55 | YES | | Parking lot; vacant portion | E | | 739 | 41504441 | 3440 W Shaw Ave | 0.84 | Regional Mixed-Use | RMX | 90 | 45 | 100% | 38 | | | 38 | YES | | Some vacant | D | | 741 | 41504445 | 3770 W Shaw Ave | 2.45 | Regional Mixed-Use | RMX | 90 | 45 | 100% | 110 | | | 110 | YES | | Parking, vacant pads | E | | 808 | 50508029S | | 11.92 | Residential - Urban Neighborhood | RM-2 | 30 | 18 | 100% | 214 | | | 214 | YES | | Agriculture | A | | 821 | 50506007 | 5326 N Grantland Ave | 28.65 | Regional Mixed-Use | RMX | 90 | 45 | 50% | 77 | 232 | 7 | 386 | YES | | Agriculture | A | | 822 | 50506033 | North of W Shaw Ave and N Bryan Ave intersection | 2.30 | Corridor - Center Mixed Use | CMX | 75 | 38 | 50% | 26 | | | 26 | NO | | Agriculture | A | | 823 | 50506020 | 6824 W Shaw Ave | 2.84 | Regional Mixed-Use | RMX | 90 | 45 | 50% | 38 | | | 38 | YES | | Residence and Trucking | D | | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Max Density (per acre) | Assumed Density (per acre) | Development Likelihood | Lower-Income Units | Moderate-Income Units | Above-Moderate Income Units | Total | In 5th Cycle Housing Element? | Environmental Constraint | Existing Use | Non-Vacant Site Category | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 824 | 50506019 | 6730 W Shaw Ave | 16.52 | Regional Mixed-Use | RMX | 90 | 45 | 50% | 45 | 134 | 45 | 224 | YES | | Residence and Agriculture. Not used for ag in many years. Now new APN. Part of this land is under construction for on/off ramp to Veterans Blvd | B | | 825 | 50506016S | W Shaw Ave east of N Grantland Ave | 14.93 | Regional Mixed-Use | RMX | 90 | 45 | 50% | 40 | 121 | 40 | 201 | YES | | Agriculture; split zoned parcel | A | | 829 | 50803027 | N Island Waterpark Dr | 3.62 | Regional Mixed-Use | RMX | 90 | 45 | 50% | 49 | | | 49 | YES | | Agriculture; split zoned parcel | A | | 852 | 51203205 | 4935 N Hayes Ave | 4.02 | Residential - Urban Neighborhood | RM-2 | 30 | 18 | 100% | 72 | | | 72 | NO | | Agriculture | A | | 853 | 51203203 | 6277 W Shaw Ave | 19.23 | Residential High Density | RM-3 | 45 | 34 | 100% | 130 | 389 | 130 | 649 | NO | | Agriculture; Canal through middle of parcel. | A | | 854 | 51203202 | 6435 W Shaw Ave | 8.77 | Residential High Density | RM-3 | 45 | 34 | 100% | 296 | | | 296 | NO | | Agriculture | A | | 860 | 51201004 | | 4.72 | Residential - Urban Neighborhood | RM-2 | 30 | 18 | 100% | 85 | | | 85 | YES | | Agriculture | A | | 977 | 51202150S | | 18.69 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 157 | 157 | NO | | Agriculture; Split zoning, removed NV | A | | 978 | 51202126 | 4445 N Grantland Ave | 126.76 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 1,065 | 1,065 | YES | | Agriculture; Split zoning, removed CC | A | | 979 | 51204317S | | 22.57 | Residential - Urban Neighborhood | RM-2 | 30 | 18 | 100% | 81 | 244 | 81 | 406 | YES | | Agriculture; Split zoned parcel | A | | 980 | 51204319 | | 4.95 | Residential - Urban Neighborhood | RM-2 | 30 | 18 | 100% | 89 | | | 89 | YES | | Agriculture; Split zoned parcel | A | | 981 | 51204312S | | 19.12 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 161 | 161 | YES | | Agriculture | A | | 982 | 51204319 | | 4.62 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 39 | 39 | YES | | Agriculture; Split zoned parcel | A | | 983 | 51204329T | | 19.11 | Residential - Medium Density | RS-5 | 12 | 8 | 50% | | | 80 | 80 | YES | | Agriculture | A | | 984 | 51204324 | | 4.78 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 40 | 40 | YES | | Agriculture | A | | 985 | 51204323 | 3361 N Grantland Ave | 28.69 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 241 | 241 | YES | | Agriculture | A | | 986 | 51204326 | | 40.94 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 344 | 344 | YES | | Agriculture; Split zoned | A | | 1026 | 44202243 | 3119 W Clinton Ave | 9.63 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 81 | 81 | YES | | Single residence on corner of parcel; Canal through middle of site | B | | 1040 | 44923118 | 1718 W Olive Ave | 0.71 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | 23 | | | 23 | YES | | Northern portion of parcel is vacant | D | | 1042 | 44926040 | 1915 W Olive Ave | 2.08 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | 67 | | | 67 | NO | | Part of parcel is vacant | D | | 1047 | 44927050 | 1015 N West Ave | 0.93 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | 30 | | | 30 | NO | | Residence on portion of parcel (fenced off); rest of parcel vacant | B | | 1057 | 44934201 | 1411 W Thomas Ave | 0.27 | Residential - Low Density | RS-3 | 4 | 3 | 100% | | | 1 | 1 | YES | | Portion paved | C | | 1064 | 45811318 | 919 W Belmont Ave | 0.45 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | | | 14 | 14 | NO | | Half of parcel is vacant; residences on parcel separated by fence | B | SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Max Density (per acre) | Assumed Density (per acre) | Development Likelihood | Lower-Income Units | Moderate-Income Units | Above-Moderate Income Units | Total | In 5th Cycle Housing Element? | Environmental Constraint | Existing Use | Non-Vacant Site Category | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1076 | 32610076 | 3555 W Whites Bridge Ave | 18.38 | Residential - Urban Neighborhood | RM-2 | 30 | 18 | 100% | 66 | 199 | 66 | 331 | NO | | Agriculture | A | | 1077 | 32610055 | | 13.22 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 63 | 63 | YES | | Agriculture | A | | 1079 | 32610022 | 3209 W Whites Bridge Ave | 9.57 | Residential - Urban Neighborhood | RM-2 | 30 | 18 | 100% | 172 | | | 172 | YES | | Agriculture | A | | 1080 | 32610027 | | 9.51 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 46 | 46 | YES | | Agriculture | A | | 1084 | 46402008 | 2119 W Whites Bridge Ave | 1.11 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 5 | 689 | YES | | Agriculture | A | | | 46402009 | | 1.59 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 8 | | | | | A | | | 46402035 | | 1.76 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 8 | | | | | A | | | 46402037 | 2745 W Whites Bridge Ave | 4.55 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 22 | | | | | A | | | 46402012 | 1106 S Hughes Ave | 4.69 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 23 | | | | | A | | | 46402034 | 2531 W Whites Bridge Ave | 4.69 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 23 | | | | | A | | | 46402013 | | 4.92 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 24 | | | | | A | | | 46402026 | | 5.83 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 28 | | | | | A | | | 46402028 | 2840 W Kearney Blvd | 7.80 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 37 | | | | | A | | | 46402036 | | 9.31 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 45 | | | | | A | | | 46402019 | 118 S Marks Ave | 9.38 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 45 | | | | | A | | | 46402031 | 2504 W Kearney Blvd | 9.49 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 46 | | | | | A | | | 46402029 | 2810 W Kearney Blvd | 9.49 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 46 | | | | | A | | | 46402030 | 2510 W Kearney Blvd | 9.50 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 46 | | | | | A | | | 46402007 | 700 S Hughes Ave | 10.83 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 52 | | | | | A | | | 46402015 | 842 S Hughes Ave | 18.34 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 88 | | | | | A | | | 46402025 | | 24.72 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 119 | | | FEMA 100-year flood zone | | A | | 1106 | 46402015 | 2845 W Kearney Blvd | 17.22 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 83 | 83 | YES | | Agriculture | A | APPENDIX 1E: CITY OF FRESNO | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Max Density (per acre) | Assumed Density (per acre) | Development Likelihood | Lower-Income Units | Moderate-Income Units | Above-Moderate Income Units | Total | In 5th Cycle Housing Element? | Environmental Constraint | Existing Use | Non-Vacant Site Category | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1107 | 46406013 | 604 S Marks Ave | 13.07 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 63 | 63 | YES | FEMA 100-year flood zone | Multi-part parcel, this only includes Agriculture, not house | A | | 1108 | 46406017 | 2448 W California Ave | 30.77 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 148 | 148 | YES | FEMA 100-year flood zone | Agriculture; Multi-part parcel | A | | 1109 | 46406017 | 2448 W California Ave | 2.71 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 13 | 13 | YES | FEMA 100-year flood zone | Agriculture; Multi-part parcel | A | | 1110 | 46406017 | 2448 W California Ave | 17.06 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 82 | 82 | YES | | Agriculture; Multi-part parcel | A | | 1111 | 46406017 | 2448 W California Ave | 16.75 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 80 | 80 | YES | | Agriculture; Multi-part parcel | A | | 1112 | 46407010 | | 9.05 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 43 | 43 | YES | | Agriculture | A | | 1118 | 47702118 | 2388 W Church Ave | 1.24 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 6 | 261 | NO | | Agriculture | A | | | 47702125 | | 7.06 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 34 | | YES | | Agriculture | A | | | 47702111 | 2184 S Hughes Ave | 9.32 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 45 | | YES | | Agriculture | A | | | 47702119 | 2404 W Church Ave | 17.07 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 82 | | YES | | Agriculture | A | | | 47702109 | 2449 W California Ave | 19.55 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 94 | | YES | | Agriculture | A | | | 47702120 | 2550 W Church Ave | 34.23 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 164 | 164 | YES | | Agriculture | A | | 1119 | 47702114 | 2394 S Hughes Ave | 20.98 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 101 | 101 | YES | | Residence; Agriculture | A | | 1186 | 47703029S | 633 W Church Ave | 18.62 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 156 | 156 | NO | | Agriculture | A | | 1187 | 47703015 | | 14.85 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 125 | 125 | YES | | Agriculture | A | | 1189 | 47703004 | | 19.35 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 163 | 163 | YES | | Agriculture | A | | 1190 | 47703028 | 194 W Church Fr | 19.60 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 188 | 188 | YES | | Agriculture | A | | 1223 | 32808001S | 2867 S Walnut Ave | 18.80 | Residential - Urban Neighborhood | RM-2 | 30 | 18 | 100% | 68 | 203 | 68 | 339 | YES | | Agriculture | A | | 1224 | 32808009 | 2911 S Walnut Ave | 6.66 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 32 | 32 | YES | | Agriculture | A | | 1225 | 32808002 | | 19.69 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 165 | 165 | YES | | Agriculture | A | | 1226 | 32808003 | | 14.53 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 122 | 122 | YES | | Agriculture; Parcel with split zoning | A | | 1227 | 32808003 | | 5.16 | Open Space - Community Park | RM-1 | 16 | 13.6 | 100% | | 70 | | 70 | NO | | Agriculture; Parcel with split zoning | A | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-7-45 SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Max Density (per acre) | Assumed Density (per acre) | Development Likelihood | Lower-Income Units | Moderate-Income Units | Above-Moderate Income Units | Total | In 5th Cycle Housing Element? | Environmental Constraint | Existing Use | Non-Vacant Site Category | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1289 | 47921116 | 2593 S Elm Ave | 0.27 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | | | 10 | 10 | NO | | Vacant/Run-down building | D | | 1293 | 47921217 | 2493 S Elm Ave | 0.27 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | | | 10 | 10 | NO | | Vacant/Rundown building | D | | 1412 | 46715418 | | 0.17 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 1 | 1 | YES | | Paved | C | | 1493 | 46706203T | 1141 G St | 0.26 | Downtown Neighborhood | DTN | N/A | 76 | 100% | | | 20 | 20 | YES | | Parking | E | | 1494 | 46706206 | 1115 G St | 0.00 | Downtown Neighborhood | DTN | N/A | 76 | 100% | 46 | | | 46 | YES | | Vacant/rundown feed supply | D | | | 46706207 | | 0.00 | | | | | | | | | | | | | | | | 46706205 | 1121 G St | 0.60 | | | | | | | | | | | | | | | 1495 | 46710202 | 1133 E St | 0.34 | Downtown Neighborhood | DTN | N/A | 76 | 100% | | | 26 | 26 | YES | | Paved | C | | 1497 | 46706606 | 1010 E St | 0.86 | Downtown Neighborhood | DTN | N/A | 76 | 100% | 66 | | | 66 | YES | | Vacant building; parking lot; vacant land | D | | 1499 | 46706604 | 1025 F St | 0.17 | Downtown Neighborhood | DTN | N/A | 76 | 100% | | | 13 | 13 | YES | | Paved | C | | 1501 | 46706615 | 1061 F St | 0.22 | Downtown Neighborhood | DTN | N/A | 76 | 100% | | | 16 | 16 | YES | | Paved | C | | 1523 | 46707410T | 930 E St | 0.35 | Downtown Neighborhood | DTN | N/A | 76 | 100% | | | 26 | 26 | YES | | Parking Lot | E | | 1525 | 46707115 | 935 China Alley | 0.17 | Downtown Neighborhood | DTN | N/A | 76 | 100% | 71 | | | 71 | NO | | Abandoned building falling apart | D | | | 46707120 | | 0.60 | | | | | | | | | | | | | | | 1532 | 46708116T | 655 G St | 0.35 | Downtown Neighborhood | DTN | N/A | 76 | 100% | | | 26 | 26 | YES | | Paved | C | | 1561 | 46705017S | 501 H St | 1.62 | Downtown Neighborhood | DTN | N/A | 76 | 100% | 123 | | | 123 | YES | | Paved | C | | 1564 | 46829507 | 507 Broadway | 0.43 | Downtown Neighborhood | DTN | N/A | 76 | 100% | | | 33 | 33 | YES | | Parking/paved | E | | | 46829503 | | | | | | | | | | | | | | | | | 1566 | 46829207 | 1920 Ventura St | 0.42 | Downtown Neighborhood | DTN | N/A | 76 | 100% | 66 | | | 66 | YES | | Warehouse/paved | D | | | 46829206 | 534 Broadway | | | | | | | | | | | | | | | | 1567 | 46829204 | 1929 Santa Clara St | 0.24 | Downtown Neighborhood | DTN | N/A | 76 | 100% | | | 18 | 18 | YES | | Paved; Business on small portion | D | | 1570 | 46826519 | 2010 Ventura St | 1.10 | Downtown Neighborhood | DTN | N/A | 76 | 100% | 83 | | | 83 | YES | | Parking | E | | 1579 | 46819534T | 2402 Ventura St | 0.73 | Downtown General | DTG | N/A | 83 | 100% | 61 | | | 61 | YES | | Only counting vacant part of parcel | C | | 1582 | 46819237 | 534 O St | 0.24 | Downtown General | DTG | N/A | 83 | 100% | | 20 | | 20 | YES | | Paved | C | | | 46819236 | 530 O St | | | | | | | | | | | | | | | | 1585 | 46811417 | 662 R St | 0.51 | Downtown Neighborhood | DTN-AH | N/A | 32 | 100% | 16 | | | 16 | YES | | Vacant building | D | | 1587 | 46816101 | 2748 Tulare St | 0.34 | Downtown General | DTG | N/A | 83 | 100% | | | 28 | 28 | YES | | Parking lot | E | | 1591 | 46840054T | | 2.87 | Downtown General | DTG | N/A | 83 | 100% | 238 | | | 238 | YES | | Parking lot | E | | 1596 | 46826414 | 2026 Mono St | 0.52 | Downtown General | DTG | N/A | 83 | 100% | 43 | | | 43 | YES | | Parking lot | E | | 1598 | 46826413S | 625 Van Ness Ave | 0.60 | Downtown General | DTG | N/A | 83 | 100% | 50 | | | 50 | YES | | Parking lot | E | | 1600 | 46829115 | 643 Fulton St | 0.26 | Downtown Neighborhood | DTN | N/A | 76 | 100% | | | 20 | 20 | YES | | Paved | C | | 1601 | 46828606 | 715 Broadway | 0.43 | Downtown Neighborhood | DTN | N/A | 80 | 100% | | | 33 | 33 | YES | | Paved; Vacant building | D | | 1603 | 46828608 | 704 H ST | 0.60 | Downtown Neighborhood | DTN | N/A | 80 | 100% | 46 | | | 46 | YES | | Vacant, rundown buildings | D | | 1606 | 46621522T | 1822 Fresno St | 2.78 | Downtown Core | DTC | N/A | 90 | 100% | 250 | | | 250 | YES | | Parking lot; HSR MP | E | | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Max Density (per acre) | Assumed Density (per acre) | Development Likelihood | Lower-Income Units | Moderate-Income Units | Above-Moderate Income Units | Total | In 5th Cycle Housing Element? | Environmental Constraint | Existing Use | Non-Vacant Site Category | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1607 | 46621426T | | 0.32 | Downtown Core | DTC | N/A | 90 | 100% | 70 | | | 70 | YES | | Parking lot; HSR MP | E | | | 46621427T | | 0.46 | | | | | | | | | | | | | | | 1609 | 46620654 | | 0.69 | Downtown Core | DTC | N/A | 90 | 100% | 62 | | | 62 | YES | | Parking lot | E | | 1610 | 46703039ST | 1705 Fresno St | 2.25 | Downtown Core | DTC | N/A | 90 | 100% | 202 | | | 202 | YES | | Dairy Semi-truck Parking; Consolidation potential, need ownership; HSR MP | E | | 1612 | 46504038ST | 1301 H St | 2.98 | Downtown Core | DTC | N/A | 90 | 100% | 268 | | | 268 | YES | | Small building on site | D | | 1615 | 46620650T | 1900 Tuolumne St | 1.32 | Downtown Core | DTC | N/A | 90 | 100% | | 56 | 56 | 112 | YES | | Parking lot (IRS building). IIGC Site HD5; on this site is proposed Market 1. | E | | | 46620651T | | 0.06 | | | | | | | | | | | | | | | 1617 | 46615318 | 2000 Tuolumne St | 0.65 | Downtown Core | DTC | N/A | 90 | 100% | 139 | | | 139 | YES | | The Business Journal Parking lot. IIGC Site HD1 and HD3. HD1 is planned for student housing and HD3 is planned to receive LIHTC funding. | E | | | ROW | | 0.05 | | | | | | | | | | | | | | | | 46615314 | | 0.55 | | | | | | | | | | | | | | | 1618 | 46615315 | 1315 Van Ness Ave | 0.52 | Downtown Core | DTC | N/A | 90 | 100% | | 50 | 50 | 100 | YES | | CVS Parking lot. IIGC Site HD6; on this is proposed Market 2. | E | | | ROW | | 0.34 | | | | | | | | | | | | | | | 1622 | 46608313T | | 0.43 | Downtown Neighborhood | DTN | N/A | 76 | 100% | | | 33 | 33 | YES | | Parking lot | E | | 1623 | 46608319T | 1357 O St | 0.43 | Downtown Neighborhood | DTN | N/A | 76 | 100% | | | 33 | 33 | YES | | Parking lot | E | | 1624 | 46608121 | 1320 O St | 0.52 | Downtown Neighborhood | DTN | N/A | 76 | 100% | 39 | | | 39 | YES | | Parking lot | E | | 1646 | 46619602 | 1635 Broadway | 0.35 | Downtown Neighborhood | DTN | N/A | 76 | 100% | | | 27 | 27 | YES | | Parking lot | E | | 1647 | 46619204 | 1704 Broadway | 0.16 | Downtown Neighborhood | DTN | N/A | 76 | 100% | | | 12 | 12 | YES | | Parking lot | E | | 1649 | 46619207 | | 0.16 | Downtown Neighborhood | DTN | N/A | 76 | 100% | | | 12 | 12 | YES | | Parking lot | E | | 1652 | 46613402 | 1753 Van Ness Ave | 0.13 | Downtown Neighborhood | DTN | N/A | 76 | 100% | | | 10 | 10 | YES | | Small commercial buildings | D | | 1655 | 46613124 | 1118 E Divisadero St | 0.32 | Downtown Neighborhood | DTN | N/A | 76 | 100% | | | 24 | 24 | YES | | Portion is parking lot | E | | 1657 | 46613333 | 946 E Divisadero St | 0.25 | Downtown Neighborhood | DTN | N/A | 76 | 100% | | | 19 | 19 | YES | | Paved and vacant business | D | | 1659 | 46618315 | 2013 Broadway | 0.42 | Downtown Neighborhood | DTN | N/A | 76 | 100% | | | 32 | 32 | YES | | Parking and Business | E | | 1660 | 46502002 | 510 E Divisadero St | 0.79 | Downtown Neighborhood | DTN | N/A | 76 | 100% | 60 | | | 60 | YES | | Paved (poor condition) | C | | 1680 | 45933139 | 149 N Abby St | 0.63 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | 24 | | | 24 | NO | | Parking lot | E | | 1681 | 45925127 | 231 N Abby St | 0.28 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | | | 10 | 10 | NO | | Parking lot | E | | 1683 | 45916125 | 333 N Abby St | 0.16 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | | | 6 | 6 | NO | | Multi-part parcel: this piece paved/vacant | C | SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Max Density (per acre) | Assumed Density (per acre) | Development Likelihood | Lower- Income Units | Moderate- Income Units | Above- Moderate Income Units | Total | In 5th Cycle Housing Element? | Environmental Constraint | Existing Use | Non-Vacant Site Category | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 1684 | 45916125 | 333 N Abby St | 0.48 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | | | 18 | 18 | NO | | Multi-part parcel; restaurant and parking lot | D | | 1687 | 45907105 | 453 N Abby St | 0.16 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | | | 6 | 6 | NO | | Paved | E | | 1691 | 45229434 | | 0.11 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 1 | 1 | NO | | Paved | C | | 1726 | 45909104 | 2542 E Belmont Ave | 0.10 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | | | 3 | 3 | NO | | Paved pad | C | | 1727 | 45909109 | 2636 E Belmont Ave | 0.15 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | | | 5 | 5 | NO | | Half of parcel vacant | D | | 1732 | 45927120 | | 0.13 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | | | 4 | 4 | YES | | Paved, poor condition | C | | 1733 | 45927128 | 230 N Fresno St | 0.14 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | | | 4 | 4 | YES | | Paved | C | | 1740 | 46606611S | 2710 Fresno St | 1.10 | Downtown Neighborhood | DTN | N/A | 76 | 100% | 84 | | | 84 | YES | | Parking lot | E | | 2428 | 45426214 | 3211 E Belmont Ave | 0.09 | Neighborhood Mixed-Use | NMX | 64 | 32 | 100% | | | 3 | 3 | NO | | Portion paved | C | | 2429 | 45126316 | | 0.11 | Residential - Urban Neighborhood | RM-2 | 30 | 18 | 100% | | | 2 | 2 | NO | | Paved | C | | 2430 | 50506041 | 6556 W Shaw Ave | 2.31 | Corridor - Center Mixed Use | CMX | 75 | 38 | 50% | 26 | | | 27 | NO | | Agriculture | A | | 2431 | 50506042 | W Shaw Ave north of intersection with N Bryan Ave | 2.12 | Corridor - Center Mixed Use | CMX | 75 | 38 | 50% | 24 | | | 24 | NO | | Agriculture | A | | 2432 | 50506043 | 6518 W Shaw Ave | 11.00 | Corridor - Center Mixed Use | CMX | 75 | 38 | 50% | 124 | | | 124 | NO | | Agriculture; Residence. | A | | 2433 | 50506036 | North of W Shaw Ave & N Grantland Ave intersection | 2.34 | Regional Mixed-Use | RMX | 90 | 45 | 50% | 32 | | | 32 | YES | | Agriculture | A | | 2434 | 50506037 | 6972 W Shaw Ave | 3.93 | Regional Mixed-Use | RMX | 90 | 45 | 50% | 53 | | | 53 | YES | | Agriculture; Farm Stand | A | | 2435 | 50506038 | East of 6972 W Shaw Ave | 2.30 | Regional Mixed-Use | RMX | 90 | 45 | 50% | 31 | | | 32 | YES | | Agriculture | A | | 2436 | 50506034 | North of W Shaw Ave & N Bryan Ave | 2.30 | Corridor - Center Mixed Use | CMX | 75 | 38 | 50% | 26 | | | 26 | NO | | Agriculture | A | | 2437 | 50506017 | 6392 W Shaw Ave | 20.31 | Corridor - Center Mixed Use | CMX | 75 | 38 | 50% | 46 | 137 | 46 | 229 | YES | | Agriculture | A | | 2438 | 50506039 | West of 6150 W Shaw Ave | 0.85 | Corridor - Center Mixed Use | CMX | 75 | 38 | 50% | 10 | | | 10 | YES | | Agriculture | A | | 2439 | 50506040 | 6150 W Shaw Ave | 14.31 | Corridor - Center Mixed Use | CMX | 75 | 38 | 50% | 32 | 97 | 32 | 161 | YES | | Agriculture | A | | 2440 | 50506016S | W Shaw Ave east of N Grantland Ave | 4.20 | Corridor - Center Mixed Use | CMX | 75 | 38 | 50% | 9 | 28 | 9 | 46 | NO | | Agriculture; split zoned parcel | A | APPENDIX 1E: CITY OF FRESNO | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Max Density (per acre) | Assumed Density (per acre) | Development Likelihood | Lower-Income Units | Moderate-Income Units | Above-Moderate Income Units | Total | In 5th Cycle Housing Element? | Environmental Constraint | Existing Use | Non-Vacant Site Category | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 2441 | 51204318 | | 4.96 | Residential - Urban Neighborhood | RM-2 | 30 | 18 | 100% | 89 | | | 89 | YES | | Agriculture; Split zoned parcel | A | | 2442 | 51204320 | | 4.94 | Public Facility - Elementary School | RM-2 | 30 | 18 | 100% | 89 | | | 89 | NO | | Agriculture; Split zoned parcel | A | | 2443 | 51204321 | | 4.92 | Public Facility - Elementary School | RM-2 | 30 | 18 | 100% | 89 | | | 103 | NO | | Agriculture; Split zoned parcel | A | | 2444 | 51204322 | | 4.91 | Public Facility - Elementary School | RM-2 | 30 | 18 | 100% | 88 | | | 103 | NO | | Agriculture; Split zoned parcel | A | | 2445 | 51204313S | | 19.13 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 161 | 161 | YES | | Agriculture | A | | 2446 | 51204314 | | 19.14 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 161 | 161 | YES | | Agriculture; Canal through parcel | A | | 2447 | 51204315 | | 9.57 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 80 | 80 | YES | | Agriculture; Canal through parcel | A | | 2448 | 51204316 | | 9.57 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 80 | 80 | YES | | Agriculture; Canal through parcel | A | | 2449 | 51204317S | | 5.79 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 49 | 49 | YES | | Agriculture; Split zoned parcel | A | | 2450 | 51204318 | | 4.61 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 39 | 39 | YES | | Agriculture; Split zones parcel | A | | 2451 | 51204320 | | 4.63 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 39 | 39 | YES | | Agriculture; Split zoned parcel | A | | 2452 | 51204321 | | 4.64 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 39 | 39 | YES | | Agriculture; Split zoned parcel | A | | 2453 | 51204322 | | 4.65 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 39 | 39 | YES | | Agriculture; Split zoned parcel | A | | 2454 | 51204325 | | 4.78 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 40 | 40 | YES | | Agriculture | A | | 2455 | 51204328 | | 12.82 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 108 | 108 | YES | | Agriculture; Cut out basin on parcel | A | | 2456 | 32610067 | 3338 W Madison Ave | 4.98 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 24 | 24 | YES | | Agriculture | A | | 2457 | 32610069 | 3240 W Madison Ave | 32.75 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 157 | 157 | YES | | Agriculture | A | | 2458 | 46407011 | 2041 W Kearney Blvd | 9.05 | Residential - Medium Low Density | RS-4 | 6 | 4.8 | 100% | | | 43 | 43 | YES | | Agriculture | A | | 2463 | 45229435 | | 0.07 | Residential - Medium Density | RS-5 | 12 | 8 | 100% | | | 1 | 1 | YES | | Paved | C | | 2464 | 46613403 | 1747 Van Ness Ave | 0.13 | Downtown Neighborhood | DTN | N/A | 80 | 100% | | | 10 | 10 | YES | | Small commercial buildings | D | | 2465 | 46619211 | 1750 Broadway | 0.29 | Downtown Neighborhood | DTN | N/A | 80 | 100% | | | 22 | 22 | YES | | Parking lot | E | | 2466 | 46619205 | 1710 Broadway | 0.24 | Downtown Neighborhood | DTN | N/A | 80 | 100% | | | 18 | 18 | YES | | Parking lot | D | FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-7-49 SECTION 1E-7: DETAILED SITES INVENTORY TABLES | Site ID | APN | Address | Size (acres) | General Plan Land Use Designation | Zoning | Max Density (per acre) | Assumed Density (per acre) | Development Likelihood | Lower-Income Units | Moderate-Income Units | Above-Moderate Income Units | Total | In 5th Cycle Housing Element? | Environmental Constraint | Existing Use | Non-Vacant Site Category | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | 2473 | 46620656T | 1976 TUOLUMNE ST | 1.40 | Downtown Core | DTC | N/A | 90 | 100% | 117 | | | 117 | YES | | Parking lot for IRS building. Housing Authority owned site. Assumed that IRS building will remain. IIGC HD2 and HD4; HD2 is planned for student housing and HD4 is planned to receive LIHTC funds. | E | | 2478 | 31020103 | 3518 N Fowler | 58.05 | Residential - Urban Neighborhood | RM-2 | 30 | 18 | 100% | 68 | 122 | 68 | 258 | YES | | Residential/Agriculture. Previous developer interest in site for private gated multi-family townhouse community of 145 units (Sterling Townhomes). | D | | 2479 | 47902039 | 2410 S Elm | 0.36 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | | | 14 | 14 | NO | | Car Wash. Previous developer interest in site for horizontal mixed-use project of 190 market-rate studio, one-, two-, and three-bedroom apartment units (Elm Avenue Living). | D | | 2480 | 24705133 | 4914 N Blackstone | 3.30 | Corridor - Center Mixed Use | CMX | 75 | 38 | 100% | 124 | | | 124 | NO | | | | D | | 2481 | 44902013 | 2809 W McKinley | 0.80 | Rural Residential | NMX | 64 | 32 | 100% | 25 | | | 25 | NO | | Existing residential | B | | 2484 | 46704023ST

46704020S | H ST & MONO ST | 0.55

1.92 | Downtown Core | DTC | N/A | 90 | 100% | 100 | 97 | 97 | 294 | | | Recently demolished building on the parcel owned by the City. The other parcel is privately-owned owned by Fresno Sports and Events Partners Inc | E | | 2485 | 46707402 | 937 F ST | 0.33 | Downtown Neighborhood | DTN | N/A | 76 | 100% | 30 | | | 30 | | | Existing commercial buildings | D | | 2486 | 44502013T | 3374 E SHIELDS | 2.8 | Office | O | N/A | N/A | N/A | 224 | | | 224 | No | | Vacant Building: Dept of Water Resources | D | | | | | | | | | | **Total** | **7,035** | | **2,488** | **8,127** | **17,650** | | | | A= Agricultural uses planned for residential. B= Largely vacant residential land. C= Mostly vacant land with paving or minor improvements. D= Existing non-residential uses on large lots with infill potential. E= Parking lots. Source: City of Fresno and Ascent, 2024. APPENDIX 1E: CITY OF FRESNO # SECTION 1E-8: PUBLIC COMMENTS RECEIVED ON THE HOUSING ELEMENT FRESNO MULTI-JURISDICTIONAL HOUSING ELEMENT | DECEMBER 2024 1E-8-1 <
> November 19, 2024 Mayor Jerry Dyer Fresno City Councilmembers Michelle Zumwalt, Planning and Development Department 2600 Fresno Street, Room Fresno, CA 93721 **RE: City of Fresno Draft 6th Cycle Housing Element Errata** *Sent via email: housingelement@fresno.gov* Dear Mayor Dyer, Councilmember, and Ms. Zumwalt: Leadership Counsel for Justice and Accountability (“LCJA”) and Public Interest Law Project (“PILP”) submit this comment letter in response to the City of Fresno’s Housing Element Draft Errata (“Errata”) released on November 12, 2024. Thank you for taking the time to meet and discuss our concerns regarding the programs and their lack of affirmative furthering fair housing. We hope that this conversation, along with California’s Department of Housing and Community Development (HCD) findings letter released on October 7, 2024, leads to amendments of strong policies and programs identified by R/ECAP communities. The Errata does not adequately respond to HCD’s findings and fails to incorporate programs with meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. **I. Releasing “Erratas” Without Meaningful Opportunities for Input Fails to Demonstrate Diligent Effort to Include Public Participation from R/ECAP Communities.** Every City of Fresno resident deserves the opportunity to engage in the Housing Element process and voice their concerns with revised drafts and elevate their housing needs. The City of Fresno released a revised Housing Element Draft on July 31, 2024. Since then the City has been releasing “Erratas” every month with only seven calendar days for comments: September 23, 2024, October 21, 2024, November 12, 2024. Such a quick turnaround does not allow the City to properly engage with residents and communities; therefore, the City is not taking the time to truly revise the housing element draft to reflect community needs, but most importantly the needs of R/ECAPs. ## II. The Assessment of Fair Housing Fails to Adequately Analyze Racially/Ethnically Concentrated Areas of Poverty (R/ECAP). As part of the comprehensive statutory duty to affirmatively further fair housing (“AFFH”), the housing needs assessment of a locality’s housing element must comply with the requirements of Gov. Code Section 65583(c)(10) by including an “assessment of fair housing” (“AFH”), in addition to an analysis of the locality’s household characteristics and housing conditions. (HCD Guidance, p.22; *see also* Gov. Code 8899.50.) The AFH must analyze how relevant factors in the locality “cause, increase, contribute to, maintain, or perpetuate” fair housing issues (HCD Guidance, p.24; *see also* Gov. Code, §§ 65583, subds. (c)(10)(A), (c)(10)(B), 8899.50, subds. (a), (b), (c).) Factors to be analyzed include spatial and temporal patterns and trends, local data and knowledge, as well as policies and practices or other information relevant to fair housing conditions. (HCD Guidance, p.25.) ### Racially or Ethnically Concentrated Areas of Poverty One mandatory portion of the AFH is an analysis of Racially or Ethnically Concentrated Areas of Poverty (“R/ECAPs”) which discusses the incidence of concentrated areas of poverty and segregation within the locality, as well as within the region. (HCD Guidance, p.32; *see also* Gov. Code, §§ 65583, subd. (c)(10), 8899.50, subds. (a), (b), (c).) Both the local and regional description are crucial, because any “difference between the locality and the region is an essential part” of evaluating policies based on the priority of fair housing issues. (HCD Guidance, p.33.) The AFH should similarly analyze Racially Concentrated Areas of Affluence (RCAAs) according to the same temporal and spatial dimensions (HCD Guidance, p.33.) In the October 7 findings letter released in response to the September errata, HCD identified several failings in the draft AFH. According to the findings, to meet the minimum level of analysis to satisfy the City’s statutory obligations, the AFH must “expand the discussion of characteristics of [RECAPs] and changes over time.” (HCD Findings, p.2.) One approach suggested by HCD would be to “consider a specific and individual description of each of the R/ECAPs including past and current neighborhood conditions, disparities in access to opportunity, effectiveness of past policies and investments and unique opportunities to promote equitable quality of life.” (HCD Findings, pp.2-3.) In addition, HCD’s findings stated that the expanded analysis “should incorporate public participation and targeted outreach to better examine needs and formulate appropriate policies and programs.” (HCD Findings, p.3.) In response to these findings, the October 21, 2024 errata released by the City included expanded descriptions of 11 R/ECAPs, identified by neighborhood. (October 21 Errata, p.1E-3-31 - p.1E-3-45.) This section appears not to have been amended since the release of the October 21, as it is not included in the November 12 Errata. However, while the edits to this section did introduce a greater level of detail compared to that included in the previous draft, the Michelle Zumwalt Page 3 of 14 expanded descriptions fall short of what is necessary for the City to meet its duty to AFFH. In general, in spite of the HCD findings, the descriptions of area development over time are inconsistently detailed, with some R/ECAPs discussed in greater depth than others. Also, there is a general lack of analysis connecting the description of development history to the contemporary fair housing issues, and explaining how the identified programs offer opportunities to address the particular issues present in each neighborhood. Until it includes the appropriate degree of analysis, the City’s AFH fails to conform to the requirements laid out in Government Code Section 65583 as articulated by HCD Guidance, and does not meet the standards set out in the HCD findings regarding the September errata. Because compliance with the requirements of Section 65583 is essential to meet the AFFH duty under Section 8899.50, this violation is inconsistent with the AB 686 goals of addressing fair housing issues and replacing segregated living patterns with integrated ones. (HCD Guidance, p.15.) Specific shortcomings include: * Downtown * While the description of the Downtown neighborhood identifies factors including redlining and the negative consequences of suburban-style development in the 1960s,[^p500-1] there is a lack of analysis connecting this historical information to the current neighborhood conditions. For instance, the section identifies “the amount of impervious surfaces results in higher levels of extreme heat” as well as “a high concentration of individuals experiencing homelessness and individuals with disabilities in the Downtown area.” (October 21 Errata, p.1E-3-33.) However, these unique characteristics are not analyzed in connection with any historical trends or patterns. This discussion should be expanded to include an analysis of how policy and investment decisions made following the 1960s period of suburbanization informed the area’s current character, with particular attention to the development of the identified urban-heat issue and the increase in the population of individuals experiencing homelessness as compared to the wider region. Without a discussion of the policies and practices relevant to this area during the past 50-60 years, it is not possible for this description to assist in the formulation of appropriate policies and programs to AFFH in this area. * Jane Addams Neighborhood * The description of this area notes that because “the area was mostly developed while in the County, the roads did not meet City standards, lacking curb, gutter, sidewalks, and street trees.” (October 21 Errata, p.1E-3-37.) However, the section lacks any meaningful analysis of this development pattern, explaining only that “[p]ast policies (or lack thereof) related to freeway construction and City-County coordination of growth and development resulted in negative impacts to this neighborhood.” (Id.) Without any degree of analysis of the particular policies and practices, or their [^p500-1]: October 21 Errata, p.1E-3-33. negative impacts, this description does not offer guidance for efforts to promote equitable quality of life in the neighborhood. The description should be expanded to include details of the policy gaps related to freeway construction and City-County development, and the negative impacts that have resulted from them. This would inform a better understanding of the unique opportunities to address these issues. * Southwest Neighborhood * The description of this neighborhood states that it developed as a “patchwork of agricultural, residential, and industrial uses, with some commercial sprinkled throughout, resulting in land use incompatibilities” and notes that at present it suffers from “high pollution burden due to … legacy land uses” and is at “risk for extreme heat due to low tree canopy of 8%, compared to the citywide average of 15%.” (October 21 Errata, 1E-3-38.) In addition, the description of the Southwest Neighborhood also refers to a local “transition pursuant to the adoption of the Southwest Fresno Specific Plan in 2017, which sought to enhance the plan area by incentivizing housing and commercial development, prioritizing parks and public facilities, and rezoning industrial land to other uses.” (October 21 Errata, p.1E-3-38.) However, this description fails to analyze the recent shift back toward industrial uses in this area; and, although it identifies Program 28: Equitable Community Investments as an opportunity to remedy the results of the inequitable historical development, that program includes language which contemplates land use changes away from those specified in the Southwest Fresno Specific Plan, potentially opening the door for re-entrenchment of industrial uses in Southwest Fresno. Because this inconsistency between the issues identified in the R/ECAP analysis and the programs identified to address them means that the planned-for transition away from industrial activities might be halted or rolled back, threatening the feasibility of future residential development due to land use incompatibility, this conflict represents a failure to AFFH. Racially Concentrated Areas of Affluence The October 21 errata includes only the following discussion of RCAAs: “There are 18 RCAA tracts within the city limits. Several of the RCAA tracts overlap with areas that are not incorporated into Fresno city limits as of 2022. Within Fresno City, RCAAs are generally found in the North and Northeast Fresno neighborhoods, often characterized by high property values, excellent schools, and well-maintained infrastructure. Neighborhoods deemed as RCAAs include portions of the Woodward Park, Bullard, McLane, and Roosevelt community areas.” (October 21 Errata, p.1E-3-45.) Michelle Zumwalt Page 5 of 14 Although there are more identified RCAAs within the city than R/ECAPs, the draft does not individually identify or analyze these areas. This failure is inconsistent with the requirement that an AFH consider RCAAs to “better evaluate trends, patterns, policies, and practices and to guide meaningful goals and actions to address fair housing issues.” (HCD Guidance, p.33.) The AFH should be amended to include an expanded discussion of RCAAs within the city, with the necessary analysis of how factors including public participation, past policies, practices, investments, and demographic trends have resulted in the pattern of development that has resulted in the identified RCAAs. ### The AFH Does Not Meet the Minimum Requirements to AFFH As described above, there is a critical lack of analysis in the draft AFH that should have been amended in the most recent errata. Until the City expands the descriptions of identified R/ECAPs to explain the relationship between historical practices and patterns and current fair housing issues, it will not meet the requirements of Housing Element law. In addition, without this analysis, the AFH cannot support the implementation of programs to address the identified fair housing issues, and the City will fail to uphold the duty to AFFH. ### III. Failure to Incorporate Community Identified Programs that will Result in a Beneficial Impact during the Planning Period and AFFH. HCD’s October 7, 2024, findings letter identified deficiencies the City needs to address in order to comply with state law: “the element must include a complete assessment of fair housing. Based on the outcomes of that analysis, the City may need to add or revise programs. Goals and actions must be significant and meaningful enough to overcome identified patterns and trends.”[^p502-2] As stated in section II of this letter, the City failed to complete an adequate assessment of fair housing in the Errata, and without a complete assessment the City is unable to adequately revise the programs in the Errata. Additionally, HCD’s findings letter directs the City to revise its programs to include geographic targeting and metrics, and targeting high resource areas, specific metrics, specific commitments, timing, and specificity regarding Specific Plans. We appreciate that the City included language in some of the programs that target RCAAs as well as additional timelines and specificity in this recent Errata, but additional changes are needed to fully comply with HCD’s findings. Additionally, our previous comments have detailed community-identified programs that are needed to respond to critical housing needs. These programs would AFFH and replace segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity. [^p502-2]: Department of Housing and Community Development. (2024, October 7). HCD’s Findings Letter to the City of Fresno on their 6th Cycle (2023-2031) Revised Draft Housing Element. Michelle Zumwalt Page 6 of 14 **Program 1 - Maintain Adequate Sites.** We appreciate that the City has added in this Errata a commitment to evaluate progress toward completion of pipeline projects annually, and to adjust its inventory relative to that progress. The city should commit to deadlines for those annual reviews to ensure that they occur—e.g., annually by July 1 or annually by the anniversary of the City Council’s adoption of the Housing Element. **Program 2 – Variety of Housing Opportunities in High Resource Areas.** This program’s goal is to increase high density housing in high-resource areas. The City acknowledges that high density housing is placed in R/ECAPs and low-density housing like single family homes are built in new growth areas like North Fresno and other RCAAs. In order to create “mobility” the City “will present potential sites or rezoning options for land in high and relatively higher resource and income areas, including RCAAs, for Council consideration to provide opportunities for higher density development in all areas of the city and reduce concentrations of poverty.” Only presenting potential sites or rezoning options in high resource areas for council consideration does not guarantee that they will be approved. As discussed at length in our prior comments, NIMBYism is a barrier to rezoning high density housing in high resource areas; deferring upzoning of sites in RCAAs and other high-resource areas to future discretionary Council action is a recipe for failure. The City should be identifying sites “throughout the community,” including in RCAAs and other high-resource areas, in its Housing Element. (Gov. Code 65583.2(a).) Where rezoning sites in those areas is necessary to accommodate affordable housing, the Housing Element should include a program to do so. In order to provide adequate capacity for multifamily and affordable housing in high-resource areas, the City must identify those sites in the Housing Element now, not after adoption. But, rather than ensuring a streamlined, ministerial process for housing approvals in high-resource areas, the City’s current plan is to defer to a future discretionary process where City Council will have the opportunity to reject any proposed rezoning. A firm commitment now will also prevent challenges from NIMBY groups. Incorporating this action will truly develop housing opportunities for low income households in high resource areas and AFFH. Program 2 continues to state that it will “include developing zoning standards to permit residential conversions in the Office Zone District, housing as a permitted use on parcels zoned Office, allow ministerial approval of office-to-residential conversions…” But there is no specificity around whether office zoned parcels in RCAAs will be prioritized over those in R/ECAPs. The goal of this program is “to increase housing mobility opportunities for lower-income households and encourage racially and socially inclusive neighborhoods.” Most of the actions are vague such as “the City will identify and pursue opportunities to promote the development of affordable housing” in RCAAs but it does not specify how this will be done. Michelle Zumwalt Page 7 of 14 The last action is also vague: “the City will incorporate Affirmatively Further Fair Housing analysis into decisions affecting funding and land use approvals for housing projects that require consideration by Planning Commission, City Council, or other boards and commissions as appropriate.” As noted in our prior comments, the City already has such an obligation pursuant to Government Code section 8899.50. Program 2 should commit to specific actions the City will take to ensure that it fulfills that obligation. In order to ensure this program affirmatively further fair housing and increases housing mobility for R/ECAPs, it must: * Identify sites RCAAs to allow multifamily residential developments in which at least 20 percent of the units are affordable to lower-income households by right, to rezoning the sites accordingly within one year of adoption. * The City Council should adopt a policy requiring staff memos to the Council and relevant commissions to include an affirmatively furthering fair housing analysis that analyzes the fair housing impacts of any proposed decisions related to housing, as well as any applicable project alternatives. The policy should include affirmative outreach to affected communities, especially for projects in R/ECAPs. **Program 14 – Partnerships with Affordable Housing Developers.** The goal of this program is “to continue to strengthen partnerships and relationships with affordable housing developers.” It continues to list vague actions such as “supporting,” “pursuing,” “encouraging.” In order to create strong relationships with affordable housing developers, the City should have addressed their concerns in the engagement process of the Housing Element and incorporated them into the Draft. Affordable housing developers need consistency, transparency, and long term commitment from the City. Building affordable housing projects takes time and funding from various avenues, therefore a streamlined process is necessary to build trust among the very few affordable housing developers that exist in the Central Valley. In addition to the existing program commitments, City should incorporate the following: * Annually publish to the public an inventory of the City’s affordable housing project pipeline that includes housing developments in various stages of development, including pre-development, planning, permitting, and near-construction. This inventory could be published in conjunction with the City’s Housing Element Annual Progress Report. This will create a transparent process for both the affordable housing developers and the public. * Make commitments to continue financing the project up to three years. Revisit the project and ensure the applicant has everything to move forward with the project. Michelle Zumwalt Page 8 of 14 **Program 19 – Home Buyer Assistance.** We appreciate the City including commitments to offer technical and financial assistance as well as reinforcing the timeframe for the project. However in order for this program to AFFH, the program must be accessible to residents who utilize an Individual Taxpayer Identification Number (ITIN). ITIN holders are part of special needs groups and among the most vulnerable to displacement and unlawful evictions. Creating opportunities to be able to own a home will give them access to opportunity and create fair housing opportunities for them. **Program 20 – Housing Choice Voucher Incentive Program.** Under State law, it is illegal for landlords to discriminate against someone due to their source of income such as a voucher recipient solely on the basis of their having a voucher. The source of income discrimination is rampant throughout California.[^p505-3] The City must include meaningful actions to ensure that voucher recipients have housing choice throughout the City of Fresno but most importantly in high resource areas and RCAAs. Currently, the Errata has vague language that does not contain meaningful actions that will allow voucher recipients to have greater access to RCAAs. In order to ensure that this program affirmatively further fair housing, integrates communities, and allows for fair housing choice the city must go beyond workshops and trainings. This program should incorporate the following additions and amendments: * Create a rent registry to keep a list of landlords throughout the City of Fresno, and to allow the City to track complaints against landlords who reject voucher tenants, by December 2025, and ensure that every tenant has access to the Rent Registry in multiple languages. * Identify and commit to specific actions that the City will take to enforce source-of-income protections. **Program 22 – Housing Rehabilitation.** We appreciate the language added to this program, we strongly urge additional actions that ensure this program truly targets residents in R/ECAPs. * Include provisions that will allow residents with ITINs to apply to this program. * Include temporary housing assistance, such as emergency housing vouchers, during extreme renovations. This will allow extremely low-income residents the opportunity to secure housing without accumulating additional financial burdens. * The City must include the HOME program as a source of funding as well as setting aside five percent of its annual general fund revenue to ensure the program remains funded throughout the planning period. * Release semi-annual reports with data on how many residents apply to the program, how many people are being funded, and whether they live in R/ECAPs. [^p505-3]: Khouri, A. (2024, Oct. 8). Housing nonprofit alleges widespread discrimination against Section 8 tenants in California. The LA Times. Retrieved from https://www.latimes.com/california/story/2024-10-08/section-8-discrimination Michelle Zumwalt Page 9 of 14 * Release an annual survey on how well the program is serving communities and reevaluate the program if it is not addressing the needs of the most vulnerable. These amendments will ensure that the program is affirmatively furthering fair housing and creating place-based strategies. **Program 27 – Environmental Justice.** This Errata does not include strong actions that will create healthy neighborhoods with access to opportunity such as a healthy environment (air, water, safe neighborhood, safety from environmental hazards, social services, and cultural institutions) particularly for R/ECAP communities. The Errata must include place-based strategies in R/ECAP as Environmental Justice actions that could then be reinforced in the Environmental Justice Element. The program should include the following actions to improve the quality of life in R/ECAPs, specifically in the communities residing in South Fresno: * Implement land use changes to rezone industrial use and prohibit future industrial uses near sensitive receptors. * Prohibit the siting of polluting uses near impacted communities and impose impact fees on polluters operating near homes. The funds generated will go towards a community benefit fund managed by the impacted community and utilized to transform R/ECAPs into areas of opportunity. * Establish a moratorium on warehouses in or near R/ECAPs. These recommended changes will help ensure that the program improves the quality of life in R/ECAPs and affirmatively further fair housing.[^p506-4] **Program 33 - Mobile Home Parks.** In order to discourage mobile home park conversions, which both displace mobile home residents and reduce the City’s supply of affordable housing, this program should include (1) a commitment to apply mobile home park zoning to existing mobile home parks, and (2) addition of relocation requirements and other protections for mobile home park residents that go beyond the requirements of Government Code sections 65863.7 and 66427.4. The latter could be included in the regulations that the program is already contemplating with respect to replacement units. **Program 34 - Eviction Protection Program.** As we discussed in our meeting today, tenants need legal representation, professional mediation, and guidance in navigating the eviction process as well as landlord/tenant law to avoid displacement. The Eviction Protection Program is a critical anti-displacement tool. The Housing Element should commit to ongoing funding of the program, and to codify it in the City’s municipal code by June 2025. [^p506-4]: California Department of Housing and Community Development. (2021). Affirmatively Furthering Fair Housing: Guidance for All Public Entities and For Housing Elements. p.54. # IV. Community-identified Programs that will Affirmatively Further Fair Housing. Once again, we appreciate the City taking the time to meet with us to discuss resident-identified priorities. Per our discussion, we encourage the City to consider and ultimately incorporate the following programs that R/ECAP communities identified as anti-displacement measures which will substantially improve their quality of life and affirmatively further fair housing. ## A. Rent Stabilization and Just Cause Protection Ordinance. **Objective:** A Rent Stabilization and Just Cause Protection ordinance will protect existing residents from displacement. It comprises strategies that protect residents in areas of lower or moderate opportunity and concentrated poverty and preserves housing choices and affordability. Based on the data analysis from the City’s Displacement Avoidance Plan, rent stabilization is critical in ensuring vulnerable tenants stay housed. Such an ordinance will also decrease the amount of evictions, thus lessen the monetary need for the Eviction Protection Program. **Actions and Timelines:** * The City will adopt a Rent Stabilization and Just Cause Protection Ordinance to protect tenants from unreasonable rent increases and unjust evictions by December 2025. * The City will develop the ordinance collaboratively with Fresno tenants, landlords, and community based organizations. * The City will make a diligent effort to engage Fresno tenants through outreach including but not limited to, canvassing apartment complexes. The city will host interactive convenings and workshops. * All material, information, and verbal public education, including outreach initiatives, will be provided in a variety of languages representative of Fresno including, but not limited to, Spanish, Hmong, and Punjabi. * The City will establish a community workgroup to develop a rent stabilization and just cause ordinance draft by March 2025. The working group will meet on a monthly basis. * The City will release a draft ordinance for public review and announce the publication of the draft by August 2025. * The City will adopt the ordinance no later than December 31, 2025. **Funding:** Local Funds. **Responsibility:** Office of the City Attorney and Office of Community Affairs. Michelle Zumwalt Page 11 of 14 If the City cannot commit to adopting and implementing a Rent Stabilization and Just Cause Protection Ordinance in the Housing Element, then we recommend that the City evaluate the feasibility of adopting measures to protect residents from displacement. Example strategies the City will evaluate include: * Adopting community benefit zoning and/or other land value recapture strategy. * Adopting an ordinance to provide for extended notice, expanded relocation benefits, and right to return when an owner evicts tenants for “no fault” causes, such as in order to remove the property from the rental market. * Adopting a just cause eviction ordinance that expands the Tenant Protection Act’s eviction protections to tenants who are not currently protected by state law–e.g., tenants in their first year of tenancy. The City will partner with three community organizations to conduct community workshops. The City will incorporate the results of community outreach into a feasibility analysis to be released publicly and presented to the City Council in a public study session. Based on Council direction, City staff will develop a workplan to adopt the Council’s recommendations. **B. Inclusionary Zoning Ordinance.** **Objective:** Currently, the mobility strategies in the Programs section of the Housing Element are insufficient to affirmatively further fair housing, or to create housing choice for residents living in R/ECAPs. An inclusionary housing ordinance would both increase the supply of deed-restricted affordable housing in the City and also also ensure that new units are integrated into market-rate buildings and higher-opportunity neighborhoods. Racial and economic segregation in Fresno is deeply entrenched, and concrete policies are needed to ensure integration and access to opportunity. Inclusionary housing is one of the most effective policy tools local jurisdictions have to affirmatively further fair housing, and the City should use it. **Actions and Timelines:** * The ordinance will be developed in accordance with the following guidelines * Apply to projects of 5 or more units * All new housing developments will set aside 20% of its units as affordable for households with an AMI of 50% or less in perpetuity. * As a compliance alternative, developers may pay an in-lieu fee that will then be used towards the development of affordable housing. * The City will draft an Inclusionary Zoning Ordinance and adopt the Ordinance by November 2025. Michelle Zumwalt Page 12 of 14 * The City will implement the ordinance and require Inclusionary Zoning for all new housing developments and inform developers of compliance requirements by December 2025. **Funding:** Local Funds **Responsibility:** Planning and Development Department If the City cannot commit to adopting and implementing an Inclusionary Zoning Ordinance then the alternative solution is to implement a feasibility study in the Housing Element. Preparing a feasibility study in support of an inclusionary requirement helps ensure that the requirement is right-sized for local conditions. The feasibility study would analyze local market conditions and the economics and tradeoffs of various policy options – affordability percentages and levels, incentives – to make sure the ordinance delivers the number and type of affordable units that a community needs. It also provides a data-driven foundation for the requirement, which can help overcome opposition by showing that it can be implemented without impeding the developers’ability to earn a profit.[^p509-5] We recommend the following: * The City will hire a consultant to work on the feasibility study by June 2025. * The City will present options to the City Council by October 2025. * The City will adopt an inclusionary zoning ordinance by December 2025. **C. Rental Assistance Program.** As we discussed on our call, the creation of a permanent program to provide emergency rental assistance to lower-income households that are unable to pay rent or have past due payments, regardless of immigration status, would help to prevent displacement, strengthen the existing Eviction Protection Program, and affirmatively further fair housing. In light of the expiration of ERAP, the City should commit to creating and funding such a program. Funding sources could include the General Fund and Local Housing Trust Fund, as well as other sources like ESG and HOPWA. The City could time the program to correspond with the adoption of its Consolidated Plan in 2025 to ensure consistency. This would provide rental assistance to households that may not have stable income, including but not limited to field-workers, the elderly, disabled persons, etc. **V. Conclusion.** [^p509-5]: Western Center on Law and Poverty. *Meeting California’s Housing Needs: Best Practices for Inclusionary Housing*. Retrieved from https://wclp.org/wp-content/uploads/2018/12/inclusionary-factsheet_v2.pdf. Michelle Zumwalt Page 13 of 14 Thank you for considering and incorporating several of our comments. Once again, we appreciate the City taking the time to meet with us to listen to our concerns. We hope that our recommendations will be incorporated in the Housing Element Draft, this will ensure a compliant housing element and will fulfill its duty to AFFH. Additionally, we strongly urge the City not to adopt the Housing Element before being found compliant with State law. Public participation and transparency is critical to this process. The undersigned organizations welcome the opportunity to continue collaborating on the City of Fresno’s Housing Element update to ensure the City is committed to meeting the housing needs of all residents, complies with state law, and provides equitable public participation opportunities throughout the revision process. Sincerely, /s/ Jovana Morales Tilgren Housing Policy Coordinator Leadership Counsel for Justice and Accountability jmtilgren@leadershipcounsel.org /s/ Seth Alston Legal Advocate Leadership Counsel for Justice and Accountability salston@leadershipcounsel.org /s/ Melissa A. Morris, Staff Attorney Public Interest Law Project mmorris@pilpca.org 510-891-9794 x 111 Cc: Architect, Michelle Zumwalt, michelle.zumwalt@fresno.gov City Manager Georgeanne White, Georgeanne.White@fresno.gov Planning Director Jennifer Clark, jennifer.clark@fresno.gov Council President Analisa Perea, annalisa.perea@fresno.gov Councilmember Mike Karbassi, mike.karbassi@fresno.gov Councilmember Miguel Arias, miguel.arias@fresno.gov Councilmember Tyler Maxwell, tyler.maxwell@fresno.gov Michelle Zumwalt Page 14 of 14 Councilmember Luis Chavez, luis.chavez@fresno.gov Councilmember Garry Bredefeld, garry.bredefeld@fresno.gov Councilmember Nelson Esparza, nelson.esparza@fresno.gov Mayor Jerry Dyer, jerry.dyer@fresno.gov Thomas Brown, Policy Analyst, California Department of Housing and Community Development thomas.brown@hcd.ca.gov Paul, McDougall, California Department of Housing and Community Development, paul.mcdougall@hcd.ca.gov From: [Chelsey Payne](mailto:chelsey.payne@ascent.inc) To: [Sophia Pagoulatos](mailto:Sophia.Pagoulatos@fresno.gov); [Heidi GenKuong](mailto:Heidi.GenKuong@ascent.inc) Cc: [Michelle Zumwalt](mailto:Michelle.Zumwalt@fresno.gov); [Rebecca Pope](mailto:Rebecca.Pope@fresno.gov) Subject: RE: Public comment Date: Friday, November 22, 2024 11:06:38 AM We will include this in the packet of public comment letters. You should consider whether to recommend the PC consider additional changes to address these public comments. I would not recommend making changes to what we submitted to HCD at this time, but any changes made in response to public comments from this point forward should be done through the public hearing process, similar to what you would do on any other project. Does that make sense? **Chelsey Norton Payne**, AICP D 916.306.2621 | M 916.396.2124 [chelsey.payne@ascent.inc](mailto:chelsey.payne@ascent.inc) *** **From:** Sophia Pagoulatos **Sent:** Friday, November 22, 2024 10:51 AM **To:** Chelsey Payne ; Heidi GenKuong **Cc:** Michelle Zumwalt **Subject:** FW: Public comment **Importance:** High Hello: Just found this email in our Housing Element in-box. How should we handle? **Sophia Pagoulatos | Planning Manager** Long Range Planning | Planning & Development 559.621.8062 *** **From:** Brandi Nuse-Villegas **Sent:** Tuesday, November 19, 2024 12:32 PM **To:** HousingElement **Subject:** Public comment **External Email:** Use caution with links and attachments Thank you for all the work you have done on the housing element. I would like to add comment on needs for Goal 7 and for the housing element at large 1. We need to commit to and implement a robust system of accountability for all programs, service providers, and the city itself. We need third party oversight with the power to address and hold all those providing services and making decisions accountable. The issue we have seen over the past years is that there have been services implemented, but issues within the programs that aren't being addressed. For instance, due to problems in the shelters, Fresno Housing Authority worked with their service provider, Turning Point, to implement a grievance system, showing that this was needed, and something that many have brought to the city to address. However, there continues to be concerns and reports of unjust exits from the shelters, with no opportunity for the occupant to reach out and seek help addressing this. In Program 36: 2. The city of Fresno needs to have a robust asset based community development approach, especially regarding those who are unhoused, including, but not limited to implementing a lived experience board of those who have been unsheltered/unhoused. We cannot be successful unless those whose needs we are addressing are at the table in a meaningful way. The city needs to identify barriers to community engagement within this group, including the need to go out to those who are unhoused to listen not only for ideas but to assess existing projects. 3. The City of Fresno needs to commit in its housing element to a Housing First approach, with the recognition that getting people into permanent housing, and then supplying needed services to ensure that people are able to address any issues that are impediment to long-term permanent housing placement has been shown in research and practice to be much more successful. One of the challenges we face is that people are going into shelter only to be exited out without housing back onto the streets, when they are housing ready, when they are still in the process, even after getting treatment. It is easier to gain and maintain a job or go through the process of getting on disability and other challenges within permanent housing. 4. As well, the city needs a policy to ensure that people are not exited from shelters until they are placed in permanent housing without a just process with oversight and assistance of unhoused advocates or other advocacy if there is a reason stated to exited otherwise and remove the 90 day limit. 5. HART is not a viable program in the effort to address housing needs. While the outreach portion, HOPE Team currently, is helping with navigation and other services, all of those who are unsheltered in Fresno, from the experience of unhoused advocates, and publicly reported at city hall public comments, video documentation, and such show that the law enforcement arm has been throwing away needed belongings of those who are unhoused, including paperwork, ID cards, and such, in violation of the city municipal codes and constitutional rights. This has impeded the victims form the process of getting housing and has resulted in victims losing secured housing in multiple occasions. As well, losing living essentials causes those who are unhoused to redirect their energy from the process of getting housing to simply replacing survival supplies. This item also highlights the first point regarding accountability. Regarding Program 34: 6. It may help to have easy to access hotline/website in which to report landlords that fail to meet requirements such as accepting vouchers in addition to violations of living conditions and illegal evictions. . Department of Housing and Community Development Division of Housing policy Development RE: City of FRESNO's 6th cycle (2023-2031) DRAFT Housing Element. pg 1: 2 Appedix City of FRESNO pg's 2, 4, 5, Housing programs pg's 7, 8. pg 9 public participation TO: Planning Board Commission FROM: H.E.A.T for South west FRESNO community RECEIVED OCT 31 2024 Planning & Development Department City of Fresno STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT DIVISION OF HOUSING POLICY DEVELOPMENT 2020 W. El Camino Avenue, Suite 500 Sacramento, CA 95833 (916) 263-2911 / FAX (916) 263-7453 www.hcd.ca.gov GAVIN NEWSOM, Governor February 1, 2024 Michelle Zumwalt, Architect Planning and Development Department City of Fresno 2600 Fresno Street Fresno, CA 93721 Dear Michelle Zumwalt: RE: City of Fresno’s 6th Cycle (2023-2031) Draft Housing Element Thank you for submitting the City of Fresno’s (City) draft housing element received for review on November 3, 2023. Pursuant to Government Code section 65585, the California Department of Housing and Community Development (HCD) is reporting the results of its review. Our review was facilitated by a conversation on December 20, 2023 with the City’s housing element team. In addition, HCD considered comments from Leadership Counsel, Public Interest Law Project, and California Consortium of Addiction Programs and Professionals pursuant to Government Code section 65585, subdivision (c). The draft element addresses many statutory requirements; however, revisions will be necessary to substantially comply with State Housing Element Law (Gov. Code, § 65580 et seq). The enclosed Appendix describes the revisions needed to comply with State Housing Element Law. As a reminder, the City’s 6th cycle housing element was due December 31, 2023. As of today, the City has not completed the housing element process for the 6th cycle. The City’s 5th cycle housing element no longer satisfies statutory requirements. HCD encourages the City to revise the element as described above, adopt, and submit to HCD to regain housing element compliance. For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if a local government does not adopt a compliant housing element within 120 days of the statutory deadline (December 31, 2023), then any rezoning to make prior identified sites available or accommodate the regional housing needs allocation (RHNA) shall be completed no later than one year from the statutory deadline pursuant to Government Code sections 65583, subdivision (c) and 65583.2, subdivision (c). Otherwise, the local government’s housing element will no longer comply with State Housing Element Law, and HCD may revoke its finding of substantial compliance pursuant to Government Michelle Zumwalt, Architect Page 2 Code section 65585, subdivision (i). Please be aware, if the City does not adopt a compliant housing element within one year from the statutory deadline, the element cannot be found in substantial compliance until these rezones are completed. Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City should continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available and considering and incorporating comments where appropriate. Please be aware, any revisions to the element must be posted on the local government’s website and to email a link to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD. Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant, the Affordable Housing and Sustainable Communities program, and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City will meet housing element requirements for these and other funding sources. For your information, some general plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor’s Office of Planning and Research at: https://www.opr.ca.gov/planning/general-plan/guidelines.html. HCD appreciates the hard work and dedication the City’s housing element team provided during the housing element update. We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Jose Ayala, of our staff, at Jose.Ayala@hcd.ca.gov. Sincerely, Paul McDougall Senior Program Manager Enclosure # APPENDIX # CITY OF FRESNO The following changes are necessary to bring the City’s housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code. Housing element technical assistance information is available on HCD’s website at https://www.hcd.ca.gov/planning-and-community-development/hcd-memos. Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at https://www.hcd.ca.gov/planning-and-community-development/housing-elements/building-blocks and includes the Government Code addressing State Housing Element Law and other resources. ## A. Review and Revision *Review the previous element to evaluate the appropriateness, effectiveness, and progress in implementation, and reflect the results of this review in the revised element. (Gov. Code, § 65588 (a) and (b).)* As part of the evaluation of programs in the past cycle, the element must also describe the cumulative effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female-headed households, farmworkers, and persons experiencing homelessness). While the element provides an overview of outcomes supporting special needs populations, the element should evaluate the cumulative effectiveness of programs in addressing the objectives of the programs and programs should be revised as appropriate to reflect the results of this evaluation. ## B. Housing Needs, Resources, and Constraints 1. *Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).)* Enforcement and Outreach: While the element discusses the City’s referral process for fair housing complaints, it should discuss the effectiveness of that process, including outreach. Further, the element should also discuss how the City complies with fair housing laws and any other fair housing legal matters such as consent decrees. For more information on fair housing laws, please see HCD’s Affirmatively Furthering Fair Housing (AFFH) Guidance (starting on page 29) at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing. Concentrated Areas of Poverty: The element includes information relative to areas of High Segregation and Poverty but should evaluate the characteristics of these areas, changes over time, comparisons to other neighborhoods in terms of equitable quality of life and consider other relevant factors, such as public participation, past policies, practices, and investments and demographic trends. The analysis should utilize local data and knowledge and other relevant factors to complement the data and analysis. Given most of the Southern portion of the City is an area of High Segregation and Poverty, and based on a complete analysis, the element should have significant and beneficial actions, including place-based strategies toward community revitalization, that are targeted towards these areas. Racially Concentrated Areas of Affluence (RCAA): While the element briefly mentions the presence of RCAAs, it should also include a specific analysis of patterns and trends for RCAAs within the City. The analysis should at least address trends, conditions, comparisons to other neighborhoods, effectiveness or absence of past strategies, local data and knowledge and other relevant factors related to equitable quality of life. The element must add or modify meaningful programs based on the outcomes of this analysis, including actions to improve housing mobility within the City. Disproportionate Housing Needs, Including Displacement Risk: The element includes some general information on persons experiencing homelessness but should also evaluate that information. Specifically, the element should examine disproportionate impacts on people with protected characteristics and services available and patterns of need or areas with higher concentrations of persons experiencing homelessness, including access to transportation and services. The element should utilize local data and knowledge such as service providers to assist this analysis. In addition, to better evaluate displacement risks, the element could utilize new data available for displacement risk on HCD’s AFFH Data Viewer available at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing. Identified Sites and AFFH: The element analyzed the identified sites by income group for various fair housing components including race, income, access to opportunity, and disproportionate housing needs. However, the element should also evaluate whether the location of sites improves or exacerbates current fair housing conditions. The analysis should utilize local data and knowledge and other relevant factors to complement the data. The analysis indicates the City is primarily high- and higher-resource in the Northern portion of the City, while the Southern portion of the City is low-resource and has areas of High Segregation and Poverty. However, the analysis provided is limited to the West Area Neighborhood Specific Plan (WANSP) and the West Shaw Avenue Town Center, with no analysis describing the developed core of the City. The element must include analysis and reasoning about the location of sites and their impact on current fair housing conditions. As noted below, upon a complete analysis the City must add or modify goals and actions, specifically increasing housing mobility options and housing opportunities in high-opportunity areas. Contributing Factors to Fair Housing Issues: The element identifies many contributing factors to fair housing issues. In addition, the element should re-assess the contributing factors to fair housing issues and consider prioritizing these factors to better formulate policies and programs and carry out meaningful actions to AFFH. 2. *Include an analysis of population and employment trends and documentation of projections and a quantification of the locality's existing and projected needs for all income levels, including extremely low-income households. (Gov. Code, § 65583, subd. (a)(1).)* Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).) Extremely Low-Income (ELI) Households: While the element quantifies existing ELI housing needs, it must still analyze their housing needs – beyond quantification. The analysis of ELI housing needs should analyze the disproportionate housing needs of ELI households, resources, the effectiveness of strategies and the magnitude of needs. For additional information, please see HCD's Building Blocks. Special Housing Needs: While the element generally quantifies special housing needs, it should also analyze those needs. The analysis should include, but is not limited to, factors such as household income, tenure, housing types, zoning, and available resources. Local officials, special needs service providers, or City/County social and health service providers may be able to assist with information to complete the analysis. In addition, while the element includes data on farmworkers, it should analyze their housing needs to better formulate policies and programs. The analysis should address trends, characteristics, disproportionate needs, the effectiveness of resources and strategies, the magnitude of the housing need, including disproportionate housing need and the effectiveness of past policies, programs, and funding to help address those gaps. The analysis may utilize past farmworker housing studies and other studies generally applicable to their special housing needs. For example, the element could utilize a recent study conducted by University California at Merced that is available at https://clc.ucmerced.edu/sites/clc.ucmerced.edu/files/page/documents/fwhs_report_2.2.2383.pdf. Based on the outcomes of the analysis, the element should add or modify programs to address this special housing need in the region. 3. *An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality's housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)* Progress in Meeting the Regional Housing Needs Allocation (RHNA): The element may utilize constructed, approved, and pending development (pipeline) toward the RHNA. However, the element must demonstrate the affordability and availability of these developments in the planning period, as follows: * **Availability:** The element lists developments by status and anticipated number of units, but should also discuss any phasing, anticipated build-out horizons beyond the planning period, and any known barriers to development in the planning period. Additionally, the element includes sites that have been submitted for review, but have not received entitlements, approvals, or been constructed. * **Monitoring and Alternative Actions:** Given the degree of reliance on pipeline projects to accommodate the RHNA, the element should include a program that commits to (1) facilitating development in the planning period (e.g., coordination with applicants to approve remaining entitlements, supporting funding applications, expediting approvals) and (2) monitoring development progress toward completion and, if necessary, by a specified date (e.g., December 31, 2027), take alternative action such as rezoning or identification of additional sites by a specified date. In addition, while the element relies on the monthly rent levels of previously-built developments, the element must also, to the extent feasible, base the affordability of approved and pending developments on the actual or projected sales, prices, rent levels, or other mechanisms establishing affordability in the planning period. This analysis should particularly address whether it is appropriate to assume new development will be affordable to moderate-income households, as noted in the element. For additional information, please see the HCD Housing Element Sites Inventory Guidebook at https://www.hcd.ca.gov/community-development/housing-element/docs/sites_inventory_memo_final06102020.pdf. **Realistic Capacity:** The element notes in place of a density standard, it relies on an analysis of development standards in the respective zones and then applies a factor using projects from 2018 to 2020 to establish a capacity assumption for the planning period. However, the capacity assumptions for the planning period should go beyond this sample size and incorporate more recent projects, such as those listed in Table 1E-2.3, to establish more appropriate capacity assumptions for the planning period. In addition, the element should account for the likelihood of 100 percent nonresidential development in zones that allow 100 percent nonresidential development. The element notes recent development activity reflect a high demand for residential development and appears to use a conservative assumption for residential development, however, the element should support these assumptions. The element should clearly describe which zones allow 100 percent nonresidential use. The element should discuss the trends in these zones for all development and how often development includes a residential component to support the residential assumption or make adjustments to account for the likelihood of residential in the calculation of capacity. Large Sites: Sites larger than ten acres in size are deemed inadequate to accommodate housing for lower-income households unless it is demonstrated, with sufficient evidence, that sites are suitable to accommodate housing for lower-income households. The element identifies several large sites and briefly describes anticipated developable areas were identified but should also discuss recent developments of equivalent size and affordability or provide other evidence for assuming the development of housing for lower-income households. For example, the element could discuss the timing for the West Area Neighborhood Specific Plan and West Shaw Avenue Town Center process, parceling, site planning, or other methods and how the City can facilitate appropriately sized lot sizes. Absent sufficient evidence that sites of equivalent size with affordability were successfully developed during the prior planning period or other evidence that demonstrates the suitability of these sites, the large sites are deemed inadequate to accommodate housing for lower-income households. Based on the outcomes of this analysis, the element must add or modify programs. Suitability of Nonvacant Sites: The element describes several categories of nonvacant sites (e.g., agricultural uses planned for residential, largely vacant, parking lots) that are assumed to have redevelopment potential in the planning period and lists a few examples of sites. However, the element should support these assumptions with an analysis of additional representative sites from the sites inventory and analyze recent development trends to support assuming these categories will redevelop in the planning period. An analysis of representative sites should evaluate the extent existing uses impede additional development, past experiences converting existing uses to higher density residential development, include current market demand for the existing use, provide analysis of existing leases or contracts or other conditions that would perpetuate the existing use or prevent additional residential development. Environmental Constraints: While the element generally describes a few environmental conditions within the City, it should also describe any other known environmental or other constraints that could impact housing development on identified sites in the planning period. Examples of other known conditions include shape, access, contamination, property conditions, easements, Williamson Act contracts, conservation easements, overlays and airport and military compatibility. Specifically, the element should describe any process delays within the Military Training Flight Route and provide a schedule for when sites subject to the Airport Land Use Commission (ALUC) will be updated per the amended Airport Influence Area (AIA) decision. In addition, based on public comments received, the element must also evaluate the suitability of sites for residential development, particularly sites located in South Fresno adjacent to industrial and agricultural uses. Publicly-Owned Sites: If the element is utilizing publicly-owned sites to accommodate a portion of the RHNA, it should include analysis to demonstrate their suitability and availability in the planning period. For example, the element should discuss the status, remaining steps to be available for development and any known barriers to development in the planning period including leases for existing uses or relocation of existing uses. Based on the outcome of this analysis, the element should add or modify Program 17 (Surplus Public Lands), if applicable, target numerical objectives consistent with the inventory and commit to a schedule of actions to facilitate development, including alternative actions, if necessary, by a specified date. Electronic Sites Inventory: For your information, pursuant to Government Code section 65583.3, the City must submit an electronic sites inventory with its adopted housing element. The City must utilize standards, forms, and definitions adopted by HCD. Please see HCD's housing element webpage at https://www.hcd.ca.gov/planning-and-community-development/housing-elements for a copy of the form and instructions. The City can reach out to HCD at sitesinventory@hcd.ca.gov for technical assistance. 4. *An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).)* **Land Use Controls:** The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types. The analysis should analyze land use controls independently and cumulatively with other land use controls. The analysis should address any impacts on cost, supply (number of units) and ability to achieve maximum allowable densities and include programs to address identified constraints. The analysis could seek input from development community. **Local Processing and Permit Procedures:** The element generally concludes that processing and permit procedures do not unduly constrain housing development. However, the element must still provide analysis to support this conclusion. An analysis should identify and analyze the permit procedure (e.g., Development Permit) for a typical development conforming to zoning, including decision-making body, number of public hearings and approval findings. The analysis should address potential impacts on housing cost, supply (number of units) and approval findings. The analysis could seek input from the development community. **On/Off-Site Improvements:** The element generally describes typical on- and off-site improvements such as street widths, street lighting and rights of way. However, the element should analyze the cost impacts on a typical development, including specifically addressing public comments and add or modify programs if necessary. **Constraints on Housing for Persons with Disabilities:** * *Residential Care Facilities (Seven or More Persons):* While the element includes a program to permit large residential care facilities in all zones where other residential uses are permitted, the element should clarify whether this use will be permitted in a similar manner to other residential uses, or subject to a Conditional Use Permit (CUP). The element must also analyze the CUP approval findings for the impacts on approval certainty relative to the approval of large residential care facilities. * *Land Use Controls:* The element should analyze parking requirements for residential care facilities for impacts on housing cost and feasibility. Based on the outcomes of this analysis, the element should add or modify programs to address the constraints on housing for persons with disabilities. * *Reasonable Accommodation Appeals:* While the element provides information regarding the reasonable accommodation process, the element should further clarify the appeals process for reasonable accommodations. Specifically, the element should describe whether a third-party can contest a reasonable accommodation approval and the applicant's appeal process for a denial of a reasonable accommodation request. ## C. Housing Programs 1. *Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city's or county's share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).)* As noted in Finding B3, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised as follows: * *Program 5 (Large and Small Lot Development):* Given the City's reliance on large sites to accommodate the RHNA, the Program should include additional and proactive actions to facilitate affordable development on lots larger than ten acres. Examples include establishing incentives or other strategies to promote affordability, priority processing, assisting with funding and fee waivers. * *Program 25 (Development Code Amendments):* While the Program commits to revising emergency shelter standards, it should also commit to amending the definition of emergency shelters in compliance with new statutory requirements (AB 2339). 2. *The Housing Element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate-income households. (Gov. Code, § 65583, subd. (c)(2).)* Farmworkers: While the element briefly mentions farmworkers in a few programs, it must have specific efforts based on the outcomes of a complete analysis. For example, the element could commit to proactive actions to coordinate with nonprofit developers, employers, and other related organizations, to explore funding and incentives, annually identify specific development opportunities, pursuing strategies to integrate affordable housing and targeting rehabilitation and conservation and improvement programs toward farmworkers. 3. *Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of* housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).) As noted in Finding B4, the element requires a complete analysis of potential governmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints. 4. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics... (Gov. Code, § 65583, subd. (c)(5).) As noted in Finding B1, the element requires a complete AFFH analysis. Depending upon the results of that analysis, the City may need to revise or add programs. In addition, goals and actions must specifically respond to the analysis and the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have specific commitment, metrics or numeric targets, geographic targeting, and milestones and must address, as appropriate, housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization, and displacement protection. 5. The housing program shall preserve for low-income household the assisted housing developments identified pursuant to paragraph (9) of subdivision (a)... (Gov. Code, § 65583, subd. (c)(6).) While Program 34 (At-Risk Housing) commits to various actions to preserve at-risk units, actions, particularly noticing, appear dependent on the event that the units are not preserved. These actions should occur regardless and before the conversion of at-risk properties. In addition, the Program should commit to provide support and education to tenants early in the process. 6. Develop a plan that incentivizes and promotes the creation of accessory dwelling units that can be offered at affordable rent... (Gov. Code, § 65583, subd. (c)(7).) While Program 3 (Encourage and Facilitate Accessory Dwelling Units) includes various actions to incentivize accessory dwelling units (ADUs.), it should also monitor permitted ADUs and affordability every other year and take appropriate actions such as adjusting assumptions or rezoning within a specified time (e.g., six months). D. Quantified Objectives *Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd. (b)(1 & 2).)* The element must include quantified objectives to establish an estimate of housing units by income category that can be constructed, rehabilitated, and conserved over the planning period. While the element includes these objectives by income group for very low-, low-, moderate- and above-moderate income, and folds objectives for ELI households into the very low-income category, the element must separate out objectives for ELI households to accurately measure the success of programs. E. Public Participation *Local governments shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the Housing Element, and the element shall describe this effort. (Gov. Code, § 65583, subd.(c)(9).)* While the element provides an overview of public comments recently received, it must also describe how prior comments are incorporated into the housing element. In addition, the discussion of public participation should not be limited to comments received on the City's housing element and should incorporate comments received on the Multi-Jurisdictional Housing Element. Further, Self Help Enterprises has provided helpful comments to other Cities in the region that have meaningful application County-Wide. HCD encourages the City to consider these comments and will send the comments under separate cover. Finally, public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. During the housing element revision process, the City must continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available while considering and incorporating comments where appropriate. Please be aware, any revisions to the element must be posted on the local government's website and to email a link to all individuals and organizations that have previously requested notices relating to the local government's housing element at least seven days before submitting to HCD. <
> October 28, 2024 Mayor Jerry Dyer Fresno City Councilmembers Michelle Zumwalt, Planning and Development Department 2600 Fresno Street, Room 3065 Fresno, CA 93721 *Sent via email:* housingelement@fresno.gov **RE: October 2024 Errata to the Revised HCD Draft Housing Element** Dear Mayor Dyer, Councilmembers, and Ms. Zumwalt: Leadership Counsel for Justice and Accountability (“LCJA”) writes in collaboration with the Public Interest Law Project (“PILP”) and the other undersigned organizations to provide comments on the Errata to the Revised HCD Draft Housing Element 2023-2031. LCJA and the undersigned organizations work alongside the most impacted communities to advocate for sound policy and eradicate injustice to secure equal access to opportunity regardless of wealth, race, income, and place. As addressed in our previous letters, we advocate for vital policy and practice changes to meet the housing needs of all residents in the City of Fresno, especially low-income communities individuals with special housing needs, and BIPOC communities to overcome fair housing disparities. **I. Inadequate Community Engagement** Following the release of HCD’s October findings, which instructed the City to “incorporate public participation and targeted outreach to better examine needs and formulate appropriate policies and programs” in R/ECAPs; to “continue to employ a variety of methods to gather input from all segments of the community, beyond making the document available as part of future revisions and submittals”; and to “specifically target individuals and organizations that represent lower-income households, including residents or representatives of R/ECAPs,” we anticipated additional community engagement efforts from the City to solicit community input Michelle Zumwalt Page 2 of 17 prior to the release of additional revisions. Although we appreciate that the City incorporated relevant feedback collected from the Climate Adaptation Plan and Environmental Justice Element workshops and “Discussions with Affordable Housing Partners,” we would have liked the opportunity to meet with City staff to discuss community concerns before the Errata was released, unfortunately the City released it less within a month of the previous Errata leaving very little opportunity to engage community members. Lastly, we advocate for additional workshops, meetings, and targeted outreach in Racially and Ethnically Concentrated Areas of Poverty to inform, and complete, the Housing Element’s Assessment of Fair Housing and subsequent revisions to Policies and Programs in the Action Plan. ## II. Failure to Include Community-Identified Programs That Will Result in A Beneficial Impact During the Planning Period and AFFH. Although we appreciate the City’s incorporation of many of the suggestions from our most recent comment letter, including recommendations regarding community-identified programs; several of the programs still have deficiencies or could otherwise be improved to address housing needs identified by community members. ### Program 1–Maintain Adequate Sites The Errata adds language regarding project-by-project evaluation of progress toward accommodating the RHNA. However, the City should also commit to a mid-cycle review of pipeline projects, development on identified sites, and development trends, generally, to determine whether identification of additional sites or other actions are necessary to ensure that adequate sites to accommodate the RHNA–especially the lower-income RHNA–are available throughout the planning period.[^p528-1] ### Program 2–Variety of Housing Opportunities in High Resource Areas This program now commits to “[i]ncorporate AFFH into land use and funding decisions beginning in January of 2025.”[^p528-2] The City is already obligated by Government Code section 8899.50 to affirmatively further fair housing in all land use and funding decisions and cannot [^p528-1]: See Letter from Paul McDougall to Jennifer Clark re: City of Fresno’s 6th Cycle (2023-2031) Revised Draft Housing Element (Oct. 7, 2024) (“HCD 10/7/2024 Findings”), p. 3 (“[T]his Program should commit to monitor progress toward completion in the planning period and take appropriate action if projects are not anticipated to be completed in the planning period.” [^p528-2]: City of Fresno. (2024). ERRATA FOR THE CITY OF FRESNO REVISED HCD REVIEW DRAFT HOUSING ELEMENT OCTOBER 21, 2024, p.1E-1-11. defer compliance with the law until 2025.[^p529-3] Further, the City needs to commit to concrete actions that it will take to ensure that it follows through on its commitment to incorporate AFFH into future decisions. The City Council should adopt a policy requiring staff memos to the Council and relevant commissions to include an affirmatively furthering fair housing analysis that analyzes the fair housing impacts of any proposed decisions related to housing, as well as any applicable project alternatives. Such a policy would be especially valuable in Fresno, where neighborhood opposition to affordable housing functions as a major constraint to the funding, siting, and development of affordable housing and housing for homeless individuals and families.[^p529-4] Active consideration of whether a particular project will promote integration and opportunity, and of its impacts on members of groups protected by fair housing laws, will help the City to ensure that it is not allowing animus against low-income people, people with disabilities, and other protected groups to cause it to violate its duty to affirmatively further fair housing. **Program 3 – Encourage and Facilitate Accessory Dwelling Units and Small Homes** Although the City revised the program objective to include the suggested language provided in HCD’s October 7th Findings letter, the City must also include extremely-low and very-low-income households in the 30 percent of ADU development that will take place in relatively higher resource and income areas and RCAAs; as well as throughout the City, in order to AFFH and promote integration. Additionally, this program should be further revised to ensure the development of ADUs is affordable to low-income households in R/ECAPs and effectively serve as a place-based strategy that affirmatively furthers fair housing. Furthermore, the City’s revisions should include a clear definition for “small homes” and the difference from ADUs. Please refer to our prior comment letter for further information. **Program – 14 Partnership with Affordable Housing Developers** We appreciate that the program was revised in the September Errata to include some of the language provided in our August 7th comment letter; however, this program can be further improved with revisions that include strategies to combat NIMBYism for projects in high-resourced areas and a commitment to utilize the quarterly convening to provide stakeholders with a detailed report outlining the success of the program. Furthermore, we restate that the project's timeframe should be revised to commit to bi-annual reporting throughout the planning period, bi-annual review and assessment of potential funding opportunities, and quarterly convening with stakeholders. [^p529-3]: See Gov. Code 8899.50(b)(1): “A public agency shall administer its programs and activities relating to housing and community development in a manner to affirmatively further fair housing, and take no action that is materially inconsistent with its obligation to affirmatively further fair housing.” [^p529-4]: See, e.g., Zisser, D. (Aug. 7, 2024). Letter from David Zisser to Georgeanne White re: Fresno City Council’s Denial of Fresno Quality Inn Homekey Project – Letter of Technical Assistance Michelle Zumwalt Page 4 of 17 # Program 17 – Surplus Public Lands We appreciate that the City revised the program to be in line with the Surplus Land Act requirement to include a “minimum of 15 percent affordable units” and for adding additional strategies to rezone sites for affordable housing. However, this program still fails to outline the additional steps the City will take to ensure the development on sites located in higher opportunity areas. # Program 19 – Home Buyer Assistance First and foremost, thank you for including commitments to offer technical and financial assistance to prospective homebuyers, ensuring that residents are guided throughout the program will greatly increase the success of the program. However, in regard to financial assistance, residents insisted that in Fresno’s housing market, offering up to $200,000 in assistance, as opposed to the October Errata’s revision of $100,000, will result in the greatest beneficial impact. Additionally, the program should be made available to residents who utilize an Individual Taxpayer Identification Number (ITIN). # Program 20 – Housing Choice Voucher Although the program was revised in the October Errata in response to HCD’s October findings letter, by adding a commitment “to conduct outreach to developments in high and relatively higher resource and income areas” the revision should have included RCAA and targeted outreach and advertisement in low-resourced areas as well. In doing so, the program will promote housing mobility to all City residents and in turn AFFH. Furthermore, the program still lacks meaningful actions with specific timelines and measurable outcomes that work towards “a beneficial impact.” We reaffirm that this program must include actions that ensure voucher holders do not face any discrimination; for example, commiting to finance a billboard displaying the protections against HCV discrimination and providing landlords with informational material on HCV and the consequences of source-of-income discrimination; the City should also establish and fund a program within the City to actively pursue enforcement against discrimination against voucher-holders and/or funding the Eviction Protection Program, which guarantees access to legal counsel to low-income tenants on housing matters. # Program 22 – Housing Rehabilitation Thank you for including commitments to offer technical and financial assistance; as well as reinforcing the timeframe for the project. However, this program requires additional revisions to ensure homes are preserved and well maintained. Residents stress the importance of adding Michelle Zumwalt Page 5 of 17 weatherization and heat resilience policies that commit to offering services that include, insulation and cooling systems, such as heat pumps. It is a necessity and will serve as a preventative measure to rehabilitation services. Additionally, residents identified the need for educational workshops and assistance prior to receiving a fine; therefore, the City’s code enforcement division should serve as a secondary outreach team that refers would-be offenders to the Housing Rehabilitation program. Furthermore, this program must be accessible to residents with ITIN’s. Lastly, offering Temporary Housing assistance, such as emergency housing vouchers, during extreme renovations will allow disadvantaged residents the opportunity to secure housing for themselves and their families without accumulating additional financial burdens. The City must reconsider including our suggested place-based policy to “set aside 5% of its annual general fund revenue” to ensure the program remains funded throughout the planning period. **Program 23 – Comprehensive Code Enforcement** The revisions made to Program 23’s Objective in response to HCD’s October findings should be more explicit. The revisions state that the City will “Conduct focused outreach and programming in older and disadvantaged neighborhoods in central and south Fresno, including Downtown Fresno. Determine any additional neighborhoods that should be identified for outreach and programming.” However, the Assessment of Fair Housing Descriptions of R/ECAP Areas states that Program 23 would be applicable to the Lowell/Jefferson Neighborhood, the Edison Neighborhood, the Southeast neighborhood, the Southwest Neighborhood, Central Southeast Neighborhoods, the Mclane Neighborhood, Fresno High-Roeding Neighborhood, the El Dorado Park neighborhood, and the Shaw/Marks Neighborhood; therefore, the objective should explicitly include these communities and the timeframe should be further revised to reflect when and how outreach will occur during the planning period. Furthermore, this program still lacks actions that would hold landlords legally accountable for retaliation, harassment, and evictions of tenants who filed code enforcement complaints. Once again, we recommend that the City analyze its code enforcement procedures, incorporate tenant feedback, and commit to adopting a tenant anti-harassment ordinance. **Program 26 – Fair Housing Services** Program 26 was revised in the September Errata, to include an action for geographic coverage and outreach and states that it “should be targeted to the most vulnerable populations as depicted in Figure 1E-3.3 – Racial Segregation by Census Tract, Figure 1E-3.7-Distribution of Poverty, and Figure 1E-3.10 – Percentage of Population with a Disability.” Yet the revisions made to the AFH Description of R/ECAPs in the October Errata state that this program would “promote equitable quality of life” in Southeast and Central Southeast neighborhoods. Therefore, this action should have been further revised to explicitly include these neighborhoods and state Michelle Zumwalt Page 6 of 17 that this action “will target the most vulnerable populations.” Additionally, this program still fails to establish timelines and concrete steps toward successfully reaching its objective to “mitigate impediments to fair housing opportunities throughout the city, with an emphasis on supporting the needs of populations and neighborhoods most impacted by fair housing issues.” Furthermore, as addressed in our August comment letter, and further reinforced in HCD’s October findings, the City should utilize additional public participation and targeted outreach to ensure input from Fresno residents directly impacted by discrimination, especially in R/ECAPs, so that the City understands and addresses the needs of R/ECAP residents. We still recommend the inclusion of additional legal representation, landlord education on fair housing law, and enforcement mechanisms against bad landlords. **Program 27 – Environmental Justice** The revisions made to the Environmental Justice Program in the September Errata better align the program with the requirements of the Environmental Justice Element. However, the September and October Errata should have also included place-based strategies in R/ECAP as Environmental Justice actions that could then be reinforced in the Environmental Justice Element. The program should include the following actions to improve the quality of life in R/ECAPs, specifically in the communities residing in South Fresno: * Implement land use changes to rezone industrial use, and prohibit future industrial uses near sensitive receptors * Prohibit the siting of polluting uses near impacted communities and impose impact fees on polluters operating near homes. The funds generated will go towards a community benefit fund managed by the impacted community and utilized to transform R/ECAPs into areas of opportunity. * Establish a moratorium on warehouses in or near R/ECAPs and a cargo/freight Prohibition and revenue tax that directly funds community-based housing and development in communities affected by the negative environmental impacts caused by freight. * Develop Public health impact reports to understand how industrial development may exacerbate existing public health disparities, especially in R/ECAPs; seek the support of public health agencies to complete this analysis; include these impact reports in the permit approval process and in decision making; and make these reports publicly accessible. Additionally, the program was revised in the September Errata to state: “The City will monitor the impact of the EJ Element policies in the General Plan by developing a data tracking program to assess program outcomes in disadvantaged communities. Every five years, the City Michelle Zumwalt Page 7 of 17 will collect data to assess its performance against a minimum of five of the following types of measures using 2024 as the base year.” This action should be revised from collecting data every five years to “annually,” and to assess performance “against all of the following types of measures, and make the data publicly available through annual reporting.” These recommended changes will help to ensure that the program improves the quality of life in R/ECAPs and affirmatively furthers fair housing.[^p533-5] **Program 28 – Equitable Community Investments** Although Program 28 was revised in the September Errata to include ongoing investments in West Fresno, Downtown, and Southwest Fresno, potential funding sources, and further revised in the October Errata to include commitments towards implementing and monitoring the Southwest Specific plan and Downtown Neighborhoods community plan, this program still comes short of authentic equitable community investments. The AFH Description of R/ECAP Areas identifies Program 28 as an opportunity “to promote equitable quality of life” in Downtown, Edison Neighborhood, Southeast Neighborhood, Jane Addams Neighborhood, Southwest Neighborhoods, Central Southeast Neighborhoods, McLane Neighborhood, Fresno High-Roeding Neighborhood, El Dorado Park Neighborhood, and Shaw/Marks Neighborhood, yet fails to include actions towards place-based revitalization in these communities other than the ones mentioned above. For example, the City could commit to incorporating complete street principles as an action that is applied into all transportation projects at all phases of development, including planning and land use decisions as well as implementation. The program must be further revised to explicitly describe planned revitalization strategies in all identified R/ECAPs and prioritize the South Fresno communities that have continuously advocated for additional investments that support healthy housing, infrastructure, amenities, and services. Unfortunately, in the October Errata, the language added to this program timeframe will not promote a future of equitable quality of life goals. To state that, “If land use is changed from an adopted use in a specific plan, the City will evaluate impacts and create new targets to better balance for residential industrial compatibility” demonstrates that the City is willing to create an opportunity that allows the poor land use decisions of placing unhealthy industrial zones near residential communities to reoccur. This program will not AFFH until it is revised to include clear actions and commitments for all R/ECAPs. **Program 29 – Equitable Community Engagement** Despite stating that this program will “promote equitable quality of life” for Southeast and Central Southeast neighborhoods in the October Errata’s AFH description of R/ECAP, the [^p533-5]: California Department of Housing and Community Development. (2021). *Affirmatively Furthering Fair Housing: Guidance for All Public Entities and For Housing Elements.* p.54. Michelle Zumwalt Page 8 of 17 program fails to explicitly address the committed actions and measurable outcomes towards ensuring equitable community engagement of these communities. Additionally, we recommended that this program be revised to include the establishment of a Housing Element Implementation Committee. As stated in our August comment letter, the Committee should be composed primarily of tenants, low-income homeowners, and at-risk populations. The goal of this committee will be to ensure that implementation meets the needs of at-risk communities and to inform potential revisions throughout the planning period. **Program 30 – Workforce Development** As stated in our August comments, we encourage the City to include additional actions that target services for the unhoused community in the workforce development program. The City should include commitments to support unhoused individuals transitioning from shelters into communities. Providing voluntary job training specifically to assist unhoused individuals apply for jobs, retain employment, and develop skills is strongly recommended. Additionally, this program still fails to integrate R/ECAP and R/ECAA. **Program 33 – Mobile Home Parks** Thank you for addressing the need for rent control policies and policies that discourage rezoning. We encourage greater specificity regarding removal of the requirement that residents must form a committee to oppose rent increases using the mobile home rent control program process, as well as adding commitments to hold Mobile Home Park owners accountable through fines for code violatons and harassment of tenants. Additionally, the October Errata was revised to include “Establish regulations to protect affordable housing on property currently occupied by mobile home parks. If the property is proposed for conversion from a mobile home park, it will be required to redevelop with a number of covenanted affordable units equal to the number of mobile home units lost in the conversion, or 10 percent of new units, whichever is higher." We recommend that the City should further reinforce this policy by committing to apply mobile home park zoning to existing mobile home parks. More should be done for the rehabilitation and preservation of mobile homes; the city must reconsider adding commitments to weatherization services and prioritizing homes in major need of repair or at risk of having damage exacerbated by the effects of climate change. Residents have stressed the inability of their outdated and underserviced homes to withstand heat waves during the summer and floods during winter months. The dangers of extreme heat became a reality to the residents of Three Palms Mobile Home Park after a community member was found unresponsive in their home after disappearing for two weeks following an extreme heat wave. Now as residents prepare for the winter, they share that they will have to resort to the use of multiple space heaters and the kitchen stove to keep their families warm. Similar to Program 22, residents stress the importance of making mobile home rehabilitation funds and services available to residents who utilize an ITIN, offering temporary housing assistance, utilizing the code enforcement division as an additional method for referrals and outreach, and committing a percentage of the General fund to the funding of this program. **Program 34 – Eviction Protection Program** We must reiterate the importance of securing a permanent source of funding to ensure the Eviction Protection Program remains effective throughout the planning period; therefore, the EPP should be codified in the City’s municipal code and revised to state that “The City will invest in this program with money from the general fund. We strongly encourage the City to include HUD’s Eviction Protection Grant Program as a source of funding and revise the program to include commitments to allocating additional funding from the City’s General fund. Additionally, the City should include a commitment to adopt a rent stabilization and just cause eviction ordinance, developed from community input, as an additional measure that guards tenants against displacement. These policies would make the eviction protection program more effective in achieving its stated purpose. **Program 35–Replacement Housing** We appreciate the City’s adding a reference to the Housing Crisis Act to this program. Please note that the full citation for the Housing Crisis Act is Government Code sections 66300 to 66301, and the replacement housing requirements are found in section 66300.6. Additionally, the program should identify specific actions that the City will take to ensure that it complies with applicable replacement housing requirements–e.g., adopting a replacement housing ordinance that complies with state law–as well as actions to implement the Housing Crisis Act’s other requirements for new development that demolishes existing: notice, right to return, relocation benefits, etc. **Program 36 – Homelessness Assistance** Although we appreciate the addition of actions that commit to providing “outreach to link unhoused residents with mental health and substance treatment services,” “ mobile home showers and restrooms for unhoused individuals through the Homeless Services Division,” and “ crisis intervention training to City staff that work with the unhoused community” in the September Errata, this program will not lead to a beneficial impact as written given the City’s recent decision to criminalize unsheltered homelessness. The program should be further revised to include commitments towards preventative measures that ensure residents residing in shelters Michelle Zumwalt Page 10 of 17 remain on a path towards permanent housing, including applying for additional funding to ensure shelters have sufficient beds. Furthermore, the City should include the recommendations outlined in our August comment letter to demonstrate a clear commitment towards homelessness assistance. **III. The Assessment of Fair Housing Fails to Comply with Section 65583(c)(10)** The Housing Element fails to include an assessment of fair housing (“AFH”) that meets the requirements of State law, and it also fails to include adequate programs to affirmatively further fair housing (“AFFH”).⁶ HCD’s findings released on October 7, 2024, ask the City to “expand the discussion of characteristics of [each of the R/ECAPs] and changes over time” including “past and current neighborhood conditions, disparities in access to opportunity” and the “effectiveness of past policies and investments and unique opportunities to promote equitable quality of life.”⁷The findings also state that the Draft should incorporate public participation and targeted outreach to better examine needs and formulate appropriate policies and programs; such an effort will help complete the assessment of fair housing and clarify the need for the City to add or revise programs.⁸Furthermore, the new and revised goals and actions “must be significant and meaningful enough to overcome identified patterns and trends.”⁹ We appreciate the edits to the Local Assessment of Fair Housing Section to include a *Description of R/ECAP Areas*, that lists the different R/ECAPs, describes them, and reports data that outlines the lack of access to opportunity. Unfortunately, though, the assessment is incomplete. The Errata did not incorporate past local knowledge from residents. It also excludes prominent policies and programs recommended and created by residents from the Here to Stay Report,¹⁰ which we incorporated in Section II of this letter. Although the *Description of R/ECAP Areas* lists the programs that are intended to create opportunities to promote equitable quality of life, the programs themselves fail to include specific commitment to deliverables, measurable metrics or objectives, definitive deadlines, dates, or benchmarks for implementation in order for them to have a “beneficial impact” during the planning period (please refer to the Section II of this letter). **A. Incomplete Analysis of Displacement Risks** The Errata did not include additional analysis of displacement risks. It fails to consider relevant information such as COVID-19 related rent increases and evictions and its impact [^p536-6]: Gov. Code §§ 65583(c)(5),(10); 8899.50; 65583.2(a). [^p536-7]: HCD 10/7/2024 Findings, p.1. [^p536-8]: Id. p.2 [^p536-9]: Ibid. [^p536-10]: Thrivance Group. (2021). *Here to Stay: A Policy Based Blueprint for Displacement Avoidance in Fresno*. https://www.transformfresno.com/wp-content/uploads/2021/06/transform-fresno-here-to-stay-report-english.pdf relating to existing and potential housing cost pressures confronting low-income residents, residents of color, and other protected classes, as well as significant displacement risks associated with tenant protection limitations, City land use policies and practices, environmental hazards, and climate change. A complete displacement risk analysis must consider these and other relevant factors.[^p537-11] The AFH’s Displacement Risk section should be revised to consider displacement risks associated with environmental hazards, environmental disasters, and climate change, pursuant to HCD’s AFFH Guidance.[^p537-12] It is important to note that the City must continue to fully analyze the displacement risks to R/ECAPs and the impacts associated with housing cost pressures. We reiterate that, although data for 2019 has been included, this time period does not capture the sharp and sustained escalation in housing costs (both rental and ownership) that occurred during the COVID-19 pandemic between 2019 and 2022.[^p537-13] Between 2017 and 2021, Fresno experienced the greatest rent increases of all large U.S. cities, with rental prices increasing nearly 39% during that time.28 The City failed to include this vital analysis and therefore the AFH’s displacement risk analysis must be supplemented with and revised based on more recent data in order to adequately fulfill this requirement.[^p537-14] A complete analysis of displacement risks considers not only displacement risks associated with housing cost pressures, but also other factors which result in housing instability, including factors relating to the adequacy of tenant protections, disinvestment, local land use policies and practices, environmental hazards, and risks associated with natural disasters and climate change. Although the Errata acknowledges that extreme heat impacts R/ECAPs, it failed to analyze those impacts. Based on our direct work with tenants and low-income residents and residents of color, these risk categories represent real and significant risk factors for Fresno residents. Once again, we ask that the City incorporate the following analysis and assessment to the Displacement risk section: * Address the adequacy of policies and resources to protect tenants from displacement as a result of eviction, harassment, and substandard housing and include additional and stronger policies and programs to protect tenants, including in particular more comprehensive and stringent rent control standards than those established by the state, just cause requirements for eviction, and right to return home for displaced residents. * Analyze the success and effectiveness of the City’s code enforcement programs. [^p537-11]: See California Department of Housing and Community Development. (2021). *Affirmatively Furthering Fair Housing: Guidance for All Public Entities and For Housing Elements* (p.40-43). [^p537-12]: Id. at p.42. [^p537-13]: CalMatters, Real estate prices soar during the pandemic, climbing 25% in parts of California, Dec. 5, 2020, available at https://calmatters.org/california-divide/2020/12/real-estate-climb-pandemic/ [^p537-14]: Gov. Code §65583(c)(10)(A)(ii); *See also* California Department of Housing and Community Development. (2021). *Affirmatively Furthering Fair Housing: Guidance for All Public Entities and For Housing Elements*. pp.39. Michelle Zumwalt Page 12 of 17 * Consider the extent to which public and private disinvestment and unequal investment continues to impact low-income neighborhoods, neighborhoods of color, and neighborhoods with a high proportion of tenants and how disinvestment perpetuates and/or increases displacement risk in these areas. * Consider the City’s land use and permitting decisions which have directed and continue to allow for and promote the concentration of industrial and waste management facilities in and around neighborhoods in Jane Addams, Southwest Fresno, South Central Fresno (referred to by the Draft Housing Element as the “South Industrial Area”), and Southeast Fresno. * Consider displacement risks associated with environmental hazards, environmental disasters, and climate change, pursuant to HCD’s AFFH Guidance.[^p538-15] **B. Incomplete analysis of the City’s response to homelessness.** As noted in prior comments, the City is aggressively criminalizing unsheltered homelessness while, at the same time, preventing the siting of supportive housing that would serve its unhoused population. These actions cause disproportionate harm to the City’s Black and disabled residents, but the City has failed to engage in a thorough analysis of their discriminatory effects; nor has the identified adequate program actions to address those effects, as discussed above. The Errata adds Figure 1E-3.33 illustrating unsheltered camping locations throughout the City and their proximity to services,[^p538-16] but it does not acknowledge that the City absolutely bans unsheltered camping and is actively displacing–including through arrest–people attempting to live unsheltered near services and facilities. According to one report, Fresno police arrested 30 people under the City’s new anti-camping ordinance between its September 24, 2024, effective date and October 11, 2024.[^p538-17] But, other than acknowledging that the local independent living center expressed concerns regarding the City’s criminalization of unsheltered homelessness and its impacts on people with disabilities, the Errata does not discuss the ordinance at all.[^p538-18] Without an analysis of the City’s criminalization of homelessness, the Assessment of Fair Housing remains incomplete. [^p538-15]: California Department of Housing and Community Development. (2021). *Affirmatively Furthering Fair Housing: Guidance for All Public Entities and For Housing Elements*, p.42. [^p538-16]: *See* City of Fresno. (2024). ERRATA FOR THE CITY OF FRESNO REVISED HCD REVIEW DRAFT HOUSING ELEMENT OCTOBER 21, 2024, pp. 1E-3-90 to 1E-3-91. [^p538-17]: Thaddeus Miller, What's new anti-camping law impact on Fresno homeless? Way more arrests than treatment, Fresno Bee (Oct. 11, 2024), available at https://www.fresnobee.com/news/local/crime/article293730944.html#storylink=cpy. [^p538-18]: *See*, *e.g.*, City of Fresno. (2024). ERRATA FOR THE CITY OF FRESNO REVISED HCD REVIEW DRAFT HOUSING ELEMENT OCTOBER 21, 2024, pp. 1E-6-26 (“The representative expressed concern about laws in the City of Fresno that prevent homeless community members from camping or living in their cars. . .”) Michelle Zumwalt Page 13 of 17 Similarly, the City also has not added analysis regarding the factors that caused its denial of the Quality Inn Homekey project in December 2023.[^p539-19] Such analysis is necessary to ensure that the single program identified to prevent future denials–Program 2–will be effective. # IV. Failure to Adequately Analyze Housing Constraints ## A. Governmental Constraints In response to the initial draft released by the City, we raised concerns that the City did not adequately analyze constraints as required by Government Code section 65583(a)(5) , and did not provide sufficient support for the conclusions reached by the City. Further, we have continually advocated for the inclusion of various meaningful suggestions from residents as to actions which would remove barriers to development and further the accessibility of affordable housing in the city in the analysis of governmental constraints. Further, throughout the drafting process, the analysis of governmental constraints has failed to adequately consider the actual constraints to the development of affordable housing posed by the zoning districts implemented by the development code. In the Local Assessment of Fair Housing of the Draft Housing Element, the City acknowledges the incompatibility of widespread single-family detached only zoning (zoning districts RE, RS-1, RS-2, and RS-3) that prohibits zero lot line dwellings, townhomes, rowhomes, duplexes, and triplexes with the objective of expanded affordable housing.[^p539-20] At the same time, the zoning code allows single-family detached development by-right in many of the zones identified for increased high-density development: RM-1, NMX, CMX, RMX, CMS, CR, DTN, DTG. As part of the City’s existing land use policies, the zoning districts should be analyzed as potential constraints on the development of multifamily affordable housing. In addition, as neither the September errata nor the October errata to the July 2024 draft amended the analysis of at-risk housing, we want to restate that the Housing Element’s analysis of at-risk housing is inadequate. A total of 695 units were identified in the September 2024 errata as being at risk of conversion from low-income residential uses to other uses within 10 years from the housing element adoption deadline.[^p539-21] However, this draft failed to meaningfully address the extent of the risks to publicly assisted affordable housing or to propose actions to meaningfully address these risks. As the October 2024 errata was released without Section 1E-4: [^p539-19]: See Errata, p. 1E-3-137. [^p539-20]: “Affordable housing development typically requires high-density zones to support construction and financing; therefore, zones limited to single dwelling units on each lot do not support affordable development.” City of Fresno. (2024). ERRATA FOR THE CITY OF FRESNO REVISED HCD REVIEW DRAFT HOUSING ELEMENT OCTOBER 21, 2024, p.1E-3-113 [^p539-21]: City of Fresno. (2024). ERRATA FOR THE CITY OF FRESNO REVISED HCD REVIEW DRAFT HOUSING ELEMENT, SEPTEMBER 23, 2024, p.1E-4-62. Michelle Zumwalt Page 14 of 17 Constraints, these errors remain uncorrected. The lack of any expansion of this analysis in the most recently released errata demonstrates that the City has failed to appropriately discuss which action would be most appropriate for the City and whether there would be any constraints posed to the action, as required under Government Code section 65583(a)(5). Throughout the drafting process, we have uplifted ways this section should be improved to achieve consistency with Housing Element law, to better effectuate the goal of improving access to affordable housing within the City of Fresno, and to reflect the concerns and suggestions of residents. We again urge the City to analyze the lack of tenant protections (e.g. source of income discrimination outreach and education, rent stabilization, and just cause protections) and how they may facilitate the displacement of lower-income renters. Because of the potential for displacement, the lack of these protections should be analyzed as a constraint on the maintenance of housing under Government Code section 65583(a)(5). ### B. Non - Governmental Constraints Although we have made previous comments on the importance of analyzing non-governmental constraints,[^p540-22] unfortunately the Errata continues to exclude such an analysis even though public comments have been submitted in response to this specific issue. The Draft failed to consider the effect of NIMBY opposition and environmental concerns. #### 1. NIMBY Opposition Once again, we reiterate that the Draft must include an analysis of NIMBY opposition to affordable housing development. As a largely sprawling suburban City, Fresno is prone to local opposition to increased density from existing single-family homeowners who have preconceived ideas of the impacts of increased density on their neighborhoods. NIMBY opposition is all too common and a pervasive issue when building multi-family projects in high-resourced areas. We recommend that the City include an analysis and incorporate programs that will address this, such as an inclusionary housing ordinance. #### 2. Environmental Concerns The Errata failed to include additional amendments and analyses on environmental constraints.[^p540-23] Environmental constraints may include limitations to water supply, nearby pollution, or infrastructure development. Per our previous comment letters, we have noted that the City of Fresno relies heavily on groundwater and surface water.[^p540-24] As climate change makes [^p540-22]: See Gov. Code § 65583(a)(6). [^p540-23]: Id. [^p540-24]: See Leadership Counsel for Justice & Accountability. City of Fresno Draft 6th Cycle Housing Element Comment Letter, August 16, 2023. Michelle Zumwalt Page 15 of 17 water availability less predictable the City must analyze how an increased population and land use will affect water availability and whether water availability will eventually constrain growth. Additionally, the City must consider the infrastructure requirements of delivering water to a denser population. For example, the City estimates that downtown Fresno, where a large portion of new housing development is projected, currently requires significant water and wastewater infrastructure upgrades. Although Program 28 - Equitable Community Investments is amended to acknowledge the need, it fails to include concrete steps to achieve this; it simply says they “will continue to prioritize investment in underserved neighborhoods” or “water, sewer, stormwater, and other infrastructure improvements to accelerate mixed-income infill housing development by 2031.” The program must have concrete steps, objectives, and metrics on how the City plans to improve infrastructure. The Errata also failed to consider industrial and polluting industries’ effects on future housing development. As we mentioned in our previous comment letters, the City must also analyze as a constraint the proliferation of warehouses and other industrial uses in and around the City, particularly in South Fresno. These industrial and warehouse projects come with an enormous increase in vehicle traffic and worsen already very poor air quality. They also result in light, sound, and vibration pollution. Many of these projects are being approved next to residential development with no buffer, driving down housing value, and worsening housing conditions. The City must consider warehouse and industrial use proliferation as a constraint, and identify impacts to residents. The City must then commit to adopting strong programs and policies with enforceable timelines to address the constraint. Additionally, the City of Fresno has evolved as a car-dependent City surrounded by heavy industry and highways. Therefore, future housing development will need to carefully consider placement and mitigation measures to avoid perpetuating environmental inequity. ### V. Conclusion Thank you for considering and incorporating several of our comments. The undersigned organizations welcome the opportunity to continue collaborating on the City of Fresno’s Housing Element update to ensure the City is committed to meeting the housing needs of all residents, complies with state law, and provides equitable public participation opportunities throughout the revision process. We look forward to meeting with the City to further discuss community priorities in detail and learn how the City will commit to its duty to Affirmatively Further Fair Housing. Respectfully, Michelle Zumwalt Page 16 of 17 /s/ Emmanuel Agraz-Torres, Policy Advocate Leadership Counsel for Justice and Accountability /s/ Seth Alston, Legal Advocate Leadership Counsel for Justice and Accountability /s/ Melissa A. Morris, Staff Attorney Public Interest Law ProjectPublic Interest Law Project mmorris@pilpca.org 510-891-9794 x 111 /s/ Sandra F. Celedon, President and CEO Fresno Building Healthy Communities /s/ Lilia Becerril, Founder Familias en Acción /s/ Marisa Moraza, Political Director PowerCA Action /s/ Alexandra Alvarado, Community Organizer Faith in the Valley /s/ Dez Martinez, CEO We are Not Invisible City of Fresno Community Residents Lisa Fores, District 2 Yonas Pauloas, District 3 Cc: Michelle Zumwalt Page 17 of 17 Architect, Michelle Zumwalt, michelle.zumwalt@fresno.gov City Manager Georgeanne White, Georgeanne.White@fresno.gov Planning Director Jennifer Clark, jennifer.clark@fresno.gov Council President Analisa Perea, annalisa.perea@fresno.gov Councilmember Mike Karbassi, mike.karbassi@fresno.gov Councilmember Miguel Arias, miguel.arias@fresno.gov Councilmember Tyler Maxwell, tyler.maxwell@fresno.gov Councilmember Luis Chavez, luis.chavez@fresno.gov Councilmember Garry Bredefeld, garry.bredefeld@fresno.gov Councilmember Nelson Esparza, nelson.esparza@fresno.gov Mayor Jerry Dyer, jerry.dyer@fresno.gov Thomas Brown, Policy Analyst, California Department of Housing and Community Development thomas.brown@hcd.ca.gov Paul, McDougall, California Department of Housing and Community Development, paul.mcdougall@hcd.ca.gov Mayor Jerry Dyer City of Fresno Planning and Development Department 2600 Fresno Street, Rm 3043 Fresno, CA 93721 Date: Dear Mayor Dyer: 4991 E. McKinley Suite 123 Fresno CA 93727 P: 559.237.4102 F: 559.456.9192 www.habitatfresno.org HFHGFA Board of Directors Jim Tienken, Chair Feleena Sutton Dale Spencer Steve Jones Mel Casey Sabrina Brown Patrick Prince Jose Platas Zak Johnson CEO Ashley Hedemann The purpose of this letter is to express our support for the latest draft of the City of Fresno Housing Element, including the Errata dated October 21, 2024. As you are aware Habitat for Humanity Greater Fresno Area (HFHGFA) has worked closely with the City of Fresno on bringing affordable homeownership opportunities to residents of this community for the last 39 years. Most recently, HFHGFA has taken part in the Multijurisdictional Housing Element process since it began in 2022, participating in outreach events and commenting on previous drafts. We are pleased with the efforts the City of Fresno is undertaking to address community needs related to housing availability, affordability and accessibility in this Housing Element cycle. Most recently we have collaborated with City staff on refining Housing Element programs to further remove barriers to the development of affordable housing in the latest draft. Specifically, we worked with staff to modify the Action Plan in Chapter 1 as follows: **Program 4: Streamline Development Review Process** • Added a provision to ensure that both the building permitting and entitlement processes were covered for future streamlining efforts **Program 14: Partnerships with Affordable Housing Developers** • Added a provision to work with affordable housing developers to structure annual funding commitments to support multiple rounds of tax credit applications • Added a provision to identify opportunities to align entitlement and permit approvals for affordable housing projects with funding deadlines (e.g., HOME), including post-entitlement processes like encroachment permits • Added a provision to participate in joint advocacy for CEQA streamlining of single-unit affordable housing **Program 15: Land Bank** • Added a provision to work to remove blight from any banked properties **Program 16: Community Land Trust** * Added a provision to collaborate on maintaining vacant sites once acquired, and to provide support for staff, stakeholder and community education on land trust models We look forward to continuing our work in partnership with the City of Fresno and doing our part to implement the 6th Cycle Housing Element through creating additional homeownership opportunities. Building Together, (Signature) CEO Habitat Greater Fresno Area CALIFORNIA STATE TRANSPORTATION AGENCY | GAVIN NEWSOM, GOVERNOR --- | --- **California Department of Transportation** | DISTRICT 6 OFFICE | 1352 WEST OLIVE AVENUE | P.O. BOX 12616 | FRESNO, CA 93778-2616 | (559) 840-6066 | FAX (559) 488-4195 | TTY 711 | www.dot.ca.gov | October 28, 2024 FRE-41-22.50 CITY OF FRESNO HOUSING ELEMENT GTS #: FRE-2024-02096 SENT VIA EMAIL Ms. Sophia Pagoulatos Planning Manager City of Fresno – Planning and Development Department 2600 Fresno Street, Room 3043 Fresno, CA 93721 Dear Ms. Pagoulatos: Thank you for the opportunity to review of the Errata for the City of Fresno’s, Revised HCD Review of the Draft Housing Element dated October 21, 2024, which includes revisions to extracted chapters from the revised HCD Review Draft Housing Element. The mission of Caltrans is to provide a safe and reliable transportation network that serves all people and respects the environment. Caltrans provides the following comments consistent with the State’s smart mobility goals that support a vibrant economy and sustainable communities: 1. Caltrans fully supports Goal 6 and Program 31, which aligns with essential steps toward energy conservation and sustainable development in our community. Reducing or waiving fees for Vehicle Miles Traveled (VMT), especially for projects near high-quality transit corridors or those with a significant proportion of affordable housing, reflects a forward-thinking approach. This exemption not only aligns with California Environmental Quality Act (CEQA) requirements but also incentivizes the creation of affordable housing and bolsters active transportation solutions, like walking and cycling infrastructure, which are key for reducing overall vehicle dependency. 2. By setting clear timelines to establish affordable housing thresholds and a VMT mitigation fee by 2026, the City of Fresno is creating a structured pathway to lessen both the costs and the processing times associated with VMT analysis in new developments. These measures will likely increase project feasibility, promote eco-friendly transit options, and make the community more accessible. Additionally, dedicating funds for active transportation capital improvements will lead to “Provide a safe and reliable transportation network that serves all people and respects the environment” tangible environmental benefits, creating a cityscape that encourages sustainable travel while improving residents' quality of life. 3. This Goal and Program is a commendable move that balances the need for growth with sustainability, and Caltrans is optimistic about the positive impact it will have on the City of Fresno’s infrastructure and environmental footprint. If you have any other questions, please call David Deel, Associate Transportation Planner at (559) 981-1041. Sincerely, Mr. Dave Padilla, Branch Chief, Transportation Planning Copy: City of Fresno, Planning@fresno.gov. “Provide a safe and reliable transportation network that serves all people and respects the environment” 1331 Fulton Street Fresno, California 93721 (559) 443-8400 TTY (800) 735-2929 www.fresnohousing.org October 25, 2024 Mayor Jerry Dyer City of Fresno Planning and Development Department 2600 Fresno Street, Rm 3043 Fresno, CA 93721 RE: City of Fresno Housing Element 2024 Dear Mayor Dyer: The purpose of this letter is to express our support for the latest draft of the City of Fresno Housing Element, including the Errata dated October 21, 2024. Our organization, Fresno Housing Authority has taken part in the Multijurisdictional Housing Element process since it began in 2022, participating in outreach events and commenting on previous drafts. We are pleased with the efforts the City of Fresno is undertaking to address community needs related to housing availability, affordability and accessibility in this Housing Element cycle. Most recently we have collaborated with City staff on refining Housing Element programs to further remove barriers to the development of affordable housing in the latest draft. Specifically, we worked with staff to modify the Action Plan in Chapter 1 as follows: **Program 4: Streamline Development Review Process** * Added a commitment to continue providing navigation and concierge services to assist applicants with entitlement and permit processing for affordable housing projects * Added a provision to ensure that both the building permitting and entitlement processes were covered for future streamlining efforts **Program 11: Incentives for Housing Development** * Added a provision to provide flexibility in meeting off-site infrastructure requirements for affordable housing projects **Program 14: Partnerships with Affordable Housing Developers** * Added a provision to work with affordable housing developers to structure annual funding commitments to support multiple rounds of tax credit applications * Added a provision to identify opportunities to align entitlement and permit approvals for affordable housing projects with funding deadlines (e.g., HOME), including post-entitlement processes like encroachment permits We look forward to continuing our work in partnership with the City of Fresno and doing our part to implement the 6th Cycle Housing Element. Best Regards, Tyrone Roderick Williams Chief Executive Office *A Nonprofit Housing and Community Development Organization* <
> October 23, 2024 Sophia Pagoulatos Planning Manager Long Range Planning, Planning & Development City of Fresno 2600 Fresno Street Fresno, CA 93721 **Re: Housing Element Participation** Dear Ms. Pagoulatos, This letter serves to confirm Self-Help Enterprises (SHE) involvement in the development of the City of Fresno draft Housing Element (2023-2031). SHE has engaged in several ways through the development of the Housing Element (HE) as follows: * SHE provided specific written feedback on the prioritization of by-right permitting, which has been incorporated in the HE draft. * SHE staff participated in group stakeholder meetings. * The City of Fresno engaged SHE for one-on-one discussion and reviewed specific programs that relate to SHE’s work and comments, and the City absorbed and incorporated that feedback in the draft. Should you have any questions about SHE’s participation, please contact me at (559) 802-1653 or betsyg@selfhelpenterprises.org. Sincerely, <
> Betsy McGovern-Garcia *Vice President* <
> Main Office: 8445 W. Elowin Court · P.O. Box 6520 · Visalia, CA 93290 · Phone (550)651-1000 · Fax (559)651-3634 info@selfhelpenterprises.org · www.selfhelpenterprises.org <
> September 30, 2024 Mayor Jerry Dyer Fresno City Councilmembers Michelle Zumwalt, Planning and Development Department 2600 Fresno Street, Room 3065 Fresno, CA 93721 *Sent via email: housingelement@fresno.gov* **RE: Errata to the Revised HCD Draft Housing Element** Dear Mayor Dyer, Councilmembers, and Ms. Zumwalt: Leadership Counsel for Justice and Accountability (“LCJA”) writes in collaboration with the Public Interest Law Project (“PILP”) to provide comments on the Errata to the Revised HCD Draft Housing Element 2023-2031. LCJA works alongside the most impacted communities to advocate for sound policy and eradicate injustice to secure equal access to opportunity regardless of wealth, race, income, and place. As addressed in our previous letters, we advocate for vital policy and practice changes to meet the housing needs of all residents in the City of Fresno, especially low-income communities individuals with special housing needs, and BIPOC communities to overcome fair housing disparities. **I. Lack of Community Engagement** The Errata, released near the end of HCD’s review of the City’s July 2024 Draft Housing Element with only seven days for public feedback, continues the City’s failure to demonstrate a diligent effort to engage the community throughout the revision process. The City failed to: * Host additional public engagement opportunities to solicit feedback from the community, particularly R/ECAP communities, to incorporate that feedback into the Errata; * Communicate to stakeholders about the development of substantial revisions during the HCD review process; and * Provide sufficient time to ensure that community members, in particular visually impaired residents, are able to review and comment on the Errata. * LCJA, its coalition partners, and community members want to participate in the development of the Housing Element to ensure that its analysis and programs reflect the community’s needs, but, the City’s process has made that participation very difficult. ## II. The Errata Amendments fail to contribute to a compliant Assessment of Fair Housing Although the Errata amends the draft Housing Element on page 1E-3-26, to include an analysis of past actions that led to R/ECAPs in Downtown neighborhoods, South Fresno, the neighborhoods in the Bullard, Shaw/Blackstone area, and the Hoover community of North Fresno, the analysis still fails to contribute to a compliant assessment: * The amendments fail to evaluate public participation and demographic trends or contributing factors that led to the concentration of South Asians, Hispanics/Latinos, and/or African Americans living in R/ECAP and RCAAs. § 65583(c)(10)(A)(iii); AFFH Guidance, p. 33. The City has local information at its disposal that should be incorporated into this evaluation to adequately inform policies and programs in the Action Plan.[^p552-1] * The City briefly addresses actions leading to R/ECAPs in South Fresno and it claims that “the City is investing in these neighborhoods as well, with several specific planning efforts complete or underway, including …the South Central Specific Plan (SCSP).” However, this fails to address current practices given the fact that the SCSP will only benefit industrial development. Please refer to our previous comment letter addressing the SCSP (see Attachment A). HCD’s February 1, 2024 findings addressed the need to compare R/ECAP and RCAA’s “in terms of equitable quality of life.” On page 1E-3-29, the Errata includes a section on the impacts the “built environment” has on the quality of life and goes on to list “physical activity, good housing conditions, and access to healthy food and healthcare” as positive impacts of a built environment that are then used as metrics to interpret data from studies comparing access to opportunity in R/ECAPs and RCAAs.[^p552-2] However, this comparison falls short of an adequate quality of life comparison of the R/ECAP neighborhoods in South Fresno and the RCAA neighborhoods in North Fresno: * The amendment fails to provide “comparisons to other neighborhoods in terms of equitable quality of life” and only inconsistently identifies the locations of R/ECAP and RCAA within the city when evaluating their proximity to infrastructure and facilities. [^p552-1]: Brown, B., Heer, N., Love, N., Pollard, K., Thomas, D. (2021, June 9). Here To Stay: A Policy-Based Blueprint For Displacement Avoidance in Fresno. Thrivance Group. https://www.transformfresno.com/wp-content/uploads/2021/06/transform-fresno-here-to-stay-report-english.pdf [^p552-2]: HCD 2/1/2024 Findings, p. 2. Michelle Zumwalt Page 3 of 16 * The quality of life comparison acknowledges the disparities in infrastructure between R/ECAPs and RCAAs, but it fails to identify policies, programs, and future investments to address these disparities. * For example, the Errata includes “Park Access” amendments acknowledging that RCAAs have more access to green spaces that are in “fair to good condition,” as opposed to the parks in R/ECAPs, which were determined to be in poor to fair condition, and it adds that the Fresno PARCS Department identified 21 high needs neighborhoods that should receive 50% of Measure P funds; yet the Errata fails to identify a solution that would improve access to green spaces in R/ECAP. Furthermore, community engagement in R/ECAP communities would reveal that residents in Southwest Fresno want additional recreational equipment at Maxie Park, including a completely paved track; Southeast residents near Winchell Elementary want a family-oriented neighborhood park with ample shade trees; and Jane Addams residents have stated that Basin XX park does not meet their families needs. The amendments on pages 1E-3-137-138 regarding Southwest Fresno fail to acknowledge and analyze the City’s current efforts to promote industrial development in Southwest Fresno, contrary to the Southwest Fresno Specific Plan and input from local residents. Therefore, these amendments fail to incorporate the full context of changes over time and current practices in the AFH. AFFH Guidance, p. 33.: * On page 1E-3-138, the City states that the 2017 SWSP “reimagines this area as transitioning from industrial to a series of small, complete neighborhoods” and “the City recognizes that there are land use incompatibilities that could have negative impacts.”[^p553-3] However, in recent years, the City has worked relentlessly with developers to rezone Elm Ave from Neighborhood Mixed use zoning back to Light Industrial, and, earlier this year, the City council approved the development of a Warehouse in Southwest Fresno.[^p553-4] * The City’s amendment on page 1E-137 states, “given the proximity to industrial uses, the City reviewed sites in the inventory adjacent to existing industrial uses, specifically near State Route 41, and removed those sites which would be most impacted during the timeframe of this Housing Element.” Simply removing these sites from the inventory is not enough to address the impact of industrial uses on existing and future housing in Southwest Fresno and the City should make stronger commitments to prevent the rezoning of this area to light industrial given that the community spent over two years [^p553-3]: HCD 2/1/2024 Findings, p. 2. [^p553-4]: Weaver, G. (2023, Nov 7). ‘I want industrial gone.’ Frustrated residents slam southwest Fresno rezone plans. *Fresnoland*. https://fresnoland.org/2023/11/07/southwest-fresno-rezone/, Morano, J. (2024, Feb 22). $100 million warehouse headed for southwest Fresno despite unanswered pollution questions. *Fresnoland*. https://fresnoland.org/2024/02/22/new-fresno-warehouse/ creating the SWSP to remove industrial sites away from sensitive receptors of their homes and schools. The City must commit to removing improper land uses near Community. The Errata failed to include a proper analysis and subsequently a compliant AFH; therefore, the current programs fail to create integrated healthy communities in R/ECAP. ## III. Homelessness The Errata acknowledges a technical assistance letter dated August 7, 2024, from HCD’s Housing Accountability Unit regarding the City’s December 2023 rejection of Homekey 3 funds for a project that would have provided 58 permanent supportive housing units for people experiencing homelessness in a moderate-resource area.[^p554-5] However, the Errata does not add any analysis regarding the impacts of the denial nor the factors that caused it. As HCD noted: “The City’s decision to return its Homekey award rendered the Project infeasible, thereby worsening access to affordable homes for the unhoused population in areas outside of R/ECAPs and to affordable housing in general. This decision raises concerns about whether it was ‘materially inconsistent’ with the City’s obligation to AFFH.”[^p554-6] But the Errata’s only response to these serious fair housing concerns is the addition of the following language to Program 2: “The City will include in project approval documentation a statement of the City’s obligation to Affirmatively Further Fair Housing and an accompanying analysis of project consistency with the law.”[^p554-7] Notably, such a policy would not have had even a nominal impact on the December 2023 Homekey project denial because (1) it only applies to project approvals, not denials; and (2) it does not apply to funding decisions. Further, an after-the-fact recitation of existing law and analysis of how an approved project complies with the duty to AFFH is not adequate to prevent discrimination against projects that serve unhoused individuals and people with disabilities. The Housing Element should commit to a robust AFFH analysis in advance of all discretionary decisions affecting housing siting and funding, including analysis of project impacts and alternatives and discussion of the project’s relationship to Fresno’s long-standing patterns of racial and economic segregation,[^p554-8] to ensure that future approvals and denials are consistent with the City’s duty to affirmatively further fair housing. The Housing Element must also analyze the City’s recent policy choices and the City Council’s demonstrated animus against the City’s unhoused residents as constraints to meeting the needs of unhoused individuals and families, and to affirmatively furthering fair housing [^p554-5]: Errata, p. 1E-3-123; *see also* Letter from David Zisser to Georgeanne White re: Fresno City Council’s Denial of Fresno Quality Inn Homekey Project – Letter of Technical Assistance (Aug. 7, 2024), available at https://www.hcd.ca.gov/sites/default/files/docs/planning-and-community/HAU/fresno-hau-806-ta-080724.pdf (8/7/2024 HAU Letter).. [^p554-6]: 8/7/2024 HAU Letter, pp. 3-4. [^p554-7]: Errata, p. 1E-1-11. [^p554-8]: See 8/7/2024 HAU Letter, p. 3. people with disabilities and people of color. HCD’s technical assistance letter also noted that “the City Council’s discussion of assumptions and stereotypes regarding homeless individuals raises further fair housing concerns.”⁹ And the City recently passed one of the most draconian anti-camping ordinances in the state, amending a prior version of the ordinance to remove language about making shelter and housing available to unsheltered individuals.¹⁰ Punitive and carceral approaches to homelessness make it harder for unhoused people to access housing and services and are counter to the City’s duty to affirmatively further fair housing.¹¹ However, the Errata does not analyze the camping ordinance, the anticipated impacts of the recent amendments, or actions the City can take to mitigate the discriminatory impacts of such policies on people with disabilities and people of color. The Housing Element should acknowledge that its current approach to homelessness–both in denying permanent supportive housing and in criminalizing unsheltered homelessness–disproportionately burdens and denies housing choice to people with disabilities and people of color and is, in turn, inconsistent with its duty to affirmatively further fair housing. It must also commit to programs that will result in meaningful policy change to reverse its discriminatory practices. IV. Sites to Accommodate the RHNA While the Errata includes amendments and additional information regarding pipeline projects and sites identified to accommodate the RHNA, multiple deficiencies remain, including: * Program 17 (Surplus Public Land) remains inconsistent with the Surplus Land Act; e.g., it requires only 10% affordable units.¹² * More and better information is needed to justify the City’s projections regarding pipeline projects. * Lack of info re committed assistance for hotel/motel conversions. Such information is especially important given the City’s recent rejection of Homekey funds for a project that would have converted a hotel into permanent supportive housing. * Ambiguous or conflicting info, e.g. re funding and affordability for Village at West Creek North. * The Errata does not analyze the impact of restrictions on ground-floor residential uses on capacity projections in commercial and mixed use zones.¹³ [^p555-9]: 8/7/2024 HAU Letter, p. 4. [^p555-10]: Ord. 2024-025. [^p555-11]: See HCD AFFH Guidance, pp. 68-70; see also Statement by UCSF Benioff Homelessness and Housing Initiative Director Dr. Margot Kushel on the Supreme Court’s Decision in City of Grants Pass v. Johnson (June 28, 2024), available at https://homelessness.ucsf.edu/resources/press-release/BHHI-grants-pass-statement. [^p555-12]: Errata, p. 1E-1-23; see also 8/7/2024 Comment Letter, pp. 19-20. [^p555-13]: See 8/7/2024 Comment Letter, p. 8. Michelle Zumwalt Page 6 of 16 * The Errata does not add any analysis of existing residential, agricultural, and commercial uses on sites identified to accommodate the RHNA.[^p556-14] Notably, it relies on many sites—including for the development of lower-income housing—on sites with existing commercial uses along the Blackstone corridor, the City’s main commercial corridor, without adequate information about the existing uses or analysis to support the City’s assumption that the site will redevelop as housing. * The Errata adds some information and analysis regarding large sites, but it still fails to comply with Government Code section 65583.2(c)(2)(B). While it includes examples of past projects developed on large sites, it lacks information about when those projects were developed, and about the development timelines and phasing for the entire site (as opposed to just the housing portion).[^p556-15] * The Errata removes some publicly owned sites from the inventory but continues to rely on publicly owned sites with either (1) a lack of information to support the assumption that they will redevelop within the planning period or (2) information that indicates the sites will not be available during the planning period. For example, Table 1E-2-9 indicates that the City plans to use site 287 for tiny homes, “micro homes,” and other uses during the planning period, which means it will not be available for permanent housing units.[^p556-16] (The description of the proposed project also raises questions about the City’s plans to site interim housing for homeless individuals and/or disaster survivors on an identified brownfield.) It also continues to list sites owned by other government agencies without adequate information about those agencies’ plans for the sites, existing uses, etc. * The Errata continues to identify sites inconsistent with its duty to AFFH without adequate programs to combat the likelihood that development as projected on identified sites will further entrench existing patterns of racial and economic segregation.[^p556-17] V. Relocation and Replacement Housing Program 35 (Replacement Units) references replacement units for density bonus projects and on sites identified in sites inventory.[^p556-18] However, the City also needs to require replacement units and relocation benefits to displaced households consistent with SB 330/AB 1218. The Errata’s description of its compliance with SB 330 does not include any discussion of that law’s replacement and relocation requirements, nor any reference to AB 1218 (2023), which expanded SB 330’s relocation and replacement housing requirements to nonresidential projects.[^p556-19] The Housing Element should describe the ways in which the City is (or is not) implementing these requirements currently and amend its programs accordingly. In addition to amending Program [^p556-14]: See 8/7/2024 Comment Letter, p. 9; HCD 2/1/2024 Findings, p. 5. [^p556-15]: See also 8/7/2024 Comment Letter, p. 13. [^p556-16]: Errata, p. 1E-2-47. [^p556-17]: See 8/7/2024 Comment Letter, p. 11. [^p556-18]: Errata, p. 1E-1-45. [^p556-19]: Errata, pp. 1E-3-115, 1E-4-43. Michelle Zumwalt Page 7 of 16 35, the City should amend Program 4 (Streamline Development Review Process) to include a commitment to incorporating replacement and relocation requirements into its application processes to ensure that it is not approving projects without the legally mandated relocation benefits and replacement units. ## VI. Mobile Home Parks As the Errata notes, mobile home parks represent an important source of affordable housing in Fresno. However, many mobile home residents are at risk of displacement due to rent increases and/or mobile home park closures. The City should strengthen Program 33 (Mobile Home Parks), including by committing to apply mobile home park zoning to existing mobile home parks to discourage mobile home park conversions and improvements to the City’s mobile home rent control process to make it more accessible to residents–e.g., removal of the requirement that residents form a committee before opposing a rent increase. ## VII. Community-identified programs that should be incorporated into the Housing Element Through our collaboration with low-income residents, community members have identified the following programs and drafted examples that the City should incorporate into the Draft Housing Element: * **Rent Stabilization and Just Cause Protection Ordinance** * **Objective** * Ensure the preservation of available affordable housing, and housing choices, and prevent the displacement of low-income residents and residents belonging to a protected class in R/ECAPs through the implementation of a Rent Stabilization and Just Cause Protection Ordinance * **Actions** * All material, information, and verbal public education, including outreach initiatives, will be provided in a variety of languages representative of Fresno including, but not limited to, Spanish, Hmong, and Punjabi. * By December 2025, the City will adopt a Rent Stabilization and Just Cause Protection Ordinance to protect tenants from unreasonable rent increases and unjust evictions. It will establish a rental registry that will be published no later than June 2025. * The City will develop the ordinance collaboratively with Fresno tenants, landlords, and community based organizations. * The City will make a diligent effort to engage Fresno tenants through outreach including but not limited to, canvassing apartment complexes. The city will host interactive convenings and workshops. * Timelines * By March 2025, The City will establish a community workgroup to develop a rent stabilization and just cause ordinance draft. The working group will meet on a monthly basis. * By August 2025, the City will release a draft ordinance for public review and announce the publication of the draft. * The City will adopt the ordinance no later than December 31, 2025. * Funding * Local Funds * Responsibility * Office of the City Attorney and Office of Community Affairs * **Inclusionary Zoning Ordinance** * Objective * In line with its duty to AFFH, the city will secure affordable housing options for low-income and very low-income residents through the adoption and implementation of an Inclusionary Zoning Ordinance by December 2025. Once adopted, the City will promote the ordinance through multilingual educational material and community workshops. * Actions * The ordinance will be developed in accordance with the following guidelines * Apply to projects of 5 or more units * All new housing developments will set aside 20% of its units as affordable for households with an AMI of 50% or less in perpetuity. * As a compliance alternative, developers may pay an in-lieu fee that will then be used towards the development of affordable housing. * Following the adoption of the ordinance, the City will host annual workshops to inform developers of compliance requirements. * Timelines * Beginning in January 2025, the City will draft an Inclusionary Zoning Ordinance and adopt the Ordinance by November 2025. * By December 2025, the City will implement the ordinance and require Inclusionary Zoning for all new housing developments and inform developers of compliance requirements. * Beginning January 2026, the City will host annual workshops to inform the community of the program and initiate its monthly reports. * Funding * Local Funds * Responsibility * Planning and Development Department * **Program 19 - Homebuyer Assistance** * Objective * In order to expand housing opportunities across Fresno, the City will commit to offering financial and technical assistance, as well as counseling services to assist low-income residents in purchasing a home. * Actions * The program will be promoted through City media outlets, community outreach, informative workshops, partnerships with local media outlets, neighborhood/homeowners associations, realtors’ associations, homebuilders, lenders, Rotary, and Community Based Organizations. Targeted outreach and promotional efforts will occur in R/ECAP and extremely low and low-income households. * This program will be accessible to residents regardless of immigration status. This program will prioritize individuals and households with special needs. * The City’s Housing and Community Development Division will offer the following support and assistance in the variety of languages representative of Fresno including, but not limited to, Spanish Hmong, and Punjabi: * **Technical assistance** - Guide applicants through the application process, offer technical support throughout the length of the program * **Financial assistance** - Offer up to $200,000 in loans, cover down payments and closing costs, zero interest fees, loan fees, or monthly payment fees, loan forgiveness after 15 years, and flexible payment plans calculated according to income at the time of application and adjusted based on changes in grantees income. * **Financial counseling services** - Intended to increase the beneficial impact of the program by preparing applicants to become strong financial candidates and offer support as grantees to help them adapt to the financial challenges of becoming homeowners. ■ The City will apply to the state’s CalHome Program and the Jose Serna, Jr. Farmworker Housing Grant to secure funding for the home buyer assistance program on an annual basis. ■ The City will provide quarterly reports every year describing how many applicants were assisted, and a description of outreach efforts and the location of where grantees were able to find housing. ■ The City will establish an oversight committee consisting of low-income residents to address residents' needs and ensure funding is secured for its intended purpose. * Timelines * Beginning January 2025, the City will host two informative workshops every quarter and emphasize accessibility to extremely low-income and very low-income residents. * Beginning in January 2025, The City will perform strong community outreach to notify residents of the availability of the program targeting extremely low-income and very low-income residents. * Beginning January 2025, the City will begin accepting applications for the program. * Beginning June 2025, the City will release its first quarterly report. * Funding * CalHome Program, Jose Serna, Jr. Farmworking Grant, Permanent Local Housing Allocation (PLHA), NAHREP (National Association of Hispanic Real Estate Professionals) Fresno, Federal Home Loan Bank (FHLBank) of San Francisco, Self-Help Enterprises, and Union Bank * Community Development Block Grant Program, HOME Investment Partnership Act Funds, Cal HFA, and California Self-Help Housing Program * Responsibility * Planning and Development Office of Community Affairs, and nonprofit community development corporations. * **Program 22 - Housing Rehabilitation** * Objective * With the goal of conserving affordable housing, preventing displacement, and cultivating thriving communities, the City of Fresno will assist households who on average have below-moderate incomes by connecting them to resources and services specialized in the rehabilitation and weatherization of their homes regardless of immigration status. Michelle Zumwalt Page 11 of 16 * Actions * The City will set aside 5% of its annual general fund revenue for home rehabilitation and weatherization grants and for the rehabilitation grants. * The program will be promoted through City media outlets, community outreach, informative workshops, and partnerships with local media outlets, neighborhood associations, and community benefit organizations. * Outreach and promotional efforts will occur in R/ECAP, targeting households who on average have extremely low to very low income, households of undocumented residents, homes with substandard living conditions, and households with special needs. All material will be made available in a variety of languages representative of Fresno including, but not limited to, Spanish Hmong, and Punjabi. * The City’s Code Enforcement division will immediately refer moderate and below moderate-income homeowners in violation of the City’s Housing code to the program and homeowners who do not seek out services will be listed as a priority for outreach efforts. * This program will prioritize rehabilitation for households with special needs, homes with damages that pose a serious health risk, and homes with damages that are likely to be exacerbated by weather and climate change. * To prevent future deterioration of substandard homes, the City will provide home weatherization services, including insulation and heat pumps as well as other cooling mechanisms, and prioritize these services for households with special needs such as the elderly, and individuals with disabilities or chronic health issues. * The City’s Housing and Community Development Division will offer the following assistance to homeowners in a variety of languages representative of Fresno: * **Technical assistance** - Guide applicants through the application process and offer technical support throughout the length of the program. * **Referral assistance** - Connect applicants to resources and services based on the level of repair needed. * **Financial assistance** - Offer rehabilitation grants to homeowners with no fees on interest. * **Temporary Housing** - The City will provide Emergency Housing Vouchers for rehabilitation efforts that require the residents to vacate their homes. * The City will employ local licensed general and paint contractors and prioritize partnerships with contractors who predominantly employ or will employ local residents including part-time jobs for youth for the duration of their participation in the program. ■ The City will provide annual and quarterly reports describing how many homeowners were assisted with revitalization, how many local residents were employed, a description of outreach efforts including the location where they took place, and the amount of funding allocated from the general fund. ○ Timeline ■ By March 2025, the City will notify the community via city media outlets, notify community benefit organizations, and update its website to promote the development of the Program. ■ Beginning in January 2025, the City will host two quarterly informative workshops. Half of the workshops will occur in an area accessible to residents residing in R/ECAP. ■ The City will begin outreach onemonth before every informative workshop by notifying Community Based Organizations, posting on social media, and canvassing R/ECAP. ■ By August 2025, the City will begin offering rehabilitation and weatherization services. ■ By February 2026, the City will release its first annual/quarterly report. ○ Funding ■ General Fund revenue, CDBG program funds. ○ Implementation ■ Planning and Development Department, Housing and Community Development Division, Office of Community Affairs, Code Enforcement Division ● Program 33 Mobile Home Parks ○ Objective ■ The City will prevent excessive rent increases for mobile home park residents, offer rehabilitation and weatherization services to homeowners regardless of immigration status, and assist in the revitalization and weatherization of mobile home parks, including, urban greening and secure pedestrian and public transportation routes. The City will preserve mobile home parks as a source of affordable housing and hold Mobile Home Park owners accountable for repeated code violations through fines that will fund mobile home park rehabilitation efforts. ○ Actions * The City will finalize its 5th Cycle assessment of housing-related needs in mobile home parks, release it for public review and comment, and use this information to direct rehabilitation and weatherization efforts. * Continue to support the Mobile Home Rent Review & Stabilization Commission. The City will evaluate potential changes to the rent review process to remove unnecessary barriers to mobile home park residents’ participation in the process, including through the possible removal of the requirement that residents form a committee prior to participation. * Provide annual notification to park owners about rent increase applications. Hold meetings at mobile home parks to explain the enforcement process. * Maintain a list and map of mobile home parks in Fresno. * Provide relevant information to interested mobile home park residents, owners, and non-profit organizations. * Compile a list of resources and provide technical assistance to mobile home residents and park owners to facilitate the maintenance and preservation of mobile home parks. * The City will enforce the California Mobile Home Park Act throughout the City. * The City will set aside 2% of its annual general fund revenue for Mobile home rehabilitation and weatherization grants and for the rehabilitation of Mobile Home Parks. * Funding generated from fines imposed on mobile home park owners for code violations will be prioritized for mobile homeowners whose homes are older than the maximum year requirement criteria of the City’s Mobile Home Repair program and toward the revitalization and weatherization of Mobile Home parks. * The City will apply to HCD’s Manufactured Housing Opportunity & Revitalization Program (MORE). * The City will assist with the replacement of mobile homes deemed irreparable. * The program will be promoted through City media outlets, community outreach, place-based informative workshops, and partnerships with local media outlets, and community benefit organizations. * Upon request by the homeowner, the City’s Community Revitalization Division will assess the safety and integrity of the home and refer the homeowner to the program if deemed necessary. * The City’s Code Enforcement Division will immediately refer mobile homeowners in violation of the City’s Housing Code to the program. Homeowners who do not seek out services will be listed as a priority for outreach efforts. * This program will prioritize rehabilitation for households with special needs, homes with damages that pose a serious health risk, and homes with damages that are likely to be exacerbated by weather and climate change. * To prevent the future deterioration of outdated mobile homes, the city will provide mobile home weatherization services, including insulation and non-evaporative cooling systems, and prioritize these services for households with special needs such as the elderly, and individuals with disabilities or chronic health issues. * The City will offer the following assistance to homeowners in a variety of languages representative of Fresno including, but not limited to, Spanish Hmong, and Punjabi: * **Technical assistance** - Guide home-owner and landlord applicants through the application process and offer technical support throughout the length of the program. * **Referral assistance** - Connect homeowners and landlords to resources and services based on level of repair needed. * **Financial assistance** - Offer rehabilitation grants to homeowners with no fees on interest. * **Temporary Housing** - The City will provide Emergency Housing Vouchers for rehabilitation efforts that require the family to vacate the home. * The City will employ local licensed general contractors and prioritize partnerships with contractors who predominantly employ or will employ local residents including part-time jobs for youth for the duration of their participation in the program. * The City will provide annual and quarterly reports describing how many homeowners were assisted, the types of revitalization and weatherization services provided for homeowners and mobile home parks, how many local residents were employed, a description of outreach efforts including the location where they took place, and a breakdown of funding generated from fines imposed on landlords, and the amount of funding allocated from the general fund. * Evaluate policy changes and funding sources to discourage mobile home park closures and mitigate the impacts of such closures on residents and the community. Possible policy changes include applying mobile home park zoning to existing mobile home parks to discourage redevelopment of those parks for other uses. ○ Timeline ■ Beginning January 2025, the City will notify the community via City media outlets, notify community benefit organizations, and update its website to promote the development of the Program. ■ By March 2025, the City will begin the process of completing its 5th Cycle assessment of housing-related needs in mobile home parks. ■ Beginning in March 2025, the City will host informative workshops at each mobile home park twice a year. ■ The City will begin outreach one month before every informative workshop by notifying community benefit organizations, posting on social media, and canvassing R/ECAP. ■ By September 2025, the City will begin offering rehabilitation and weatherization services. ■ By January 2026, the City will release its first annual/quarterly report. ■ By March 2026, the City will release its 5th Cycle assessment of housing-related needs in mobile home parks. ■ By January 2026, the City will have rehabilitated 25% of owner-occupied mobile homes and Mobile Home parks. ■ By a date certain within the planning period, present ordinance options to the City Council for preserving mobile home parks. ■ By a date certain within the planning period, evaluate and recommend changes to improve mobile home park residents’ ability to access the rent review process. ○ Funding ■ General Fund revenue, rehabilitated home sale revenue, CDBG program funds, Manufactured Housing Opportunity & Revitalization Program (MORE). ○ Responsibility ■ Planning and Development Department, Housing and Community Development Division, Office of Community Affairs, Community Revitalization Division, Code Enforcement Division **VIII. Conclusion** Thank you for considering our comments. We welcome the opportunity to continue collaborating on the City of Fresno’s Housing Element update to ensure the City complies with state law and is committed to meeting the housing needs of all residents. The City of Fresno is Michelle Zumwalt Page 16 of 16 not exempt from the State’s ongoing housing crisis and must abide by its duty to Affirmatively Further Fair housing and remain committed to securing safe and affordable housing. Respectfully, /s/ Emmanuel Agraz-Torres, Policy Advocate Leadership Counsel for Justice and Accountability /s/ Melissa A. Morris, Staff Attorney Public Interest Law Project mmorris@pilpca.org 510-891-9794 x 111 Cc: Architect, Michelle Zumwalt, michelle.zumwalt@fresno.gov City Manager Georgeanne White, Georgeanne.White@fresno.gov Planning Director Jennifer Clark, jennifer.clark@fresno.gov Council President Analisa Perea, annalisa.perea@fresno.gov Councilmember Mike Karbassi, mike.karbassi@fresno.gov Councilmember Miguel Arias, miguel.arias@fresno.gov Councilmember Tyler Maxwell, tyler.maxwell@fresno.gov Councilmember Luis Chavez, luis.chavez@fresno.gov Councilmember Garry Bredefeld, garry.bredefeld@fresno.gov Councilmember Nelson Esparza, nelson.esparza@fresno.gov Mayor Jerry Dyer, jerry.dyer@fresno.gov Thomas Brown, Policy Analyst, California Department of Housing and Community Development thomas.brown@hcd.ca.gov Paul, McDougall, California Department of Housing and Community Development, paul.mcdougall@hcd.ca.gov # Rebecca Pope **From:** Brooke Frost **Sent:** Thursday, August 8, 2024 9:34 AM **To:** HousingElement **Subject:** Comment on Fresno Housing Element **External Email: Use caution with links and attachments** Hello, Below are some comments on the housing element. I am a resident in southeast Fresno who is not a housing expert. Program 21 - Advocate for Repeal of Article 34 - this references a ballot measure that occurred in March 2024, shouldn't the result status be included and the effect of whether the City will place its own measure on the ballot in a subsequent election? I realize this was first prepared before the vote, but since it is being resubmitted in August 2024, shouldn't it be updated? Vacancy rate math adds up to more than 100%. You say 95.5% are occupied and 5.5% are vacant. Shouldn't it be 4.5% vacant? Overpayment seems to not include any reference to increases after 2020. There have been significant housing cost increases since COVID and that is not reflected in this section. How can it be included? It seems the same is true for sub-standard housing. What seems to be happening is eviction to improve substandard conditions. But there is nowhere to go that is affordable. How is this to be reflected in the housing element? In general, I don't see any reference to encouraging outreach for developers to use middle housing (duplexes, cottages/courtyards, 4 plexes) for infill in residential areas that are affordable and fit in better in residential areas. Everything doesn't need to be 3 or 4 story apartments. Thank you. Brooke Frost 559-288-4082 August 7, 2024 Mayor Jerry Dyer Fresno City Councilmembers Michelle Zumwalt, Planning and Development Department 2600 Fresno Street, Room 3065 Fresno, CA 93721 *Sent via email:* housingelement@fresno.gov **RE: City of Fresno Draft 6th Cycle Housing Element** Dear Mayor Dyer, Councilmembers, and Ms. Zumwalt: Leadership Counsel for Justice and Accountability (“LCJA”) and Public Interest Law Project (“PILP”) write in collaboration with local community residents and the undersigned organizations to submit this comment letter on the City of Fresno’s second Housing Element Draft 2023-2031. LCJA and the undersigned organizations work alongside the most impacted communities to advocate for sound policy and eradicate injustice to secure equal access to opportunity regardless of wealth, race, income, and place. We advocate for policy and practice changes to meet the housing needs of all residents in the City of Fresno, especially low-income residents and those with special housing needs, and to overcome fair housing disparities that impact low-income communities. Residents with whom we partner experience high rates of cost burden, escalating housing costs, reside in unsafe and unsanitary rental housing units, experience displacement risks, and are impacted by disparities in access to opportunity, including a lack of access to a healthy environment and public and private investment in critical infrastructure, services, and amenities. Founded in 1996, PILP provides crucial litigation and advocacy support to local legal services and public interest programs throughout California. For more than two decades, PILP has fought for affordable and fair housing, access to public benefits, homelessness prevention, Michelle Zumwalt Page 2 of 26 and civil rights in partnership with low income communities, communities of color and legal services organizations throughout California. In the context of the Housing Element Law, PILP has been instrumental in the passage of legislation to strengthen that law, which has included the review and comment upon thousands of housing elements throughout the state to ensure access to affordable housing opportunities for California’s residents who reside in lower-income communities. The City of Fresno’s 6th Cycle Housing Element Update presents a critical opportunity for the City to identify and address long-standing, wide-ranging, and severe housing needs and fair housing disparities that impact residents, disadvantaged unincorporated communities, and racially and ethnically concentrated areas of poverty (“R/ECAPs”), in particular, the Southwest, South Central and Southeast areas. Unfortunately, the Draft has failed to adequately address these disparities; therefore, we are providing the following comments that highlight further steps and actions the City must take to meet State Housing Element Law requirements. (Gov. Code § 65583 et. seq.)[^p569-1] We recognize the City made improvements in the second Draft, but we believe further revisions are necessary to substantially comply with Housing Element law. In particular, the City needs to continue to and further engage communities that have been historically left out of previous Housing Element Cycles, adopt and implement enforceable policies and programs with discrete timelines to meet the housing needs of all residents, and abide by its duty to affirmatively further fair housing (“AFFH”). (Gov. Code § 8899.50). ## I. Failure to Demonstrate A Diligent Effort to Solicit and Incorporate Input from All Economic Segments of the Community and Protected Classes As stated in our previous letters, and further reinforced by HCD in their February 1, 2024 letter under section E. Public Participation of their findings, the City must make a diligent effort to engage the community during the housing element revision process, including the organizations that represent low-income and special needs households, and describe how it incorporated community feedback into its Draft. Lastly, the City must make information readily available, during the development of the Housing Element. This includes the revision process. Between February and July 2024, we attempted to communicate with the City to understand how and when it would engage community residents in their Draft revision process. Despite our multiple efforts, the City demonstrated an unwillingness to offer information. This greatly inhibited residents' ability to contribute to the development of the Draft; including two visually-impaired residents who requested large-font hard copies of the revised Draft to review and provide comments within the anticipated 7 day review period. Furthermore, the City did inform LCJA that the revised Draft had been posted to its website and was available for public comment and review until 5:00 pm on August 7, 2024; however, they neglected to include the [^p569-1]: Hereafter all Code sections refer to the California Government Code, unless otherwise noted. Michelle Zumwalt Page 3 of 26 deadline on the Housing Element webpage, thereby, failing to disclose limited review period to the public. By neglecting to make information readily available, and their lack of making a diligent effort to engage the community, or explain where it incorporated, or did not incorporate community feedback and public comments into the revised Draft, the City demonstrates that it fails to substantially comply with State law. ## II. Failure to Adequately Analyze Housing Constraints ### A. Governmental Constraints to Housing Development While the City did address some of the concerns related to their analysis of governmental constraints, there still remains an incomplete analysis. As a reminder the City is required to have “[a]n analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, . . . and for persons with disabilities. . . including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, local processing and permit procedures, and any locally adopted ordinances that directly impact the cost and supply of residential development. The analysis shall also demonstrate local efforts to remove governmental constraints that hinder the locality from meeting its share of the regional housing need. . . and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters.” (Gov. Code § 65583(A)(5)). In our previous comment letters, we uplifted the need to identify constraints to the development of housing affordable to households at different income levels, as well as possible constraints to the development and maintenance of a variety of types of housing, unfortunately this recent Draft continues to fail in adequately analyzing these constraints. *1. Development Standards* “The housing element must identify all relevant land-use controls, discuss impacts on the cost and supply of housing, and evaluate the cumulative impacts of standards, including whether development standards impede the ability to achieve maximum allowable densities.”² The City added a Table 1E-4.6 which analyzes multi-family zone requirements for prototype site development and helps identify the ability to achieve maximum densities in the City’s multi-family zones. Unfortunately, this analysis is insufficient and does not address our previous concerns regarding constraints associated with the widespread availability of single family [^p570-2]: HCD, Building Blocks, Land Use Controls, available at https://www.hcd.ca.gov/planning-and-community-development/housing-elements/building-blocks/land-use-controls. zoning and the limited availability of high density zoned sites. The city continues to allow by-right single-family units more than multi-family affordable housing developments. Additionally, the City still permits single family uses by-right in many of the zones identified for increased high-density development: RM-1, NMX, CMX, RMX, CMS, CR, DTN, DTG. But multi-family units are not allowed in RS-1, RS-2, or RS-3 areas, despite the large majority of the City being zoned one of these zones, and where many high resource areas have developed. Duplexes are similarly constrained, they are excluded from RS-1, RS-2, RS-3, RS-4, and only allowed through conditional use permit in R-5. ### 2. Single Room Occupancy (SRO) Units, Emergency Shelters, Supportive Housing Although we appreciate the City’s amendment to the Single Room Occupancy (SRO) section to remove the “current limit of 15 guests in SRO units, as well as changing SRO to permitted use in RM-1, RM-2, RM-3, NMX, CMX, and RMX, and evaluating objective design standards for SROs to ensure that units are maintained and safe for all residents long term;” additional analysis must be done for emergency shelters and supportive housing. The City has a significant homeless population and a serious dearth of housing and shelter options to serve that population; it must analyze the constraints to building additional shelters to ensure that the unhoused population has access to housing. Little is said in response to supportive housing and whether it is allowed in any zone where multi-unit or mixed use development is permitted. ### 3. Parking The Draft had previously amended the Development Code to remove parking minimums within a half mile of public transit, consistent with AB 2097. In the revised Draft the City added an action to reduce the parking standard for Residential Care, General. But once again failed to analyze whether its parking requirements act as a constraint on housing development, especially in downtown and along transit corridors. Parking requirements increase the cost of housing.[^p571-3] The Draft states it “determines the required number of parking spaces based on the type and size of the residential unit and has found the required parking spaces to be necessary to accommodate the number of vehicles typically associated with each residence.”[^p571-4] The analysis ignores principles of induced demand and downstream effects of entrenching car-centric land use. The Draft implicitly acknowledges that parking increases costs and may not be critical as it allows waivers for parking requirements in affordable housing developments and other transit-friendly areas.[^p571-5] The ad hoc basis of reduced parking requirements introduces uncertainty which can increase the overall cost and time delays in housing development. Once again, the City failed to [^p571-3]: Green Trip. Parking Database: http://database.greentrip.org/. [^p571-4]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-10 [^p571-5]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-10 Michelle Zumwalt Page 5 of 26 include a program that would identify steps to remove this constraint, particularly in the development of affordable housing. ### 4. Risk Analysis and Distribution of Affordable Housing Additionally, we want to reiterate the Draft’s analysis of at-risk housing is incomplete and under-analyzes the risks to publicly assisted affordable housing and its distribution. The Draft identified 695 units at risk of conversion to uses other than low-income residential within 10 years from the housing element adoption deadline. Although the City considered the cost of replacing the at-risk units as required under §65583(a)(8), it failed to examine which pathway would be most appropriate for the City and what constraints, if any, would be associated with the pathway chosen. Once again, we urge the City to analyze the lack of tenant protections, such as source of income discrimination outreach and education, rent stabilization, and just cause protections, and how they may operate as a constraint on the maintenance of housing available to lower income people and facilitate the displacement of lower income renters. The lack of these protections should be analyzed as a constraint on the maintenance of housing under Government Code section 65583(a)(5). ### 5. Accela In Table 1E-2.3, the Draft identifies Accela, the City’s land management software, as a barrier to the timely completion of multiple projects on which it is relying to accommodate its RHNA.[^p572-6] The Draft should describe how Accela is creating barriers to the completion of new housing development—especially affordable development—analyze these barriers as constraints, and, if appropriate, add program language to reduce or mitigate any constraints caused by the system. ### B. Non-Governmental Constraints to Housing Development In addition to analyzing governmental constraints, the Draft must also analyze the potential and actual non-governmental constraints upon the maintenance, improvement, or development of housing for all income levels. Gov’t Code § 65583(a)(6). Unfortunately, the second Draft continues to exclude such an analysis even though public comments have been submitted in response to this specific issue. The Draft failed to consider the effect of market forces, availability of financing, environmental concerns, and NIMBY opposition. [^p572-6]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-2-10 to 1E-2-11. 1. NIMBY Opposition The Draft must include an analysis of NIMBY opposition to housing development. As a largely sprawling suburban City, Fresno is prone to local opposition to increased density from existing single-family homeowners that have preconceived ideas of the impacts of increased density on their neighborhoods. Further, the zoning code requires conditional use permits for duplexes and multi-family housing in some areas, making them especially susceptible to opposition and defeat from NIMBY residents. NIMBY opposition is all too common and a pervasive issue when building multi-family projects in high resourced areas. The latest example: on July 25, 2024, the City Council voted (4-3) to uphold the Planning Commission’s vote to reject the development permit application for a market-rate housing complex at the northeast corner of West Herndon and North Prospect Avenues (North of the City of Fresno). Even though this project is market-rate without any subsidy for people who cannot afford rent, comments were made that perpetuate stereotypes that have been mostly disproven— such as decreasing property value, increased crime rates and worsening traffic.[^p573-7] This is just one example of how pervasive NIMBY-ism is in the City of Fresno and thus a significant reason to complete a full analysis of this constraint. 2. Environmental Concerns Once again, the Draft failed to consider environmental constraints as part of its analysis under Gov’t Code § 65583(a)(6). Environmental constraints may include limitations to water supply, nearby pollution, or infrastructure development. Per our previous comment letters, we have noted that the City of Fresno relies heavily on groundwater and surface water. As climate change makes water availability less predictable the City must analyze how an increased population and land use will affect water availability and whether water availability will eventually constrain growth. Additionally, the City must consider the infrastructure requirements of delivering water to a denser population. For example, the City estimates that downtown Fresno, where a large portion of new housing development is projected, currently requires significant water and wastewater infrastructure upgrades. Again, we must reiterate the fact that the Draft failed to consider industrial and polluting industries’ effect on future housing development. The City must also analyze as a constraint the proliferation of warehouses and other industrial uses in and around the City, particularly in South Fresno. These industrial and warehouse projects come with an enormous increase in vehicle traffic and worsen already very poor air quality. They also result in light, sound, and vibration pollution. Many of these projects are being approved next to residential development with no buffer, driving down housing value, and worsening housing conditions. The City must consider [^p573-7]: Parsons, R. (2024, May 19). A Big Housing Project Gets Rejected. Fresnoland. https://fresnoland.org/newsletter/a-big-housing-project-gets-rejected/ warehouse and industrial use proliferation as a constraint, and identify impacts to residents. The City must then commit to adopting strong programs and policies with enforceable timelines to address the constraint. Additionally, the City of Fresno has evolved as a car dependent City surrounded by heavy industry and highways. Therefore, future housing development will need to carefully consider placement and mitigation measures to avoid perpetuating environmental inequity. ### III. Further Revisions and Analysis are needed to determine if the City’s Draft Includes Adequate Sites #### 1. Entitled and Permitted Units The Draft adds information about the entitled and permitted units that the City seeks to credit against its RHNA obligation, but the information provided for multiple projects still remains inadequate to comply with the requirements of Housing Element Law. **Hotel/Motel Conversions**—the Draft relies on four hotel/motel conversions to accommodate 211 units of its lower-income RHNA. However, the Draft is missing the requisite information and program language to claim credit for these units.[^p574-8] Government Code 65583.1(c)(2)(D) allows credit for such units, but they must be converted with committed assistance from the City and be made available to people experiencing homelessness, and the Housing Element must include a program for the conversion(s). Table 1E.2-3 should be amended to specify the committed assistance *from the City* for each of these projects and to clarify whether each of them will be made available to people experiencing homelessness. Additionally, the City should add concrete program language to **Program 36 (Homeless Assistance)** to specify the committed assistance and other actions on the part of the City to facilitate hotel conversions and to ensure that the converted units remain safe and habitable over time. Additionally, for project P-23 (San Joaquin Hotel), Table 1E.23 does not describe the status of entitlement review for the 59 units on which the Draft relies; nor does it provide any information about build-out, phasing, or projected rents. **City-Caused Barriers to Completion**—The City relies on project P-12, Fresno Rescue Mission RTC 2, to accommodate 49 units of its low-income RHNA. However, the Draft acknowledges that there is no phasing plan for the project and no expected completion date—there is no indication that this project can be completed during the planning period. Additionally, the Draft identifies “having difficulties with affordable housing contracts with the City” as a barrier to completion.[^p574-9] The Draft should describe the “difficulties” and analyze the [^p574-8]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-2-5, 1E-2-9 to 1E-2-11 [^p574-9]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-2-8. City’s role in creating or ameliorating project delays. Such analysis should inform program language to expedite the funding and development of affordable units. Unsupported Affordability Assumptions for Moderate-Income Units—the Draft still lacks adequate information and analysis to support its assumptions regarding the affordability of market-rate units. Table 1E-2.2 does not include any information about the unit type, number, or density of rental units in projects it lists as examples. Table 1E-2.3 does not include information about the expected tenure of many of the projects, so it is unclear whether the units will be rental or for-sale; the draft does not provide any indication that new market-rate for-sale units will be sold at prices affordable to moderate-income households. By way of example, Table 1E-2.3 acknowledges that the City is “not sure of rents” for project P-8, a market-rate gated duplex community but nonetheless has switched its affordability projection since the prior draft from above-moderate to moderate-income without any justification. The City should provide additional information and analysis to ensure that its assumptions regarding the affordability of market-rate units are supported. Ambiguous Entries—Several entries in Table 1E-2.3 include ambiguous or conflicting information about project timelines and projected affordability. For example, for project P-1, the Village at West Creek North, the Table identifies funding sources but then indicates that the “challenge is getting funded” and that the affordability levels “will be dictated by funding source.” It’s also unclear if the project is one development or multiple developments. This lack of clarity makes it difficult to assess whether the planned units will be available at the projected affordability levels during the planning period. The City should provide additional information and analysis regarding recent and pending developments that it seeks to credit against its RHNA. Where there is not adequate information to support projections that a project will develop at a particular affordability level during the planning period, that project should be removed from the list, and the site inventory should be adjusted accordingly. ### 2. Unsupported Capacity Projections The Draft adds information about sites in zones that allow nonresidential development—including 100% nonresidential development—but it still lacks adequate information and analysis to support its capacity projections, especially with respect to affordable development. For example, while the Draft notes that the City recently removed the absolute prohibition of ground-floor residential development in mixed use zones to facilitate the development of lower-income housing, it notes that “all five [commercial and mixed use] zones have some level of restrictions on ground floor residential uses in order to activate the sidewalk.”¹⁰ All of the pipeline projects listed in Table 1E.2-3 that have ground-floor [^p575-10]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-2-18. Michelle Zumwalt Page 9 of 26 nonresidential uses are market-rate projects. But the Draft does not indicate whether or not the sites identified in commercial or mixed use zones prohibit residential uses on the ground floor, nor does it analyze ground-floor restrictions as a potential constraint to affordable development. Similarly, the Draft adds information about which commercial and mixed-use zones allow 100 percent non-residential development, but it does not describe whether the sites identified to accommodate the RHNA allow 100 percent non-residential development, nor does it break down past mixed-use development trends by zone. Draft, 1E-2.18 to 1E-2.19. While the summary table of “Project Examples” has been amended to cover 2018-2023 instead of 2018-2020, the Draft does not provide information about the projects themselves. It is therefore impossible to assess whether the capacity projections are supported by past and current development trends. ### 3. Non-Vacant Sites The City continues to rely on non-vacant sites with a variety of uses—including residential, agricultural, parking lots, commercial buildings, and at least one “trucking” use--to accommodate its RHNA without the requisite analysis. The Draft adds examples of past development on sites with similar prior uses, but it does not include “an analysis of additional representative sites from the sites inventory” or “analyze recent development trends.”[^p576-11] It does not include any site-specific information to support its assumptions that existing uses will discontinue or that owners are interested in redevelopment. It also does not analyze any potentially negative impacts of replacing existing uses with new housing, including potential displacement of lower-income households caused by the demolition of existing, unspecified “residential” uses; the health and environmental justice impacts of housing development on sites with current or recent commercial, industrial, or “trucking” uses (e.g., site 823); or the loss of apparently active agricultural uses (e.g., site 2434, agricultural and farm stand). ### 4. Publicly Owned Sites The City continues to rely on government-owned sites to accommodate a significant portion of its RHNA. Some of these are owned by the City and its Redevelopment Successor Agency, while others are owned by other government entities. The Draft does not describe any communications with the other government entities to gauge their interest in or ability to redevelop the sites—many of which have existing uses—with housing. It does not “discuss the status, remaining steps to be available for development and any known barriers to development in the planning period including leases for existing uses or relocation of existing uses.”[^p576-12] More information and analysis is needed to support the City’s assumptions regarding these sites. [^p576-11]: HCD 2/1/2024 Findings, p. 5. [^p576-12]: HCD 2/1/2024 Findings, p. 5. Michelle Zumwalt Page 10 of 26 With respect to City-owned properties, the City should strengthen Program 17 (Surplus Public Lands) to describe, not only how it will comply with the Surplus Land Act, but also proactive steps it will take to solicit and support 100 percent affordable projects on City and Successor Agency sites during the planning period. 5. Large Sites The Draft adds further discussion of large sites but still fails to adequately support its projections for sites over 10 acres.[^p577-13] The Draft provides examples of prior developments on large sites, but it is lacking information critical to understanding whether these examples support the City’s assumptions regarding large site development. For example, it does not describe additional uses included in the project, timeline and phasing, or the percentage of the total site area that developed as residential v. commercial. Accordingly, the 60% residential assumption applied to large sites is not supported, nor is the assumption that units could be built within the planning period. Further, just comparing overall residential densities projected for identified large sites to overall residential densities for the large site examples indicates that the City is projecting generally higher densities for the sites than were realized in past projects, without explanation or justification.[^p577-14] The City should provide additional information and analysis to support its projections, or it should revise its projections downward. Because the Draft relies so heavily on large sites to accommodate its lower-income RHNA, the City should revise Program 5 (Large and Small Sites) to adopt incentives for affordable development on large sites, rather than deferring the consideration of such incentives to a later date. 6. Environmental Constraints Both community groups and HCD commented on the prior Draft’s lack of analysis regarding environmental constraints to development of identified sites. The current Draft removes sites within Zones 1-4 of the new Airport Influence Area for Fresno-Chandler Executive Airport and indicates which sites are within the 100-year FEMA floodplain but does not provide any additional site-specific information regarding “shape, access, contamination, property conditions, easements, Williamson Act contracts, conservation easements, overlays and airport and military compatibility.”[^p577-15] It does not discuss the impact of adjacent freeways, industrial uses, or agriculture on site conditions, even though many identified sites have existing agricultural or commercial uses, and at least one has a highway on/off ramp.[^p577-16] The Draft acknowledges the disproportionately severe environmental health conditions in the Southwest Fresno Specific Plan and Downtown areas, where the Draft identifies the bulk of sites for new housing, lower-income housing in particular.[^p577-17] However, this recognition did not prompt a reevaluation of sites nor commitments to [^p577-13]: See Gov. Code § 65583.2(c)(2)(B). [^p577-14]: See Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-2-54 to 1E-2-61. [^p577-15]: HCD 2/1/2024 Findings, p. 5. [^p577-16]: See Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-7-47. [^p577-17]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-3-131. Michelle Zumwalt Page 11 of 26 place-based strategies to mitigate environmental hazard on or near identified sites. The City should review the site inventory, informed by community input, and revise as necessary to address environmental justice concerns with site identification. It should also commit to concrete actions to address environmental hazards in neighborhoods with existing and planned lower-income housing. ### 7. Site Concentration and AFFH The housing element must identify sites “throughout the community,” consistent with the duty to affirmatively further fair housing.[^p578-18] The Draft does not do so, instead acknowledging: “The distribution of sites across the city displays a concentration of lower-income housing in areas like Downtown and the West Area, while other areas like McLane and Woodward Park have a higher proportion of moderate and above moderate income housing, reflecting an unequal distribution of housing capacity across the city. This has the potential to exacerbate fair housing issues in Fresno by providing more capacity for lower-income housing in disproportionately impacted communities.”[^p578-19] In other words, the Draft admits that the City’s selection of sites for new development during the planning period is inconsistent with its duty to affirmatively further fair housing.[^p578-20] In making this admission, the Draft references, in general terms, policies and actions elsewhere in the document, but it does not identify any specific program that will mitigate the acknowledged segregative impacts of the City’s chosen site distribution.[^p578-21] HCD’s February 1, 2024, findings instructed the City to “add or modify goals and actions, specifically increasing housing mobility options and housing opportunities in high-opportunity areas.”[^p578-22] However, the Draft’s programs to address these and other fair housing issues remain inadequate, as discussed in greater detail below. We strongly encourage the City to amend the Draft to include programs that will identify different sites, and directly invest in infrastructure in low-income neighborhoods.[^p578-23] ### 8. Electronic Sites Inventory As noted in HCD’s February 1, 2024, findings, the City must utilize HCD’s electronic sites inventory, but the current Draft does not. We encourage the City to create an electronic site inventory as soon as possible for ease of review by both HCD and community members. ### IV. The Assessment of Fair Housing Fails to Comply with Section 65583(c)(10) [^p578-18]: Gov. Code § 65583.2(a). [^p578-19]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-3-127. [^p578-20]: See Gov. Code § 8899.50(b)(1) (“A public agency shall administer its programs and activities relating to housing and community development in a manner to affirmatively further fair housing, and take no action that is materially inconsistent with its obligation to affirmatively further fair housing.”) [^p578-21]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-3-127. [^p578-22]: HCD 2/1/2024 Findings, p. 3. [^p578-23]: https://www.transformfresno.com/wp-content/uploads/2021/06/transform-fresno-here-to-stay-report-english.pdf Michelle Zumwalt Page 12 of 26 Government Code section 65583(c)(10)(A) requires that the Housing Element include an analysis of available federal, state, and local data and knowledge to identify integration and segregation patterns and trends; as well as Racially or Ethnically Concentrated Areas of Poverty (R/ECAP) and Racially or Ethnically Concentrated Areas of Affluence (R/ECAA). A complete assessment must identify key issues and prioritize contributing factors to fair housing issues; it must also point to the clearest fair housing issue trends and patterns within the jurisdiction as well as be detailed and comprehensive enough to develop strong actions and programs that will overcome and undo the identified fair housing issues. See AFFH Guidance, pp. 25. Although we appreciate the City adding data, some historical context, and descriptions of the policies that have contributed to the formation of Racially and Ethnically Concentrated Areas of Poverty (R/ECAPs) and Racially or Ethnically Concentrated Areas of Affluence (RCAAs), the Assessment of Fair Housing (AFH) continues to fall short. It lacks an in depth analysis of and fails to incorporate public input as necessary to address the requirements set forth in Section 65583(c)(10) and does not achieve the requirement to ensure that the City AFFHs through its housing element. ### A. Integration and Segregation and R/ECAP and Concentrated Area of Affluence Analyses Lack Required Detail In our previous comment letters, we outline the gaps that render the AFH analysis incomplete (please see attachment A) such as failure to provide any data or analyze integration and segregation patterns for racial groups other than Hispanic/Latinos; failure to accurately or thoroughly analyze distribution of low- and high-income households across Fresno; the AFH’s analysis of R/ECAPs and RCAAs fails to address “public participation, past policies, practices, [and] investments” as required. HCD Guidance, p. 33. Although the current Draft was amended on page 1E-3-27 to include bullet points outlining the policies and historical background that contributed to the creation of R/ECAPs it did not include an evaluation or analysis on why certain ethnicities or races live in certain areas or which past policies or practices led South Fresno to have a higher concentration of low-income households or households that are predominantly Hispanic/Latino and/or African American. Reports have shown that “the cultural evolution of resident identities and land-use purposes in Fresno includes a series of hostile land acquisitions imposed on Indigenous Americans, forced labor exploitation of Black farmers, unjust labor practices toward Brown migrants, and the socio-economic alienation of Hmong residents.”[^p579-24] Similarly, the RCAAs section which is on page 1E-3-31 was only amended to include additional areas that are considered affluent such as North and Northeast Fresno neighborhoods [^p579-24]: Brown, B., Heer, N., Love, N., Pollard, K., Thomas, D. (2021, June 9). Here To Stay: A Policy-Based Blueprint For Displacement Avoidance in Fresno. Thrivance Group. https://www.transformfresno.com/wp-content/uploads/2021/06/transform-fresno-here-to-stay-report-english.pdf Michelle Zumwalt Page 13 of 26 and McLane community area. Once again it fails to include an in-depth analysis of how and why these areas are high-resourced and more affluent, as well as the policies and programs that have led to creating and building opportunities. It goes on to include a list of characteristics and a list of programs that will promote inclusivity, affordability, and diversity in RCAAs. But without an adequate analysis of RCAAs and R/ECAPs, these programs will continue to fall short and therefore fail to comply with Government Code section 65583(c)(10)(A)(ii). **B. Incomplete Analysis of Disproportionate Housing Needs Based on Race, Ethnicity, Familial Status, Disability, and Income** The analysis of disproportionate housing needs must analyze needs relating to cost burden, overcrowding, substandard housing, homelessness and other factors for protected characteristics, including at least race and ethnicity, familial status, persons with disabilities, and income. § 65583(c)(10)(A)(ii); AFFH Guidance, p. 39. The requirement to analyze disproportionate housing needs is fundamental to achieving the purpose of the AFH to ensure that the housing element affirmatively further fair housing by identifying disparities impacting protected classes which have been subject to historic discrimination, describes the factors contributing to those disparities, and adopts meaningful actions that overcome patterns of segregation and address disparities in housing needs and opportunity for protected classes. Unfortunately, this recent Draft failed to satisfy this requirement once again. In our previous letters (see attachment A), we made recommendations to include any information about the separate occurrence of overcrowding, cost burden, and substandard housing conditions based on race or ethnicity and provide any information at all about how these factors disproportionately impact Fresno residents based on familial status and disability. We also recommended that the Draft include information relating to familial status. We strongly urge the City to include information that reflects “local knowledge” or public input, which would strengthen the analysis with details about specific housing needs within the categories identified above and the scale of those needs in relation to others. Again, the City must supplement its disproportionate needs analysis to include the required demographic information and revise the AFH further to ensure its contributing factors and meaningful actions reflect that information. The Draft acknowledges that homelessness in Fresno disproportionately impacts people of color—in particular Black residents of the City—and people with disabilities. However, it does not analyze the City’s role in causing the segregation and forced displacement of its unhoused residents. The City is in the process of amending sections 10-1703(a), 10-1707, 10-2101, 10-2204, 10-2205 of the Fresno Municipal Code, Relating to the Prohibition of Encampments in Michelle Zumwalt Page 14 of 26 Public Places, with a second reading of the ordinance scheduled for August 15, 2024.[^p581-25] The purpose of the ordinance is the increased criminalization of unsheltered homelessness within the City, and it explicitly removes any requirement that the City ensure that shelter is available before citing, arresting, or displacing unsheltered individuals from public space. Such criminalization makes it harder for unhoused people to access housing, shelter, employment, medical care, and other services. The Housing Element must analyze these practices, including the disproportionate impact of these practices on people with disabilities and people of color, and it must include programs to ensure that its law enforcement and policing practices are not creating or perpetuating “disparities in access to opportunity.” HCD AFFH Guidance, 69. ### C. Incomplete Analysis of Displacement Risks Although we appreciate the amendments in the Draft identifying tracts that are assigned the different levels of displacement, on page 1E-3-82, and a note stating that concentrated areas of poverty, lower medium income neighborhoods with greater populations of color and larger proportion of renter households are most sensitive to displacement, the Draft has once again failed to evaluate and analyze the impact displacement has on R/ECAP and protected classes and therefore has failed to incorporate meaningful policies and programs that will protect residents. The AFH’s displacement risk analysis falls short by failing to consider other relevant information relating to existing and potential housing cost pressures confronting low-income residents, residents of color, and other protected classes, as well as significant displacement risks associated with tenant protection limitations, City land use policies and practices, environmental hazards, and climate change. A complete displacement risk analysis must consider these and other relevant factors. See AFFH Guidance, pp. 40-43. Additionally, we are extremely concerned that the Draft has removed the displacement risk assessment regarding climate disaster. The risk of climate disaster can also put pressure on lower income communities. South Fresno neighborhoods have been impacted by a series of fires at warehouse, recycling, and other industrial facilities that have occurred during the increasing number of high and extreme-heat days over the past five years. Potentially toxic smoke from these fires has at times densely concentrated in South Fresno neighborhoods, which can make breathing difficult and unsafe for residents even within their homes with windows closed. pg. 1E-3-82. As mentioned in our previous comment letters (see attachment A), the AFH’s Displacement Risk section should be revised to consider displacement risks associated with environmental hazards, [^p581-25]: MCC § 10-1703(a). Retrieved from: https://fresno.legistar.com/View.ashx?M=F&ID=13187124&GUID=01FAFD3D-FA86-4812-9928-3F4ECF7AECB4 Michelle Zumwalt Page 15 of 26 environmental disasters, and climate change, pursuant to HCD’s AFFH Guidance. AFFH Guidance, p. 42. By removing this analysis the Draft fails to adhere to its AFFH duty. We urge the City to reinsert this section and build on this analysis to ensure implementation of strong programs that address the needs of communities impacted the most by climate disaster. We must reiterate[^p582-26] that using The Urban Displacement Project’s criteria alone is not sufficient to accurately describe displacement risks impacting residents associated with housing cost pressures. Although data for 2019 has been included, this time period does not capture the sharp and sustained escalation in housing costs (both rental and ownership) that occurred during the COVID-19 pandemic between 2019 and 2022.[^p582-27] Between 2017 and 2021, Fresno experienced the greatest rent increases of all large U.S. cities, with rental prices increasing nearly 39% during that time.[^p582-28] The City failed to include this vital analysis and therefore the AFH’s displacement risk analysis must be supplemented with and revised based on more recent data in order to adequately fulfill this requirement. §65583(c)(10)(A)(ii); AFFH Guidance, pp. 39. As previously stated, the “Displacement Avoidance Efforts” do not remedy the need for a complete analysis addressing the displacement risk factors above, including relevant City policies and practices, and the adoption of meaningful actions to address those risks. And although it mentions the City’s Displacement Avoidance Plan (DAP) and the Here to Stay Report[^p582-29], we must once again ask that the AFH incorporate and consider relevant information and policy recommendations contained in that report. ### 1. Tenant Protection, Land Use, Environmental, and Climate-Related Displacement Risks Not Considered in the AFH Displacement Risk Analysis A complete analysis of displacement risks considers not only displacement risks associated with housing cost pressures, but also other factors which result in housing instability, including factors relating to the adequacy of tenant protections, disinvestment, local land use policies and practices, environmental hazards, and risks associated with natural disasters and climate change. The Draft Housing Element considers none of these risk categories, yet, based on our direct work with tenants and low-income residents and residents of color, they represent real and significant risk factors for Fresno residents. [^p582-26]: See attachment A, previous comment letters from LCJA. [^p582-27]: CalMatters, Real estate prices soar during the pandemic, climbing 25% in parts of California, Dec. 5, 2020, available at https://calmatters.org/california-divide/2020/12/real-estate-climb-pandemic/ [^p582-28]: Los Angeles Times, The Nation’s Hottest Housing Market? Surprise – it’s Fresno, Mar. 31, 2021, available at https://www.latimes.com/homeless-housing/story/2021-03-31/fresno-rent-spike-taps-into-california-covid-housing-tends [^p582-29]: Brown, B., Heer, N., Love, N., Pollard, K., Thomas, D. (2021, June 9). Here To Stay: A Policy-Based Blueprint For Displacement Avoidance in Fresno. Thrivance Group. https://www.transformfresno.com/wp-content/uploads/2021/06/transform-fresno-here-to-stay-report-english.pdf Michelle Zumwalt Page 16 of 26 Once again, we ask that the City incorporate the following analysis and assessment to the Displacement risk section: * Address the adequacy of policies and resources to protect tenants from displacement as a result of eviction, harassment, and substandard housing and include additional and stronger policies and programs to protect tenants, including in particular more comprehensive and stringent rent control standards than those established by the state, just cause requirements for eviction, and right to return home for displaced residents. * Analyze the success and effectiveness of the City’s code enforcement programs. * Consider the extent to which public and private disinvestment and unequal investment continues to impact low-income neighborhoods, neighborhoods of color, and neighborhoods with a high proportion of tenants and how disinvestment perpetuates and/or increases displacement risk in these areas. * Consider the City’s land use and permitting decisions which have directed and continue to allow for and promote the concentration of industrial and waste management facilities in and around neighborhoods in Jane Addams, Southwest Fresno, South Central Fresno (referred to by the Draft Housing Element as the “South Industrial Area”), and Southeast Fresno. * Consider displacement risks associated with environmental hazards, environmental disasters, and climate change, pursuant to HCD’s AFFH Guidance. AFFH Guidance, p. 42. The City must revise the AFH to include a complete and accurate Displacement Risk analysis as described above and modify other sections of the Housing Element, including the AFHs contributing factors and meaningful actions to overcome disparities relating to access to a healthy environment associated with these land use patterns. V. The AFH Fails to Consider Significant Disparities in Access to Opportunity to Multi-Modal Transportation Options, a Healthy Environment, and Quality Education As a reminder, the AFH must include an analysis of disparities in access to opportunity. § 65583(c)(10)(A)(ii). Access to opportunity broadly encompasses the place-based characteristics which are linked to critical life outcomes, including “education, employment, economic development, safe and decent housing, low rates of violent crime, transportation, recreation, food, and a healthy environment (air, water, safety from environmental hazards, social services, and cultural institutions). (AFFH Guidance, p. 34). Michelle Zumwalt Page 17 of 26 Although the previous Draft was amended to include some of the barriers to transit, unfortunately, the analysis continues to fail in comparing access to transportation opportunities based on protected characteristics; assess any disproportionate transportation needs for members of protected classes; provide important information about the adequacy of public transportation service in different areas of the City, protected classes, and low-income households; and entirely fails to consider access to other forms of transportation, including walking and bicycling.[^p584-30] The Draft states that, in order to “address these issues, the Housing Element includes a program to direct investments to address infrastructure and public service deficiencies in high-need areas including areas classified as high segregation and poverty, low resource, and moderate resource.” But without a comprehensive analysis, the City cannot create programs that will address the needs of communities living in R/ECAP. As discussed in our previous letter, a complete analysis of access to a healthy environment should consider any impacts on access to a healthy environment associated with the zoning, siting and operation of polluting or toxic land uses in disadvantaged communities and with climate change. Id. at pp. 16, 73. It must also be informed by public input, which is especially important in Fresno given the high concentration of communities in low-income South Fresno neighborhoods of color that rank among the most burdened by multiple sources of pollution in the state. Once again, the current Draft failed to incorporate this analysis. City policies and practices have intentionally concentrated polluting and noxious industrial and waste management land uses in South Fresno neighborhoods and policies and practices remain in place that all promote the exacerbation of these patterns to the detriment of housing opportunities and quality of life for South Fresno residents. The City must fulfill a robust analysis to inform better policies and programs such as impact fees for a community benefit fund, public health impact reports, and cargo/freight prohibition and revenue tax. The current Draft failed to include any additional analysis for educational opportunities. Per our previous comment letter, we urge the City to consider how policies, practices, and investments or disinvestments relating to access to green space, tree canopy, and climate resiliency (including adequate cooling and wildfire smoke protection) impact educational opportunities at schools, especially in low-income neighborhoods. The City must revise its analysis of educational opportunities to address these and other issues not addressed in the Draft Element and revise and add to its actions accordingly. # VI. Failure to Adopt Community-Identified Programs That Will Result in A Beneficial Impact During the Planning Period and AFFH **Program 1—Maintain Adequate Sites.** HCD’s February 1, 2024, findings instructed the City to include program language to facilitate development of pipeline projects during the planning [^p584-30]: See our past comment letters, attachment A. period, to monitor the progress of those projects, and to take alternative actions if the projects are not on track to be available before the end of the Sixth Cycle. The City has amended Program 1 to indicate that the City will “work with applicants of pipeline projects,” to “monitor the progress made on these sites,” and to reevaluate pipeline sites if their entitlements expire. However, this program needs more specific language about the concrete actions the City will take to facilitate the timely development of pipeline projects–especially affordable pipeline projects–and timelines for reevaluating sites when pipeline projects are abandoned or modified, as well as for when entitlements expire. Additionally, prior comments stressed the importance of community outreach and transparency in site identification, including in future site identification to address changes in pipeline projections and/or no-net-loss issues. The City should add commitments to this program to ensure that it is seeking, receiving, and acting on community input regarding the identification of new sites. Local knowledge and input regarding proposed sites can help ensure that the City is identifying sites in a way that encourages affordable development, avoids environmental harms, and promotes racial and economic integration. **Program 2 – Variety of Housing Opportunities in High Resource Areas.** The City must go beyond their revision to “encourage racially and socially inclusive neighborhoods” and provide a detailed explanation on how it will promote the development of affordable units to lower income households. Furthermore, the program still lacks a clear commitment to zone sites for multi-family development in areas of high resource, a commitment to ensure that units are affordable to all income levels, and a commitment to match funding opportunities with the identification of available sites to facilitate their development. Although the Timeframe was revised to increase the number of units for high density-multifamily development in high resource areas from 750 to 1250, specifically by adding 500 additional units by December 2031, the timeline should still be shorten to ensure the City is making a clear effort to promote housing mobility and Affirmatively Furthering Fair Housing. **Program 3 – Encourage and Facilitate Accessory Dwelling Units and Small Homes.** The revisions made to program 3 should have outlined the City’s intention to make the development of ADUs affordable to low-income families, specifically as a place-based revitalization strategy in order to AFFH. The City must also provide a definition for “small homes” that clearly explains how they differ from ADU’s. Furthermore, the City should do more than “subsidize” ADU inspection fees and keep the original language to “waive” these fees. Lastly, the revisions made to the objective should not exclude the development of ADUs for extremely-low and lower-income families and maintain its original goal to facilitate the development of 50 ADUs for these households while also keeping the revised goal to make 50 small homes available for lower-income households. Michelle Zumwalt Page 19 of 26 **Program 9–Use of Sites in Previous Housing Elements.** Government Code section 65583.2(c) requires that non-vacant sites identified in at least one prior housing element and vacant sites identified in at least two prior housing elements must be rezoned “to allow residential use by right for housing developments in which at least 20 percent of the units are affordable to lower income households.” Because the City failed to adopt a housing element that substantially complies with Housing Element Law by April 29, 2024 (120 days from the City’s statutory deadline to adopt), it must complete that rezoning within one year of the City’s statutory deadline to adopt. Gov. Code 65583.2(c). Accordingly, the timeframe for this Program must be amended to ensure that rezoning will be complete by December 31, 2024. **Program 11 – Incentives for Housing Development.** Although the program to incentivize housing development was revised to include access to resources “for lower-income residents, and promote racially and socially inclusive neighborhoods,” when working with multifamily and affordable housing project developers it still lacks a clear commitment towards actions taken to complete the program. Furthermore, the City should do more than “consider additional incentives” and provide additional incentives as well as list all available incentives on a publicly accessible database. Lastly, in order to promote housing mobility and AFFH, the city must do more than “Consider incorporating the location of affordable housing in High Resourced Areas” and ensure the placement of affordable housing in these areas. **Program 14 – Partnerships with Affordable Housing Developers.** Program 14 should be further revised to state that the City will “identify site opportunities for affordable housing in higher-resourced areas and areas with higher median incomes to reduce concentrations of poverty and improve access to resources.” Furthermore, when convening stakeholders to identify ongoing regulatory and funding barriers to affordable and mixed-income development, the City should include lower income households, special needs households and individuals in protected classes. (HCD AFFH Guidance pg. 20). The program should be amended to include strategies to combat NIMBYism, which has stalled and terminated several affordable housing projects in high resourced areas. The quarterly convenings should also be used to provide stakeholders with a report on the success of the program. Additionally, the time frame should be changed to bi-annual reporting throughout the planning period, bi-annual reporting review and assessment of potential funding opportunities, and quarterly convenings with stakeholders. In order to truly integrate communities this program must be amended. (HCD AFFH Guidance pg. 12). **Program 17–Surplus Public Lands.** The City should review and revise Program 17 to ensure that it complies with the Surplus Land Act. HCD’s just-released Updated Surplus Land Act Guidelines (Aug. 1, 2024) can be a helpful resource. For example, the current Draft replaced 15 percent with 10 percent in describing the minimum percentage of affordable units in developments built on surplus land, but the Act requires 15 percent affordable units in projects of 10 or more units. *See* HCD SLA Guidelines, p. 28. Additionally, the reference to evaluating Michelle Zumwalt Page 20 of 26 surplus sites for “other community-serving uses” prior to disposition under the SLA is ambiguous but could be read to indicate that the City plans to attempt to use surplus City-owned sites for commercial or other uses in violation of the SLA. Additionally, because the City has identified so many City-owned sites in its site inventory, this program should include proactive steps, beyond the base requirements of the SLA, to facilitate affordable housing development on those sites, especially sites in higher-opportunity areas. The list of potential sites, disposition and disposal strategy, and rezoning of city-owned sites are good first steps. See Draft 1E-1-23. Since land acquisition is one of the biggest challenges for affordable developers, these sites represent a rare and valuable opportunity for the City to facilitate the development of much-needed affordable housing. **Program 19 – Home Buyer Assistance.** This action commits the City to “strive to support a total of 40 low- and moderate-income households with home purchases during the planning period.” These commitments lack specificity and do not ensure a beneficial outcome within the planning period. Without a complete and comprehensive AFH, it is impossible to create a meaningful and impactful Home Buyer Assistance program since they failed to analyze constraints, access to opportunity, past programs etc. We reiterate that this program must include additional commitments to ensure that low-income residents, undocumented residents, residents who speak languages other than English, and residents in racially and /ethnically-concentrated areas of poverty (R/ECAPs) have the opportunity to benefit from these funds. If the City had done their due diligence in engaging the community, they would have heard from residents that during the 5th Cycle planning period, residents without social security numbers or who faced language access barriers were unable to apply for the City’s homebuyer assistance program. The City must amend this program, possible solutions include: ensuring that low-income residents are knowledgeable about the programs, undocumented residents are able to successfully apply for this program, including closing costs as part of funding packages. In order to ensure that residents living in R/ECAPs are targeted, we recommend the City create annual reports listing how many applicants were assisted, outreach efforts made and whether they live in R/ECAPs. Due to the concerns outlined above, the program as currently implemented and drafted fails to adhere to HCD’s AFFH Guidance that “actions must be specific with timelines, discrete steps and measurable outcomes to have a ‘beneficial impact’ during the planning period.” **Program 20 – Housing Choice Voucher Incentive Program.** The revisions made to Program 20, Housing Choice Voucher Incentive program, did not incorporate meaningful actions with specific timelines and measurable outcomes that would result in a “beneficial impact.” The City should take steps to ensure that voucher holders face no discrimination or limitations. The City should do more than conduct HCV outreach to developments in high resourced areas and revise Michelle Zumwalt Page 21 of 26 this program to incorporate targeted community outreach and HCV advertisement in low-resourced to promote Housing Mobility throughout the City. Please refer to our previous letter, Attachment A for further recommendations regarding how to limit HCV discrimination. **Program 22 – Housing Rehabilitation.** The current program fails to meet its AFFH duty. It does not address the needs of extremely low income residents and vulnerable populations such as undocumented residents. This program fails to address equity concerns, disparities, and neglects the needs of marginalized communities particularly in R/ECAP; and it fails to incorporate strong actions and concrete steps. The Draft states that it will aim to connect at least 80-120 lower-income households with rehabilitation resources during the planning period and complete a third of these in areas of concentrated poverty.” This is not enough. Proper AFH analysis would have shown that the most impacted are extremely low income households and therefore these should be prioritized with at least half or more than half. Additionally, once again we ask that this include rehabilitation in response to the negative effects of climate change such as weatherization, cooling mechanisms, like heat pumps, air conditioning, insulation and other cooling assets to increase resilience to extreme heat as part of the rehabilitation program. **Program 23 – Comprehensive Code Enforcement.** Unfortunately, this program as written continues to fail to address critical housing issues since the last housing element cycle. The program should be revised to include actions around legally holding landlords accountable for retaliation, unlawful evictions, and harassment towards tenants who file code enforcement complaints such as a commitment to adopt a tenant anti-harassment ordinance. As stated, we recommend that the City adequately analyze code enforcement’s procedures and incorporate tenant feedback for a comprehensive code enforcement program. **Program 26 – Fair Housing Services.** This program is vague. Although it states that the goal is to “mitigate impediments to fair housing opportunities throughout the city, with an emphasis on supporting the needs of populations and neighborhoods most impacted by fair housing issues,” it fails to establish timelines and concrete steps on how the City will achieve this. A full AFH analysis would have helped identify the needs of R/ECAP as well as strong milestones, objectives and timelines. Housing discrimination has been a pervasive issue in the City of Fresno and only those who have been impacted can inform this program, for example additional legal representation, landlord education on fair housing law, enforcement mechanism against bad landlords etc. **Program 27 – Environmental Justice.** The City is already required to work on their Environmental Justice Element. In order to transform R/ECAP into areas of opportunity (AFFH Guidance, p.15), this program should focus on placed-based strategies in R/ECAP areas such as Southwest, South Central and Southeast Fresno. Such actions must include land use changes to rezone industrial uses away from sensitive receptors, prohibit siting of polluting uses in Michelle Zumwalt Page 22 of 26 communities identified as R/ECAP and adding a moratorium on warehouses in these areas. As written, this current program and its actions fail to affirmatively further fair housing. (AFFH Guidance, p.54). **Program 28 – Equitable Community Investments.** This program states that the City has “initiated multiple efforts to incentivize investment in established areas rather than in new growth areas,” they will focus on areas in the General Plan Figure IM-1 which have been identified as areas of priority for incentives and that they closely align with census tracts designated as areas of greatest need (high segregation & poverty, low resource, and moderate resource).” Unfortunately, the map only highlights areas, there is no analysis beyond the map. We strongly recommend that the City amend this program to prioritize South Fresno neighborhoods explicitly. South Fresno is identified as a R/ECAP, residents have continuously called for and advocated for increased investment for decades to support healthy housing, infrastructure, amenities and services. The program must include actionable items and strong commitments in order to comply with its duty to affirmatively further fair housing. **Program 29 – Equitable Engagement.** The goal of this program is to “expand outreach and public education strategies to increase engagement amongst historically underrepresented populations and residents with the greatest need.” This action contains non-specific commitment and fails to identify measurable outcomes with respect to equitable engagement. This program is identified as one that will improve the quality of life and access to opportunities in R/ECAPs but fails to identify how exactly it will accomplish this. **Program 30 – Workforce Development.** Although we appreciate changes to this program, we strongly encourage the City to include a program that targets the unhoused community. Residents have identified a systemic issue within the unhoused community when they receive keys to their new unit, where once they transition out of the shelter they are sent back out into communities, expected to get a job and maintain it without proper training on how to apply for a job, keep it and budget for their expenses. As written this program fails to integrate R/ECAP and R/ECAA. **Program 33 – Mobile Home Parks.** Although we appreciate language that acknowledges the additional need of this specific group, it still falls short in fulfilling AFFH requirements. Once again, we request that the Draft address the need for heat resiliency such as weatherization and insulation especially to older mobile home parks by funding a mobile home park renovation fund for all mobile homes. This fund will help low income families with issues that they need to address due to inspection violations or other habitability concerns. The Draft must also include HCD’s Manufactured Housing Opportunity & Revitalization Program (MORE) as an additional funding source. These funds can be used for the acquisition, conversion to resident organization ownership, rehabilitation, reconstruction and replacement of mobilehome parks, as well the Michelle Zumwalt Page 23 of 26 remediation of health and safety items of both parks and individual mobile homes.[^p590-31] Additionally, this program should include a commitment to penalize and fine mobile home park owners who are not providing adequate and safe conditions for their tenants. The 5th Cycle Housing Element included Program 10A, a similar program, that directed the City to “Conduct and publish an assessment of housing-related needs in mobile home parks through communications with residents and owners, identifying city, state, federal, and private resources available to address those needs.” The City must include an action in this program that finalizes this report, releases it for public input and implements MHP resident needs. The City must amend this program to fulfill their responsibility to AFFH, support quality of life and access to opportunity improvements for all mobilehome parks in Fresno. Program 34 – Eviction Protection Program. In 2021, the City created their Eviction Protection Program (EPP) in response to communities’ advocacy for a comprehensive Right to Counsel Program. Despite heavy resident support, the City opted to establish a less comprehensive program which failed to address specific community needs. During this year’s budget hearing, the City shared data going back to 2021 showing the total number of tenants the City has supported - a total of 2,199 since the inception of the program; and a majority of them live in District 3, which is primarily a R/ECAP area. The data shows that the program has done the following: * 364 people by preventing unlawful detainers filed, * 597 People had their move-out time extended * 107 people had the money owed to a landlord reduced * 18 families helped with the Cash for Keys program * 267 tenants remain in the home * 293 Settlement with the landlord * 580 Unlawful Detainers were prevented on the tenant's record * 25 families had unlawful detainers removed from the record * 18 Families, stopped lock-outs * 186 people's unlawful detainers were successfully dismissed Currently the City has allocated $2 million to continue the program. Unfortunately, this is an inadequate response to vulnerable communities’ needs. The Draft’s revisions soften the commitment to this program by striking “implement” and replacing it with “seek funding” and notes that funding will end in 2025. We strongly recommend that the City improve the EPP by [^p590-31]: California Department of Housing and Community Development. (2024). Manufactured Housing Opportunity & Revitalization Program (MORE). https://www.hcd.ca.gov/grants-and-funding/programs-active/manufactured-housing-opportunity-and-revitalization-p rogram Michelle Zumwalt Page 24 of 26 adopting and implementing a comprehensive Right to Counsel program,[^p591-32] create a permanent source of funding, and increase the annual funding for this program. The City can also include HUD’s Eviction Protection Grant Program (EPGP) as an additional source of funding. This grant will fund nonprofit organizations and government entities to provide no cost legal assistance to low-income tenants at risk of or subject to eviction.[^p591-33] This City must improve this program in order to comply with AFFH law. **Program 36 – Homeless Assistance.** Although we appreciate the Draft’s amendment to establish a pilot program funded by Encampment Resolution Funding (ERF) to resolve the experience of unsheltered homelessness for people residing in encampments, we strongly urge the City to host additional workshops to engage directly with the unhoused community to include much needed programs such as: * Providing mental health outreach by doing home visits, trainings on how to deal with family members who have severe mental illnesses, as well as offering educational tools such as pamphlets and other services * Helping newly housed individuals who show symptoms of hoarding issues, continued care is essential for a recently housed individual in order for them to continue living in their unit and not face eviction * Currently, the City provides stationary showers in locations where few unhoused individuals live. We recommend adding mobile bus showers, along with an outreach team to assist the unhoused community throughout the City * Mental health services provided longer than 60 days. The City can collaborate with the County to create such a program * Open detox centers that allow an individual to stay 24 hours a day, 7 days a week without a 10 day limit in order for them to seek assistance anytime of the day or night * Create an advisory board or an oversight committee with diverse stakeholders that include a majority of individuals that work directly with the unhoused community for accountability and transparency regarding the decision making process for all homelessness funds * Trainings for City staff that work primarily with the unhoused community that have mental health and substance abuse illnesses * Create free sober living with job training and housing navigation for a year * Use of emergency funds to support the outreach and care for unhoused children/youth with a response of 24 hours. [^p591-32]: The Fresno Right to Counsel Coalition. (2020) Right to Counsel Proposal. Retrieved from: https://leadershipcounsel.org/wp-content/uploads/2021/01/Fresno-Right-to-Counsel-Coalition-Community-Proposal.pdf. [^p591-33]: Office of Policy Development and Research. (2024). Eviction Protection Grant Program. Retrieved from: https://www.huduser.gov/portal/eviction-protection-grant.html Michelle Zumwalt Page 25 of 26 * Development and implementation of shelter standards for all City-supported shelters to provide due process for shelter residents facing “exits” from shelters and to ensure that shelters are providing reasonable accommodations to individuals with disabilities. Additionally, the Draft element lacks policies and programs that have been uplifted by community residents for decades, also identified in LCJA’s August 2023 comment letter (see attachment A). We strongly urge the City to incorporate community-identified programs listed below into the Draft before submitting to HCD. * **Reinstate the Emergency Rental Assistance Program and Incorporate a Rent Stabilization and Just Cause Protection Ordinance.** Once again we must reiterate that the data from Figure 1E-3.31: Percent of Renters Overpaying, Fresno, 2014-2019 fails to capture data from the housing crisis that ensued after the pandemic. According to the U.S. Census Bureau’s 2021 American Community Survey data, 52% of all Fresno tenants renting are cost burdened and 92% of the 18,259 households that earn less than $20,000 annually are rent-burdened.[^p592-34] The need for an Emergency Rental Assistance was created to respond to the needs of all residents but particularly those living in R/ECAP communities. This program was removed entirely from the July Draft to the November Draft and remains excluded in this revised Draft, even after continuous advocacy from residents. More than 19% of all households are cost burdened and more than 20% of all households are severely cost burdened. Additionally, the increase in rents are only exacerbating the housing crisis. This program would help R/ECAP communities as a placed based strategy. Additionally, we recommend the inclusion of a Rent Stabilization and Just Cause Protection Ordinance, which will protect existing residents from displacement and preserve housing choice and affordability. (HCD AFFH Guidance pg. 74). We recommend the following: * The City will implement a Rent Stabilization and Just Cause ordinance by December 2025 to protect tenants from unreasonable rent increases and unjust evictions, and develop a rental registry. * The City will establish a community workgroup to develop a rent stabilization and just cause ordinance draft by Winter 2025. * The City will conduct at least one community workshop to inform the development of the ordinance by Spring 2025. * The City will release a draft ordinance for public review by Summer 2025. * The City will adopt the ordinance by December 2025. [^p592-34]: Montalvo, M. (2024). Fresno Family Spends Over 30% of Its Income on Housing. Would Rent Control Change That? The Fresno Bee. Retrieved from:https://www.fresnobee.com/news/local/article276839841.html. * Inclusionary Zoning Ordinance. In order to replace segregated living patterns with truly integrated and balanced living patterns and comply with local fair housing laws, the City must add stronger programs to their Draft. (HCD AFFH Guidance pg. 30). We strongly recommend that the City create and implement an Inclusionary Zoning Ordinance. Per our analysis on governmental and non-governmental constraints and AFH, the City’s inadequate assessment does not provide sufficient information to create strong programs. Based on decades of experience, residents understand and want the City to adopt an Inclusionary Zoning program that would help the City reach its VLI and LI household units for this planning period. NIMBYism is a top constraint to build housing in Fresno, for example the *Martinez v. City of Clovis* case highlighted this issue. Advocates were instrumental in winning this case where the court required sites to be rezoned to accommodate the RHNA for lower income housing or for the RHNA carried over from the prior planning period must be made available at minimum densities as well as being available for development by-right...the Court decided that the City’s failure to zone for multi-family housing also violated the City’s AFFH duty.[^p593-35] * Establish a safe maximum indoor air temperature for residential dwellings. The Draft failed to complete an adequate AFH, site inventory analysis and a disaster-driven displacement risk analysis that assessed the impact of climate change on vulnerable communities particularly R/ECAP. As climate change exacerbates the intensity and longevity of heat waves, the City must take swift action to ensure the health and safety of all residents, but particularly at-risk populations such as children, senior citizens, people with disabilities, people with section 8, and people with autoimmune diseases. Therefore, we recommend the City include a program to establish a safe maximum indoor air temperature threshold for residential dwellings and a program to help facilitate the provision of cooling systems, such as heat pumps. * Urban Greening. We strongly recommend the Draft include a program that addresses urban greening inorder to transform R/ECAP into areas of opportunity. Urban greening should be used to create buffer zones for residential dwellings that are surrounded by polluting land uses to mitigate health impacts. * Citing Industrial Uses. In order for the City to fulfill their AFFH duty, they must incorporate place-based strategies to encourage community conservation and revitalization. (AFFH Guidance, pg. 73). We recommend that the City include a program that limits placing housing projects aways from heavy, light industrial uses or phasing out light/heavy industrial zones near R/ECAP. This will address the negative environmental, neighborhood, housing and health impacts associated with siting and operation of land [^p593-35]: Insert link to case. Michelle Zumwalt Page 27 of 26 uses such as industrial, agricultural, waste storage, freeways, energy production, etc. in disadvantaged communities. (AFFH Guidance, pg. 73). * **Impact Fees.** We urge the City to include a program that places impact fees into a community benefit fund when polluting land uses and practices are placed near housing. The community benefit fund will create revenue and should be managed by the community directly impacted to dictate where funds will be allocated in order to transform R/ECAP and fulfill the City’s AFFH duty. * **Developing Public Health Impact Reports** for new industrial development in order to understand existing public health disparities and the potential of those conditions worsening as a result of industrial development, particularly in R/ECAP. Public health agencies should be resourced to support this analysis. The findings of these reports should be available publicly and be included in permit approval processes and other key decision-making milestones. * **Establish a Cargo/Freight Prohibition and Revenue Tax** to directly fund community-based housing and projects in the neighborhoods most negatively impacted by years of environmental toxicity caused by freight. * **Incorporate Complete Streets principles** into all transportation projects at all phases of development, including planning and land use decisions, scoping, design, implementation, maintenance, and performance monitoring. * **Establish a Housing Element Implementation Committee** to oversee the timelines and implementation of each program and policy. The committee should be composed primarily by tenants, low-income homeowners, and at-risk populations to ensure implementation meets the needs of most at-risk communities. Including the program recommendations listed above will ensure the City reaches state law compliance on their Housing Element and ensure programs and policies have clear timelines, metrics and Affirmatively Further Fair Housing. We reemphasize the need for the City to identify funding sources for all programs to ensure they will effectively be implemented in the upcoming years. **VII. Conclusion** The undersigned organizations welcome the opportunity to continue collaborating on the City of Fresno Housing Element Update to ensure the housing needs of all residents in the City are met in the upcoming years. Housing is an essential component of everyday life and tenants Michelle Zumwalt Page 28 of 26 who live in fear of losing their homes suffer tremendously, not just economically, but mentally and physically as well. California is currently facing a devastating housing crisis and the City of Fresno has a responsibility to ensure residents throughout the City live in safe, equitable and healthy housing. Respectfully, /s/ Jovana Morales Tilgren, Housing Policy Coordinator, Leadership Counsel for Justice and Accountability /s/ Emmanuel Agraz-Torres, Policy Advocate Leadership Counsel for Justice and Accountability /s/ Melissa A. Morris, Staff Attorney Public Interest Law Project mmorris@pilpca.org 510-891-9794 x 111 /s/ Lilia Becerril, Founder Familias en Acción Marisa Moraza, Political Director PowerCA Action Alexandra Alvarado, Community Organizer Faith in the Valley Dez Martinez, CEO We are Not Invisible Julian Mosley, Chair Fresno Homeless Union City of Frenso Community Residents Lisa Fores, District 2 Ilda Villa, District 7 Guillermina Leon, District 3 Michelle Zumwalt Page 29 of 26 Rosalina Peña, District 3 Jose Jimenez, District 3 Araceli Sanabria, District 5 Yonas Pauloas, District 3 Cc: Architect, Michelle Zumwalt, michelle.zumwalt@fresno.gov City Manager Georgeanne White, Georgeanne.White@fresno.gov Planning Director Jennifer Clark, jennifer.clark@fresno.gov Council President Analisa Perea, annalisa.perea@fresno.gov Councilmember Mike Karbassi, mike.karbassi@fresno.gov Councilmember Miguel Arias, miguel.arias@fresno.gov Councilmember Tyler Maxwell, tyler.maxwell@fresno.gov Councilmember Luis Chavez, luis.chavez@fresno.gov Councilmember Garry Bredefeld, garry.bredefeld@fresno.gov Councilmember Nelson Esparza, nelson.esparza@fresno.gov Mayor Jerry Dyer, jerry.dyer@fresno.gov Jose Ayala, Housing Policy Specialist, California Department of Housing and Community Develoment jose.ayala@hcd.ca.gov Paul, McDougall, California Department of Housing and Community Development, paul.mcdougall@hcd.ca.gov August 7th, 2024 Michelle Zumwalt Planning and Development Department, City of Fresno, 2600 Fresno Street, Room 3065, Fresno, CA 93721 On behalf of the California Apartment Association (CAA), I reiterate CAA’s support for the Fresno County Multi-Jurisdictional Housing Element Update as currently written and as a follow-on to our letter from August 2023. The Housing Element update’s core goals and proposed policies reflect the importance and urgency of developing housing across Fresno County that is affordable and available to families of all income levels. CAA looks forward to working with all jurisdictions in successfully implementing this plan’s goals. CAA appreciates the work Fresno County, the incorporated cities of Fresno County, and the Council of Governments have done on this Housing Element update. CAA looks forward to working with all stakeholders in the passage and implementation of the Multi-Jurisdictional Housing Element in its current iteration. Sincerely, Greg Terzakis Senior Vice President <
> April 12, 2024 Michelle Zumwalt, Architect Planning and Development Department, City of Fresno 2600 Fresno Street, Room 3065 Fresno, CA 93721 *Sent via Email* **RE: State Noncompliance Findings for the City of Fresno’s Revised Public Review Draft 2023–2031 Housing Element** Dear Ms. Zumwalt: Leadership Counsel for Justice and Accountability (LCJA) works alongside the most impacted communities to advocate for sound policy and eradicate injustice to secure equal access to opportunity regardless of wealth, race, income, and place. We submitted letters in October 2022, August 2023, and December 2023 (attached in same email) to comment on the November 2023 Revised Draft Housing Element submitted to the California Department of Housing and Community Development (HCD) on November 3, 2023 (the Draft). We appreciate the City of Fresno taking the time to read and respond to our comments. There are, however, substantial revisions needed before the second draft is released, including addressing community concerns and priorities and adhering to the requirements in HCD’s Noncompliance Findings Letter from February 1, 2024.[^p599-1] # I. The City Must Engage the Community Throughout the Housing Element Draft Revision Process The City must meaningfully engage all economic segments of the community in varied ways that consider the diverse and unique needs of community members. Gov’t Code § 65583(c)(9). As stated in our previous letters, the Draft was not informed by adequate engagement. HCD’s Noncompliance Findings require the City to adequately engage community residents in disadvantaged communities—specifically, the residents in Southwest, South Central, and Southeast Fresno, the mobile home park communities of Three Palm and Jane Addams, and the community-based organizations that represent them—as the City revises its Draft. HCD Appendix at 9. LCJA has not been made aware of any effort by the City to conduct community engagement or inform residents of its statutorily mandated Housing Element revisions to date. We recommend the City engage the community in the following ways: (1) conduct workshops in impacted communities[^p599-2] at various times, including outside of the typical working hours of 5 AM – 6 PM; (2) provide multilingual materials and translation services (e.g., Spanish, Hmong, Punjabi); (3) provide helpful services to facilitate more inclusive engagement (e.g., child care services, meals, transportation); (4) supply a mix of in-person and virtual engagement opportunities; and (5) conduct varied, targeted, and multilingual outreach considering the unique needs of individual communities (e.g., mailers, local neighborhood newsletters, leaving materials in community spaces, bilingual radio ads). See AFFH Guidance at 11. Without this engagement, the City will not be able to adopt a compliant Final 6th Cycle Housing Element. # II. The City Must Complete an Analysis of Fair Housing and Constraints A.B. 686 (Cal. 2018) addresses discriminatory land use and housing policies and practices by imposing an independent state mandate expanding the duty of all California’s public agencies to [^p599-1]: Letter from the Department of Housing and Community Development to Michelle Zumwalt, Architect, Planning and Development Department of the City of Fresno (Feb. 1, 2024), https://fresnomjhe.com/wp-content/uploads/2024/02/ fre-fresno-draft-out-020124.pdf [hereinafter HCD Letter]; Letter from the Department of Housing and Community Development to Michelle Zumwalt, Architect, Planning and Development Department of the City of Fresno app. (Feb. 1, 2024), https://fresnomjhe.com/wp-content/uploads/2024/02/fre-fresno-draft-out-020124.pdf [hereinafter HCD Appendix]. [^p599-2]: E.g., Southwest, South Central, and Southeast Fresno and the mobile home parks of Three Palms and Jane Addams.. AFFH and also ensures local jurisdictions comply with new housing element requirements. Gov’t Code § 8899.50; see AFFH Guidance at 7. In order to ameliorate past actions that led to inequity, decisionmakers must create land-use and funding policies to increase affordable housing in high resource neighborhoods and bring additional resources to traditionally under-resourced neighborhoods. AFFH Guidance at 6. HCD has stipulated certain inadequacies with the City’s AFFH duty and housing element requirements which require revision for the City to be found in compliance for its 6th Cycle Housing Element. See HCD Appendix at 1–3, 8. The November Draft and the City’s plans and discussions to date regarding the 6th Cycle Housing Element and its implementation do not AFFH and are materially inconsistent with this duty. Gov’t Code § 8899.50; see AFFH Memo at 1; AFFH Guidance at 8–9. For example, please see the discussion regarding the exclusion of resident priorities in the City’s creation of its programs infra Section I. In addition, the City has recently engaged in problematic rhetoric around the 2023 Annual Progress Report on its 5th Cycle Housing Element, its RHNA, and the 6th Cycle Housing Element drafting: The City has reiterated it is not prioritizing affordable housing production; it is not willing to create the necessary conditions to facilitate its development; and it is subjecting itself to the consequences[^p600-3] of a noncompliant housing element, including shorter rezoning deadlines, possible legal enforcement, and forfeiture of millions of dollars in development funding.[^p600-4] Through these actions, the City has violated its broad AFFH Duty. HCD’s Findings, which the City has not prioritized or taken seriously,[^p600-5] compel the City to discuss how it complies with fair housing laws, including the City’s broad duty to AFFH. HCD Appendix at 1; see Gov’t Code § 8899.50. The City must critically examine its past and current policies and practices (including City staff’s rhetoric, characterization, and actions regarding state housing and civil rights laws) and ensure its 6th Cycle Housing Element, in accordance with HCD’s Findings, fulfills its duty to AFFH. [^p600-3]: HCD Letter at 1–2. [^p600-4]: See Hearing to Receive Public Comment on the 2023 Housing Element and General Plan Annual Progress Reports, City Council Meeting, City of Fresno (Mar. 21, 2024), https://fresno.granicus.com/player/clip/1603?view_id=1&redirect=true [hereinafter 3/21 CC Meeting]. During this meeting, the City presented its 2023 Housing Element Annual Progress Report (APR). Sophia Pagoulatos, the Senior Manager of Long Range Planning (LRP) for the City’s Planning and Development Department gave a presentation covering an overview of the APR, including discussing what the housing element is, the five main objectives of the City’s housing element, the City’s Regional Housing Needs Allocation (RHNA) data, housing applications processed, affordable housing in the pipeline, highlights about programs, and outreach. This presentation was followed by public comment and council members' response to the public comment. [^p600-5]: See 3/21 CC Meeting supra note 4. The City delayed in notifying City Council and the public that it was out of compliance with its 6th Cycle Housing Element, showing they are not serious with complying with state housing and civil rights laws. A. The City must adopt programs that address disproportionate housing needs, result in a beneficial impact, and affirmatively further fair housing. HCD finds that the City fails to evaluate the characteristics of Racially and Ethnically Concentrated Areas of Poverty(R/ECAP), their “changes over time, comparisons to other neighborhoods in terms of equitable quality of life and consider other relevant factors, such as public participation, past policies, practices, and investments and demographic trends.” HCD continues to state that most of the Southern portion of the City is an area of High Segregation and Poverty that was not properly analyzed and therefore the City failed to include significant and beneficial actions, including place-based strategies toward community revitalization that are targeted towards these areas. In order to Affirmatively Further Fair Housing(AFFH), the City must engage communities and incorporate policies and programs that address their needs, but specifically decrease the trajectory of continual concentrated areas of poverty. Outlined below is a list of community-based priorities we submitted on October 3, 2022 that the City should include in the second draft. * Adopt a local rent stabilization ordinance, to protect tenants from continuously rising rents, including a rent stabilization board to hear and approve rental increases submitted by landlords * Adoption of tenant protections to reduce displacement risks, including just cause eviction that address gaps in protections afforded under the 2019 Tenant Protection Act and a right to counsel guaranteeing access to affordable legal counsel for low-income tenants in housing matters * Inclusionary Zoning Ordinance * Industrial Zoning Moratorium for heavily burdened low income residential areas * Future Industrial Zoning siting prohibited near underserved communities - placing housing sites away from heavy, light industrial uses or phasing out light/heavy industrial zones * Establish a permanent emergency rental assistance program to assist residents at risk of homelessness due to rent increases and changed circumstances and ability to pay. Identification of a permanent local source of funding will ensure continuous funding and that the program can be used to prevent displacement. The City of Fresno can leverage the Local Housing Trust Fund dollars and the State is continuing to grant monies for rental assistance programs * Establish a permanent first-time homeownership assistance program to help tenants become first-time homeowners. Closing costs and downpayment assistance for low-income, first-time homebuyers can help close the housing gap. Residents with ITIN numbers should be eligible for this program * Investments in improvements to mobile home parks to address the needs, including needs from the mobile park assessment study, including weatherization and climate resiliency needs, to improve indoor and outdoor air quality, and to expand access to green space * Establish a safe maximum indoor air temperature for residential dwellings * Extreme heat and weatherization programs to address climate change. This includes funding for weatherization upgrades to homes and rental units, specifically in census tracts that rank the highest on CalEnviroScreen for pollution and poor health outcomes and are most vulnerable to climate change * Establish an acquisition and rehabilitation fund to purchase older, blighted, and/or abandoned homes/buildings. The County and the City of Fresno can establish a revolving fund to insure that rehabilitated homes are sold back to the community at a low cost * Grants for residents who want to develop affordable accessory dwelling units on their land in both the City and County of Fresno. Some residents are willing to sell parcels of land to the County to develop affordable housing and increase housing supply * Urban Greening is used as buffer zones when residential is placed or already placed near existing polluting land uses to mitigate health impacts * Suitable Vacant Land should be prioritized for affordable housing in order to bring Very Low Income and Low Income RHNA allocations into compliance * Impact fees should be placed into a community benefit fund when polluting land uses and practices are placed near housing. The community benefit fund will be managed by the community directly impacted to dictate to who these funds should be allocated. HCD notes that the element must reevaluate the patterns and trends of Racially Concentrated Areas of Affluence (RCAA) in the City and, depending on the outcome of the analysis, implement or modify meaningful programs that take action to promote housing mobility in the city such as: * Anti Discrimination and Harassment Renter Protections * Development of more affordable housing rental units in High Opportunity Zones of Affluence * Prioritize Suitable vacant land for development of affordable purchasable housing builders ie: Habitat for Humanity or Self Help Enterprises Additionally, section C-2 in HCD’s findings state that, “based on the outcomes of a complete analysis” the element must make specific efforts towards programs that include the housing needs of Farmworkers. Community members highlighted the benefit of a program that informs Farmworkers of their rights in a way that is accessible to them. A program such as this would involve: * Employing a bilingual/multilingual outreach team that reasonably operates outside of the typical working hours of a Farmworker. * Implementing Outreach Methods that meet Farmworkers where they are without fear of hostility or inquiry of legal status in spaces frequented by Farmworkers (i.e Fresno Cherry Auction, Resource Fairs that take place in heavily impacted communities.) ### B. Governmental Constraints The City must also identify constraints to the sites identified for potential housing as required by Gov. Code § 65583(a)(5), and abide by its duty to Affirmatively Further Fair Housing (“AFFH”) by “not only [conducting] an analysis of site capacity to accommodate the RHNA, but identif[ying] sites [that] serve the purpose of replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity.” HCD AFFH Guidance, p. 12, Gov. Code § 8890.50. subd. (b). Depending on a complete analysis of potential Government constraints, the city may have the opportunity to revise or add programs and potentially “address and remove or mitigate any identified constraints”. Section B4 of HCD’s Findings list Land use controls, Local processing and permit procedures, and on/off site improvements, and Constraints on Housing for Persons with disabilities (Residential Care Facilities, land use controls, and Reasonable accommodations appeals). In our previous housing Element Community meeting, residents identified the following priorities that could be developed into programs that meaningfully address governmental constraints. * Allowing higher-density units in high resourced areas * Supporting multi-family developers who are in competition with single family developers for the same sites * Reduced permitting timelines for multi-family developments * The City should commit not only to removing the limit on the number of units that can be contained in an SRO but also add it as a permitted use in the following zones: RM-MH, RM-2, and downtown while removing conditional use permit requirements from RM-2, RM-3, NMX, CMX, and RMX. * Changes to the Muni Code section 15-2729, which will remove constraints on the development of emergency shelters * Programs to support at-risk housing ### III. Conclusion We urge the City to address the issues outlined in this letter and previous letters submitted by LCJA and HCD. We look forward to discussing them with you and continuing to work with the City to ensure that it adopts a Housing Element that fully complies with the law and addresses the serious housing needs and disparities that impact City of Fresno residents. Sincerely, Emmanuel Agraz-Torres Housing Policy Advocate, City of Fresno **Leadership Counsel for Justice & Accountability** <
> Jasmine Robinson Legal Advocate/Legal Fellow Sponsored by Weil, Gotshal & Manges LLP **Leadership Counsel for Justice & Accountability** Val Feldman Staff Attorney **Public Interest Law Project** Marisa Moraza Political Director **Power California** Edith Rico Project Director **Fresno Building Healthy Communities** Naymin Martinez Executive Director **Central California Environmental Justice Network** Marcel Woodruff Community Organizers **Faith in the Valley** **CC:** Land Use and Planning Unit (HousingElements@hcd.ca.gov), California Department of Housing and Community Development Jose Ayala, Housing Policy Specialist, California Department of Housing and Community Development Robert Swanson, Deputy Attorney General, Department of Justice—California Attorney General’s Bureau of Environmental Justice Lucas Williams, Partner, Lexington Law Group <
> December 12, 2023 Michelle Zumwalt, Architect Planning and Development Department, City of Fresno 2600 Fresno Street, Room 3065 Fresno, CA 93721 *Sent via Email* **RE: City of Fresno’s Revised Public Review Draft 2023–2031 Housing Element** Dear Ms. Zumwalt: Leadership Counsel for Justice and Accountability (LCJA) writes this comment letter in collaboration with the Public Interest Law Project (PILP) and residents of South Fresno neighborhoods impacted by the severe lack of decent quality, affordable, and permanent housing options, gaping disparities in access to opportunity in Fresno, and continued refusal of the City of Fresno (the City) to meaningfully engage with residents, especially those in disadvantaged communities, and incorporate their priorities into city planning and policies. This comment letter addresses the November 2023 Revised Draft Appendix 1-E: City of Fresno in the Fresno Multi-Jurisdictional 2023–2031 Housing Element (November Draft). LCJA works alongside the most impacted communities to advocate for sound policy and eradicate injustice to secure equal access to opportunity regardless of wealth, race, income, and place. Through community organizing, research, communications, legal representation, and policy advocacy, LCJA influences land use and transportation planning, shifts public investment priorities, guides environmental policy, and promotes the provision of basic infrastructure and services. PILP works statewide to support local legal programs that address issues involving housing, land use, public benefits and homelessness. PILP has been providing substantive training, litigation support, and technical assistance in these areas for over twenty-five years. The following recommendations are based on our experience to push for transformative community-led and identified solutions to elevate and advance their priorities for safe, affordable housing options and fair housing choices. The Housing Element is an important piece of planning our communities and solving our housing crisis together. Further, the State of California has recently strengthened the laws governing the Housing Element. With laws such as A.B. 686 (Santiago, 2018) and A.B. 1397 (Low, 2017), we expect this Housing Element to be robust, --- LCJA: 2210 San Joaquin Street, Fresno, CA 93721 | (559) 369-2790 PILP: 449 15th Street, Suite 301, Oakland, CA 94612 | (510) 891-9794 meaningful, and indicative of solving our housing crisis. As always, we are willing to partner and work alongside the City to ensure that these requirements are fulfilled and even exceeded in order to create the change we want to see in the San Joaquin Valley. Our comments below highlight further steps and actions the City must take to meet state Housing Element Law, Affirmatively Furthering Fair Housing (AFFH) law, and state and federal civil rights law requirements. We have also attached previous comment letters that we have collaboratively written with other community-based organizations (CBOs) regarding the City’s 6th Cycle Housing Element (2023–2031) identified as Attachments A,[^p607-1] B,[^p607-2] and C.[^p607-3] While the November Draft does include some revisions that address certain comments in our previous letters, many issues we and community members previously raised remain unaddressed. In short, the November Draft fails to meet Fresno’s housing needs and relevant state statutory requirements in several different ways and the City must undertake the following: * **Meaningful Public Participation** * Conduct meaningful and varied community engagement, targeted outreach and consideration of the unique communities and populations served, especially communities with protected characteristics, before the final adoption of the Housing Element. *See Gov’t Code § 65583(c)(9); AFFIRMATIVELY FURTHERING FAIR HOUSING: GUIDANCE FOR ALL PUB. ENTITIES & FOR HOUSING ELEMENTS, CAL. DEP'T OF HOUSING & CMTY. DEV'T 18 (2021) [hereinafter HCD AFFH Guidance].* * Provide for meaningful ongoing public participation and incorporation of community priorities to facilitate implementation of housing-related policies throughout the 6th Cycle planning period. *See Gov’t Code § 65583(c)(9); HCD AFFH Guidance at 18.* * **Adequate Incorporation of Public Comments** * Summarize all comments received—this includes information gathered in stakeholder consultations, study sessions, community workshops, the community survey, any public comments and comment letters received during city council meetings and received via email. *See HCD AFFH Guidance at 22.* * Discuss the process the City used to prioritize the housing issues raised across all comments. *See id.* [^p607-1]: Comment Letter from Leadership Couns. for Just. & Accountability et al. to the Fresno Cnty. Bd. of Supervisors, the Cities of Fresno Cnty. City Councils, & Deputy Dir. Kristine Cai of the Fresno Council of Gov'ts (Oct. 3, 2022) (on file with author) [hereinafter Attachment A]. [^p607-2]: Comment Letter from Leadership Couns. for Just. & Accountability et al. to Mayor Jerry Dyer, Fresno City Councilmembers, & Michelle Zumwalt (Aug. 16, 2023) (on file with author) [hereinafter Attachment B]. [^p607-3]: Comment Letter from Pub. Int. L. Project & Leadership Couns. for Just. & Accountability to Mayor Jerry Dyer, Fresno City Councilmembers, & Michelle Zumwalt (Aug. 16, 2023) (on file with author) [hereinafter Attachment C]. o Explain how the prioritized housing issues were incorporated into the Housing Element and acknowledge the housing issues raised in public comments that were not incorporated into the Housing Element and why. *See id.* * **Analyze and Prioritize Constraints and Contributing Factors to Fair Housing Issues** o Analyze and prioritize governmental constraints on developing affordable housing. *See Gov’t Code § 65583(c)(3); HCD AFFH Guidance at 52.* Ultimately, an analysis should be thought of as a detailed and critical questioning of anything complex in order to understand its nature, determine its features, and assess its progress or fitness. *See discussion on the definition of the word analysis infra note 9.* Specific analyses include, but are not limited to: ■ Impacts of current and planned zoning regulations. ■ Risks to publicly assisted affordable housing and distribution. ■ Impacts of the lack of tenant protections on the maintenance of housing. ■ Impacts of the implementation and enforcement of the building code. ■ Delays or restrictions in development resulting from required onsite/offsite improvement standards. o Analyze, *see discussion on the definition of analysis infra note 9*, and prioritize nongovernmental constraints that delay developing affordable housing. *See Gov’t Code § 65583(c)(3).* Specific analyses include, but are not limited to: ■ Impacts of NIMBYs. ■ Risks of climate change, extreme weather, pollution, water instability, infrastructure development and other environmental constraints. ■ Effects of market forces and availability of financing. ■ Significance of land and construction costs. o Analyze, identify, and prioritize all fair housing issues and contributing factors—considering community input, the Local Assessment of Fair Housing (AFH), and the sites inventory—especially considering the addition of data in the November Draft providing evidence of more housing issues but a failure to identify any new contributing factors. *See HCD AFFH Guidance at 25.* o Justify the implementation programs with meeting the needs addressing the contributing factors to fair housing issues—this means linking the contributing factors to policy and meaningful actions. Gov’t Code § 65583(c)(10)(A)(iv); *see* HCD AFFH Guidance at 12. o Analyze how 5th Cycle Housing Element programs have continued segregation and not adequately facilitated integration, healthy communities, and access to opportunity. Gov’t Code § 65583(c)(10)(A)(iii); *see* HCD AFFH Guidance at 46. * **Adequate Sites and AFFH Compliance** o Analyze the viability of non-vacant sites and large sites. *See Gov’t Code* *§§ 65583(c)(1); 65583.2; HCD AFFH Guidance at 12.* o Provide evidence of approval during the projection period credited against the Regional Housing Needs Assessment (RHNA). *See Gov’t Code § 65583(c)(1).* ○ Analyze environmental constraints on the overall availability of inventory sites. *See Gov’t Code § 65583(5).* * **Adequate Implementation Programs** ○ Add needed implementation programs that are reflective of community priorities—this includes priorities from a recent LCJA Community Meeting on December 5, 2023, previous comment letters, and public hearings and workshops. *See Gov’t Code, § 8890.50(a)(1), (b), (d); Gov’t Code § 65583(c).* ○ Revise implementation programs which are noncompliant with the Housing Element and AFFH laws regarding specific, concrete, enforceable actions with measurable outcomes, milestones, and timelines. *See Gov’t Code, § 8890.50(a)(1), (b), (d); Gov’t Code § 65583(c).* ○ Strengthen implementation programs to better constitute meaningful actions. *See Gov’t Code, § 8890.50(a)(1), (b), (d); Gov’t Code § 65583(c).* **I. The City Fails to Facilitate Meaningful Public Participation Infrastructure in Its Housing Element Practices to Promote Sustainable Community Involvement.** The preparation, adoption, and implementation of a housing element requires a diligent effort to include all economic segments of the community. Gov’t Code § 65583(c)(9). The element must describe meaningful, frequent, and ongoing community participation, consultation, and coordination that is integrated with the broader stakeholder outreach and community participation process for the overall housing element. Gov’t Code § 65583(c)(9)–(10); Gov’t Code § 8899.50(a)–(c). The City must proactively reach out to individuals and organizations that represent lower income households, people in protected classes, and households with special needs to develop open and mutual communication. HCD AFFH Guidance at 18. The City’s November Draft does not demonstrate compliance with the statutory public participation requirements. A short outline of these issues includes: * A failure to demonstrate meaningful and varied community engagement and effective meetings. * A lack of effective targeted outreach and consideration of the unique communities and populations served. * A lack of regard for ongoing public participation and consideration of residents’ housing issue priorities. As the CBO October 2022 Comment Letter highlighted, the City’s public participation efforts should proactively and broadly be conducted through various methods[^p609-4] to ensure access and [^p609-4]: The California Housing and Community Development Department (HCD) provides guidance on approaches to public participation, including the following: Be proactive in reaching out to the community. Visit neighborhoods and participate in local events. Establish an ongoing housing-element update and implementation committee . . . . Use direct mail, participation (e.g., holding workshops in disadvantaged communities and conducting effective outreach for them; conducting targeted outreach to special needs populations/protected classes; advertising opportunities to participate in and provide feedback on the housing element update in non-English language print media, radio, and television, including media in Spanish, Hmong, and other languages spoken by Fresno residents). *See* Attachment A at 2–4. Successful public participation is important because a diverse cross section of the population can be engaged in defining the housing problem and in crafting solutions that work for everyone in the community.[^p610-5] ## A. The Housing Element is Not Informed by Meaningful or Varied Engagement The City lacks the ability to “maintain integrity” with the community by failing to “conduct effective meetings and establish rapport early” and by treating public participation requirements as an opportunity to “rubber stamp’ a predetermined objective or policy.[^p610-6] While the City did conduct a series of community workshops[^p610-7] after its release of the July Draft, there is no evidence that this public engagement was meaningful for the community or provided an avenue to translate any of their priorities into concrete actions. The City did collect a lot of information, noting that these workshops provided almost two hundred comments,[^p610-8] but there seems to be no analysis (defined by Merriam-Webster’s Dictionary as “a detailed examination of anything complex in order to understand its nature or to determine its essential features : a thorough study”),[^p610-9] discussion, or even radio ads, and local print or electronic media (such as neighborhood newsletters) to communicate opportunities to engage in the housing-element process. Always consider the composition of your target audience and use communication tools that are language-appropriate, culturally sensitive, and grade-level readability. Use creative methods to communicate the importance of all stages of the housing-element process. Use attractive direct-mail brochures and surveys to capture information. Consider mobile resources . . . . Consider having barbeques or set up information displays at community events to enhance interaction with the public. Public Participation, CAL. DEP’T OF HOUSING & CMTY. DEV.: BLDG. BLOCKS: A COMPREHENSIVE HOUSING-ELEMENT GUIDE, https://www.hcd.ca.gov/planning-and-community-development/housing-elements/building-blocks/public-participation (last visited on Dec. 7, 2023). [^p610-5]: Public Participation, supra note 4; see also Affirmatively Furthering Fair Housing, 80 Fed. Reg. 42272, 42293–94 (July 16, 2015) [hereinafter HUD’s AFFH Rule] (describing how all localities “shall ensure that all aspects of community participation are conducted in accordance with fair housing and civil rights laws” and that “community participation processes must consider the populations served, and where they are located, and they must choose public participation approaches that will reach the populations served”). [^p610-6]: Public Participation, supra note 4. [^p610-7]: The City conducted six community workshops between July 20 and August 9, 2023. See November Draft at 1E-i, 1E-6-2, 1E-6-3. [^p610-8]: Id. at 1E-6-14. [^p610-9]: It is important to note that an analysis is not a mere summary or description. It involves questioning a topic in more detail. Ultimately, an analysis should be thought of as a detailed and critical questioning of anything complex in order to understand its nature, determine its features, and assess its progress or fitness. Merriam-Webster’s Dictionary definition of analysis is: “a detailed examination of anything complex in order to understand its nature or to determine its essential features : a thorough study.” Analysis, MERRIAM-WEBSTER: MERRIAM-WEBSTER.COM DICTIONARY, https://www.merriam- acknowledgment of the importance of this feedback, following up with residents, or any effort to show that the City took the comments seriously and incorporated them into the November Draft.[^p611-10] Community participation “means a solicitation of views and recommendations from members of the community and other interested parties, a consideration of the views and recommendations received, and a process for incorporating such views and recommendations into decisions and outcomes.” HCD AFFH Guidance at 64. Not communicating with the community about what happened to their feedback, where you are in the process and what final decisions are made can easily break the trust you are working to build through a robust community engagement process.[^p611-11] Additionally, the City provided limited direct engagement methods: community workshops and sending out a community survey.[^p611-12] The main source of direct engagement with residents was workshops and this does not constitute varied or creative methods to engage the community.[^p611-13] Community members need to be engaged through a variety of forms so that residents who have less capacity to attend traditional meetings or are not as civic-minded have a chance to make their voices heard.[^p611-14] We recommend focusing on building rapport and trust in the community, providing other forms of engagement outside of community meetings (e.g., guided tours of housing developments/sites, mobile sources, and attending community events), following up with residents after this engagement, and creating safe and accommodating spaces for community-focused public meetings. The City should engage in more public engagement before its January 31, 2024 deadline for its adopted 6th Cycle Housing Element in order to be compliant with the statutory mandates under Government Code section 8890.50(a)(1), (b) and (d) and Government Code section 65583(c)(9). This engagement must be varied and meaningful. We recommend focusing on building rapport and trust in the community, providing other forms of engagement outside of community meetings (e.g., webster.com/dictionary/analysis (last visited Dec. 10, 2023). For further clarification, the word examine is defined as: “to inspect closely . . . to test by questioning in order to determine progress, fitness, or knowledge.” Examine, MERRIAM-WEBSTER: MERRIAM-WEBSTER.COM DICTIONARY, https://www.merriam-webster.com/dictionary/examine (last visited Dec. 10, 2023). And finally, the word inspect is defined as: “to view closely in critical appraisal : look over.” Inspect, MERRIAM-WEBSTER: MERRIAM-WEBSTER.COM DICTIONARY, https://www.merriam-webster.com/dictionary/inspect (last visited Dec. 10, 2023). [^p611-10]: See Public Participation, supra note 4 (describing how localities should “[f]ollow up after each event. After holding a public forum or activity, establish a procedure to follow up with concrete action to address the community’s concerns. Be sure that all information relevant to the process is made available, either at regular meetings or by posting to a website. This will help to establish and maintain the jurisdiction’s credibility”). [^p611-11]: Id. provides helpful links to additional public participation resources; for one helpful resource, see Pillar 3: Engage, INST. FOR LOC. GOV’T: HOUSING & PUB. ENGAGEMENT TOOLKIT, https://housingtoolkit.ca-ilg.org/post/pillar-3-engage (last visited December 7, 2023). [^p611-12]: November Draft at 1E-6-1. [^p611-13]: See Public Participation, supra note 4 (giving examples of creative engagement methods such as: mobile resources, barbeques, information displays at community events, guided tours of market-rate and affordable developments and sites being considered for housing development, training and education workshops, and computer simulations). [^p611-14]: Pillar 3: Engage, supra note 10. guided tours of housing developments/sites, mobile sources, and attending community events), following up with residents after this engagement, and creating safe and accommodating spaces for community-focused public meetings. We also recommend maximizing the efficiency of meetings by having the Housing Division promote involvement of all appropriate local departments to ensure interdepartmental issues are addressed in a comprehensive and efficient manner.[^p612-15] ### B. The City Failed to Facilitate Targeted and Inclusive Outreach and Meetings. Government Code section 65583(c)(9) requires that the local government shall make “a diligent effort . . . to achieve public participation of all economic segments of the community in the development of the housing element, and the program shall describe this effort.” In addition, the Federal Department of Housing and Urban Development’s (HUD) AFFH 2015 Final Rule—which was “essentially preserve[d] by the passage of California’s A.B. 686, HCD AFFH Guidance at 13—states the importance of localities outreach efforts, saying they should “tailor outreach efforts to ensure effectiveness given the populations in their areas . . . that will provide for meaningful actions . . . [Localities] should employ communications methods that are designed to reach the broadest audience, and that are conducted in accordance with fair housing and civil rights laws, including Title VI of the Civil Rights Act of 1964.” HCD AFFH Guidance at 16; 80 Fed. Reg. at 42295. The City has failed to demonstrate adequate outreach and meetings inclusive of all sectors of the population. For the July/August community meetings, the City states its only outreach conducted was that city staff sent out four citywide email blasts and four social media posts. November Draft at 1E-6-13. The City provides no information on the adequacy of the outreach to all sectors of the community, providing no explanation regarding the demographics of their followers and subscribers or explanation what languages the information was presented in. This is problematic considering the demographic statistics: 28.3 percent of people, approximately 245,209 individuals, in Fresno County have limited-English speaking proficiency[^p612-16] and 15.9 percent of households, approximately 28,000 households, lack access to internet in the City of Fresno,[^p612-17] with these realities disproportionately affecting low-income neighborhoods and communities of color. Furthermore, the City appears to not have offered translation services at the July/August meetings and did not indicate having provided materials at the meetings in multiple languages. November Draft at 1E-6-13 to 1E-6-16. These same issues—lack of adequate outreach, translation services at [^p612-15]: *Public Participation*, supra note 4 (“For example, the public works department may be able to provide information about infrastructure issues, and the codes department may have information about the condition of the housing stock.”). [^p612-16]: FRESNO CNTY. RURAL TRANSIT AGENCY, FRESNO CNTY. RURAL TRANSIT AGENCY’S TITLE VI PROGRAM: UPDATE 2023–2026, at 29 (2023), https://www.ruraltransit.org/wp-content/uploads/2023/07/FCRTA-Title-VI-2023-Final.pdf. [^p612-17]: Annalisa Perea, *Fresno Councilmember Seeks to Close the Digital Divide With More Internet* | Opinion, FRESNO BEE (July 25, 2023, 11:02 AM), https://www.fresnobee.com/article277638528.html#storylink=cpy. meetings, and multilingual presentation materials—seemed absent at the City’s Events #2-10: Community and Stakeholder Meetings (October/November 2022) and Events #11-15: Community Workshops (February/March 2023) as well: The City provided no information or discussion on the availability of these facets in relation to these meetings. See November Draft at 1E-6-8 to 1E-6-13. This all stands in stark contrast to the detailed information regarding outreach and language accessibility related to Event #1: Community Workshop (August 31, 2022),¹⁸ in which outreach was described as varied, targeted, and multilingual, the meeting provided translation services and multilingual materials, and the meeting had refreshments and activities for kids. See November Draft at 1E-6-3. Thus, the Housing Element indicates that the City engaged in targeted, varied, multilingual outreach for Event #1 and nothing else for the remaining fourteen events. Such meaningful outreach efforts must be continuous throughout the Housing Element process: One meeting reflective of appropriate community engagement standards at the outset of the Housing Element’s development is inadequate and constitutes noncompliance with state law. The City should engage in more public engagement before its January 31, 2024 deadline for its adopted 6th Cycle Housing Element in order to be compliant with the statutory mandates under Government Code section 8890.50(a)(1), (b) and (d) and Government Code section 65583(c)(9). The engagement must reflect that the City was diligent in its efforts to conduct outreach.¹⁹ We recommend utilizing more methods that will reach disadvantaged communities such as direct mail, radio ads, and local print or electronic media (such as neighborhood newsletters) to communicate opportunities to engage in the housing-element process.²⁰ Another strategy is to specifically target disadvantaged and special needs groups,²¹ many of which are identified in our previous comments. See Attachment A at 2-3. The City must always consider the composition of its target audience and [^p613-18]: The City notified the community of this meeting with flyers distributed in English, Spanish, Hmong and Punjabi through the Fresno Council of Governments (FCOG) listserv of regional stakeholders and community-based organizations (CBOs), and through the Fresno Housing Authority. November Draft at 1E-6-3. Linguistica interpreters were available for Spanish, Hmong, and Punjabi monolingual speakers. *Id.* Materials in Spanish, Hmong and Punjabi were available in-person at the workshop and online at the project website, accessible via QR code. *Id.* An Eventbrite registration page and Facebook event was created advertising that Spanish, Hmong, and Punjabi language interpretation would be provided, along with refreshments, and activities for kids. *Id.* Flyers were sent out through the Fresno Housing Authority to affordable housing residents. *Id.* City staff distributed the event to the email lists that they maintain for General Plan updates and the Anti-Displacement Task Force. *Id.* Fresno City Community Affairs Representatives distributed the event to Hmong and Punjabi speaking communities. *Id.* [^p613-19]: See HCD AFFH Guidance at 22 (“Outreach activities intended to reach a broad audience, such as utilizing a variety of methods, broad and proactive marketing, including targeted areas and needs, promoting language access and accessibility for persons with disabilities (which can include effective communication, reasonable accommodations, and remote participation opportunities), and consulting with relevant organizations.”). [^p613-20]: *Public Participation*, supra note 4. [^p613-21]: *Id.* (listing the following as special needs and disadvantaged groups: “tenants in units at risk of conversion to market-rate, health- and human-service providers, homeless-shelter and mental-health service providers, places of worship, seniors, farmworkers, and non- and for-profit affordable housing developers”). use communication tools that are language-appropriate, culturally sensitive, and grade-level readability.[^p614-22] The City must also revise the outreach section of its November Draft to “clearly describe efforts to engage the community throughout the housing element process (e.g., types of outreach, meetings)” related to its outreach methods and adequacy of translation and multilingual services for Community Meetings #2–15.[^p614-23] The November Draft must describe who was invited to participate, how they were invited to participate, which groups actually participated, and how the engagement provided an inclusive and accommodating environment for all sectors of the community to participate.[^p614-24] Finally, the City should anticipate all logistical concerns and address them, including: language barriers, transportation, meeting times, and child care.[^p614-25] Additionally, the City must revise the November Draft to include an explanation of why there was a lack of participation, particularly from disadvantaged groups, in its public participation process. The HCD AFFH Guidance states: “The element must describe . . . [a] [s]ummary of issues that contributed to lack of participation in the housing element process by all economic segments, particularly people with protected characteristics, if that proves to be the case.” HCD AFFH Guidance at 22. We recommend the City acknowledge its lack of inclusive, varied, and targeted outreach and engagement for its Community Meetings #2–15 to be in compliance with the guidance. Because the Housing Element “was developed without the required community participation or the required consultation,” HCD must find the City of Fresno’s Housing Element is “substantially incomplete.” See 80 Fed. Reg. at 42358. ## II. The City Fails to Summarize Public Comments Received and How Those Comments Were Considered and Incorporated Into the Housing Element. The Housing Element must “describe and incorporate meaningful engagement that represents all segments of the community into the development of the housing element, including goals and actions.” HCD AFFH Guidance at 21, 62. The City’s obligations to diligently engage all economic segments of the community and to AFFH through the housing element require more than just seeking input about the contents of the housing element. Gov’t Code § 65583(c)(9); Gov’t Code § 8899.50(a)(1), (b), (d). As discussed in our previous comment letters, inviting residents to provide input but failing to incorporate that input into the housing element undermines the purpose of resident participation in the housing element update, fosters distrust, and fails to constitute “engagement” as required by Government Code section 65583(c)(9) of the Housing Element Law. Attachment A at 4, 6; Attachment B at 1; Attachment C at 2–3, 13. In short, the City must: [^p614-22]: Id. [^p614-23]: Public Participation, supra note 4. [^p614-24]: Id. [^p614-25]: Id. ● Summarize all comments received—this includes information gathered in stakeholder consultations and focus groups, study sessions with planning commissions, city councils, and the County Board of Supervisors, community workshops, the community survey, any public comments received during city council meetings related to the Housing Element, and all comments and comment letters received via email. ● Discuss the process the City used to prioritize the housing issues raised across all comments. ● Explain how the prioritized housing issues were incorporated into the Housing Element. ● Acknowledge the housing issues raised in public comments that were not incorporated into the Housing Element and why. The HCD AFFH Guidance explains how housing elements must describe “a summary of [public] comments and how the comments are considered and incorporated (including comments that were not incorporated), particularly with changes to the housing element.” HCD AFFH Guidance at 22; see 80 Fed. Reg. at 42315, 42356, 42361–62, 42364. The November Draft fails to comply with the statutory and regulatory requirements regarding the summary of comments and reasons they were or were not incorporated. As happened with the July Draft, the November Draft provides some description of public input provided, its summary of public comments generally lacks sufficient detail for the reader to understand the nature of the issue raised or the solution proposed. See Attachment C at 2–3. The City fails to explain how it prioritized the housing issues raised in comments during the workshops, public comments received via email, and comment letters submitted by CBOs, including LCJA and PILP’s multiple comment letters. In addition, the November Draft, like the July Draft, fails to demonstrate the City’s incorporation of input provided and to identify input the City chose not to incorporate as required. See Attachment C at 2–3. Thus, the City’s summary of comments—including comments from workshops, the survey, focus groups, comment letters, and comments received via email—explanation for prioritization of housing issues, explanation of how the comments were incorporated into the November Draft,[^p615-26] and “summary of any comments, views, or recommendations not accepted by the [City] and the reasons for nonacceptance” is grossly inadequate and must be revised. HCD AFFH Guidance at 22; see 80 Fed. Reg. at 42356. We recommend the City adhere to the statutory and regulatory requirements regarding the full summary of all comments received and explanation of incorporation (and lack of incorporation) of those comments. [^p615-26]: The City is expected to “[d]escribe the dates that the housing element and subsequent revisions were made available for public comment and how those comments were incorporated.” *Public Participation, supra* note 4. III. The City Fails to Analyze and Prioritize Constraints and Contributing Factors—Including Ways the City’s 5th Cycle Housing Element’s Implementation Programs Fell Short—That Limit or Deny Fair Housing Choice/Access to Opportunity and Negatively Impact Civil Rights. A. The City Fails to Analyze Governmental and Nongovernmental Constraints Housing Element law requires an analysis of potential and actual governmental and nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels including land-use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures.” Gov’t Code § 65583(a)(5)–(6); see HCD AFFH Guidance at 55; 80 Fed. Reg. at 42275, 42279. While the City did address our previous comment letter’s concerns regarding the parking requirements constraint analysis, Attachment C at 6–7, the November Draft fails to address the remaining constraints analysis issues from our comment letter and remains substantially out of compliance with the statutory and regulatory requirements regarding constraints analysis, justification, and creation of a program to remove those constraints. Gov’t Code § 65583(a), (a)(5)–(6), (c)(3); HCD AFFH Guidance at 52; see also discussion on the requirement for a program to remove constraints infra Section V. The November Draft only made nine changes to the entirety of the constraints analysis. While the constraints section does adequately list laws, ordinances, and conditions, it lacks sufficient analysis (see discussion on the definition of the word analysis supra note 9) how these components could delay, prevent, or negatively affect the maintenance, improvement, or development of housing for all income levels. Any analysis given concludes that the constraints are limited or nonexistent. Listing constraints without analysis, however, will not result in meaningful action. The following references our previous comments that went unaddressed by the City in the November Draft: * The Housing Element under analyzes the impacts of current and planned zoning regulations[^p616-27] on housing development. Attachment C at 4–5; see Martinez v. City of Clovis, 90 Cal.App.5th 193, 271 (2023); HCD AFFH Guidance at 55; 80 Fed. Reg. at 42310. [^p616-27]: It should be noted that courts have found civil rights violations regarding zoning ordinances with discriminatory effects. Martinez v. City of Clovis, 90 Cal.App.5th 193, 271 (2023) (holding a City defendant’s zoning ordinance violated the FEHA and the FHA by having a discriminatory effect—which includes a disparate impact and a segregative effect on protected classes—when housing opportunities were made unavailable for protected classes); see 80 Fed. Reg. at 42310 (“Zoning and land use laws that are barriers to fair housing choice and access to opportunity can be quite varied and often depend on the factual circumstances in specific cases, including zoning and land use laws that were intended to limit affordable housing in certain areas in order to restrict access by low-income minorities or persons with disabilities.”). * The constraint analysis must examine what constraints exist to the development of: supportive housing, transitional housing, single-room occupancy units, and emergency shelters. Attachment C at 5–6; *see* Gov’t Code § 65583(c)(1). * The Draft’s analysis of at-risk housing is incomplete and under-analyzes the risks to publicly assisted housing and its distribution. Attachment C at 7. * The City’s lack of tenant protections should be analyzed as a constraint on the maintenance of housing under Government Code section 65583(a)(5). Attachment C at 7. * The City lacks analysis on nongovernmental constraints: * The Draft must include an analysis of Not-In-My-Backyard (NIMBY)[^p617-28] and other local opposition to affordable housing and housing development. Attachment C at 8; *see* HCD AFFH Guidance at 55. * The Draft did not consider environmental constraints as part of its analysis under Government Code section 65583(a)(6). Environmental constraints may include limitations to water supply, nearby pollution, or infrastructure development. Attachment C at 8–9. * The Draft failed to include an explanation of the effects of market forces and availability of financing.[^p617-29] Attachment C at 9. Upon further review, we find additional places in the constraints analysis that are missing the requisite and required components as put forth by HCD: * Describe how the building code is implemented and whether the process optimizes predictability for developers.[^p617-30] * Identify and analyze any local amendments to the state housing law or building code.[^p617-31] * Discuss the type and degree of building code enforcement.[^p617-32] * Describe any efforts to link code enforcement activities to housing rehabilitation programs.[^p617-33] [^p617-28]: Just this month, in December 2023, “[e]ven at the threatened loss of future state money, the Fresno City Council . . . sided with neighbors who said a hotel conversion near Fresno and Bullard avenues is the wrong place for affordable housing. Edward Smith, *Fresno Council Votes Down Affordable Housing Project in North Fresno*, GV WIRE (Dec. 8, 2023), https://gvwire.com/2023/12/08/fresno-council-votes-down-affordable-housing-project-in-north-fresno/. “Opposing councilmembers cited cost concerns and the view that affordable housing would bring blight to the area . . . Advocates for the project, however, accused the detractors of NIMBYism (not-in-my-backyard).” Id. [^p617-29]: See HCD AFFH Guidance at 53; 80 Fed. Reg. at 42346 (“A basic tenet of planning and performance management is recognition of ‘external factors’ and other barriers to achieving goals, and which are beyond an organization to control . . . Included in such considerations is the identification of funding dependencies and contingencies.”). [^p617-30]: *Codes and Enforcement of Onsite/Offsite Improvement Standards*, CAL. DEP’T OF HOUSING & CMTY. DEV.: BLDG. BLOCKS: A COMPREHENSIVE HOUSING-ELEMENT GUIDE, https://www.hcd.ca.gov/planning-and-community- development/housing-elements/building-blocks/codes-and-enforcement-and-onsite-offsite-improvement-standards (last visited Dec. 10, 2023) [hereinafter Improvement Standards]. [^p617-31]: Id. [^p617-32]: Id. [^p617-33]: Id. * Identify and analyze improvements to street widths, curbs, gutters, sidewalks, water and sewer connections, landscaping, circulation improvement, and any other onsite/offsite improvement required by the jurisdiction that could potentially be a constraint to development of housing. In addition, the housing element must describe any generally applicable level of service standards or mitigation thresholds.[^p618-34] * Discuss the following nongovernmental constraints:[^p618-35] * Land costs — Estimate the average cost or the range of costs per acre for single-family and multifamily-zoned developable parcels. * Construction costs — Generally estimate typical total construction costs, including materials and labor. * Availability of financing — Consider whether housing financing, including private financing and government assistance programs, is generally available in the community. This analysis could indicate whether mortgage deficient areas or underserved groups exist in the community. The financing analysis may also identify the availability of financing from private foundations (including bank foundations) corporate sponsors, community foundations, community banks, insurance companies, pension funds, and/or local housing trust funds. Thus, the City is still under-analyzing or omitting required governmental and nongovernmental constraints analyses under Government Code section 65583(a)(5)–(6). Therefore, we recommend the City revise all subsections of its governmental constraints analysis in the November Draft as well as add the entirely missing nongovernmental constraints subsections of analysis. ### B. The Housing Element Lacks Adequate Analysis, Prioritization, and Justification of Its Identified Contributing Factors and Evidence of Correlation to the Implementation Programs. A.B. 686 both creates a broad duty to AFFH in policies and practices, Gov’t Code § 8899.50(a)(1), (b), as well as advances a Housing Element framework of AFFH which requires linking fair housing issues analysis with policy and action formulation. Gov’t Code § 65583(c)(10)(a)(iii). As we mentioned in our previous comment letter, the City is required to identify and prioritize contributing factors to fair housing issues based on all the previously required analysis (outreach, fair housing assessment, site inventory). Attachment A at 6; Gov’t Code § 65583(c)(10)(a)(iii); *see* HCD AFFH Guidance at 12; 80 Fed. Reg. at 42279–80. This identification and prioritization must give highest priority to factors that limit or deny fair housing choice or access to opportunity or negatively impact fair housing or civil rights. HCD AFFH Guidance at 12. The November Draft is not in compliance with Government Code sections 8899.50(a)(1), (b) and 65583(c)(10)(a)(iii) [^p618-34]: Improvement Standards, supra note 30. [^p618-35]: Non-Governmental Constraints, CAL. DEP'T OF HOUSING & CMTY. DEV.: BLDG. BLOCKS: A COMPREHENSIVE HOUSING-ELEMENT GUIDE, https://www.hcd.ca.gov/planning-and-community-development/housing-elements/building-blocks/non-governmental-constraints (last visited Dec. 10, 2023). related to AFFH as its contributing factors are under-analyzed, not prioritized according to community priorities and local knowledge,[^p619-36] and not described in any way to show justification for linking the contributing factors to the implementation programs.[^p619-37] HCD has made clear the requirements regarding identification, prioritization, and justification of contributing factors as they relate to implementation programs: Contributing factors should be based on all the prior efforts and analyses: outreach, assessment of fair housing, and site inventory. Contributing factors must also be prioritized in terms of needed impact on fair housing choice and strongly connect to goals and actions. The identification and evaluation of contributing factors must: Identify fair housing issues and significant contributing factors; [p]rioritize contributing factors, including any local information and knowledge, giving highest priority to those factors that most limit or deny fair housing choice or access to opportunity or negatively impact fair housing or civil rights compliance; and [d]iscuss strategic approaches to inform and strongly connect to goals and actions. HCD AFFH Guidance at 49. While the City’s November Draft has myriad revisions regarding data, statistics, maps, tables, and diagrams within its AFH,[^p619-38] it has failed to comply with its required statutory and regulatory requirements involving contributing factors. The following shows the components of the AFH and [^p619-36]: The Housing Element is informed by communities and residents of these communities will have the opportunity to weigh in on whether jurisdictions have accurately identified contributing factors and have established programs appropriate for identified contributing factors and related fair housing issues. *See* HCD AFFH Guidance at 49; 80 Fed. Reg. at 42288. [^p619-37]: The Housing Element must create programs for overcoming the effect of contributing factors as prioritized. *See* HCD AFFH Guidance at 49; 80 Fed. Reg. at 42288. For each program, the City must identify one or more contributing factors that the program is designed to address, describe how the program relates to overcoming the identified contributing factor(s) and related fair housing issue(s), and identify metrics and milestones for determining what fair housing results will be achieved. *See* HCD AFFH Guidance at 49; 80 Fed. Reg. at 42288. [^p619-38]: We acknowledge, specifically, that the City responded to our previous comment letters and added the following to its November Draft: (1) a short description related to development trends across income levels in its contributing factors to segregation section, November Draft at 1E-3-30; *see* Attachment C at 9; (2) data related to integration and segregation patterns for racial groups other than Hispanic/Latinos, November Draft at 1E-3-9 to 1E-3-13; *see* Attachment C at 13; (3) description regarding the distribution of low- and high-income households across Fresno, November Draft at 1E-3-14 to 1E-3-18; *see* Attachment C at 13; (4) information about the separate occurrence of overcrowding and cost burden based on race or ethnicity and information about these factors disproportionately impact Fresno residents based on familial status, November Draft at 1E-3-62, 1E-3-63; *see* Attachment C at 14–15; (5) information relating to familial status of unhoused residents, November Draft at 1E-3-70; *see* Attachment C at 15; (6) consideration of the extent to which public and private disinvestment and unequal investment continue to impact low-income neighborhoods, neighborhoods of color, and neighborhoods with a high proportion of tenants and how disinvestment perpetuates or increases displacement risk in these areas, November Draft at 1E-3-85, 1E-3-86; *see* Attachment C at 18–19. its determination and analysis of contributing factors—some identified in our previous comment letters and incorporated by reference herein—that need to be revised in the November Draft: * **Integration and Segregation** * The AFH’s analysis of R/ECAPs and RCAAs fails to address “public participation, past policies, practices, [and] investments” as required. HCD AFFH Guidance at 31; *see* Attachment C at 14. * **Disproportionate Housing Needs** * The AFH does not include any analysis, or even acknowledgement of, housing needs of undocumented immigrants. *See* Attachment C at 3. * The November Draft, while noting a difference between communities of color and predominantly white communities as it relates to overcrowding and cost burden, fails to identify the separate occurrence based on individual race or ethnicity. *See* Attachment C at 14–15. * The November Draft includes no information about the occurrence of substandard housing conditions based on race or ethnicity. *See* Attachment C at 14–15. * The November Draft fails to provide sufficient information about how overcrowding, overpayment, and substandard housing conditions disproportionately impact Fresno residents based on familial status[^p620-39] and disability. *See* Attachment C at 14–15. * The analysis does not adequately reflect local knowledge or public input. *See* Attachment A at 6. * **Displacement Risk** * The AFH’s displacement risk analysis must be supplemented with and revised based on more recent data—the data used is from 2012–2017; the City should use data at least from 2019 and later, with preference for more recent data. *See* Attachment C at 16. * Must identify and evaluate the expiration of affordability covenants attached to Low-Income Housing Tax Credit financed properties during the Planning Period. *See* Attachment C at 16. * Must identify and evaluate the major federal, state, and local investments in public works infrastructure projects in South Fresno neighborhoods. *See* Attachment C at 17. * Consider the impact of speculation associated with High Speed Rail on housing availability, prices, and displacement risk. *See* Attachment C at 17. * Analyze the conversion of housing units to short-term rentals and their impact on housing cost pressures and displacement risk. *See* Attachment C at 17. [^p620-39]: There was one sentence added regarding familial status as it relates to overcrowding: “In addition, there is a greater presence of single-parent households and low levels of labor market engagement.” November Draft at 1E-3-62. * Given the significant stakeholder engagement conducted for the development of the *Here to Stay Report*[^p621-40] the AFH should incorporate and consider relevant information and policy recommendations contained in that report. *See* Attachment C at 18. * Address the adequacy of policies and resources to protect tenants from displacement as a result of eviction, harassment, and substandard housing. *See* Attachment A at 7; Attachment C at 17. * **Disparities in Access to Opportunity** * Analyze inadequate or absent infrastructure to facilitate safe and efficient active transportation.[^p621-41] *See* Attachment A at 5, 9–10; Attachment C at 8, 17, 24, 26, 28. * Analyze inadequate or absent protection from extreme weather, including climate-related weather events that impact walking, biking, and public transportation use. *See* Attachment A at 8; Attachment C at 24, 26, 35. * Analyze the presence of high volumes of traffic, including heavy-duty truck traffic, on roadways used by pedestrians or bicyclists, including in and near areas zoned for industrial land uses and along designated truck routes. *See* Attachment C at 23, 26–28. * Analyze and describe policies, practices, and investments that impact access to a healthy environment for protected groups. While the November Draft adds some data related to this, it lacks sufficient analysis (see discussion on the definition of the word analysis *supra* note 9). *See* Attachment C at 24–28. * Secondarily, the November Draft mentions that an Environmental Justice (EJ) Element will be completed by the City. This statement, however, is not sufficient to find compliance with this requirement; the City would need to have the EJ Element already completed and be able to use specific citations to the compliant EJ Element to show the City has adequately considered EJ and access to a healthy environment for disadvantaged communities. *See* HCD AFFH Guidance at 11. * Consider impacts on access to a healthy environment regarding zoning, siting and operation of noxious land uses in disadvantaged communities, and climate change. *See* Attachment A at 8–9; Attachment C at 26–27. * Analyze the basis for pollution disparities impacting the City of Fresno itself, including West Fresno, Jane Addams, and South East Fresno. *See* Attachment C at 27. * Consider how policies, practices, and investments or disinvestments relating to access to green space, tree canopy, and climate resiliency (including adequate cooling [^p621-40]: THRIVANCE GROUP, HERE TO STAY: A POLICY-BASED BLUEPRINT FOR DISPLACEMENT AVOIDANCE IN FRESNO (2021), https://www.transformfresno.com/wp-content/uploads/2021/06/transform-fresno-here-to-stay-report-english.pdf. [^p621-41]: The November Draft does mention this as a concern for students traveling to school but does not analyze this for the public as a whole. November Draft at 1E-3-33. and wildfire smoke protection) impact educational opportunities at schools, especially in low-income neighborhoods. *See* Attachment C at 27. * **Other Relevant Factors and Local Knowledge** * Consider current, planned and past developments, investments, policies, practices, demographic trends, public comments, and other factors to inform the Local Knowledge section—the November Draft added a couple statements related to this, but they are not sufficient. *See* HCD AFFH Guidance at 45. * Consider any other factors impacting socio-economic patterns and segregation relating to accommodating the RHNA—this can include pending or approved plans, other elements of the general plan, relevant portions of the housing element and site inventory analysis (e.g., effectiveness of past programs, suitability of sites, existing uses and impacts of additional development potential, including potential for displacement of residents, businesses and other community amenities and infrastructure capacity). HCD AFFH Guidance at 46. * **Site Compliance with AFFH Duty** * Consider the impacts of integration and segregation on the distribution of Hispanic/Latino households more thoroughly; and consider the impact on relative integration and segregation of other races—as the November Draft does not consider other racial/ethnic communities. November Draft at 1E-3-101 to 1E-3-104; *see* Attachment C at 28. * Acknowledge how the lack of lower-income sites identified in high-resource areas, will perpetuate patterns of RCAAs and R/ECAPs. *See* Attachment C at 28. * Analyze the impact of site locations on access to specific forms of access to opportunity. *See* Attachment C at 28. * Analyze the impacts on access to a healthy environment of siting housing in low-income neighborhoods with poor environmental health indicators, industrial zoning near homes, heavy traffic, and major highways. *See* Attachment C at 28. * Analysis how absent or incomplete infrastructure, services, and amenities impact access to opportunity on sites included in the inventory. *See* Attachment C at 28. * Include discussion of local knowledge and community input, pending development, development potential and other relevant factors. *See* Attachment C at 29. The AFH is designed to analyze inequities related to fair housing, identify contributing factors to these inequities, prioritize those factors based on public comment and highest need, and create programs that are justified by those prioritized factors. The City is grossly out of compliance with the legal requirements of the AFH due to the following: * A failure in both the July Draft and the November Draft to adequately complete the analyses of fair housing issues in the City of Fresno. * A failure in identifying all contributing factors[^p623-42] to the fair housing issues in the City of Fresno—in fact, the City continues to egregiously fail in this regard with the addition of data and information in the November Draft that provides evidence of more housing issues but a failure to identify any new contributing factors. * A failure to prioritize, and explain its prioritization process, contributing factors based on community input, the AFH, and the sites inventory. * A failure to adequately justify—linking the contributing factors to policy and meaningful actions—the implementation programs with meeting the needs addressing the contributing factors to fair housing issues. We recommend substantial revisions to the AFH if the City wishes HCD to find its Housing Element compliant with state law. HCD will not accept an AFH if it finds that the AFH or a portion of the AFH is inconsistent with fair housing or civil rights requirements or is substantially incomplete. For example, an AFH will be found inconsistent with fair housing and civil rights requirements if it does not identify policies or practices as fair housing contributing factors,[^p623-43] even though they result in the exclusion of a protected class from areas of opportunity. Compliance with Housing Element law is listing contributing factors *with robust analysis* so jurisdictions can create programs with meaningful actions. HCD AFFH Guidance at 51. Thus, the November Draft’s noncompliance with the above-mentioned components of the AFH results in the City being in violation of the Housing Element Law, Gov’t Code § 65583 et seq., the Duty to AFFH statute, Gov’t Code § 8899.50, California’s nondiscrimination statute, Gov’t Code § 11135, the Fair Employment and Housing Act, Gov’t Code § 12940 et seq., the Federal Housing Act, 42 U.S.C. § 3601 et seq., and Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000(d) et seq. Therefore, we recommend the City properly analyze all fair housing issues, identify and prioritize contributing factors to those fair housing issues, and justify the programs as addressing the contributing factors and adequately overcoming patterns and practices of segregation and creating areas of opportunity for R/ECAPs. [^p623-42]: See e.g., HCD AFFH Guidance at 68–70 (listing Contributing Factors examples). [^p623-43]: Contributing factors are not limited to public actions. *Id.* at 51. Private actions can also contribute to patterns of segregation, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, and disproportionate housing needs. *Id.* at 51. While public agencies do not directly control private actions or contributing factors beyond a locality’s boundaries, the actions of public agencies can influence private action and have impacts beyond local boundaries. *Id.* at 51. As a result, regardless of whether contributing factors are public or private or local, region, state or federal, the housing element must recognize a broader social and legal obligation to affirmatively further fair housing and still identify and prioritize those contributing factors to commit to commensurate goals and actions. *Id.* at 51. C. The Housing Element’s Analysis of Past Accomplishments and Programs Is Inadequate. The Housing Element requires a review of the previous housing element for progress in implementation, effectiveness of programs in meeting goals, and appropriateness of modifying programs for the current planning period. Localities should make a specific effort to gather input from all segments of the community on the effectiveness of these programs and how to make adjustments moving forward. HCD AFFH Guidance at 22; *see* 80 Fed. Reg. at 42356. The City fails to properly look at its past actions and programs both in the Housing Element Past Accomplishments section as a whole as well as specific analyses in the AFH that require addressing past programs; those specific analyses include failing to address “public participation, past policies, practices, [and] investments” as required in its R/ECAPs and RCAAs AFH analysis. HCD AFFH Guidance at 33; *see* Attachment C at 14. It also fails to inspect the “effectiveness of past programs in achieving the goals of the housing element” as a factor influencing the impacts of the identification of sites to accommodate the RHNA on socioeconomic patterns and segregation. HCD AFFH Guidance at 33; *see* Attachment C at 14. We recommend the City adequately analyze why its past programs have continued segregation and not adequately facilitated integration, healthy communities, and access to opportunity. IV. The City Fails to Demonstrate Site Capacity to Accommodate Its RHNA and Show Its Sites Inventory is Consistent With the Duty to AFFH. While the AFH is robust and the revised draft adds a lot of good information, data, and analysis, it applies very little of it to actions. Programs fail to address the need, sites are inadequate, and constraints aren’t properly removed. Government Code section 65583(a)(3) requires an assessment of the available land that is suitable and available to accommodate the RHNA. Additional information is required for the City’s Revised Draft Element to comply with the statute. In brief, the following is still required: * Analysis demonstrating the viability of non-vacant sites. * Evidence of approval during the projection period credited against the RHNA. * The viability of large sites, especially in light of the concentration of these sites in one area of the City. * The impact of environmental constraints on inventory sites (and proximity to incompatible uses) on the overall availability of inventory sites. Several of these issues were raised in our comment letter regarding the publicly available draft circulated in July 2023 and the November Draft fails to provide the additional necessary analysis highlighted in our comment letter. For instance, the City’s projection period began on June 30, 2023, but numerous projects that we highlighted on page 10 of our August 2023 that have not received approvals since the beginning of the project period and yet are still included in Table 1E-2.3. See *e.g.*, San Joaquin Hotel—submitted entitlement review in December 2022, review not completed; Los Pueblos Apartments—project submission deemed incomplete in 2022, waiting for resubmittal; *see also* Attachment C at 10. None of the projects we highlighted were removed from Table 1E-2.3 despite the fact that they have not received approvals during the projection period. *See* HCD’s Housing Element Sites Inventory Guidebook, available at https://www.hcd.ca.gov/community-development/housing-element/housing-element-memos/docs/sites_inventory_memo_final06102020.pdf. Because many of the zoning designations do not have a minimum density the City provides an alternate method to estimate capacity on sites by looking at projects during a very limited time frame—2018 to 2020. An alternate calculation is permitted but it should evaluate the average capacity for each zone based on a more expansive time period to make sure the calculation accurately reflects the development patterns that a two -year time frame cannot do. *See* Attachment C at 10. Also noted in our August 2023 letter remains the City’s incomplete analysis of non-vacant sites, which relies primarily on describing the existing use and does not consider the other required factors included in Government Code section 65583.2(g). *See* Attachment C at 11. The City also relies on several large sites that are in close proximity to each other to accommodate its RHNA for lower income households. Not only are there obstacle to obtaining the highly competitive funding for affordable housing to build projects of more than two hundred units, as a large site would necessitate, but including so many large sites in close proximity triggers another constraint to receiving funding and certainly creates an impediment to further fair housing if so many units intended to accommodate the lower income housing need are in one concentrated area. *See* Attachment C at 12. Although the City did revise its original draft element to include one example of development on a large site Fancher Creek Town Center. But this does not address the comment we previously raised regarding the concentration of large sites in one area of the City and the resulting concentration of sites to accommodate the lower income RHNA in one section of the City and the inconsistency with the City’s duty to affirmatively further fair housing. The November Draft describes one half of one large parcel as being occupied by two existing retail establishments, yet the Draft then goes on to determine that 60 percent of the site is available for infill housing even though existing uses occupy 50 percent of the site. November Draft at 1E-2-21. The November Draft includes information about sites in close proximity to the airports and the accompanying restrictions on residential density in these zones. The Draft indicates sites will need to be removed from the inventory of available sites based on the Airport Land Use Compatibility Plan (ALUCP) but does not indicate how many sites and the capacity of those sites and whether it will result in a shortfall for any income category. This information is necessary before a final determination about the adequacy of the site inventory can be made. HCD advises that the impact from a wide variety of environmental factors be considered when evaluating the suitability of sites in the land inventory. The November Draft considers sites in the floodplain, near airports, and infrastructure availability but HCD's Sites Inventory Guidebook requires more: “Other characteristics to consider when evaluating the appropriateness of sites include physical features (e.g., size and shape of the site, improvements currently on the site, slope, instability or erosion, or environmental and pollution considerations), location . . . .” HCD's Housing Element Sites Inventory Guidebook at 3. According to Figure 1E–2.2 Sites Inventory, Fresno 2023, there are many higher density and mobile home sites that are proximate to existing heavy industrial uses in South Fresno. To comply with the City's duty to affirmatively further fair housing sites for lower income households should not be identified close to known pollution sources since lower income families and individuals in South Fresno already face higher exposures to air pollution.[^p626-44] ### V. The City Fails to Include Programs—With Definitive Timelines—That Remove Identified Constraints on Affordable Housing Production. Existing federal law requires departments and agencies to administer programs relating to housing in a way that affirmatively furthers fair housing.[^p626-45] These obligations extend to state and local governments that receive funds or contract with the federal government. A.B. 686 extends the obligation to affirmatively further fair housing to all public agencies in the State of California. This affirmative duty is not limited to those agencies with relationships with the federal government and is to be broadly applied throughout agencies at the state and local level. Gov’t Code § 8899.50(a)(2). Now, all public agencies must both (1) administer programs and activities relating to housing and community development in a manner that affirmatively furthers fair housing, and (2) take no action inconsistent with this obligation. Affirmatively furthering fair housing means “taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities.” Gov’t Code § 8899.50(a)(1). These new statutory obligations charge all public agencies with broadly examining their existing and future policies, plans, programs, rules, practices, and related activities and make proactive changes to promote more inclusive communities. Gov’t Code § 8899.50(a)(1)–(2), (b), (c), (d); see HCD AFFH Guidance at 9. [^p626-44]: CalEnviroScreen 4.0, CAL. OFF. OF ENV’T HEALTH HAZARD ASSESSMENT (May 1, 2023), https://oehha.ca.gov/ calenviroscreen/report/calenviroscreen-40. [^p626-45]: See Executive Order 12892 – Leadership and Coordination of Fair Housing in Federal Programs: Affirmatively Furthering Fair Housing. January 17, 1994. In addition, the A.B. 686 updated the Housing Element law to specifically require the creation of programs to promote fair housing. Specifically, Government Code section 65583(c) states that: The [Housing] Element shall contain . . . . A program that sets forth a schedule of actions during the planning period, each with a timeline for implementation, that may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the housing element . . . . Goals and policies must be created with the intention to have a significant impact, well beyond a continuation of past actions, and to provide direction and guidance for meaningful action. HCD AFFH Guidance at 52. The Housing Element’s implementation program must AFFH in accordance with Government Code section 8899.50 and include a diligent effort to achieve public participation of all economic segments of the community in the development of the Housing Element. Gov’t Code § 65583(c)(9), (10)(A). Programs must address various statutorily mandated areas, such as identification of adequate sites, zoning for a variety of types, assisting development for lower and moderate income households, addressing governmental and non-governmental constraints, conserving the existing housing stock, preserving at-risk units, and promoting housing opportunities for all people. HCD AFFH Guidance at 10. Finally, the Housing Element requires identification of metrics or quantified objectives and milestones for determining what fair housing results will be achieved through these programs. HCD AFFH Guidance at 13. Despite previous comment letters and specific identification by the public of prioritized fair housing issues, the November Draft remains noncompliant regarding its adequacy of meaningful actions and adherence to the requirements in creating the implementation programs. We have separated our recommendations into two subsections: (1) Programs that need to be added based on revision of the AFH and adequate identification of fair housing issues, see discussion supra Section III, identified and prioritized contributing factors to the fair housing issues, and direct justification of programs from the identified contributing factors; and (2) Programs included in the November Draft that can be improved. ### A. The City Must Add Needed Implementation Programs to Adequately Address Prioritized Contributing Factors Informed by the Public. The Housing Element requires an identification of priorities and goals based on identified contributing factors that limit or deny fair housing choice or access to opportunity, or that negatively impact fair housing or civil rights compliance. HCD AFFH Guidance at 12. The November Draft, like the July Draft, is grossly inadequate in fulfilling the requirements under Government Code sections 8899.50 and 65583. The following includes the programs best suited to address contributing factors and prioritized community fair housing issues: * **Most Up-To-Date Priorities Identified by City of Fresno Residents at LCJA’s December 5, 2023 Community Meeting:** * Holistic Tenant Protections * Adopt a local rent stabilization ordinance, including a rent stabilization board to hear and approve rental increases submitted by landlords. * Adoption of just cause eviction * A right to counsel guaranteeing access to affordable legal counsel for low-income tenants in housing matters. * Establish a permanent emergency rental assistance program. * Know-Your-Rights education and enforcement for discrimination against pet ownership in rental properties. Currently, California law says: “Landlords are not allowed to outright refuse to rent to tenants based solely on their ownership of pets. However, landlords may impose reasonable restrictions and conditions for pet ownership, such as size or breed restrictions allowing pets, with some exceptions for service animals or emotional support animals.”[46] * More enforcement against landlords and property management companies who discriminate against or harass tenants; including a focus on harassing surveillance of tenants and privacy issues. * Add back in July Draft’s Program 30: Emergency Rental Assistance Program. * Homelessness * Providing housing to unhoused veterans * Build Tiny Home Villages. * Housing Stock * Increase the supply of rental properties that allow pets. * Consider creating tax incentive programs or reward/relief programs for landlords and management companies who allow pets. * Build the housing stock with the majority age demographic, 25 to 44 years (November Draft at 1E-0-1), in mind; build less single-family homes and build more duplexes and triplexes. * **Community Priorities as Referenced in Previous Comment Letters** * Reducing barriers for undocumented immigrants to rent. *See Attachment C at 3.* * Pursue an Inclusionary Zoning ordinance. *See Attachment A at 8.* * Extreme heat and weatherization programs to address climate change. *See Attachment A at 8; Attachment C at 24, 26, 35.* [^p628-46]: See e.g., HCD AFFH Guidance at 72–74 (listing Housing Action Examples). * Establish an acquisition and rehabilitation fund to purchase older, blighted, or abandoned homes/buildings. *See Attachment A at 8.* * Grants for residents who want to develop affordable accessory dwelling units on their land. *See Attachment A at 8.* * Urban Greening as buffer zones for residences zoned near polluting land uses. *See Attachment A at 8.* * Prohibit siting industrial uses next to Housing Element sites used to accommodate the RHNA. *See Attachment A at 8.* * Suitable Vacant Land should be prioritized for affordable housing in order to bring Very Low Income and Low Income RHNA allocations into compliance. *See Attachment A at 9.* * Impact fees should be placed into a community benefit fund when polluting land uses and practices are placed near housing. *See Attachment A at 9.* * Developing Public Health Impact Reports for new development. *See Attachment A at 9.* * Establish a Cargo/Freight Prohibition and Revenue Tax. *See Attachment A at 9.* * Incorporate Complete Streets principles into all transportation projects at all phases of development. *See Attachment A at 9.* * Establish a Housing Element Implementation Committee to oversee[^p629-47] the timelines and implementation of each program and policy. The committee should be comprised primarily by tenants, low-income homeowners, and at-risk populations to ensure implementation meets the needs of most at-risk communities. *See Attachment A at 9.* ### B. The November Draft Must Revise Implementation Programs Which Are Noncompliant and Should Strengthen Programs Which Could Better AFFH. The November Draft, like the July Draft, is noncompliant under Government Code sections 8899.50 and 65583 regarding some of its implementation programs. We also wanted to identify programs that could be strengthened to better accomplish residents’ priorities and better move toward overcoming segregation and creating areas of opportunity for R/ECAPs. We do not have any new recommendations for the November Draft’s Programs 2, 17, 19, 22, 23, 27, 29, and 32 beyond the recommendations in our previous comment letters; please reference Attachment B and Attachment C for those comments as well as additional comments on the Programs we do address below. The following includes the programs with the recommended changes to policy, goals, and [^p629-47]: The plan must describe the standards and procedures that the jurisdiction will use to monitor activities carried out in furtherance of the plan, including strategies and actions that address the fair housing issues and goals identified in the AFH, and that the jurisdiction will use to ensure long-term compliance with requirements of the programs involved, including civil rights related program requirements, minority business outreach, and the comprehensive planning requirements. *See 80 Fed. Reg. at 42365.* concrete steps best suited to address compliance, contributing factors, and prioritized community fair housing issues: * **Missing Required Programs** * **Addressing Governmental and Nongovernmental Constraints** * As the AFH did not fully identify and analyze governmental and nongovernmental constraints and concluded that the few identified constraints were either not significant or were being addressed, the Action Plan did not include a program(s) to remove them. The November Draft does not adequately meet the requirements of Government Code section 65583(c)(3) to address and remove constraints. * Program 25 provides some limited development code amendments to remove barriers to housing development, but these are a far cry from addressing and removing the myriad constraints to affordable housing development. * Consider adding a program(s) relating to the identified governmental and nongovernmental constraints identified in Section III.A. *supra.* * **Emergency Rental Assistance Program** * This program was removed entirely from the July Draft to the November Draft. This program should be included in the next Housing Element draft as tenant protections is an identified community priority. * **Program 1 – Maintain Adequate Sites** * Create a strategy to work with unwilling developers when rezoning. * Create a strategy for responding to YIMBY’s when conducting comprehensive outreach. * Define who the City is reaching out to during comprehensive outreach. * Define what the City is seeking input on during the outreach. * Develop a robust outreach strategy to ensure varied and inclusive outreach as required by law, ensuring a diligent effort is made by the City to seek input from communities with protected characteristics and fulfilling its duty to AFFH. Gov’t Code § 65583(c)(9)–(10). * **Program 3 – Encourage and Facilitate Accessory Dwelling Units** * Specify targeted areas to promote public outreach for the educational program around the opportunity for ADUs; this is a reasonable and measurable outcome, while promoting to all parts of the city is vague and hard to enforce. * Match funds with Housing Choice Vouchers for ADU units in high resource areas for landlords that make ADUs deed restricted affordable for low- or very-low-income households, in addition to waiving inspection fees. * Advance the City’s free ADU standard plans for farmworker dwelling units and cottage communities by adding a section describing these structures, showing pictures, and including the plans on the City’s ADU Programs website (i.e., making this a more concrete commitment than simply “encourag[ing]” the use of the plans). * Define what a farmworker dwelling unit is. * Create additional incentives for landlords who accept Housing Choice Vouchers to make it more feasible for low-income households. * Institute an advertising plan so all communities, especially R/ECAPs, are aware of the ADU resources on the City’s website, ADU hotline, and ADU email to answer questions. * Waive inspection fees for landlords of low-income properties immediately upon adoption of the Housing Element (i.e., removing the unnecessary waiting of the timeline to start waiving fees in July 2024). * Provide financial support to farmworkers in poverty status who want to build ADUs—who otherwise would not have the downpayment to build ADUs. * **Program 5 – Large and Small Lot Development** * Revise objective (of 600 units) to build 800–1,000 lower-income units. * Create enforceable outcomes in the timeframe section—e.g., create a permanent fund for assisting nonprofit developers by January 1, 2025; build 200 units by December 31, 2025; build 400 units by December 31, 2027, etc. * **Program 8 – List of Local Labor Unions and Apprenticeship Programs** * Host in-person and virtual webinars highlighting the benefits of hiring local labor and best practices for establishing these programs and working with labor unions (i.e., making this a more concrete commitment than simply “encourag[ing]” the hiring of local labor). * Define what “hire local labor” means (e.g., state whether there is a connection to labor unions and apprenticeship programs). * **Program 9 – Use of Sites in Previous Housing Elements** * Edit the second paragraph to be compliant with Government Code section 65583.2(c). It should read (important components bolded for emphasis): * The City will implement a zoning amendment to **permit developments by right** where 20 percent or more of the units are affordable to lower-income households on any **vacant sites** identified in the lower-income inventory of the **4th and 5th RHNA cycles** and and **non-vacant sites** identified in the lower-income inventory of the **5th RHNA cycle** as part of the Housing Element. * **Program 10 – Annual Reporting Program** * Develop a robust outreach strategy to ensure varied and inclusive outreach as required by law, ensuring a diligent effort is made by the City to seek input from communities with protected characteristics and fulfilling its duty to AFFH. Gov’t Code § 65583(c)(9)–(10); HCD AFFH Guidance at 18. * Evaluate, modify, and revise Housing Element implementation programs based on input received from the public. HCD AFFH Guidance at 51. o The Housing Element Does Not Currently Provide for Adequate Public Participation Regarding the Implementation Programs from 2023–2031. * **Program 11 – Incentives for Housing Development** * Host in-person and virtual webinars highlighting the incentives for housing development and best practices for utilizing these and where to access additional resources on the City’s website (i.e., making this a more concrete commitment than simply “post[ing] and maintain[ing]” a list). * **Program 12 – Local Housing Trust Fund** * Revise objective (of 320 units total) to build 300–400 extremely low-, 400–500 very low-, and 400–500 low-income housing units. * **Program 14 – Partnerships with Affordable Housing Developers** * Revise objective (of 1750 units) to build 1900–2000 very low-income units. * **Program 20 – Housing Choice Voucher Incentive Program** * Revise objective section: It should be clear that the City, itself, will enforce source of income laws and the City will work with the Fresno Housing Authority on outreach and educational opportunities regarding HCVs. * **Program 24 – Special Needs Housing** * The November Draft’s insertions are vague, unenforceable, and have unclear outcomes. Words needing more specificity, defining, or measurable outcomes are bolded. * The City will **support** and **work actively** to identify the housing needs of farmworkers in Fresno and **will cooperate** with public and private agencies to seek funding to **identify and implement strategies** leading to the provision of housing for farmworkers. * The Mayor’s Office of Community Affairs **will assist in engaging** all residents of the community including youth, Black, Indigenous, People of Color (BIPOC), Latino, Asian/Pacific Islander, Indian, and LGBTQ on their housing needs. * **Program 30 – Mobile Home Parks** * Define specific aspects of the rehabilitation resources and repair program—e.g., heat resiliency, weatherization, insulation, repairs for inspection violations or other habitability concerns. * Establish a Mobile Home Park Improvement Program focused on community resources such as green space, parks, transit access, infrastructure and other resource improvements. * **Program 33 – Homeless Assistance** * Establish a safe parking program (i.e., provides an enforceable and measurable outcome as opposed to merely “explor[ing] the feasibility” of a program. * Define what services would be provided during the safe parking program to help individuals find permanent housing. December 11, 2023 City of Fresno Revised Draft Housing Element Comment Letter Page 28 * Provide a timeline for conducting and completing the assessment for youth at risk of homelessness. * * * * * Thank you for your consideration of our comments. We look forward to discussing them with you and continuing to work with the state and the City to ensure that the City adopts a Housing Element that fully complies with the law and addresses the serious housing needs and disparities that impact the City of Fresno’s residents. Sincerely, Jasmine Robinson Legal Advocate/Legal Fellow Sponsored by Weil, Gotshal & Manges LLP Leadership Counsel for Justice & Accountability Valerie Feldman Staff Attorney Public Interest Law Project City of Fresno Community Residents Yonas Paulos, Southwest Fresno Lisa Flores, Southwest Fresno Estela Ortega, Ann Leavenworth Ida Villa, Southeast Fresno CC: Ashley Werner, Directing Attorney, Leadership Counsel for Justice & Accountability Ivanka Saunders, Regional Policy Manager (City and County of Fresno), Leadership Counsel for Justice & Accountability Natalie Delgado, Policy Advocate (City of Fresno), Leadership Counsel for Justice & Accountability Leslie Martinez, Community Engagement Specialist, Leadership Counsel for Justice & Accountability Connor Malone, Communications Manager, Leadership Counsel for Justice & Accountability Land Use and Planning Unit (HousingElements@hcd.ca.gov), California Department of Housing and Community Development Jose Ayala, Housing Policy Specialist, California Department of Housing and Community Development Robert Swanson, Deputy Attorney General, Department of Justice—California Attorney General’s Bureau of Environmental Justice Lucas Williams, Partner, Lexington Law Group # Attachment A Comment Letter from Leadership Couns. for Just. & Accountability et al. to the Fresno Cnty. Bd. of Supervisors, the Cities of Fresno Cnty. City Councils, & Deputy Dir. Kristine Cai of the Fresno Council of Gov'ts (Oct. 3, 2022) (on file with author). <
> October 3rd, 2022 Board of Supervisors, Fresno County City Councils, Cities of Fresno County Deputy Director Kristine Cai, Fresno Council of Governments **Re: Fresno COG Multi-Jurisdictional Housing Element Update 2023-2031** Dear Supervisors, Councilmembers, and Kristine Cai: The undersigned organizations write to you to advocate for a Housing Element process and update that is equitable, inclusive, and responsive to disadvantaged communities’ needs. We are a group of community-based organizations working hand-in-hand with community partners and leaders throughout the City and County of Fresno. The following recommendations are based on our experience to push for transformative community-led and identified solutions to elevate and advance their priorities for safe, affordable housing options and fair housing choices. We thank you for taking the time to read the following memo and welcome the opportunity to discuss our letter in further detail. As the Housing Element process begins, it is important and necessary to start the process correctly and with strong community engagement. The Housing Element is an important piece of planning our communities and solving our housing crisis together. Further, the State of California has recently strengthened the laws governing the Housing Element. The Fresno Council of Governments (FCOG), jurisdictions participating in this multi-jurisdictional housing element, and city leaders must apply these laws conscientiously and diligently. With laws such as AB 686 and AB 1397, we expect this Housing Element to be robust, meaningful, and indicative of solving our housing crisis. As always, we are willing to partner and work alongside you all to ensure that these requirements are fulfilled and even exceeded in order to create the change we want to see in the Valley. We look forward to working alongside the Fresno COG, city leaders, and staff in the multijurisdiction Housing Element update (collectively referred to herein as “Fresno jurisdictions” or “jurisdictions”) and solving our housing crisis together. ### I. Jurisdictions Must Meaningfully Engage the Public in their Housing Element Updates Practices, Including Lower-Income Residents and Protected Classes As Fresno jurisdiction begins the 6th Cycle Multi-Jurisdictional Housing Element Update, the jurisdictions must meaningfully engage the public, including in particular lower-income residents, members of protected classes under civil rights statutes, residents of disadvantaged communities, and racially and ethnically concentrated areas of poverty (“R/ECAPs”), and community-based organizations that work closely with these groups over the course of the housing element update. Gov. Code Sec. 65583(c)(9); HCD Affirmatively Furthering Fair Housing Guidance (“AFFH Guidance”), p.21. The jurisdictions must engage the public throughout the housing element update process, and engagement must support “meaningful, frequent, and ongoing community participation, consultation, and coordination.”[^p637-1] HCD, Building Blocks, Public Participation. Pursuant to HCD’s AFFH Guidance, public participation efforts should be proactively and broadly conducted through various methods to ensure access and participation. Key stakeholders that jurisdictions seek to engage directly must include community-based organizations and advocacy groups which work directly with lower-income households and protected classes; lower-income and extremely-low income households; persons and households with special housing needs, including but not limited to farmworkers, seniors, single-parent households, and persons with disabilities; tenants, including residents of publicly-subsidized housing; members of protected classes, residents of disadvantaged communities and R/ECAPs; and fair housing agencies.[^p637-2] Outreach plans should include “in-person meetings in various locations to ensure residents from [^p637-1]: HCD AFFH Guidance, p. 10; Gov. Code §8899.50(a),(b),(c); see also AFFH Final Rule and Commentary (AFFH Rule), 80 Fed. Reg. 42271, 4253-42360 (July 16, 2015) [^p637-2]: HCD AFFH Guidance, p. 21 across the jurisdiction have the opportunity to participate.”³ As the process begins, we ask that jurisdictions plan in-person workshops in all parts of the jurisdictions, especially in rural areas where internet access is scarce, and virtual options are impractical. To satisfy Government Code § 65583(c)(9) and its duties to Affirmatively Further Fair Housing, some specific public outreach efforts that we recommend that jurisdictions undertake to achieve the above-referenced objectives include but are not limited to the following: * holding interactive housing element workshops in at least three disadvantaged unincorporated communities (DUCs) in areas across the jurisdictions, including fringe and island communities located adjacent to or near participating cities and legacy communities as defined by Government Code § 65302.10. Residents living in DUCs, as well as other lower-income communities and neighborhoods, are most likely to attend workshops held in their own communities because many low-income residents in these communities lack personal vehicles and many DUCs are not served by efficient or reliable public transportation. The jurisdictions should partner with community residents and/or community-based organizations with ties to the community to plan and perform effective outreach for the workshops; * conducting targeted outreach to and stakeholder interviews with members of special needs populations and protected classes, including but not limited to farm workers, the elderly, members of large families and single-headed households, people of color, and non-English speakers; * soliciting completion of the community survey performed by the jurisdictions by low income and special needs residents, including by the jurisdictions’ housing division and other city and County staff during their interaction with residents in the course of performance of their duties. * advertising opportunities to participate in and provide feedback on the housing element update in non-English language print media, radio, and television, including media in Spanish, Hmong, and other languages spoken by Fresno County residents. Examples of non-English media outlets include Univision, Radio Bilingue, Hmong TV, and the Vida en el Valle publication among others. Many of these media outlets offer free advertising [^p638-3]: HCD AFFH Guidance, p. 10 space for public service announcements. The housing element should document these additional efforts to achieve public participation by all economic segments of the community and explain how input received through those efforts is incorporated therein. Leadership Counsel is willing to support the jurisdictions in planning these additional public outreach efforts. In addition, and importantly, the Draft Amendments must meaningfully incorporate public input provided on the housing element update, prioritizing input provided by lower-income residents, residents with special housing needs, protected classes, and residents of lower-income and disadvantaged communities. The housing needs analysis sites inventory analysis, assessment of fair housing, including discussion of fair housing issues in R/ECAPs and impacting protected classes, displacement risks, disparities in access to opportunity impacting protected classes, meaningful actions, and programs must all incorporate, reflect, and respond to resident input and priorities. The Multi-Jurisdictional Housing Element must incorporate input from residents from all participating jurisdictions to tailor the analysis, sites inventories, actions, and programs applicable to specific jurisdictions accordingly.[^p639-4] The jurisdictions, cities, and the Fresno COG can start to gain public trust if steps to proactively engage the public, including on an ongoing basis, in the multi-jurisdictional housing element update and incorporate and significantly reflect public input provided. Jurisdictions must ensure that strong public engagement efforts are maintained following jurisdictions’ adoption of the element, including, for example, through the incorporation into the housing element of actions committing to the establishment and facilitation of a housing element oversight advisory committee to assist the jurisdictions in obtaining community feedback on housing element implementation from lower-income residents and protected classes. ## II. The Multi-Jurisdictional Housing Element Update Must Comply with Cities’ and the County’s duties under AB 686 [^p639-4]: HCD AFFH Guidance, p. 21 To avoid the continuation of past and current discriminatory practices and to overcome their legacy, the State of California enacted AB 686 (2018). AB 686 requires the state, cities, counties, and other public agencies to affirmatively further fair housing (“AFFH”) in all programs and activities relating to housing and community development. AFFH means taking meaningful actions, in addition to combating discrimination, that overcomes patterns of segregation and fosters inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. It means taking meaningful actions that, taken together, addresses significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws. AB 686 also amended the Housing Element Law to require that housing elements include an assessment of fair housing (“AFH”) and identify sites throughout the jurisdiction to satisfy its regional housing needs allocation. We recommend that jurisdictions and FCOG carefully review HCD’s AFFH Guidance which contains a detailed discussion of AB 686’s requirements, including the requirements for a complete AFH. The AFH Some of these requirements include: * **Summary of Fair Housing Issues.**[^p640-5] The Housing Element must analyze and address patterns of integration and segregation; racially or ethnically concentrated areas of poverty; racially concentrated areas of affluence, disparities in access to opportunity for lower-income residents and protected classes,; and disproportionate housing needs impacting lower-income residents and protected classes, including displacement risk. The analysis of disparities in access to opportunity must include disparities in access to educational, employment, transportation, and environmental opportunity and cover the specific topics identified in HCD’s AFFH guidance for each opportunity category. HCD’s AFFH Guidance, pp. 35-36. The disproportionate housing needs analysis must consider disparities in housing cost burdens, overcrowding, substandard housing, homelessness, and other issues and must evaluate displacement risks holistically, considering the impacts of rising rents, infrastructure and service deficiencies, [^p640-5]: https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27-2021.pdf, pg.11 climate change, and other displacement risks that may disproportionately impact lower-income households and protected classes. The analysis must incorporate local data and knowledge, including the input of lower-income households and protected classes, and discuss the fair housing issues specific to distinct jurisdictions, R/ECAPs, and lower-income communities. * **Identification and Prioritization of Contributing Factors.** The AFH must analyze and prioritize factors that contribute to identified fair housing issues and prioritize factors that limit or deny fair housing choice or access to opportunity or negatively impact fair housing or civil rights. * **Sites Inventory AFFH Analysis.[^p641-6]** The housing element must not only demonstrate site capacity to accommodate each jurisdiction’s RHNA, but also that the identified sites are consistent with the duty to AFFH, serving the purpose of replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity.[^p641-7] This evaluation must include the specific components described in the AFH Guidance, including how sites better integrate the community considering historical patterns and trends; the extent to which sites may exacerbate existing patterns of segregation; whether the RHNA by income group is concentrated in areas of the community; and local data, knowledge, and community input. Based on the outcome of the analysis, the site inventory must be modified, and/or actions must be included to overcome patterns of segregation and barriers to opportunity in relation to the sites contained in the inventory. * **Meaningful Goals and Actions.** Existing Housing Element Law requires programs with a schedule of actions with timelines and specific commitment to have a “beneficial impact” within the planning period to achieve the goals and objectives of the housing element. As stated in the AFH guidelines “actions implement goals and consist of *concrete steps, timelines, and measurable outcomes.*” [^p641-6]: https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27-2021.pdf, pg.12 [^p641-7]: 24 Gov. Code, § 8890.50. subd. (b). As the draft Housing Element is produced, we will be looking for these components and compliance with jurisdictions’ duties under AB 686 to ensure that drafts reflect residents’ input and priorities. Further, suppose barriers are identified that impede the application and implementation of programs, policies, and production of housing. In that case, the City should analyzealso analyze these barrierstempt to make a good-faith effort to find alternative solutions. ### III. The Housing Element Must Analyze and Incorporate Programs and Policies That Adequately Respond to our Housing Crisis As discussed above, the housing element must include programs and actions prioritized by lower-income residents, protected classes, and residents of lower-income communities and R/ECAPs during the housing element update to solve our housing crisis. Below are community-identified programs and policies which residents from South Fresno neighborhoods and disadvantaged unincorporated communities across the jurisdictions have repeatedly identified as priorities to solve our housing crisis and AFFH which we ask jurisdictions consider: a. County of Fresno * Create or support expansion of local funding opportunities for farmworker housing. Farmworker housing should be accessible for migrant farmworkers and affordable. b. City of Fresno and County of Fresno: * Adopt a local rent stabilization ordinance, to protect tenants from continuously rising rents, including a rent stabilization board to hear and approve rental increases submitted by landlords. This would apply to the City of Fresno and Fresno County. * Adoption of tenant protections to reduce displacement risks, including just cause eviction that address gaps in protections afforded under the 2019 Tenant Protection Act and a right to counsel guaranteeing access to affordable legal counsel for low-income tenants in housing matters; * Establish a permanent emergency rental assistance program to assist residents at risk of homelessness due to rent increases and changed circumstances and ability to pay. Identification of a permanent local source of funding will ensure continuous funding and that the program can be used to prevent displacement. *The City of Fresno can leverage the Local Housing Trust Fund dollars and the State is continuing to grant monies for rental assistance programs* * Establish a **permanent first-time homeownership assistance program** to help tenants become first-time homeowners. Closing costs and downpayment assistance for low-income, first-time homebuyers can help close the housing gap. Residents with ITIN numbers should be eligible for this program. * Investments in **improvements to mobile home parks** to address the needs, including needs from the mobile park assessment study. Further, it should address weatherization and climate resiliency needs, to improve indoor and outdoor air quality, and to expand access to green space. * Pursue an **Inclusionary Zoning ordinance** in the County of Fresno and the City of Fresno once a General Plan Update has occurred. * **Extreme heat and weatherization programs** to address climate change. This includes funding for weatherization upgrades to homes and rental units, specifically in census tracts that rank the highest on CalEnviroScreen for pollution and poor health outcomes and are most vulnerable to climate change. * Establish an **acquisition and rehabilitation fund** to purchase older, blighted, and/or abandoned homes/buildings. The County and the City of Fresno can establish a revolving fund to insure that rehabilitated homes are sold back to the community at a low cost. * Grants for residents who want to develop **affordable accessory dwelling units** on their land in both the City and County of Fresno. Some residents are willing to sell parcels of land to the County to develop affordable housing and increase housing supply. * **Urban Greening is used** as buffer zones when residential is placed or already placed near existing polluting land uses to mitigate health impacts. * **Citing industrial uses** cannot be sited next to Housing Element sites and compliance with placing housing sites away from heavy, light industrial uses or phasing out light/heavy industrial zones o **Suitable Vacant Land** should be prioritized for affordable housing in order to bring Very Low Income and Low Income RHNA allocations into compliance o **Impact fees should be placed into a community benefit fund** when polluting land uses and practices are placed near housing. The community benefit fund will be managed by the community directly impacted to dictate to who these funds should be allocated. c. All Jurisdictions: o **Establish local hire provisions** requiring that a certain percentage of workers reside within 10 miles or less of a Project Site. This can reduce the length of trips, reduce greenhouse gas emissions and provide localized economic benefits o **Developing Public Health Impact Reports** for new development in order to understand existing public health disparities and the potential of those conditions worsening as a result of development. Public health agencies should be resourced to support this analysis. The findings of these reports should be available publicly and be included in permit approval processes and other key decision-making milestones. o **Establish a Cargo/Freight Prohibition and Revenue Tax** to directly fund community-based housing and projects in the neighborhoods most negatively impacted by years of environmental toxicity caused by freight. o **Incorporate Complete Streets principles** into all transportation projects at all phases of development, including planning and land use decisions, scoping, design, implementation, maintenance, and performance monitoring. o **Establish a Housing Element Implementation Committee** to oversee the timelines and implementation of each program and policy. The committee should be comprised primarily by tenants, low-income homeowners, and at-risk populations to ensure implementation meets the needs of most at-risk communities. IV. The Sites Inventory Must Comply with New Housing Element Law Requirements, Including Requirements for Access to Infrastructure and Services Under AB 1397 <
> As aforementioned, the State of California has added further requirements and specificity to the obligation of the Housing Element to identify adequate sites for further development of affordable housing. Under AB 1397, for all sites in the inventory, the jurisdiction must determine the number of units “that can be realistically accommodated.[^p645-8]” These requirements do not include “current or planned availability and accessibility of sufficient water, sewer and dry utilities.[^p645-9]” In other words, sites that are served by water, sewer, and other dry utilities available and accessible within three years of the beginning of the planning period will be considered suitable for residential development. In addition, jurisdictions may not reuse on-vacant sites identified in a prior housing element or vacant sites identified in the last two housing element updates to meet lower-income RHNA requirements. Finally, we recommend FCOG and the jurisdictions ensure that sites chosen conform to HCD’s site inventory guidance. Following HCD’s guidance would increase planning efficiency for local agencies, while ensuring compliance with housing element requirements. We look forward to seeing local compliance. * * * * * Thank you for taking our comments into consideration. We look forward to continuing to work with the Fresno jurisdictions on developing a compliant Housing Element that responds to the needs of participating Fresno Jurisdiction Residents and ensures access to safe and affordable housing for all. [^p645-8]: Cal Gov Code 65583.2(c) [^p645-9]: Cal Gov Code 65583.2(c)(2) <
> Sincerely, Karla Martinez, Policy Advocate Leadership Counsel for Justice and Accountability Alexandra Alvarado, Community Organizer Faith in the Valley Marisa Moraza, Senior Campaign Strategist PowerCA Action Shar Thompson, CV Regional Coordinator Tenants Together Josefa Vega, Central Valley Regional Organizer ACLU Northern California Ruben Espinoza, Policy Advocate Fresno Barrios Unidos Guadalupe Ramos, Project Specialist Fresno Building Healthy Communities # Attachment B Comment Letter from Leadership Couns. for Just. & Accountability et al. to Mayor Jerry Dyer, Fresno City Councilmembers, & Michelle Zumwalt (Aug. 16, 2023) (on file with author). August 16, 2023 Mayor Jerry Dyer Fresno City Councilmembers Michelle Zumwalt, Planning and Development Department 2600 Fresno Street, Room Fresno, CA 93721 RE: City of Fresno Draft 6th Cycle Housing Element Dear Councilmembers, Mayor Dyer, and Ms. Zumwalt, The undersigned organizations write to you to advocate for a Housing Element that is equitable, inclusive, and responsive to disadvantaged communities’ needs. We are a group of community-based organizations working alongside community partners and leaders throughout the City of Fresno. Housing Element Law requires that cities and counties make a diligent effort to meaningfully incorporate public input provided on the housing element update, prioritizing input provided by lower-income residents, residents with special housing needs, protected classes, and residents of lower-income and disadvantaged communities. Goals, policies and actions must be aggressively set to overcome those contributing factors to meet the “meaningful impact” requirement in statute and to avoid actions that are materially inconsistent with the obligation to affirmatively further fair housing. Goals and policies must be created with the intention to have a significant impact, well beyond a continuation of past actions, and to provide direction and guidance for meaningful action. AFFH Guidance, p. 52. The draft element’s Housing Action Plan contains numerous actions that lack concrete steps and measurable outcomes and will not necessarily result in a beneficial impact during the planning period in violation of the Housing Element Law’s standards. The following programs are inadequate and include our recommendations to improve them. * **Program 1 - Maintain Adequate Sites.** Program 1 states that the City shall continue to maintain a current inventory of Housing Element sites to ensure that it can adequately accommodate the 2023-2031 RHNA” Given the impact of rezoning to the availability of and location of sites suitable for housing, the City should take additional steps to ensure transparency in decision-making related to proposed rezones and take diligent steps to provide notice of the proposed rezone along with an assessment of the potential impacts of the rezone on housing opportunity prior to a decision on the proposal. This includes but is not limited to public hearings and door to door canvassing to facilitate effective notice. Further, the city must conduct a racial equity analysis which would include the benefits and disadvantages of the proposed rezone and whether it would result in displacement of protected racial/ethnic groups, reduce housing opportunities for protected groups, and how it would impact patterns of segregation. Finally, the program should explicitly prohibit the rezoning of sites suitable for lower income households to industrial land use classifications which would bring industrial uses next to or near neighborhoods that include or are planned for housing affordable to lower income residents. This is critical to ensure that the City is compliant with its duty to affirmatively further fair housing. * **Program 2- Variety of Housing Opportunities in High Resource Areas *(identified in the AFH as a Meaningful Action)*.** The program states that the City “will identify and pursue opportunities” with affordable housing developers to promote the development of affordable units in high resource areas. Unfortunately, it does not provide any details on how they will in fact promote the development of affordable units for lower income households in high opportunity areas. There is no clear commitment to zone sites for multi-family development in areas of high opportunity or a commitment to ensure that such units are affordable to all income levels. Further, there is no commitment to match funding opportunities with the identification of available sites to facilitate their development. Notably, the City will not conform with its duty to AFFH if it does not ensure adequate sites for affordable housing for lower income residents in high resource areas. Without clear and enforceable commitments and timelines, this program will not provide a beneficial impact or further fair housing. Furthermore, in order to expeditiously address the lack of housing opportunities accessible to lower-income residents in high resource areas, the timeline of this program should be shortened. Accordingly, a specific objectives of this program should be changed to (a) assess the number of sites that must be rezoned in high resource areas (as identified in TCAC/ HCD’s Opportunity Maps) to effectively AFFH , and (b) rezone the adequate number of sites pursuant to that analysis by December of 2025. * **Program 3 - Encourage and Facilitate Accessory Dwelling Units (ADUs) *(identified in the AFH as a Meaningful Action)*.** While we support and encourage the development of ADUs, the program does not outline clear commitments that will yield identifiable beneficial outcomes. The program states “a primary objective of this program is to increase the supply of affordable units throughout the city” but fails to identify any specific commitments to take any action on how this objective will be reached. Additionally, building ADUs is generally not an accessible housing option to low income households who cannot afford predevelopment costs associated with ADUs. We recommend additional measures in this program to make ADUs accessible to lower income households such as targeted outreach to low-income homeowners, incentives for landlords to make ADUs affordable, no interest loans for ADU development and waivers for inspection fees Additionally, a dedicated liaison in the Office of Community Affairs should be available for all questions regarding ADUs. * **Program 8 - Use of Sites in Previous Housing Elements.** Program 8 should be updated to clarify that streamlined approval will be available to both vacant and non-vacant sites through a zoning amendment. As written it appears that the zoning amendment will only apply to vacant sites included in the 4th and 5th cycle housing elements. * **Program 9 - Annual Reporting Program.** While we appreciate the sentiment that the City will “engage all members of the Fresno community,” and the specific commitment to use multilingual notices and media, the City should revise this program and avoid using vague language with no commitments. To make the public engagement associated with this program meaningful, we recommend that the program include a commitment and associated timeframe for the City to implement input received through its various outreach efforts such as workshops and surveys in addition to the annual public hearing. The annual report should include specific actions the City will take to overcome identified constraints and barriers to complying with Housing Element programs. * **Program 10 - Incentives for Housing Development (*identified in the AFH as a Meaningful Action*).** This program does not present a commitment to address housing production for low-income units or actions that will be taken to complete the program. To facilitate and promote the use of available incentives, the city should make a list of incentives, including density bonus incentives and impact fee waivers, available to the public through an accessible database. Additionally, the program’s current language that it will “identify site opportunities in higher resource areas and …improve access to resources” suffers from the same issues hat program 2 does insofar as it fails to identify clear and enforceable commitments and steps that it will take to ensure the availability of sites for lower income households in high opportunity areas. It is critical for this program’s success and the City’s role in AFFH that the housing element includes clear, timebound, and enforceable actions to ensure availability of sites for lower income households in high resource areas, as outlined above. Finally, the City should include enforceable commitments to avoid displacement and gentrification in the Downtown Planning Area, and assess the role that priority processing in the area has on the City’s duty to AFFH. * **Program 11 - Local Housing Trust Fund *(identified in the AFH as a Meaningful Action)***. The Local Housing Trust Fund is a great tool to alleviate the housing crisis and we are glad to see the City’s commitment to leverage State matching funds. We recommend adding the creation of a Community Advisory Board as an action to ensure that projects are driven by a community process and benefit the most impacted residents. Housing advocates have met previously with City staff to develop an equitable Community Advisory Board made up of a diverse group of residents most impacted by housing barriers, legal experts, and small landlords. * **Program 16 - Surplus Public Lands.** The commitment to release surplus sites appears to simply be a commitment to comply with its existing duties under the Surplus Lands Act. The language is ambiguous, non-committal and must be revised. In addition, the program states the City will “consider depositing a portion of up to 100 percent [of sale proceeds] to the LHTF” We recommend instead that the City commit to depositing 100 percent of sale proceeds into the LHTF. * **Program 18 – Home Buyer Assistance *(identified in the AFH as a Meaningful Action)***. While a critical program for many Fresnans, this Program should include additional commitments to ensure that low-income residents, undocumented residents, residents who speak languages other than English, and residents in racially and /ethnically-concentrated areas of poverty (R/ECAPs) have the opportunity to benefit from these funds. During the 5th Cycle planning period, many residents without social security numbers or who faced language access barriers were unable to apply for the City’s homebuyer assistance program. While the City was able to assist nine families with this program, this program must incorporate mechanisms that will allow more families to apply during the next 8-year cycle by addressing barriers and pursuing state funds every year. This program has other deficiencies that must be addressed such as lack of public outreach and lack of interpretation for applicants applying by phone. Solutions include: ensuring that low-income residents are knowledgeable about the programs, undocumented residents are able to successfully apply for this program, including closing costs as part of funding packages. In order to ensure that residents living in R/ECAPs are targeted, we recommend the City create annual reports listing how many applicants were assisted, outreach efforts made and whether they live in R/ECAPs. Due to the concerns outlined above, the program as currently implemented and drafted fails to adhere to HCD’s AFFH Guidance that “actions must be specific with timelines, discrete steps and measurable outcomes to have a ‘beneficial impact’ during the planning period.” * **Program 19 – Housing Choice Voucher Incentive Program (HCV)** *(identified in the AFH as a Meaningful Action)*. This action fails to include meaningful actions with specific timelines, and measurable outcomes to have a “beneficial impact” during the planning period. The program should develop and implement a proactive enforcement program housed within that legal department to ensure HCV . The City should revise this program to include a timeline of one workshop a month (twelve workshops throughout the year) to ensure residents and landlords are able to access housing quickly and better assist residents/landlords going through any issues that prevent them from using/accepting HCV. Additionally, collaborating with and funding CBOs and fair housing organizations to provide information to voucher holders and landlords on California’s source of income discrimination prohibitions. The program should also commit the City of Fresno to finance billboard ads about protections against HCV discrimination and send informational materials to all landlords in Fresno registered in the rental registry regarding HCV. Finally, the program should be revised to include a commitment to actively pursue enforcement against discrimination against voucher-holders and supplementing vouchers with additional subsidies to support voucher use in higher-cost markets in high resource areas. Northeast Fresno has very limited HCV use, with only four census tracts north of Herndon Avenue containing any HCVs, and of those four tracts, no tract exceeds 5 percent HCV use. By revising the program to include the above recommendations would help address fair housing needs in Fresno. * **Program 21 – Housing Rehabilitation** *(identified in the AFH as a Meaningful Action)*. Government Code section 8899.50 requires ““meaningful actions” well beyond combating discrimination to overcome patterns of segregation and foster inclusive communities. These actions, as a whole, must address significant disparities in housing needs and in access to opportunity.” The current program has failed to address the needs of extremely low income residents and vulnerable populations such as undocumented residents. As we continue to see the negative effects of Climate Change across the world, it is imperative that the City include weatherization such as cooling mechanisms, like heat pumps, air conditioning, insulation and other cooling assets to increase resilience to extreme heat as part of the rehabilitation program. It is a critical and urgent need given that extreme heat kills thousands per year and impacts disadvantaged communities the most. Additionally, the City must establish an acquisition and rehabilitation fund to purchase older, blighted, and/or abandoned homes/buildings. The City of Fresno can establish a revolving fund to insure that rehabilitated homes are sold back to the community at a low cost.Finally, for the program to have a beneficial impact the timeframe section should include 15 rehabilitation grants annually, and 5 distressed property grants using PLHA and CDBG funding for extremely low and low income residents. * **Program 22 – Comprehensive Code Enforcement.** While we appreciate Code Enforcement’s response and the City’s diligence to keep increasing staff, there are still additional actions that should be taken to create a comprehensive code enforcement. HCD’s AFFH Guidance recommends that “to overcome contributing factors to fair housing and affirmatively further fair housing, actions must consider a wide range of actions across all action areas. The number and scale of actions will depend on the severity of the needs but regardless of need, a cohesive and effective program will consider multiple action areas.” This program as written continues to fail to address critical housing issues since the last housing element cycle. The program should be revised to include actions around legally holding landlords accountable for retaliation, unlawful evictions, and harassment towards tenants who file code enforcement complaints such as a commitment to adopt a tenant anti-harassment ordinance. As stated, we recommend that the City adequately analyze code enforcement’s procedures and incorporate tenant feedback for a comprehensive code enforcement program. * **Program 23 - Special Needs Housing (identified in the AFH as a Meaningful Action).** Much of the language in this program is vague, noncommittal, and does not provide adequate actions in order to provide a beneficial outcome. This program states the City “shall advocate for provision of special needs,” “partner with and encourage local and state non profits,” and “provide/encourage.” These actions are not concrete or specific and provide no assurance of a beneficial impact on persons’ with disabilities access to housing. This should be revised to include review and enforcement of compliance with legal requirements for accessibility of multi-family and affordable housing, including in permitting processes, not just “encourage[ing]” accessibility features. Additionally, we recommend that the program add specific actions to remove barriers to housing by special needs groups such as allowing undocumented residents to apply for and receive housing assistance, vouchers and other subsidies unless otherwise required by federal law. * **Program 26 - Equitable Community Investments *(identified in the AFH as a Meaningful Action)***. Program 26 states it will “seek funding,” “continue to actively seek resources,” and “continue implementing the written policies.” These commitments are vague and non-committal. There are no actions on how these will be completed and is ambiguous and as a result provides no indication that a beneficial outcome will result from the program and further fair housing. The programs continue not to commit the City to take a lead role in planning, funding, and/or constructing projects or indeed any role beyond identifying issues and needs and seeking funding on an annual basis. Additionally, it should not rely on the General Plan’s identification of Priority Areas for Development Incentives in Chapter 12 and should instead use the Urban Displacement Project data to guide investments. * **Program 28 – Opportunity To Purchase Act (OPA) *(identified in the AFH as a Meaningful Action)***. Although we appreciate the City’s action to initiate research on a local Opportunity to Purchase Act, we strongly recommend that the City implements robust outreach and engagement, in partnership with CBOs that work closely with low-income communities in racially/ethnically-concentrated. Additionally, the program states it "shall research" and "consider establishing an OPA." These are not commitments and fail to implement any specific, firm, or enforceable commitment such that no beneficial outcome of the action is indicated. * **Program 29 – Mobile Home Parks *(identified in the AFH as a Meaningful Action)***. Program 29 contains no commitments, actions, or enforceable language that will ensure a beneficial impact throughout the planning period. Additionally, this program repeats verbatim language included in Program 10A of the 2015-2023 without explaining how or why reliance on the same program action will have better results during the next planning period. With residents like Three Palms and Trails End Mobile Home Park experiencing the negative impacts of slumlords, it is crucial that the City make significant improvements to the program actions. Furthermore, the program must address the need for heat resiliency such as weatherization and insulation especially to older mobile home parks by funding a mobile home park renovation fund for all mobile homes. This fund will help low income families with issues that they need to address due to inspection violations or other habitability concerns. Additionally, this program should include a commitment to penalize and fine mobile home park owners who are not providing adequate and safe conditions for their tenants. For example, Three Palms Mobile Home Park had not had safe drinking water for quite some time and the owner was never made responsible for this clear human rights violation. Finally, consistent with the City’s responsibility to AFFH, the program should support quality of life and access to opportunity improvements for all mobilehome parks in Fresno by taking meaningful actions to increase green space, transit, and resources near mobile home parks. * **Program 30 – Emergency Rental Assistance Program (*identified in the AFH as a Meaningful Action*).** Although we appreciate the City adding this program, it states that the City will “seek additional funding” and fails to commit ongoing funding that can come from the Local Housing Trust Fund, the General Fund, or its own permanent funding source to ensure a beneficial impact during the planning period. Identification and commitment of a permanent local source of funding by 2024 will highlight a commitment to prevent displacement and protect tenants. * **Program 31 - Eviction Protection Program (EPP) (*identified in the AFH as a Meaningful Action*).** The Eviction Protection Program is a critical anti-displacement and anti-homeless tool. However, the program's current language to “seek additional funding” to support the “EPP” is not a strong commitment and does not provide indication that a beneficial outcome will occur if funding is not replenished. We strongly recommend that the City commit to staffing 5 full-time staff for screening so tenants are able to receive help as soon as possible. We also recommend program expansion to include: * Wide-reaching outreach and education campaigns * Direct legal representation and assistance for low-income tenants encountering legal issues. This includes but is not limited to being served with a notice from their landlord (e.g. 3-day notice, notice of rent increase, etc.) * Evaluation of the Eviction Protection Program to ensure it is effective and address issues to improve the program. * **Program 33 – Homeless Assistance (*identified in the AFH as a Meaningful Action*).** Program 33 does not commit the City to any concrete action. The program states it will “identify partnership opportunities,” “leverage the homeless assistance response team” and “support the Voucher Incentive Program” none of which commit to any enforceable and actionable items. The city must commit to completing an adequate analysis of needs of unhoused City residents. This should include the completion of an AFH analysis of disproportionate needs. ● **Program 34 - At-Risk Housing.** Program 34 includes actions without a clear commitment to take steps that will lessen the severity or impact of the issue in any timeframe. Again, the language is non-committal, vague, and ambiguous in how the program will reach its objective. Additionally, stronger tenant protections should be included as an objective and completed no later than June 2024 for residents facing displacement and an affordable housing resource map for tenants so they have the option to relocate. Additionally, the draft element lacks policies and programs identified in Leadership Counsel’s February 2023 letter, attached hereto. We incorporate the policies and programs recommended in that letter here by reference. In addition to the policies and programs highlighted in Leadership Counsel’s February 2023 letter, the draft element should also be revised to include the following programs: A. Rent Control and Just Cause Protection Ordinance. The Housing Element draft mentions tenant protection “strategies” but in no way does the draft commit to tangible solutions. City of Fresno tenants, along with advocates, have been demanding rent control and just cause ordinance since 2021. The Here To Stay Report lists this as the communities’ top priorities. Tenants have attended City Council meetings for the past two years asking for this; they have met with every city council member; and have lifted this as a priority in the City’s Housing Element workshops. Yet, the City refuses to acknowledge residents’ need. We strongly recommend that the City incorporate this into the Housing Element. B. Inclusionary Zoning Ordinance. The City should adopt a program to develop and adopt an inclusionary zoning ordinance by a date certain that is no more than three years into the planning period in order to allow the ordinance to result in the production of lower-income units during the planning period. To ensure that the ordinance AFFH and maximizes the production of affordable units, the ordinance should apply to single-family and multi-family housing and require a minimum share of affordable units (approx. 25-30%) and affordability levels of those units, including affordability for very-low and extremely-low income households. The City should develop this ordinance in partnership with lower-income residents and CBOs. C. Urban Greening is used as buffer zones when residential is placed or already placed near existing polluting land uses to mitigate health impacts. D. Citing industrial uses. Programs should explicitly prohibit the rezoning of sites suitable for lower income households to industrial land use classifications which would bring industrial uses next to or near neighborhoods that include or are planned for housing affordable to lower income residents. This is critical to ensure that the City is compliant with its duty to affirmatively further fair housing. E. Impact fees should be placed into a community benefit fund when polluting land uses and practices are placed near housing. The community benefit fund will be managed by the community directly impacted to dictate to who these funds should be allocated. F. Establish local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of a Project Site. This can reduce the length of trips, reduce greenhouse gas emissions and provide localized economic benefits G. Developing Public Health Impact Reports for new development in order to understand existing public health disparities and the potential of those conditions worsening as a result of development. Public health agencies should be resourced to support this analysis. The findings of these reports should be available publicly and be included in permit approval processes and other key decision-making milestones. H. Establish a Cargo/Freight Prohibition and Revenue Tax to directly fund community-based housing and projects in the neighborhoods most negatively impacted by years of environmental toxicity caused by freight. I. Incorporate Complete Streets principles into all transportation projects at all phases of development, including planning and land use decisions, scoping, design, implementation, maintenance, and performance monitoring. J. Establish a Housing Element Implementation Committee to oversee the timelines and implementation of each program and policy. The committee should be composed primarily by tenants, low-income homeowners, and at-risk populations to ensure implementation meets the needs of most at-risk communities. As discussed previously, each program must contain clear action steps, deadlines, and measurable outcomes that will be achieved within the planning period and address housing and fair housing needs prioritized during the public process. * * * * * Thank you for your consideration of our comments. Please contact us if you would like to find a time to discuss them. We look forward to working together to advance access to safe, affordable housing for all City of Fresno residents. Sincerely, Karla Martinez, Policy Advocate Leadership Counsel for Justice and Accountability Edith Rico, Project Director Building Healthy Communities Shar Thompson, Central Valley Regional Coordinator Tenants Together Marisa Moraza, Campaign Director Power California # Attachment C Comment Letter from Pub. Int. L. Project & Leadership Couns. for Just. & Accountability to Mayor Jerry Dyer, Fresno City Councilmembers, & Michelle Zumwalt (Aug. 16, 2023) (on file with author). August 16, 2023 Mayor Jerry Dyer Fresno City Councilmembers Michelle Zumwalt, Planning and Development Department 2600 Fresno Street, Room Fresno, CA 93721 **RE: City of Fresno Draft 6th Cycle Housing Element** Dear Mayor Dyer, Councilmember, and Ms. Zumwalt: Leadership Counsel for Justice and Accountability write in collaboration with the Public Interest Law Project (“PILP”) and residents of South Fresno neighborhoods impacted by the severe lack of decent quality, affordable, and permanent housing options and gaping disparities in access to opportunity in Fresno to provide comments on the July 2023 Draft Appendix 1-E: City of Fresno of the Fresno Multi-Jurisdictional 2023-2031 Housing Element (“City of Fresno Draft Housing Element” or “Draft Element”). Leadership Counsel works alongside the most impacted communities to advocate for sound policy and eradicate injustice to secure equal access to opportunity regardless of wealth, race, income, and place. Leadership Counsel advocates for policy and practice changes to meet the housing needs of all residents in Fresno, especially low-income and residents with special housing needs, and to overcome fair housing disparities that impact low-income communities of color. Residents with whom we partner experience high rates of cost burden and escalating housing costs, reside in unsafe and unsanitary rental housing conditions, and ever-present and magnifying displacement risks and are simultaneously impacted by striking disparities in access to opportunity compared to more affluent Fresno neighborhoods, including a lack of access to a healthy environment and public and private investment in critical infrastructure, services, and amenities. The Public Interest Law Project (PILP) works statewide to support local legal programs that address issues involving housing, land use, public benefits and homelessness. PILP has been providing substantive training, litigation support, and technical assistance in these areas for over 25 years. The City of Fresno’s 6th cycle housing element update presents a critical opportunity for the City to identify and address long-standing, wide-ranging, and severe housing needs and fair housing disparities that impact the City’s residents, disadvantaged communities, and racially and 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 2 of 40 ethnically concentrated areas of poverty (“R/ECAPs”), in particular, the Southwest, South Central and Southeast areas. The City must ensure that it does not miss this opportunity to develop and adopt a housing element that complies with the State Housing Element Law and civil rights laws and that meaningfully incorporates the input of lower-income residents and the community-based organizations that work alongside them. Our comments below highlight further steps and actions the City must take to meet State Housing Element Law requirements. In short, the Draft Element must be revised in order to meet Fresno’s housing needs and relevant statutory requirements in several different ways, including: * Incorporate input regarding key housing issues and disparities and actions needed to address those issues provided to the City by community members as required by HCD’s AFFH Guidance; * Revise the constraint analysis to address non-governmental constraints, as well as constraints on supportive housing and the maintenance of the housing stock. * Revise the AFH analysis to consider all of the required displacement factors, barriers in access to opportunity, and fair housing issues associated with the Draft Sites Inventory; * Revise programs to include specific actions and deadlines and add programs that will result in a beneficial impact on Fresno housing needs and disparities during the planning period and overcome patterns of segregation and foster inclusive communities, including but not limited programs 14, 15, 19, 23, 29, and 33; * Revise the site inventory analysis to exclude projects that have not been approved during the projection period, include a realistic capacity calculation based on development throughout the 5th cycle, and determine the adequacy of the non-vacant site # I. The City Has Not Diligently Engaged the Public As Required, Because the Draft Element Fails to Adequately Reflect Public Input The City’s obligations to diligently engage all economic segments of the community and to affirmatively further fair housing through the housing element require more than just seeking input about the contents of the housing element. Government Code sections 65583(c)(8), 65583(10)(a) & 8899.50. Inviting residents to provide input but failing to incorporate that input into the housing element undermines the purpose of resident participation in the housing element update, fosters distrust, and fails to constitute “engagement” as required by section 65583(c)(8) of the Housing Element Law. HCD’s Affirmatively Furthering Fair Housing (“AFFH”) Guidance 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 3 of 40 states that housing elements must describe “a summary of [public] comments and how the comments are considered and incorporated (including comments that were not incorporated), particularly with changes to the housing element. HCD, Affirmatively Furthering Fair Housing: Guidance for all Public Entities and for Housing Element (“AFFH Guidance”), 2021, p. 22.[^p662-1] While the Draft Element provides some description of public input provided, its summary of public comments generally lacks sufficient detail for the reader to understand the nature of the issue raised or the solution proposed. In addition, the Draft Element fails to demonstrate the City’s incorporation of input provided and to identify input the City chose not to incorporate as required. For example, at the March 1, 2023 community workshop on the housing element update held at Helm Home, residents identified the establishment of rent control, tenant assistance and protections, and reducing barriers to undocumented residents as among their top suggestions and solutions. The Draft Element fails to demonstrate how this solution will be incorporated into the final draft and to even to study the housing needs of undocumented residents. The Draft Element also fails to acknowledge, discuss, or incorporate recommendations contained in the letter submitted to the City by Leadership Counsel and several other community-based organizations in February 2023 relating to the development of this Draft. *Attachment 1, Leadership Counsel February 2023 Letter*. The letter identifies policies and programs which the signatory organizations believe should be prioritized in the housing element update, based on our direct and daily work with low-income residents of color, farmworkers, residents of disadvantaged unincorporated communities, and other residents with special housing needs and members of protected classes. The City must revise the draft element to acknowledge this letter, summarize its contents, and revise goals, policies, and programs to incorporate its recommendations, in addition to other input it receives. The City must also revise the element to indicate what public input it chose not to incorporate, which the element currently fails to do. ## II. The Housing Element Fails to Adequately Analyze and Remove Governmental Constraints to Housing Development To fully comply with Housing Element law, the City of Fresno must identify constraints to the development of housing affordable to households at different income levels, as well as possible constraints to the development and maintenance of a variety of types of housing, including supportive housing, single room occupancy units, emergency shelters, and transitional housing. *See Gov’t Code* §65583(a)(5) and (c)(1). This analysis includes potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all [^p662-1]: All references to code sections hereafter refer to the Government Code unless stated otherwise. income levels. Gov’t Code § 65583(a)(5). Following a close analysis, the City must include a description of efforts to remove constraints and a program to remove those constraints. Gov’t Code §65583(c)(3). ### A. Land Use Controls Are Under-Analyzed as a Constraint The Housing Element under analyzes the impacts of current and planned zoning regulations on housing development. A jurisdiction must include an analysis of potential and actual governmental constraints, including land use controls that directly impact the cost and supply of residential development. Gov’t Code § 65583(a)(5). The constraints analysis fails to demonstrate the direct connection between its currently proposed zoning on cost and supply of housing. The City has not adequately analyzed the effects of constraints associated with wide-spread availability of single family zoning and the limited availability of high density zoned sites. For example, the HE acknowledges “growth in the City of Fresno over the past few decades has traditionally been low density suburban development, which has resulted in conditions of sprawl in various areas of the city.[^p663-2] Despite the acknowledgement, the City continues to allow by right single-family units in. Despite the historical preference for single family development, the abundance of available single family homes in Fresno, and the underproduction of affordable housing,the the City still permits single family uses by-right in many of the zones identified for increased high-density development: RM-1, NMX, CMX, RMX, CMS, CR, DTN, DTG. Further, although single family development is allowed in almost every zone that permits residential development, higher-density units are not allowed in certain areas in the City. For example, multi-family units are not allowed in RS-1, RS-2, or RS-3 areas, despite the large majority of the City being zoned one of these zones, and where many high resource areas have developed.[^p663-3] Duplexes are similarly constrained, they are excluded from RS-1, RS-2, RS-3, RS-4, and only allowed through conditional use permit in R-5. Because both single-family and multi-family development is permitted in most residential zones, it puts multi-family developers in competition with single family developers for the same sites. Single family units also benefit from reduced permitting timelines. For single--family developments it typically takes up to 30 days for developers to pull building permits after its [^p663-2]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-1. [^p663-3]: City of Fresno, 2023. Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on ACS data. entitlements are approved.[^p664-4] In contrast, based on recent projects, it can take three months to a year for multifamily developers to receive building permits after entitlements.[^p664-5] Although the Draft concluded that higher permit processing schedules for multi-family units compared to single family units are not a constraint, the increased complexity and expected timeline does appear to act as a constraint on multi-family development based on the very low production number of multi-family housing in the 5th cycle. [^p664-6] ### B. Land Use Controls' Effect on Types of Housing A complete constraint analysis does not only focus on housing by income levels but must also consider constraints to the different types of housing.. As noted above, the Draft constraint analysis must examine what constraints exist to the development of : supportive housing, transitional housing, single room occupancy units, and emergency shelters. Gov’t Code 65583(c)(1) #### 1. Single Room Occupancy (SRO) Units The City’s constraint analysis regarding SRO’s should examine more than the limit on the number of units but also where SRO’s are permitted to develop. SRO’s are a crucial source of affordable housing for many people and can augment the deed restricted affordable housing available to lower income people. The City should commit not only to removing the limit on the number of units that can be contained in an SRO but also add it as a permitted use in the following zones: RM-MH, RM-2, and downtown while removing conditional use permit requirements from RM-2, RM-3, NMX, CMX, and RMX. #### 2. Emergency Shelters The Draft must consider whether its development standards act as a constraint on the development of emergency shelters. Although the City seems to determine that its requirements do not act as a constraint to the development of shelters it also states it may consider making further amendments to the development code to remove any possible constraints. If further amendments are necessary, especially any needed to comply with Government Code section 65583(a)(4)(A), the City should commit to making those changes immediately. For instance, the City’s current requirement for the number of toilets per person in a shelter (Muni Code section [^p664-4]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-35 [^p664-5]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-35 [^p664-6]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-38 Michelle Zumwalt Page 6 of 40 15-2729), if it exceeds the building code requirement is a likely constraint on the development of shelters because of the additional cost it adds to this type of development. 3. Supportive Housing The Draft is silent as to whether the development oecd complies with Government Code section 65583(c)(3) that allows supportive housing in any zone where multi-unit or mixed use development is permitted. If the City’s code does not reflect this requirement that is a constraint on housing for people with disabilities and a program to revise the development code to comply with the statute is required. 4. The HE Under-Analyzes Parking Requirement Effects on Housing Construction The Draft fails to fully analyze whether its parking requirements act as a constraint on housing development, especially in the downtown and along transit corridors. Parking requirements increase the cost of housing.[^p665-7] The Draft states it “determines the required number of parking spaces based on the type and size of the residential unit and has found the required parking spaces to be necessary to accommodate the number of vehicles typically associated with each residence.”[^p665-8] The analysis ignores principles of induced demand and downstream effects of entrenching car-centric land use. The Draft implicitly acknowledges that parking increases costs and may not be critical as it allows waivers for parking requirements in affordable housing developments and other transit-friendly areas.[^p665-9] The ad hoc basis of reduced parking requirements introduces uncertainty which can increase the overall cost and time delays in housing development. Recently, the City has made clear how much of an impediment parking really is. In negotiations with the state to receive a large grant to support increased housing in downtown Fresno, the City earmarked about $70 million of a possible $250 million grant for two new parking structures in the downtown area. Mayor Jerry Dyer stated [the cost of parking structures] “is always a big challenge for us when we try to bring in developers to build housing… Taking that off the table allows for these projects not only to occur faster, but it allows the developers to be more incentivized to build in our downtown area.”[^p665-10] [^p665-7]: http://database.greentrip.org/ [^p665-8]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-10 [^p665-9]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-10 [^p665-10]: https://www.fresnobee.com/news/local/article275363746.html 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 7 of 40 Although parking has been identified as a constraint to increased housing development, the City has not put forward a program to identify steps to remove the constraint. The City asserts “[p]arking standards are one area where many communities are seeking to decrease housing costs.”¹¹ Yet, minimum parking requirements are squarely within the control of the jurisdiction and could be reduced if the City so decided. The direct link on parking’s costs in relation to housing development in Fresno must be further analyzed, and a reduction in parking requirements is likely required. *C. Risk Analysis and Distribution of Affordable Housing* The Draft’s analysis of at-risk housing is incomplete. under-analyzes the risks to publicly assisted affordable housing and its distribution. There are more than 8,500 publicly assisted affordable housing units in the City of Fresno.¹² The Draft identified 695 units at risk of conversion to uses other than low-income residential within 10 years from the housing element adoption deadline.¹³ Although the City of Fresno considered the cost of replacing the at-risk units as required under §65583(a)(8), it failed to examine which pathway would be most appropriate for the City and what constraints, if any, would be associated with the pathway chosen. The City’s lack of tenant protections, such as source of income discrimination outreach and education, rent control, just cause protections may operate as a constraint on the maintenance of housing available to lower income people and facilitate the displacement of lower income renters. The lack of these protections should be analyzed as a constraint on the maintenance of housing under Government Code section 65583(a)(5). **III. The Housing Element Fails to Adequately Analyze and Remove Non-Governmental Constraints to Housing Development** In addition to analyzing governmental constraints, the HE must also analyze the potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels. Gov’t Code § 65583(a)(6). To that end, the Draft failed to consider the effect of market forces, availability of financing, environmental concerns, and NIMBY opposition. [^p666-11]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-14 [^p666-12]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-55 [^p666-13]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-55 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 8 of 40 *A. NIMBY Opposition* The Draft must include an analysis of NIMBY opposition to housing development. As a largely sprawling suburban City, Fresno is prone to local opposition to increased density from existing single-family homeowners that have preconceived ideas of the impacts of increased density on their neighborhoods. Further, the zoning code requires conditional use permits for duplexes and multi-family housing in some areas, making them especially susceptible to opposition and defeat from NIMBY residents. The chilling effect of NIMBY opposition to housing development is not a foreign concept to jurisdictions in Fresno County. For example, in the adjacent City of Clovis, the Clovis City Council recently voted to shut down a proposed 40-unit development near Old Town Clovis because neighbors expressed concerns about traffic congestion, overflow parking and the “monolithic” height of the planned apartment building.[^p667-14] NIMBY opposition to housing development is a widespread phenomenon across California but is especially prevalent in areas that have historically been primarily low-density developments. The Draft’s failure to analyze NIMBY opposition as a constraint must be addressed in the City’s next Housing Element draft, and the City should include a program to reduce this type of opposition by ensuring that more than single family developments are permitted by-right and reducing the discretionary review of multi-family housing. *B. Environmental Concerns* The Draft did not consider environmental constraints as part of its analysis under 65583(a)(6). Environmental constraints may include limitations to water supply, nearby pollution, or infrastructure development. The City of Fresno relies heavily on groundwater and surface water. As climate change makes water availability less predictable the City must analyze how an increased population and land use will affect water availability and whether water availability will eventually constrain growth. Further, separate from water availability, the City must consider the infrastructure requirements of delivering water to a denser population. For example, the City estimates that downtown Fresno, where a large portion of new housing development is projected, currently requires significant water and wastewater infrastructure upgrades. Broke Broche, the City’s director of public utilities, estimated that downtown Fresno would require between $160-$180 [^p667-14]: https://www.fresnobee.com/fresnoland/article255749376.html 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 million in water and wastewater upgrades to support planned housing development.[^p668-15] The Draft should analyze the cost of these needed improvements as a possible constraint on development. Finally, the Draft failed to consider industrial and polluting industries’ effect on future housing development. The City of Fresno has evolved as a car dependent City surrounded by heavy industry and highways. Therefore, future housing development will need to carefully consider placement and mitigation measures to avoid perpetuating environmental inequity. ### C. Market Forces and Availability of Financing The Draft failed to include an explanation of current housing development trends and applications across all income levels. Market forces are relevant to the types of housing that are likely to develop in the future. Once this analysis is done it might make it clear what actions the City must take, such as further financing for programs.. Using the example mentioned above, requiring private investment to implement required infrastructure in downtown Fresno would likely make housing development in the area infeasible. Similarly, lower margins or a lack of developer interest in serving lower income portions of the market may require the City to provide incentives to spur greater housing development in the segment. Without a proper analysis such a conclusion is impossible and falls short of the requirements listed in Government Code § 65583(a)(6). For example, Fresno had some of the highest rental price increases in the country, with a 28% increase in one-bedroom rent prices between January 2021 and January 2022.[^p668-16] The spike in rent prices disproportionately affects low-income individuals who are often on fixed incomes or receive low wages that have not kept up with the rapid rise in rents. Further, existing conditions in many rental units in Fresno have failed to keep up with required maintenance and would fail habitability requirements.[^p668-17] The combination of unmaintained housing in Fresno alongside rising rents was not analyzed as a constraint. As a result, the condition of housing stock available to low-income populations must be analyzed and the City must take steps to redress those constraints identified. [^p668-15]: https://www.fresnobee.com/news/local/article275363746.html [^p668-16]: https://www.fresnobee.com/fresnoland/article258073823.html [^p668-17]: https://www.fresnobee.com/fresnoland/article251600613.html # IV. Further Revisions and Analysis are needed to determine if the City’s Draft Includes Adequate Sites ## A. Regional Housing Need Allocation (RHNA) The City’s calculation of the RHNA it must accommodate must be revised to exclude units that have not been approved during the projection period. State law permits cities to reduce the number of units they must accommodate in their inventory of adequate sites, by income level, by the number of units approved or permitted since the beginning of the planning period: Projects that have been approved, permitted, or received a certificate of occupancy since the beginning of the RHNA projected period may be credited toward meeting the RHNA allocation based on the affordability and unit count of the development. For these projects, affordability is based on the actual or projected sale prices, rent levels, or other mechanisms establishing affordability in the planning period of the units within the project. See HCD’s Housing Element Sites Inventory Guidebook, p. 5, available at https://www.hcd.ca.gov/community-development/housing-element/housing-element-memos/docs/sites_inventory_memo_final06102020.pdf The City’s Draft Element appears to take credit for units that are still under review and have not yet been approved or permitted. The Draft Element cannot claim credit, meaning reduce the RHNA, with the following projects because project approvals have not been obtained for these units: Villa Baraca Apartments (P-1); DADA Lofts (p-13)(indicates the application is still being reviewed); Lincoln Park Apartments (P-16); Starling Townhomes (P-17); Latitudes at Armstrong (P-18); Helm Tower Office and Lofts (P-19); Elm Avenue Living (P-21); Majestic Palm Apartments (P-22); and, Los Pueblos Apartments (P-23). The Number of sites needed to accommodate the RHNA should reflect the removal of the above-described projects. ## B. Capacity calculation If a site does not have a required minimum density then the City must analyze the development capacity based on the patterns of typical development patterns in the same zone. The City uses a very narrow time frame to assess the development capacity of projects in the City – 2018-2020, it is unclear why the City has chosen such a narrow time frame but in order to assess if the Draft’s capacity calculations truly reflect realistic development patterns the City should use a broader time frame to establish the types of developments and capacity typically achieved. Also, the Draft should explain why the capacity calculation for the RM-1 zone was rounded down from 85 percent to 80 percent, while the same calculation was rounded up from 77 percent to 80 percent in the RM-3 zone. The City has chosen not to rely on the minimum density to calculate capacity on some mixed-use zone site (NMX, CMX, RMX) and because there are no maximum densities imposed, the City instead creates a formula that determines what is likely “reasonable density” density that could develop on these sites and then divides that “reasonable density” in half to determine the Capacity for the site. This formula is flawed because it relies on very few submitted projects (that may not be approved) to determine what reasonable density might be during this planning period. It is crucial that the capacity calculation accurately reflects patterns of development especially where the City intends to accommodate a significant portion of the lower income RHNA (72 percent) on mixed-use sites. Two examples are not sufficient to establish a pattern of development. Although the City relies less on the Downtown sites to accommodate the lower income RHNA, a correct calculation of capacity is still crucial in the DTC, DTG, and DTN zones and the DTN-AH overlay. And again, the City relies on very few projects during a very limited time period (2018-2020) to support its calculation for realistic capacity on downtown sites. *C. Non-vacant Sites* Non-vacant sites must demonstrate through the City’s methodology that they are feasible for residential development during the planning period. Government Code section 65583.2(g)(1). The methodology is required to consider certain factors. *Id.* The July Draft Element includes a description of the current use of the sites but the analysis must be revised to apply the required factors[^p670-18] in order to assess the availability and feasibility of these sites for residential development during the planning period beginning in December 2023, including the City’s past experience converting existing uses to higher density residential development. [^p670-18]: The methodology shall consider factors including the extent to which existing uses may constitute an impediment to additional residential development, the city’s or county’s past experience with converting existing uses to higher density residential development, the current market demand for the existing use, an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development, development trends, market conditions, and regulatory or other incentives or standards to encourage additional residential development on these sites. Gov. Code section 65583.2(g)(1). Michelle Zumwalt Page 12 of 40 *D. Large Sites and Concentrated Sites* The July Draft requires revisions to provide examples of whether “sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower income housing units as projected for the site…” Gov. Code section 65583.2(c)(2)(B). The Draft must also be revised to specifically identify what portions of the large parcels will accommodate the lower income housing needs in the City. The City is correct to assume that 100 percent of large sites, a site that is over 10 acres, will not likely develop for affordable housing. This is due, in part, to the limitation of available funding mechanisms for projects of over 200 units. But, identifying so many large parcels to accommodate housing for the lower income RHNA in close proximity to each other also acts as a constraint on development as affordable housing due to the same funding limitations. To be clear, identifying a large percentage of the sites to accommodate the lower income RHNA in close proximity to each other is a constraint on obtaining funding for affordable housing, funding which is critical to developing affordable housing, and it will create an obstacle to the development of these sites as affordable housing. In addition, many of these sites are also concentrated in one area of the City and that also prevents the City from meeting its duties to remove patterns of segregation and comply with its duty to affirmatively further fair housing. [As mentioned in the AFFH section above, the over concentration of sites intended to accommodate the lower income housing need in specific areas of the City is inconsistent with the City’s duty to Affirmatively Further Fair Housing.] As noted above the City’s inventory of available sites will need revisions and further analysis in order to determine whether the City has identified adequate sites to accommodate its RHNA for this planning period. **V. The Assessment of Fair Housing Fails to Comply with Section 65583(c)(10)** For generations, local mayors and council members have described Fresno as a “tail of two cities”, an illusion to Charles Dickens’ tragic 1859 novel of pre-revolution France, in acknowledgement of the outstanding disparities in quality of life and access to opportunity that exists between neighborhoods in the Northern and Southern portions of the City and the striking racial and economic differences that underlie them. Studies and data have repeatedly confirmed not only that South Fresno neighborhoods and people of color in Fresno are impacted by a severe lack of access to housing choice and access to opportunity across many indicators compared to North Fresno neighborhoods and White residents, but that the disparities impacting South Fresno, people of color and other protected classes stand out as among the most significant in the state and the country. The City’s duty to AFFH through the Housing Element and to complete an 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 13 of 40 Assessment of Fair Housing in order to do so presents the City with a crucial new opportunity to address the intergenerational disparities and barriers to opportunity that persist in Fresno. Unfortunately, as discussed further below, the AFH lacks information and analysis and fails to incorporate public input as necessary to address the requirements set forth in Section 65583(c)(10) and does not achieve the requirement to ensure that the City AFFHs through its housing element. *A. Integration and Segregation and R/ECAP and Concentrated Area of Affluence Analyses Lack Required Detail* The AFH’s analyses of patterns of integration and segregation and R/ECAPs and Racially Concentrated Areas of Affluence (“RCAAs”) fail to address important factors which must be considered as part of a complete analysis pursuant to section 65583(c)(10)(A)(ii) and HCD’s AFFH Guidelines. See AFFH Guidelines, pp. 30-34. These gaps render the AFH analysis incomplete and include but are not limited to the following: * Failure to provide any data or analyze integration and segregation patterns for racial groups other than Hispanic/Latinos. Table 1:E-3.1, “Population by Race and Hisppanic Origin, Fresno, 2000-2020,” provides data about the share of the population of different racial groups in Fresno in 2000, 2010, and 2020, but no data is included that addresses the spatial composition and segregation or integration status of Black, AAPI, Native American, and other racial and ethnic groups. Similarly, the analysis fails to identify groups experiencing the highest levels of segregation as required. AFFH Guidelines, p. 31. * Failure to accurately or thoroughly analyze distribution of low- and high-income households across Fresno. The Figure 1E-3.4, Median Household Income, Fresno, 2019 indicates median income levels across the City and depicts median incomes of $100,000 or over in some areas West of State Route 99, Northwest Fresno, Northeast Fresno, and in the Sunnyside neighborhood of South Fresno. Yet the AFH’s analysis of the data depicted by the map fails to acknowledge these high-income neighborhoods throughout the City, stating only that “Northwest neighborhoods of the city…have the highest median incomes. Otherwise, most of the remaining census block groups in the city have household incomes that fall below the statewide median indicating high poverty levels.” This analysis washes out important information about relative income levels across Fresno, including concentrations of high-income households and low-income households in specific neighborhoods, which should be used to inform and geographically-target programs and the location of sites included in the inventory to AFFH. See HCD 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Guidelines, p. 32. For neighborhoods like West Fresno, which experience particularly acute barriers to opportunity linked to policies and practices that created and enforced segregation, an accurate and complete analysis and programs that respond to that analysis are essential. * The AFH’s analysis of R/ECAPs and RCAAs fails to address “public participation, past policies, practices, [and] investments” as required. HCD Guidance, p. 33. The R/ECAP analysis provides only the generic statement that “R/ECAPs generally have less private investment from financial institutions, grocery stores, and other retail outlets,” but does not provide any analysis specific to Fresno City or regional policies, practices, and investments that contributed to the creation and/or perpetuation of R/ECAPs. The RCAA analysis only identifies that 18 RCAAs exist in Fresno, with no analysis at all of the factors giving rise to those RCAAs or their persistence or variation over time nor does it consider any public input on this topic. As a result of these and other deficiencies, the AFH’s analysis of integration and segregation and R/ECAPs and RCAAs is incomplete. The analysis and the Draft Element’s contributing factors, goals and actions must be revised accordingly. *B. Incomplete Analysis of Disproportionate Housing Needs Based on Race, Ethnicity, Familial Status, Disability, and Income* The analysis of disproportionate housing needs must analyze needs relating to cost burden, overcrowding, substandard housing, homelessness and other factors for protected characteristics, including at least race and ethnicity, familial status, persons with disabilities, and income. § 65583(c)(10)(A)(ii); AFFH Guidance, p. 39. Disproportionate housing needs “generally refers to a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing need” compared to the proportion of members of other relevant groups or the total population HCD’s guidance emphasizes that local data and knowledge are particularly important to this analysis. *Id.* The requirement to analyze disproportionate housing needs is fundamental to achieving the purpose of the AFH to ensure that the housing element affirmatively further fair housing by identifying disparities impacting protected classes which have been subject to historic discrimination, describes the factors contributing to those disparities, and adopts meaningful actions that overcome patterns of segregation and address disparities in housing needs and opportunity for protected classes. Yet, the AFH fails to satisfy this requirement. While it provides the percentage of households experiencing any one of four specified housing problems - lack of complete kitchen facilities, lack of complete plumbing facilities, overcrowding, cost burden – by race and ethnicity, the analysis of overcrowding, cost burden, and substandard conditions only addresses 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 15 of 40 the prevalence of those housing issues based on housing tenure (renter or owner) and census tract. The analysis fails to include any information about the separate occurrence of overcrowding, cost burden, and substandard housing conditions based on race or ethnicity and fails to provide any information at all about how these factors disproportionately impact Fresno residents based on familial status and disability. While the AFH includes some data relating to the race, gender, and mental disability of unhoused residents, it fails to include information relating to familial status. Further, the analysis includes no information that reflects “local knowledge” or public input, depriving the analysis of details about specific housing needs within the categories identified above and the scale of those needs in relation to others. The City must supplement its disproportionate needs analysis to include the required demographic information and revise the AFH further to ensure its contributing factors and meaningful actions reflect that information. *C. Displacement Risk Analysis Fails to Consider Relevant Housing Cost, Tenant Protection, Land Use, and Environmental Risks* The AFH evaluation of displacement risk consists of the identification of census tracts which qualify as “sensitive communities” that may be vulnerable to displacement as a result of rising housing costs and market-based displacement pressures based on demographic, tenure, rent burden, and rent change criteria developed by The Urban Displacement Project of UC Berkeley and the University of Toronto. Figure 1E-3.31, Communities Sensitive to Displacement in Fresno, provides useful information indicating that large swaths of the City, including most South Fresno and Central Fresno neighborhoods, as well as the Blackstone Avenue Corridor are vulnerable to displacement, the AFH’s displacement risk analysis falls short by failing to consider other relevant information relating to existing and potential housing cost pressures confronting low-income residents, residents of color, and other protected classes, as well as significant displacement risks associated with tenant protection limitations, City land use policies and practices, environmental hazards, and climate change. A complete displacement risk analysis must consider these and other relevant factors. See AFFH Guidance, pp. 40-43. *1. Displacements Risks Associated with Housing Cost Pressures* As mentioned above, the AFH’s identification of sensitive communities using The Urban Displacement Project’s criteria provides a helpful high-level view of the displacement pressures impacting most of the City of Fresno, and almost all South Fresno and Central Fresno neighborhoods. That mapping alone however is not sufficient to accurately describe displacement risks impacting residents associated with housing cost pressures. 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 16 of 40 First, the criteria used in the analysis rely on data from 2017 and earlier, including data relating to the change in rent between 2012 and 2017. This time period does not capture the sharp and sustained escalation in housing costs (both rental and ownership) that occurred during the COVID-19 pandemic between 2019 and 2022.[^p675-19] Between 2017 and 2021, Fresno experienced the greatest rent increases of all large U.S. cities, with rental prices increasing nearly 39% during that time.[^p675-20] Pandemic-era and ongoing housing price increases disproportionately impact the housing stability of renters, people of color, and other populations that have less disposable income and assets on average and are impacted by discrimina and sustained nature of the housing cost increases which have occurred in Fresno since 2017, the AFH’s displacement risk analysis must be supplemented with and revised based on more recent data. Second, while the AFH’s displacement risk section provides a snapshot of neighborhoods vulnerable to increased housing costs that occurred between 2012 and 2017, the section does not actually discuss housing cost trends over time or analyze the factors driving increased housing costs across the City and certain neighborhoods. The use of census tract level data alone to determine whether an area qualifies as a “sensitive community” or not, without further discussion, also washes out unique vulnerabilities experienced by particular neighborhoods which comprise only a portion of a census tract. The City must supplement the displacement risk section to include this additional information and analysis, using available data and local knowledge, in order to meaningfully identify displacement risks associated with housing cost pressures and on particular neighborhoods and protected classes. Several factors are likely or definitely associated with rising housing costs in Fresno which the AFH does not but must identify and evaluate for their impact on displacement risk. These include but are not limited to the following: * The expiration of affordability covenants attached to Low-Income Housing Tax Credit financed properties during the Planning Period. According to the Draft Housing Element’s At Risk Analysis, three properties consisting of 115 affordable units in the next four to eight years. The expiration of the affordability covenants on these properties creates a direct displacement risk to residents who are unable to pay market-rate rents. [^p675-19]: CalMatters, Real estate prices soar during the pandemic, climbing 25% in parts of California, Dec. 5, 2020, available at https://calmatters.org/california-divide/2020/12/real-estate-climb-pandemic/ [^p675-20]: Los Angeles Times, The Nation’s Hottest Housing Market? Surprise – it’s Fresno, Mar. 31, 2021, available at https://www.latimes.com/homeless-housing/story/2021-03-31/fresno-rent-spike-taps-into-california-covid-housing-trends 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 17 of 40 * Major federal, state, and local investments in public works infrastructure projects in South Fresno neighborhoods, including a $250 million phased budget commitment for downtown revitalization in the 2023/2024 California State Budget[^p676-21]; the June 2023 Federal Railroad Administration and State High Speed Rail Authority $20 million award for the Fresno High-Speed Rail Station Historic Depot Renovation and Plaza Activation Project; and an $80 million July 2023 award from the State’s Transit and Intercity Rail Program[^p676-22] for grade separation and intersection improvements in Central Fresno at McKinley Avenue and Blackstone Avenue. None of these historic awards have requirements attached to them to reduce the risk of displacement as a result of rising rents associated with neighborhood improvements. * The development of the California High Speed Rail project, with a depot in Fresno, which the draft Housing Element recognizes is expected to increase housing demand in Fresno by enabling commuting between Fresno, Coastal California, and/or Sacramento. Draft Housing Element, p. 3-79. The analysis should also consider the impact of speculation associated with HSR on housing availability, prices, and displacement risk. * The conversion of housing units to short-term rentals and their impact on housing cost pressures and displacement risk. The Draft Housing Element indicates that 7% of vacant units in the city are seasonal, short-term rentals, or “other” housing accommodations, but does not state what percentage of total units are seasonal housing or short-term rentals. The Draft states that stakeholders with Llaves De Tu Casa (an initiative involving real estate professionals, banks, the City of Fresno, and affordable housing developers) expressed concern about investors displacing community members to establish short-term rentals. Draft Housing Element, p. 1E-6-15. According to a recent news story, 811 homes were available as short-term rentals in Fresno and Clovis in June 2023, which represents a 27% increase in available rentals since 2020 and almost twice the number of homes listed for sale at that time.[^p676-23] [^p676-21]: YourCentralValley, City of Fresno announced $250 million for downtown, June 28, 2023, available at https://www.yourcentralvalley.com/news/local-news/city-of-fresno-announces-250-million-for-downtown/ [^p676-22]: See Fresno Bee, State will help Fresno rebuild a major railroad crossing. Where is it, and what will it cost?, Jul. 6, 2023, available at https://www.fresnobee.com/news/local/article277074553.html [^p676-23]: GVWire, Is an Airbnb Crisis Looming in Fresno as Demand Plummets?, June 29, 2023, available at https://gvwire.com/2023/06/29/is-an-airbnb-crisis-looming-in-fresno-as-demand-plummets/ 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 18 of 40 The AFH’s discussion of City “Displacement Avoidance Efforts” does not remedy the need for a complete analysis addressing the displacement risk factors above, including relevant City policies and practices, and the adoption of meaningful actions to address those risks. That section describes certain planning efforts the City undertook to evaluate displacement risks from rising housing prices and consider, but it does not actually provide any information about the findings of that policy recommendations and the policies that the City did or did not adopt. Given the significant stakeholder engagement conducted for the development of the “Here to Stay Report,” the AFH should incorporate and consider relevant information and policy recommendations contained in that report. ### 2. Tenant Protection, Land Use, Environmental, and Climate-Related Displacement Risks Not Considered in the AFH Displacement Risk Analysis A complete analysis of displacement risks considers not only displacement risks associated with housing cost pressures, but also other factors which result in housing instability, including factors relating to the adequacy of tenant protections, disinvestment, local land use policies and practices, environmental hazards, and risks associated with natural disasters and climate change. The Draft Housing Element considers none of these risk categories, yet based on our direct work with tenants and low-income residents and residents of color, they represent real and significant risk factors for Fresno residents. First, the Displacement Risk section does not address the adequacy of policies and resources to protect tenants from displacement as a result of eviction, harassment, and substandard housing. A coalition of residents and community-based organizations have called to the City’s attention the need for and have repeatedly asked the City to adopt additional and stronger policies and programs to protect tenants, including in particular more comprehensive and stringent rent control standards than those established by the state, just cause requirements for eviction, and right to return home for displaced residents. And while the AFH mentions the City’s code enforcement programs, it does not analyze how successful these programs have been in preventing tenant displacement and ensuring residents have a habitable space in which to live. Draft Housing Element, p. 3-79. Second, while the Draft Housing Element recognizes the occurrence of historic disinvestment and describes recent initiatives to increase investment in South Fresno neighborhoods, the AFH does not but should consider the extent to which public and private disinvestment and unequal investment continues to impact low-income neighborhoods, neighborhoods of color, and neighborhoods with a high proportion of tenants and how 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 19 of 40 disinvestment perpetuates and/or increases displacement risk in these areas. See AFFH Guidance, p. 40. Yet even today, many South Fresno neighborhoods lack sidewalks, streetlights, park space, grocery stores and other public and private investments that contribute to neighborhood and housing-stability. Third, the Draft Housing Element fails to consider the displacement risks associated with the City’s land use and permitting decisions which have directed and continue to allow for and promote the concentration of industrial and waste management facilities in and around neighborhoods in Jane Addams, Southwest Fresno, South Central Fresno (referred to by the Draft Housing Element as the “South Industrial Area”), and Southeast Fresno. The City’s General Plan land use map designates thousands of acres of land in these neighborhoods for industrial and business park uses, which encompass warehouse distribution facilities, agricultural processing operations (e.g., slaughterhouses, meat rendering facilities), chemical storage, landfills, waste transfer stations, biomass facilities, and more. Draft Housing Element, p. 1E-3-77. These designations are applied to land adjacent to land designated for and/or developed with residential neighborhoods as well land currently developed with housing. Several General Plan policies direct the City to expedite development on sites designated for industrial land uses by streamlining permitting and making sites “shovel ready” for new development through the installation of infrastructure and connection to services. City of Fresno General Plan, ED-1-d, ED-1-e, ED-1-j. *The General Plan therefore envisions and plans for the conversion of existing housing and neighborhoods to industry* and the continued proliferation of industrial land uses surrounding housing and other sensitive uses, both within existing City limits and within the City’s Sphere of Influence. 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 20 of 40 <
> City of Fresno Official General Plan Land Use and Circulation Map (Excerpt)[^p679-24] [^p679-24]: Portion of City of Fresno Official General Plan Land Use and Circulation Map, available at https://www.fresno.gov/wp-content/uploads/2023/03/Official-General-Plan-Land-Use_20220411-1.pdf 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 21 of 40 <
> **Google Earth Image Depicting S Rose Ave. & E. Kaviland Ave Neighborhood, Zoned Industrial on General Plan Land Use Map, and Adjacent West Fresno** (captured 08/16/2023) 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 22 of 40 <
> **Google Earth Image of Unincorporated Daleville Neighborhood, Zoned Industrial on the General Plan Land Use Map, & Orange Center Elementary School** 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 <
> **San Joaquin Estates Mobile Home Park (“MHP”), Villa Fresno MHP, and Fresno MHP, Adjacent to and/or Surrounded by Industrial Zoning on the General Plan Land Use Map** (captured 08/16/2023) These new warehouse facilities, in combination with existing industrial facilities clustered in South Fresno neighborhoods, have severe negative and destabilizing impacts on nearby housing. Warehouse distribution facilities, such as the Amazon and Ulta Beauty warehouses in South Central Fresno, attract thousands of truck trips that travel on roads shared with homes, schools, and parks every day. This truck traffic creates toxic diesel air emissions, dust, vibration, noise, and light glare which negatively impacts residents in their homes, including their health and well-being, the longevity and potential future occupancy of their housing. The construction and operation of facilities themselves often creates excessive dust, noise, light glare, heat, odors, and other effects which have similar impacts on residents and housing quality and stability. We have attached to this comment letter a declaration from a South Central Fresno resident describing impacts she has experienced due to the proliferation of 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 24 of 40 industrial facilities in her neighborhood. Attachment A, Declaration of Katie Taylor.[^p683-25] The City must revise the AFH’s Displacement Risk analysis to include a full evaluation of the impacts of its policies and practices relating to industrial development on displacement risks, including based on protected class status and income and reflecting the local knowledge of residents impacted by this issue, and incorporate meaningful actions to address those risks. Fourth, the AFH’s Displacement Risk section does not and should be revised to consider displacement risks associated with environmental hazards, environmental disasters, and climate change, pursuant to HCD’s AFFH Guidance. AFFH Guidance, p. 42. For instance, South Fresno neighborhoods have been impacted by a series of fires at warehouse, recycling, and other industrial facilities that have occurred during the increasing number of high and extreme-heat days over the past five years.[^p683-26] Potentially toxic smoke from these fires has at times densely concentrated in South Fresno neighborhoods, which can make breathing difficult and unsafe for residents even within their homes with windows closed. In addition, residents who live in neighborhoods with incomplete sidewalks, stormwater drainage and other infrastructure and in housing without adequate cooling are at greater risk of displacement than other residents from climate-related weather events, including extreme heat and flooding. In Fresno, which recorded temperatures of 100 degrees Fahrenheit or higher on 23 days and a high temperature of 109 degrees in July 2023, extreme heat poses a serious threat of displacement for residents who lack adequate cooling in and/or cannot afford the cost of cooling their homes. The City must revise the AFH to include a complete and accurate Displacement Risk analysis as described above and modify other sections of the Housing Element, including the AFHs contributing factors and meaningful actions to overcome disparities relating to access to a healthy environment associated with these land use patterns. **VI. The AFH Fails to Consider Significant Disparities in Access to Opportunity to Multi-Modal Transportation Options, a Healthy Environment, and Quality Education** [^p683-25]: While the resident, Ms. Katie Taylor lives immediately outside of City of Fresno city limits, she resides within the City’s Sphere of Influence and her experiences of the impacts of industrial development mirror those of many South Fresno residents who reside within the City of Fresno. [^p683-26]: See for example, ABC30, Crews Battling Large Fire at Southwest Fresno Recycling Center, June 18, 2021, available at https://abc30.com/fresno-fire-recycling-center-reyclcing-timely/10807838/; KSEE24, Massive fire burns industrial building in Fresno. What made the battle difficult for firefighters, June 26, 2021, available at https://www.yourcentralvalley.com/news/local-news/massive-fire-breaks-out-at-warehouse-near-downtown-fresno/; ABC30, Flames break out at warehouse in Southeast Fresno with homes and businesses nearby,” Apr. 3, 2023, available at https://abc30.com/warehouse-fire-southeast-fresno-east-and-florence-homeless-activity/13077246/ 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 25 of 40 The AFH must include an analysis of disparities in access to opportunity. § 65583(c)(10)(A)(ii). Access to opportunity broadly encompasses the place-based characteristics which are linked to critical life outcomes, including “education, employment, economic development, safe and decent housing, low rates of violent crime, transportation, recreation, food, and a healthy environment (air, water, safety from environmental hazards, social services, and cultural institutions). AFFH Guidance, p. 34. The AFH fails to consider disparities relating to several key components of access to opportunity, including in particular disparities in access to multi-modal transportation opportunities, a healthy environment, and neighborhood investments – issues which residents and CBOs have long raised with the City. *A. Disparities in Access to Multi-Modal Transportation Opportunities* An analysis of access to transportation opportunities must, at minimum, compare concentrations of protected groups with access to transportation options; assess any disproportionate transportation needs for members of protected classes; and analyze combined housing and transportation cost impacts on protected groups. *Id.* at p. 35. Transportation options include personal vehicles and public transportation, as well as options for pedestrians and bicyclists and other forms of group or shared transportation. *See Id.* at 48, 69, 73. The AFH’s Transit Mobility analysis, as indicated by its title, focuses exclusively on the availability of public transit, including the FAX bus system and Handy Ride, through a brief discussion of available routes and programs and policies in place to reduce fares for certain populations. This analysis fails to compare access to transportation opportunities based on protected characteristics; assess any disproportionate transportation needs for members of protected classes; provide important information about the adequacy of public transportation service in different areas of the City, protected classes, and low-income households; and entirely fails to consider access to other forms of transportation, including walking and bicycling. The City must revise the Draft Housing Element to include and analyze this missing information. In addition to the categories identified in the paragraph above, specific issues which must be considered include but are not limited to: * Barriers to access to public transportation based on route limitations, especially for neighborhoods located on the fringes of the City. This includes both disadvantaged neighborhoods which are more strongly reliant on public transportation, such as Jane Addams and areas of West Fresno and South Central Fresno, and high resource neighborhoods in Northeast and Northwest Fresno, which Figure 1E-3.18, Fresno Area Express (FAX) indicates have significant less route access than South Fresno. The housing element must consider how route 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 limitations in these areas impact mobility of residents of disadvantaged communities and their access to various forms of opportunity as well mobility and housing opportunities for low-income residents in North Fresno, considering affordable housing subsidy scoring criteria which often prioritizes public transit accessibility. * Barriers to mobility resulting from lengthy travel times for residents’ using public transportation due to bus wait times, lack of direct routes, and route limitations requiring residents to use other forms of transportation to reach their first and last stop, especially for residents in fringe neighborhoods. * Inadequate and/or absent infrastructure to facilitate safe and efficient active transportation, including but not limited to sidewalks, curbs, stormwater drainage, streetlights, crosswalks, and protected bike lanes. * Inadequate and/or absent protection from extreme weather, including climate-related weather events, such as extreme heat and flooding, that impact walking, biking, and public transportation use. This includes but is not limited to the availability of shade (e.g., trees, structures), shelter, sidewalks, and stormwater drainage. * The presence of high volumes of traffic, including heavy-duty truck traffic, on roadways used by pedestrians or bicyclists, including in and near areas zoned for industrial land uses and along designated truck routes. *B. Disparities in Access to a Healthy Environment* An analysis of access to a healthy environment must describe any disparities in access to environmentally healthy neighborhoods by protected groups, consider available statewide data such as CalEnviroScreen, evaluate consistency with the environmental justice element (if relevant), and discuss policies, practices, and investments that impact access to environmentally healthy neighborhoods. AFFH Guidance, p. 35. A complete analysis should consider any impacts on access to a healthy environment associated with the zoning, siting and operation of polluting or toxic land uses in disadvantaged communities and with climate change. *Id.* at pp. 16, 73. A robust analysis of disparities in access to a healthy environment, informed by public input, is especially important in Fresno given the high concentration of communities in low-income South Fresno neighborhoods of color that rank among the most burdened by multiple sources of pollution in the state and the relatively low-pollution burdens on many indicators born by comparatively affluent and Whiter North Fresno neighborhoods and RCAAs. The AFH’s Healthy Environment analysis includes data demonstrating cumulative pollution burdens impacting Fresno neighborhoods by census tract and provides some 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 27 of 40 information about industrial and waste processing facilities in South Fresno. However, it fails to include *any* discussion of City policies and practices underlying the stark environmental health disparities between South Fresno and North Fresno neighborhoods reflected in the data or any information or analysis about what policies, practices, and investment underlie those disparities. The analysis points to agricultural industry practices as a basis for high pollution indicator scores in Western Fresno County but does not discuss the bases for pollution disparities impacting the City of Fresno itself, including West Fresno, Jane Addams, South East Fresno neighborhoods with high cumulative pollution scores. As discussed above, City policies and practices have intentionally concentrated polluting and noxious industrial and waste management land uses in South Fresno neighborhoods and policies and practices remain in place that all promote the exacerbation of these patterns to the detriment of housing opportunities and quality of life for South Fresno residents. These policies and practices include but are not limited to impact fees for a community benefit fund, public health impact reports, and cargo/freight prohibition and revenue tax. ### C. Disparities in Access to Educational Opportunity The AFH’s analysis of educational opportunities must include an evaluation of the presence or lack of policies, practices, and investment to promote proficient schools or that contribute to a disparity in access to opportunity,” among other factors. HCD’s AFFH Guidance, p. 35. Disparities in access to transportation opportunities and environmental health, including those discussed above, significantly impact access to educational opportunity. For instance, a lack of or incomplete sidewalks, stormwater drainage, and streetlights in R/ECAPs; inefficient public transportation options; and the use of local roads by heavy-duty truck traffic may prevent students from traveling to and from school safely and on time, which may in turn have a series of impacts on students’ access to educational opportunity. Likewise, the presence of heavy industrial facilities near and surrounding schools and ongoing construction for the development of new warehouse distribution centers may disrupt learning by exposing students to air, noise and light pollution and increasing temperatures and thereby also undermining opportunities for outdoor recreation during school hours. The City should also consider how policies, practices, and investments or disinvestments relating to access to green space, tree canopy, and climate resiliency (including adequate cooling and wildfire smoke protection) impact educational opportunities at schools, especially in low-income neighborhoods. The City must revise its analysis of educational opportunities to address these and other issues not addressed in the Draft Element and revise and add to its actions accordingly. ### VII. Incomplete Analysis of Housing Element Sites’ Compliance with AFFH Duty 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 28 of 40 Housing Element Law requires that jurisdictions’ sites inventory “identify sites throughout the community” consistent with its duty to AFFH. § 65583.2; 8899.50; HCD AFFH Guidance, p. 45. The AFH must evaluate sites “relative to the full scope of the assessment of fair housing” and provide detailed instructions describing the required components of this evaluation. AFFH Guidance, p. 45. Here, the AFH fails to evaluate important components of whether the distribution of sites in the inventory AFFH and to summarize conclusions and identify specific programs to address fair housing issues associated with the locations of those sites. Deficiencies of the evaluation include but are not limited to the following: * The AFH’s analysis of the sites inventory’s impact on segregation and integration trends, like other sections of the AFH, only briefly considers impacts on the distribution of Hispanic/Latino households and does not consider at all the impact on relative integration and segregation of other races. Critically, it fails to acknowledge how the lack of lower-income sites identified in high-resource areas, including for example Northeast Fresno, will perpetuate patterns of RCAAs and R/ECAPs. *See* AFFH Guidance, p. 45. * The AFH lacks analysis of the impact of its sites locations on access to specific forms of access to opportunity and therefore fails to identify any programs to address fair housing barriers to which its site selection gives rise. The sites inventory includes a large share of sites in low-income neighborhoods of color impacted by poor environmental health indicators, industrial zoning and concentrations of industrial and waste management facilities. The inventory also includes sites located near State Routes 99, 41, and 180 as well as many sites on Blackstone Avenue, a heavily trafficked thoroughfare. The City must analyze these and other impacts on access to a healthy environment implicated in its choice of sites. In addition, the AFH lacks analysis of how absent or incomplete infrastructure, services, and amenities impact access to opportunity on sites included in the inventory and fails to identify programs to address these barriers. The Draft Element includes a significant share of sites in areas West of State Route 99 which are not yet developed and which lack basic infrastructure, services, and amenities, such as sidewalks, streetlights, public transportation, park space, and grocery stores as well as City water and sewer connections. Many of the lower-income sites identified in low-income South Fresno neighborhoods also experience disparities in access to critical infrastructure and services which must be considered in an analysis. * Only 23% of sites included in the inventory to meet the lower-income RHNA are in high and highest resource areas, which the AFH states is due to the predominance of single-family zoning north of Shaw Avenue. 1E-3-109. “Where the analysis of the 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 inventory indicates that the community has insufficient sites appropriately zoned and located to accommodate its lower-income RHNA in a manner that affirmatively further fair housing, the housing element must include a program to address this inconsistency, such as making additional sites available to accommodate its lower-income RHNA in a manner that affirmatively further fair housing.” AFFH Guidance, p. 45. Despite its recognition of the limited number of lower-income inventory sites in high resource areas, the AFH fails to describe a program included in the Draft Element to adequately address this fair housing issue. As further discussed in this letter below, while the AFH points to Program 2 as the Draft Element’s action to address this fair housing issue, the program fails to ensure that it will actually add sites to the inventory to meet the lower-income RHNA in high-resource areas or that it will facilitate development of lower-income housing in high-resource areas at all. The program commits only to “present potential sites or rezoning options for land in high resource areas for Council consideration for higher density development.” p. 1E-18. While the time frame section indicates that City will rezone sites in high resource areas by 2027, the language in the body of the program does not make the City to actually rezoning sites or to include additional sites located in high-resource areas to the housing element and therefore renders the commitment that the Program is making ambiguous. The Program also makes no commitment to ensure that sites that may or may not be rezoned or impacted by this Program are “suitable” for development pursuant to the Housing Element Law’s standards, including that increased capacity is created on vacant and/or underutilized sites. Further, the City provides no analysis justifying its selection of 750 units of additional capacity as its target or if that quantity is sufficient; if changes to permitting and zoning standards of sites located in the Office District will create sites near amenities and resources and with relatively low environmental burdens within high-resource census tracts; why rezoning of sites within low-density, higher income neighborhoods which are still under development is not proposed and that impact of the failure to include such sites on addressing patterns of segregation and exclusion. The Program also fails to address barriers to housing opportunity for lower-income residents who reside in housing developed in high resource areas, including inadequate public transportation options, affordable fresh food, and cultural and linguistic resources. * The AFH sites inventory analysis includes no discussion of local knowledge and community input, pending development, development potential and other relevant factors which must be discussed in a complete analysis. AFFH Guidance, p. 45-46. Michelle Zumwalt Page 30 of 40 The City must address these deficiencies in the AFH’s sites inventory analysis and include additional meaningful actions, with deadlines and clear outcomes, to overcome the fair housing issues associated with the Draft Element’s inventory. **VIII. Failure to Fully Analyze Contributing Factors and Lack of Meaningful Actions to Affirmatively Further Fair Housing Render the Draft Housing Element Noncompliant.** The City has failed to complete an adequate analysis of factors that have contributed to patterns of segregation and as discussed above the program actions included in the draft housing element do not and will not effectively AFFH as required by law. Unless and until the City fully analyzes factors that have contributed to patterns of segregation, identifies which factors it will address along with the programs and policies it will rely on to do so and metrics that demonstrate success, the housing Element will be out of compliance with state mandates. (See Government Code section 65583(c)(10)) **IX. Failure to Adopt Community Identified Programs That Will Result in A Beneficial Impact During the Planning Period and AFFH** Housing Element Law requires that housing elements include programs with a schedule of actions with timelines and specific commitments that will have a “beneficial impact” within the planning period to achieve the housing element’s goals and objectives. As stated in the AFFH guidance “actions implement goals and consist of *concrete steps, timelines, and measurable outcomes*.” Pursuant to the requirement that housing elements AFFH, housing elements must also include actions to implement priorities and goals identified in an Assessment of Fair Housing (AFH). Those actions must be “meaningful” and go beyond combatting discrimination to “overcome patterns of segregation and foster inclusive, affordable and stable communities.” AFFH Guidance, p. 46; *See* Government Code §§ 65583(c)(5)&(10, 8899.50(a)&(b). The draft element’s Housing Action Plan contains numerous actions that lack concrete steps and measurable outcomes and will not necessarily result in a beneficial impact during the planning period in violation of the Housing Element Law’s standards. Certain programs fail to identify concrete steps, specific actions the city will take to complete each program, use of vague language, and do not provide adequate timelines. Finally, the action plan fails to include community identified programs and solutions collected from public hearings and workshops. Examples of inadequate programs, and some of our recommendations to improve them, include the following: 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt * **Program 1 - Maintain Adequate Sites.** Program 1 states that the City shall continue to maintain a current inventory of Housing Element sites to ensure that it can adequately accommodate the 2023-2031 RHNA” Given the impact of rezoning to the availability of and location of sites suitable for housing, the City should take additional steps to ensure transparency in decision-making related to proposed rezones and take diligent steps to provide notice of the proposed rezone along with an assessment of the potential impacts of the rezone on housing opportunity prior to a decision on the proposal. This includes but is not limited to public hearings and door to door canvassing to facilitate effective notice. Further, the city must conduct a racial equity analysis which would include the benefits and disadvantages of the proposed rezone and whether it would result in displacement of protected racial/ethnic groups, reduce housing opportunities for protected groups, and how it would impact patterns of segregation. Finally, the program should explicitly prohibit the rezoning of sites suitable for lower income households to industrial land use classifications which would bring industrial uses next to or near neighborhoods that include or are planned for housing affordable to lower income residents. This is critical to ensure that the City is compliant with its duty to affirmatively further fair housing. * **Program 2- Variety of Housing Opportunities in High Resource Areas (*identified in the AFH as a Meaningful Action*).** The program states that the City “will identify and pursue opportunities” with affordable housing developers to promote the development of affordable units in high resource areas. Unfortunately, it does not provide any details on how they will in fact promote the development of affordable units for lower income households in high opportunity areas. There is no clear commitment to zone sites for multi-family development in areas of high opportunity or a commitment to ensure that such units are affordable to all income levels. Further, there is no commitment to match funding opportunties with the identification of available sites to facilitate their development. Notably, the City will not conform with its duty to AFFH if it does not ensure adequate sites for affordable housing for lower income residents in high resource areas. Without clear and enforceable commitments and timelines, this program will not provide a beneficial impact or further fair housing. Furthermore, in order to expeditiously address the lack of housing opportunities accessible to lower-income residents in high resource areas, the timeline of this program should be shortened. 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Accordingly, a specific objectives of this program should be changed to (a) assess the number of sites that must be rezoned in high resource areas (as identified in TCAC/ HCD’s Opportunity Maps) to effectively AFFH , and (b) rezone the adequate number of sites pursuant to that analysis by December of 2025. * **Program 3 - Encourage and Facilitate Accessory Dwelling Units (ADUs) (*identified in the AFH as a Meaningful Action*).** While we support and encourage the development of ADUs, the program does not outline clear commitments that will yield identifiable beneficial outcomes. The program states “a primary objective of this program is to increase the supply of affordable units throughout the city” but fails to identify any specific commitments to take any action on how this objective will be reached. Additionally, building ADUs is generally not an accessible housing option to low income households who cannot afford predevelopment costs associated with ADUs. We recommend additional measures in this program to make ADUs accessible to lower income households such as targeted outreach to low-income homeowners, incentives for landlords to make ADUs affordable, no interest loans for ADU development and waivers for inspection fees Additionally, a dedicated liaison in the Office of Community Affairs should be available for all questions regarding ADUs. * **Program 8 - Use of Sites in Previous Housing Elements..** Program 8 should be updated to clarify that streamlined approval will be available to both vacant and non-vacant sites through a zoning amendment. As written it appears that the zoning amendment will only apply to vacant sites included in the 4th and 5th cycle housing elements. * **Program 9 - Annual Reporting Program.** While we appreciate the sentiment that the City will “engage all members of the Fresno community,” and the specific commitment to use multilingual notices and media, the City should revise this program and avoid using vague language with no commitments. To make the public engagement associated with this program meaningful, we recommend that the program include a commitment and associated timeframe for the City to implement input received through its various outreach efforts such as workshops and surveys in addition to the annual public hearing. The annual report should include specific actions the City will take to overcome identified constraints and barriers to complying with Housing Element programs. * **Program 10 - Incentives for Housing Development (*identified in the AFH as a Meaningful Action*).** This program does not present a commitment to address housing 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 production for low-income units or actions that will be taken to complete the program. To facilitate and promote the use of available incentives, the city should make a list of incentives, including density bonus incentives and impact fee waivers, available to the public through an accessible database. Additionally, the program’s current language that it will “identify site opportunities in higher resource areas and …improve access to resources” suffers from the same issues hat program 2 does insofar as it fails to identify clear and enforceable commitments and steps that it will take to ensure the availability of sites for lower income households in high opportunity areas. It is critical for this program’s success and the City’s role in AFFH that the housing element includes clear, timebound, and enforceable actions to ensure availability of sites for lower income households in high resource areas, as outlined above. Finally, the City should include enforceable commitments to avoid displacement and gentrification in the Downtown Planning Area, and assess the role that priority processing in the area has on the City’s duty to AFFH. * **Program 11 - Local Housing Trust Fund *(identified in the AFH as a Meaningful Action)*.** The Local Housing Trust Fund is a great tool to alleviate the housing crisis and we are glad to see the City’s commitment to leverage State matching funds. We recommend adding the creation of a Community Advisory Board as an action to ensure that projects are driven by a community process and benefit the most impacted residents. Housing advocates have met previously with City staff to develop an equitable Community Advisory Board made up of a diverse group of residents most impacted by housing barriers, legal experts, and small landlords. * **Program 16 - Surplus Public Lands.** The commitment to release surplus sites appears to simply be a commitment to comply with its existing duties under the Surplus Lands Act. The language is ambiguous, non-committal and must be revised. In addition, the program states the City will “consider depositing a portion of up to 100 percent [of sale proceeds] to the LHTF” We recommend instead that the City commit to depositing 100 percent of sale proceeds into the LHTF. * **Program 18 – Home Buyer Assistance *(identified in the AFH as a Meaningful Action)*.** While a critical program for many Fresnans, this Program should include 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 additional commitments to ensure that low-income residents, undocumented residents, residents who speak languages other than English, and residents in racially and /ethnically-concentrated areas of poverty (R/ECAPs) have the opportunity to benefit from these funds. During the 5th Cycle planning period, many residents without social security numbers or who faced language access barriers were unable to apply for the City’s homebuyer assistance program. While the City was able to assist nine families with this program, this program must incorporate mechanisms that will allow more families to apply during the next 8-year cycle by addressing barriers and pursuing state funds every year. This program has other deficiencies that must be addressed such as lack of public outreach and lack of interpretation for applicants applying by phone. Solutions include: ensuring that low-income residents are knowledgeable about the programs, undocumented residents are able to successfully apply for this program, including closing costs as part of funding packages. In order to ensure that residents living in R/ECAPs are targeted, we recommend the City create annual reports listing how many applicants were assisted, outreach efforts made and whether they live in R/ECAPs. Due to the concerns outlined above, the program as currently implemented and drafted fails to adhere to HCD’s AFFH Guidance that “actions must be specific with timelines, discrete steps and measurable outcomes to have a ‘beneficial impact’ during the planning period.” * **Program 19 – Housing Choice Voucher Incentive Program (HCV) *(identified in the AFH as a Meaningful Action)*.** This action fails to include meaningful actions with specific timelines, and measurable outcomes to have a “beneficial impact” during the planning period. The program should develop and implement a proactive enforcement program housed within that legal department to ensure HCV . The City should revise this program action to include a timeline of one workshop a month (twelve workshops throughout the year) to ensure residents and landlords are able to access housing quickly and better assist residents/landlords going through any issues that prevent them from using/accepting HCV. Additionally, collaborating with and funding CBOs and fair housing organizations to provide information to voucher holders and landlords on California’s source of income discrimination prohibitions. The program should also commit the City of Fresno to finance billboard ads about protections against HCV discrimination and send informational materials to all landlords in Fresno registered in the rental registry regarding HCV. Finally, the program should be revised to include a commitment to actively pursue enforcement against discrimination against voucher-holders and supplementing vouchers with additional subsidies to support voucher use in higher-cost markets in high resource areas. Northeast Fresno has very 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 limited HCV use, with only four census tracts north of Herndon Avenue containing any HCVs, and of those four tracts, no tract exceeds 5 percent HCV use. By revising the program to include the above recommendations would help address fair housing needs in Fresno. * **Program 21 – Housing Rehabilitation (identified in the AFH as a Meaningful Action).** Government Code section 8899.50 requires “meaningful actions” well beyond combating discrimination to overcome patterns of segregation and foster inclusive communities. These actions, as a whole, must address significant disparities in housing needs and in access to opportunity.” The current program has failed to address the needs of extremely low income residents and vulnerable populations such as undocumented residents. As we continue to see the negative effects of Climate Change across the world, it is imperative that the City include weatherization such as cooling mechanisms, like heat pumps, air conditioning, insulation and other cooling assets to increase resilience to extreme heat as part of the rehabilitation program. It is a critical and urgent need given that extreme heat kills thousands per year and impacts disadvantaged communities the most. Additionally, the City must establish an acquisition and rehabilitation fund to purchase older, blighted, and/or abandoned homes/buildings. The City of Fresno can establish a revolving fund to insure that rehabilitated homes are sold back to the community at a low cost.Finally, for the program to have a beneficial impact the timeframe section should include 15 rehabilitation grants annually, and 5 distressed property grants using PLHA and CDBG funding for extremely low and low income residents. * **Program 22 – Comprehensive Code Enforcement.** While we appreciate Code Enforcement’s response and the City’s diligence to keep increasing staff, there are still additional actions that should be taken to create a comprehensive code enforcement. HCD’s AFFH Guidance recommends that “to overcome contributing factors to fair housing and affirmatively further fair housing, actions must consider a wide range of actions across all action areas. The number and scale of actions will depend on the severity of the needs but regardless of need, a cohesive and effective program will consider multiple action areas.” This program as written continues to fail to address critical housing issues since the last housing element cycle. The program should be revised to include actions around legally holding landlords accountable for retaliation, unlawful evictions, and harassment towards tenants who file code enforcement complaints such as a commitment to adopt a tenant anti-harassment ordinance. As stated, Michelle Zumwalt Page 36 of 40 we recommend that the City adequately analyze code enforcement's procedures and incorporate tenant feedback for a comprehensive code enforcement program. * **Program 23 - Special Needs Housing *(identified in the AFH as a Meaningful Action)*.** Much of the language in this program is vague, noncommittal, and does not provide adequate actions in order to provide a beneficial outcome. This program states the City “shall advocate for provision of special needs,” “partner with and encourage local and state non profits,” and “provide/encourage.” These actions are not concrete or specific and provide no assurance of a beneficial impact on persons’ with disabilities access to housing. This should be revised to include review and enforcement of compliance with legal requirements for accessibility of multi-family and affordable housing, including in permitting processes, not just “encourage[ing]” accessibility features. Additionally, we recommend that the program add specific actions to remove barriers to housing by special needs groups such as allowing undocumented residents to apply for and receive housing assistance, vouchers and other subsidies unless otherwise required by federal law. * **Program 26 - Equitable Community Investments *(identified in the AFH as a Meaningful Action)*.** Program 26 states it will “seek funding,” “continue to actively seek resources,” and “continue implementing the written policies.” These commitments are vague and non-committal. There are no actions on how these will be completed and is ambiguous and as a result provides no indication that a beneficial outcome will result from the program and further fair housing. The programs continue not to commit the City to take a lead role in planning, funding, and/or constructing projects or indeed any role beyond identifying issues and needs and seeking funding on an annual basis. Additionally, it should not rely on the General Plan’s identification of Priority Areas for Development Incentives in Chapter 12 and should instead use the Urban Displacement Project data to guide investments. * **Program 28 – Opportunity To Purchase Act (OPA) *(identified in the AFH as a Meaningful Action)*.** Although we appreciate the City’s action to initiate research on a local Opportunity to Purchase Act, we strongly recommend that the City implements robust outreach and engagement, in partnership with CBOs that work closely with low-income communities in racially/ethnically-concentrated. Additionally, the program states it “shall research" and “consider establishing an OPA.” These are not commitments 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 and fail to implement any specific, firm, or enforceable commitment such that no beneficial outcome of the action is indicated. * **Program 29 – Mobile Home Parks (*identified in the AFH as a Meaningful Action*).** Program 29 contains no commitments, actions, or enforceable language that will ensure a beneficial impact throughout the planning period. Additionally, this program repeats verbatim language included in Program 10A of the 2015-2023 without explaining how or why reliance on the same program action will have better results during the next planning period. With residents like Three Palms and Trails End Mobile Home Park experiencing the negative impacts of slumlords, it is crucial that the City make significant improvements to the program actions. Furthermore, the program must address the need for heat resiliency such as weatherization and insulation especially to older mobile home parks by funding a mobile home park renovation fund for all mobile homes. This fund will help low income families with issues that they need to address due to inspection violations or other habitability concerns. Additionally, this program should include a commitment to penalize and fine mobile home park owners who are not providing adequate and safe conditions for their tenants. For example, Three Palms Mobile Home Park had not had safe drinking water for quite some time and the owner was never made responsible for this clear human rights violation. Finally, consistent with the City’s responsibility to AFFH, the program should support quality of life and access to opportunity improvements for all mobilehome parks in Fresno by taking meaningful actions to increase green space, transit, and resources near mobile home parks. * **Program 30 – Emergency Rental Assistance Program (*identified in the AFH as a Meaningful Action*).** Although we appreciate the City adding this program, it states that the City will “seek additional funding” and fails to commit ongoing funding that can come from the Local Housing Trust Fund, the General Fund, or its own permanent funding source to ensure a beneficial impact during the planning period. Identification and commitment of a permanent local source of funding by 2024 will highlight a commitment to prevent displacement and protect tenants. * **Program 31 - Eviction Protection Program (EPP) (*identified in the AFH as a Meaningful Action*).** The Eviction Protection Program is a critical anti-displacement and anti-homeless tool. However, the program's current language to “seek additional funding” to support the “EPP” is not a strong commitment and does not provide indication that a beneficial outcome will occur if funding is not replenished. We strongly recommend that 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 38 of 40 the City commit to staffing 5 full-time staff for screening so tenants are able to receive help as soon as possible. We also recommend program expansion to include: * Wide-reaching outreach and education campaigns * Direct legal representation and assistance for low-income tenants encountering legal issues. This includes but is not limited to being served with a notice from their landlord (e.g. 3-day notice, notice of rent increase, etc.) * Evaluation of the Eviction Protection Program to ensure it is effective and address issues to improve the program. * **Program 33 – Homeless Assistance (identified in the AFH as a Meaningful Action).** Program 33 does not commit the City to any concrete action. The program states it will “identify partnership opportunities,” “leverage the homeless assistance response team” and “support the Voucher Incentive Program” none of which commit to any enforceable and actionable items. The city must commit to completing an adequate analysis of needs of unhoused City residents. This should include the completion of an AFH analysis of disproportionate needs. * **Program 34 - At-Risk Housing.** Program 34 includes actions without a clear commitment to take steps that will lessen the severity or impact of the issue in any timeframe. Again, the language is non-committal, vague, and ambiguous in how the program will reach its objective. Additionally, stronger tenant protections should be included as an objective and completed no later than June 2024 for residents facing displacement and an affordable housing resource map for tenants so they have the option to relocate. * * * * * 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 39 of 40 Thank you for your consideration of our comments. We look forward to discussing them with you and continuing to work with the state and the City to ensure that the City adopts a Housing Element that fully complies with the law and addresses the serious housing needs and disparities that impact Fresno City residents. Sincerely, Valerie Feldman Staff Attorney PILP Karla Martinez Policy Advocate LCJA CC: Hillary Prasad, Housing Policy Specialist, California Department of Housing and Community Development Jose Ayala, Housing Policy Specialist, California Department of Housing and Community Development Scott Lichtig, Deputy Attorney General, Bureau of Environmental Justice, Department of Justice Robert Swanson, Deputy Attorney General, Bureau of Environmental Justice, Department of Justice 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 40 of 40 **Attachment A:** **Resident Katie Taylor’s Declaration of Industrial Impacts** <
> **DECLARATION OF KATIE TAYLOR IN SUPPORT OF** **SOUTH FRESNO COMMUNITY ALLIANCE’S COMMENTS ON THE CITY OF** **FRESNO’S GENERAL PLAN FINAL PROGRAMMATIC** **ENVIRONMENTAL IMPACT REPORT (SCH #2109050005)** I, Ms. Katie Taylor, declare: 1. I am a resident of Fresno, California. For over fifty years, I have lived on Central Avenue near its intersection with Orange Avenue in unincorporated Fresno County, just South of Fresno City limits. 2. The Amazon Fulfillment Center was constructed across the street from my house in 2017. The Ulta Beauty distribution center was built less than half a mile from my house in 2017 as well. There are other large facilities near my house, including the FedEx terminal, that attract traffic. Several other truck terminals and truck stops have been built around my neighborhood in the last few years as well. It seems like there are always new facilities being built nearby. 3. I was never notified that large warehouses were going to be built so close to me. When I saw the orchard trees being plowed down across the street, I did not know why. I thought the property owners were just going to plant more fruit trees. My neighbors thought the same thing. The next thing we knew there were big buildings being constructed. We were not given an opportunity to provide input on whether these projects went forward, the types of impacts they might have on the community, and what types of mitigation to avoid and reduce the projects’ impacts might be appropriate. We were not given the opportunity for our voices to be heard. 4. I am not aware of the City ever contacting me or my family to inform us of the City’s development of its current General Plan (“2014 General Plan”), the 2014 General Plan Master Environmental Impact Report, the Programmatic Environmental Impact Report for the 2014 General Plan, the Roosevelt Community Plan, or other action to zone or pre-zone land in my neighborhood for industrial land uses. 5. Three of my family members have passed away from cancer. My husband, daughter, and son all died of cancer. Some of my neighbors have died of cancer too. I have a heart condition and thyroid problems. I have allergies as well. My allergies have gotten worse since the warehouses were built. Some of my neighbors’ children have asthma, which they say has gotten worse. 6. The construction of the Amazon facility had major impacts on me and my neighborhood. While construction was ongoing for months, the Amazon construction covered my house with dust. The construction occurred at night as well. The nighttime construction was loud and they used very bright lights. The truck traffic during the construction was also extremely loud. and I could hear the noise from within my home with the windows shut. The construction caused vibrations that were so strong that my house shook on some occasions. 7. Since the Amazon and Ulta facilities began operating, the car and truck traffic in my neighborhood has increased significantly. People who come visit my house are shocked by how much traffic there is now. There is traffic traveling to the facilities 24 hours a day, seven days week. A loud rumbling from the trucks passing can be heard all hours of the day and night. The vibration from the trucks shakes my house. The trucks are so loud sometimes that it sounds like someone is knocking at my door, and it can sometimes be hard to hear visitors talking in my house when trucks pass by. 8. The trucks going to and from the facilities create a lot of dust and fumes, which covers my house and car constantly. I have to clean the dust off the windows of my house and car almost every day. The dust also seeps into my house through cracks in my doors and windows. My neighbors complain about the dust getting inside their houses too. 9. Traffic lights were put up at the intersection of Central and Orange when the Amazon warehouse was constructed. The lights are very bright and blink continuously. They shine into my windows, which disrupts my sleep. My daughter has Down syndrome and autism. The constant flashing of the traffic lights is very disturbing for her because of her condition. 10. I have noticed that my neighborhood has become hotter since the warehouses were constructed, including during the night. I am forced to use my air conditioning more, which increases my energy bill. My neighbors have also noticed that it is hotter, that the neighborhood does not seem to cool down as much in the evening as it used to, and that they have to use their air conditioners more. 11. I have noticed that the traffic from the warehouses affects pedestrians. People I know that walk around the neighborhood have to be very careful because of the traffic. Some of the Amazon employees drive recklessly. I have noticed more accidents because of the traffic from the warehouses. There is frequently congestion from employee vehicles backed onto Orange Avenue near my house. 12. The water pressure at my house has dropped in the last four or five years. I have to pay for a water tank that comes every two weeks. My water is contaminated. One of my family members tested the water and found that it was not safe to drink. A person from UC Davis came and tested my water too and told me not to drink it because of the contamination. 13. I am worried that the value of my house has gone down because of the warehouses and other facilities. I believe that the value of my neighbors' houses has gone down too. This really hurts us because we do not have very much money, my home is my main source of wealth, and we are trying to pass our homes down to our kids to help support them economically. 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 14. Since about 2017, my neighbors and I have made many efforts to seek that the City stop approving new warehouses and industrial facilities in my neighborhood, that they notify us before studying and approving any new projects and allow us an opportunity to provide input, and that industrial developers and land owners respect these requests. When I and my neighbors have talked to the City and the developers, we tell them about the noise, dust, traffic, health problems, lowered property values, and other impacts from the warehouses and other projects. But they ignore us and keep building projects here without even notifying us first. It feels like we are not being heard. It feels like they are bullying us—like we are being targeted because of our race and because we do not have a lot of money. 15. The traffic, noise, dust, health, and other impacts from the facilities have caused me to suffer from a significant amount of stress and anxiety. For example, the abrupt loud noises and flashing lights are very unnerving and stressful. The heavy traffic from cars and trucks makes me constantly worry about my family's safety. My daughter has also said that she worries about the traffic, noise, and other impacts from the facilities. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration is executed on September 13, 2021, in Fresno, California. [Signature of Ms. Katie Taylor] Ms. Katie Taylor 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 *A Nonprofit Housing and Community Development Organization* October 20, 2023 **Re: Comment Letter - 6th Cycle 2023-2031 Housing Element Update (HEU)** Dear Partner: Self-Help Enterprises (SHE) appreciates the opportunity to comment on your 6th Cycle Housing Element Update. We believe it is essential we all work together to identify meaningful opportunities to create affordable housing opportunities in the San Joaquin valley. Our service territory includes San Joaquin, Stanislaus, Mariposa, Merced, Madera, Fresno, Tulare, Kings, and Kern counties. Incorporated as a nonprofit in 1965, SHE has built, acquired, or substantially rehabilitated nearly 16,000 units of home ownership and rental housing exclusively for low-income households in this footprint. Our general comments are outlined below: 1. **Affirmatively Furthering Fair Housing:** It is imperative that cities and counties include as many high or highest resource sites as possible in their Housing Element site inventory. The ratio of these sites to other lower resource sites should be 1:1. The City/County should overlay the high opportunity zones on the housing inventory map to determine sufficient high opportunity sites are included and/or identify additional high opportunity sites to be included in the site inventory. This should be done in accordance with the 2023 California Tax Credit Allocation Committee and the Department of Housing and Community Development Opportunity Mapping Methodology to promote access to opportunities. 2. **Surplus sites:** We encourage City/County partners to adopt a program to review all surplus property within one year of adoption of the Housing Element and make those sites available for the development of affordable housing. There are provisions in the Surplus Land Act (SLA) which allow for an expedited process for sites that qualify as “exempt surplus land” which is land determined by a local agency and verified by HCD and allows for streamlining the process for disposing of land for affordable housing. There are currently scoring incentives for funding affordable housing on surplus sites and it is imperative these sites be identified quickly and made available for the development of affordable housing. 3. **Entitlement Processes:** Increasingly, we have found it expedient to utilize “by right” pathways to project approvals through density bonus law, SB 35 permit streamlining, and the Housing Accountability Act. Frivolous and NIMBY-driven CEQA challenges have been “discovered” in valley communities to delay and sometimes kill projects. It is imperative that cities and counties ensure their ordinances and local practices do not conflict with such streamlined processes. Requirements for Conditional Use Permits in otherwise compatible zoning is to be discouraged wherever possible. Main Office: 8445 W. Elowin Court · P.O. Box 6520 · Visalia, CA 93290 · Phone (550)651-1000 · Fax (559)651-3634 info@selfhelpenterprises.org · www.selfhelpenterprises.org 4. **Suitable Sites:** Many jurisdictions in past Housing Element cycles have come up with what may initially look like impressive inventories of available sites, when in fact most have no feasibility for development. Suitable sites must include: a. Sewer, water, and dry utilities proximate to the site in question, without a need for upsizing or significant offsite development. b. A significant portion of the available acreage in the adequate sites inventory (at least 50%) should have minimum parcel sizes of 2.5 to 3 acres (and larger if onsite storm drainage is required.) c. Reasonable densities. In most valley communities’ reasonable densities are 20-50 units per acre, and projects below 50 units are generally not feasible in today’s funding environment. d. Access to quality transit. The City/County should adopt a program to evaluate the site inventory in relation to the transit system and ensure 75% of the inventory sites available for high density multifamily development are within 0.5 miles of a transit stop. 5. **Manufactured Homes** The City/County should consider adding a program to revise its zoning ordinance to add Manufactured Home on a Permanent Foundation to be allowed in all zones that allow single-family residences. The City/County should allow this in the identified zones without requiring a discretionary approval process. 6. **Fee Waivers or Deferral** The City/County should consider a fee waiver program for projects that include 100% affordable housing serving households below 80% of area median oncome. If the City/County is unable to waive fees, we strongly encourage deferral for a period not to exceed 30 years with the deferral recorded as a form of deferred note and secured by the property for affordable single-family housing development and 55 years for affordable multi-family housing development. The note would be due and payable if the property were sold, refinanced, or the rent is no longer affordable (with multifamily properties), or is no longer occupied by the owner (single-family home). Thank you for the opportunity to comment on your Housing Element. Self-Help Enterprises is available to serve as an affordable housing resource and we encourage you to reach out if you ever have questions on how to promote and support affordable housing development in your community. If you are interested in consultation, please contact me at betsyg@selfhelpenterprises.org or at (559) 802-1653. Sincerely, Betsy McGovern-Garcia Vice President EMAIL TO: housingelement@fresno.gov BY AUGUST 15TH! SUBJECT: MJHE Plan 2 and PLAN 3 The following are my reasons for opposing Plans 2 and 3: 1- Your MJHE Plan is a Plan which takes a law passed in Sacramento to address the issues of homelessness and housing shortages and arrives at “A SACRAMENTO SOLUTION”. Homelessness & housing shortages are conditions that WE IN THIS NEIGHBORHOOD did NOT create! 2. ADU’s (Plan 2)- Most of us chose this neighborhood BECAUSE it is zoned “Single-Family Residential”. AARP cites that “ADUs change the character of a neighborhood and cause problems for a community that was NOT BUILT for higher density”. We SAVED to buy our homes in this lower density neighborhood! 3. Your “Masterpiece Plan” presents a VERY ONE-SIDED VIEW of ADUs. It emphasizes “Make an income/extra money. House extra family or caregivers.” Shame on you for not providing FULL DISCLOSURE of the downside to ADUs to any and all interested parties! 4. In reviewing professional, expert opinions, we are advised “DO NOT COUNT ON ADU INCOME TO LIVE ON... due to the frequent jurisdictional changes [for rentals] that occur”. (Think Covid- property owners were unable to evict for non-payment, unable to collect rent owed, owners are limited to a “Sacramento-fixed” percentage of raising rent depending on how many rentals they owned- just to identify a few issues.) 5. Your Plan states placing ADUs in single-family neighborhoods with higher median incomes is to “facilitate housing mobility opportunities for lower-income households...” (Pg 1E-4-17). This is nothing more than a “Calif Social Experiment”! Your Plan has no mention of: 6. ... the costs and responsibilities involved in rental units that eat into passive rent income. Yet you hilight income... 7. ... how extra POLICE or FIRE PROTECTION will be provided at a time when our Mayor and Chiefs of Police & Fire are desperate for recruits to fill CURRENT vacancies. Then there are CITY RENTAL INSPECTIONS! 8. ... details like parked cars crowding our streets, about how adding mailboxes or garbage cans will be determined, the disruption to the privacy of neighbors and those in the main home w/ADU renters coming or going. 9. ... about a home that is already a rental. Can the property owner simply ADD an ADU if the current renter objects? 10. *Low-Income Housing (Plan 3)*- Fresno's low-income housing is poorly kept. I OBJECT to what becomes eyesores in my neighborhood! 11. Building low-income, multi-family units in our neighborhood- in your "Infill Opportunity Zones" or ANY "rezoned" property- again brings up the issue of A LACK OF police and fire personnel. 12. In the *Wall Street Journal*, 8/8/23, front page HEADLINES- "*Apartment Landlords Face Peril As Their Debt Costs Skyrocket*". Talk about housing that will be falling apart, will be unattended, and become *OUR NEIGHBORHOOD'S PROBLEM*... 13. Incorporating your Plans 2 & 3 into NEW areas of building homes- NOT IN EXISTING SINGLE-FAMILY, LOW-DENSITY NEIGHBORHOODS- is where these plans need to be enacted. Home buyers will KNOW what they're getting, they'll KNOW what the residential components will be/are, and these buyers will have 100% awareness of the decision they make to buy in such a neighborhood. it is CRUEL to inflict these misguided plans on our neighborhoods! 14. HERE'S TWO IDEAS- A- CONTINUE the outstanding efforts to remodel and repurpose the motels and inns that have fallen into disrepair or been abandoned and use these for low-income/homeless opportunities. B- Bring in the "NECESSARY RESOURCES" to these sites. Thank you, ALLAN + BRENDA WONG 8/12/2023 From: Susan B. <[REDACTED]> Sent: Wednesday, August 16, 2023 2:13 PM To: HousingElement Subject: Comments on Fresno City Planning External Email: Use caution with links and attachments To whom it may concern I attended the meeting at Nelson Elementary with the planning group. It is clear that expanding affordable housing is and will be a pervasive issue especially in California. As a local homeowner I object to the proposal to mix our established single family neighborhood with any version of higher density building. I am also concerned about the various financial incentives to the land owner/developer and the city; that puts their interests counter to mine as any high density housing will lower my property values. Thank you for your consideration of my concerns. Best - Susan Barrows To Whom it may Concern, This housing plan is so flawed it is hard to know where to begin to critique it first. I suppose a good start is the attempt to hide the plan from the public by holding the public comment meeting during the month of August, a month when many of the potential citizens at risk from this plan would be on vacation and otherwise unavailable for comment. The basic premise of the plan is that it is only "equitable" for the majority of the rezoning for low income housing to occur in "high resource" areas, which is another way of stating high income neighborhoods. This is egregiously unfair to current homeowners in these neighborhoods, who chose to buy their homes when existing zoning laws stipulated that these neighborhoods were ONLY for single family homes of a specified lot size. If the rules of the game are to be changed, it is only fair that potential home owners know from the beginning that they are buying into a mixed ownership neighborhood. Purchasing a home is one of the largest investments most people make during their lifetime. Allowing low income housing in high income neighborhoods will destroy the property values in those areas where people have chosen to invest their life savings in their homes. Not only is this manifestly unfair, it represents an untested socialist belief that "seeding" these neighborhoods with the poor will somehow improve their lot in life. What it will achieve instead is the degradation of once stable communities and an erosion of the property values of these communities. I strenuously object to almost all elements of this plan and would urge that more meetings, well announced to the public in advance, be conducted to review any potential plans before their implementation. Furthermore, in the interest of transparency, all financial incentives for developers, current property owners, and municipalities need to be explicitly delineated for the public to understand potential conflicts of interest. Sincerely yours, Stephen P. Yeagle [REDACTED] Fresno, CA 93711 From: Michael O'Banion <[REDACTED]> Sent: Wednesday, August 16, 2023 7:29 PM To: HousingElement Subject: Fresno Multi-Jurisdictional Housing Element External Email: Use caution with links and attachments Hello, I am a long time resident of northwest Fresno at address: [REDACTED] [REDACTED] I am concerned about the Fresno Multi-Jurisdictional Housing Element program disrupting the neighborhood that I have called home for years. When my neighborhood was developed, it was zoned for single family dwellings and not multi-family residences and whatnot. We feel this program is unfair to the long-time property owners in this area who purchased and built homes with the understanding the single family zoning laws would be upheld and honored - not have the rules changed at a later date. Thanks, Mike O'Banion <
> August 16, 2023 Mayor Jerry Dyer Fresno City Councilmembers Michelle Zumwalt, Planning and Development Department 2600 Fresno Street, Room Fresno, CA 93721 **RE: City of Fresno Draft 6th Cycle Housing Element** Dear Mayor Dyer, Councilmember, and Ms. Zumwalt: Leadership Counsel for Justice and Accountability write in collaboration with the Public Interest Law Project (“PILP”) and residents of South Fresno neighborhoods impacted by the severe lack of decent quality, affordable, and permanent housing options and gaping disparities in access to opportunity in Fresno to provide comments on the July 2023 Draft Appendix 1-E: City of Fresno of the Fresno Multi-Jurisdictional 2023-2031 Housing Element (“City of Fresno Draft Housing Element” or “Draft Element”). Leadership Counsel works alongside the most impacted communities to advocate for sound policy and eradicate injustice to secure equal access to opportunity regardless of wealth, race, income, and place. Leadership Counsel advocates for policy and practice changes to meet the housing needs of all residents in Fresno, especially low-income and residents with special housing needs, and to overcome fair housing disparities that impact low-income communities of color. Residents with whom we partner experience high rates of cost burden and escalating housing costs, reside in unsafe and unsanitary rental housing conditions, and ever-present and magnifying displacement risks and are simultaneously impacted by striking disparities in access to opportunity compared to more affluent Fresno neighborhoods, including a lack of access to a healthy environment and public and private investment in critical infrastructure, services, and amenities. The Public Interest Law Project (PILP) works statewide to support local legal programs that address issues involving housing, land use, public benefits and homelessness. PILP has been providing substantive training, litigation support, and technical assistance in these areas for over 25 years. The City of Fresno’s 6th cycle housing element update presents a critical opportunity for the City to identify and address long-standing, wide-ranging, and severe housing needs and fair housing disparities that impact the City’s residents, disadvantaged communities, and racially and 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 <
> Michelle Zumwalt Page 2 of 40 ethnically concentrated areas of poverty (“R/ECAPs”), in particular, the Southwest, South Central and Southeast areas. The City must ensure that it does not miss this opportunity to develop and adopt a housing element that complies with the State Housing Element Law and civil rights laws and that meaningfully incorporates the input of lower-income residents and the community-based organizations that work alongside them. Our comments below highlight further steps and actions the City must take to meet State Housing Element Law requirements. In short, the Draft Element must be revised in order to meet Fresno’s housing needs and relevant statutory requirements in several different ways, including: * Incorporate input regarding key housing issues and disparities and actions needed to address those issues provided to the City by community members as required by HCD’s AFFH Guidance; * Revise the constraint analysis to address non-governmental constraints, as well as constraints on supportive housing and the maintenance of the housing stock. * Revise the AFH analysis to consider all of the required displacement factors, barriers in access to opportunity, and fair housing issues associated with the Draft Sites Inventory; * Revise programs to include specific actions and deadlines and add programs that will result in a beneficial impact on Fresno housing needs and disparities during the planning period and overcome patterns of segregation and foster inclusive communities, including but not limited programs 14, 15, 19, 23, 29, and 33; * Revise the site inventory analysis to exclude projects that have not been approved during the projection period, include a realistic capacity calculation based on development throughout the 5th cycle, and determine the adequacy of the non-vacant site ### I. The City Has Not Diligently Engaged the Public As Required, Because the Draft Element Fails to Adequately Reflect Public Input The City’s obligations to diligently engage all economic segments of the community and to affirmatively further fair housing through the housing element require more than just seeking input about the contents of the housing element. Government Code sections 65583(c)(8), 65583(10)(a) & 8899.50. Inviting residents to provide input but failing to incorporate that input into the housing element undermines the purpose of resident participation in the housing element update, fosters distrust, and fails to constitute “engagement” as required by section 65583(c)(8) of the Housing Element Law. HCD’s Affirmatively Furthering Fair Housing (“AFFH”) Guidance 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 3 of 40 states that housing elements must describe “a summary of [public] comments and how the comments are considered and incorporated (including comments that were not incorporated), particularly with changes to the housing element. HCD, Affirmatively Furthering Fair Housing: Guidance for all Public Entities and for Housing Element (“AFFH Guidance”), 2021, p. 22.[^p711-1] While the Draft Element provides some description of public input provided, its summary of public comments generally lacks sufficient detail for the reader to understand the nature of the issue raised or the solution proposed. In addition, the Draft Element fails to demonstrate the City’s incorporation of input provided and to identify input the City chose not to incorporate as required. For example, at the March 1, 2023 community workshop on the housing element update held at Helm Home, residents identified the establishment of rent control, tenant assistance and protections, and reducing barriers to undocumented residents as among their top suggestions and solutions. The Draft Element fails to demonstrate how this solution will be incorporated into the final draft and to even to study the housing needs of undocumented residents. The Draft Element also fails to acknowledge, discuss, or incorporate recommendations contained in the letter submitted to the City by Leadership Counsel and several other community-based organizations in February 2023 relating to the development of this Draft. *Attachment 1, Leadership Counsel February 2023 Letter*. The letter identifies policies and programs which the signatory organizations believe should be prioritized in the housing element update, based on our direct and daily work with low-income residents of color, farmworkers, residents of disadvantaged unincorporated communities, and other residents with special housing needs and members of protected classes. The City must revise the draft element to acknowledge this letter, summarize its contents, and revise goals, policies, and programs to incorporate its recommendations, in addition to other input it receives. The City must also revise the element to indicate what public input it chose not to incorporate, which the element currently fails to do. ## II. The Housing Element Fails to Adequately Analyze and Remove Governmental Constraints to Housing Development To fully comply with Housing Element law, the City of Fresno must identify constraints to the development of housing affordable to households at different income levels, as well as possible constraints to the development and maintenance of a variety of types of housing, including supportive housing, single room occupancy units, emergency shelters, and transitional housing. *See Gov’t Code* §65583(a)(5) and (c)(1). This analysis includes potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all [^p711-1]: All references to code sections hereafter refer to the Government Code unless stated otherwise. 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 4 of 40 income levels. Gov’t Code § 65583(a)(5). Following a close analysis, the City must include a description of efforts to remove constraints and a program to remove those constraints. Gov’t Code §65583(c)(3). *A. Land Use Controls Are Under-Analyzed as a Constraint* The Housing Element under analyzes the impacts of current and planned zoning regulations on housing development. A jurisdiction must include an analysis of potential and actual governmental constraints, including land use controls that directly impact the cost and supply of residential development. Gov’t Code § 65583(a)(5). The constraints analysis fails to demonstrate the direct connection between its currently proposed zoning on cost and supply of housing. The City has not adequately analyzed the effects of constraints associated with wide-spread availability of single family zoning and the limited availability of high density zoned sites. For example, the HE acknowledges “growth in the City of Fresno over the past few decades has traditionally been low density suburban development, which has resulted in conditions of sprawl in various areas of the city.[^p712-2] Despite the acknowledgement, the City continues to allow by right single-family units in. Despite the historical preference for single family development, the abundance of available single family homes in Fresno, and the underproduction of affordable housing,the the City still permits single family uses by-right in many of the zones identified for increased high-density development: RM-1, NMX, CMX, RMX, CMS, CR, DTN, DTG. Further, although single family development is allowed in almost every zone that permits residential development, higher-density units are not allowed in certain areas in the City. For example, multi-family units are not allowed in RS-1, RS-2, or RS-3 areas, despite the large majority of the City being zoned one of these zones, and where many high resource areas have developed.[^p712-3] Duplexes are similarly constrained, they are excluded from RS-1, RS-2, RS-3, RS-4, and only allowed through conditional use permit in R-5. Because both single-family and multi-family development is permitted in most residential zones, it puts multi-family developers in competition with single family developers for the same sites. Single family units also benefit from reduced permitting timelines. For single--family developments it typically takes up to 30 days for developers to pull building permits after its [^p712-2]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-1. [^p712-3]: City of Fresno, 2023. Data downloaded from HCD AFFH Data and Mapping Tool in 2021, based on ACS data. 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 entitlements are approved.[^p713-4] In contrast, based on recent projects, it can take three months to a year for multifamily developers to receive building permits after entitlements.[^p713-5] Although the Draft concluded that higher permit processing schedules for multi-family units compared to single family units are not a constraint, the increased complexity and expected timeline does appear to act as a constraint on multi-family development based on the very low production number of multi-family housing in the 5th cycle. .[^p713-6] B. Land Use Controls’ Effect on Types of Housing A complete constraint analysis does not only focus on housing by income levels but must also consider constraints to the different types of housing.. As noted above, the Draft constraint analysis must examine what constraints exist to the development of : supportive housing, transitional housing, single room occupancy units, and emergency shelters. Gov’t Code 65583(c)(1) 1. Single Room Occupancy (SRO) Units The City’s constraint analysis regarding SRO’s should examine more than the limit on the number of units but also where SRO’s are permitted to develop. SRO’s are a crucial source of affordable housing for many people and can augment the deed restricted affordable housing available to lower income people. The City should commit not only to removing the limit on the number of units that can be contained in an SRO but also add it as a permitted use in the following zones: RM-MH, RM-2, and downtown while removing conditional use permit requirements from RM-2, RM-3, NMX, CMX, and RMX. 2. Emergency Shelters The Draft must consider whether its development standards act as a constraint on the development of emergency shelters. Although the City seems to determine that its requirements do not act as a constraint to the development of shelters it also states it may consider making further amendments to the development code to remove any possible constraints. If further amendments are necessary, especially any needed to comply with Government Code section 65583(a)(4)(A), the City should commit to making those changes immediately. For instance, the City’s current requirement for the number of toilets per person in a shelter (Muni Code section [^p713-4]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-35 [^p713-5]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-35 [^p713-6]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-38 15-2729), if it exceeds the building code requirement is a likely constraint on the development of shelters because of the additional cost it adds to this type of development. 3. Supportive Housing The Draft is silent as to whether the development oecd complies with Government Code section 65583(c)(3) that allows supportive housing in any zone where multi-unit or mixed use development is permitted. If the City’s code does not reflect this requirement that is a constraint on housing for people with disabilities and a program to revise the development code to comply with the statute is required. 4. The HE Under-Analyzes Parking Requirement Effects on Housing Construction The Draft fails to fully analyze whether its parking requirements act as a constraint on housing development, especially in the downtown and along transit corridors. Parking requirements increase the cost of housing.[^p714-7] The Draft states it “determines the required number of parking spaces based on the type and size of the residential unit and has found the required parking spaces to be necessary to accommodate the number of vehicles typically associated with each residence.”[^p714-8] The analysis ignores principles of induced demand and downstream effects of entrenching car-centric land use. The Draft implicitly acknowledges that parking increases costs and may not be critical as it allows waivers for parking requirements in affordable housing developments and other transit-friendly areas.[^p714-9] The ad hoc basis of reduced parking requirements introduces uncertainty which can increase the overall cost and time delays in housing development. Recently, the City has made clear how much of an impediment parking really is. In negotiations with the state to receive a large grant to support increased housing in downtown Fresno, the City earmarked about $70 million of a possible $250 million grant for two new parking structures in the downtown area. Mayor Jerry Dyer stated [the cost of parking structures] “is always a big challenge for us when we try to bring in developers to build housing… Taking that off the table allows for these projects not only to occur faster, but it allows the developers to be more incentivized to build in our downtown area.”[^p714-10] [^p714-7]: http://database.greentrip.org/ [^p714-8]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-10 [^p714-9]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-10 [^p714-10]: https://www.fresnobee.com/news/local/article275363746.html Michelle Zumwalt Page 7 of 40 Although parking has been identified as a constraint to increased housing development, the City has not put forward a program to identify steps to remove the constraint. The City asserts “[p]arking standards are one area where many communities are seeking to decrease housing costs.”[^p715-11] Yet, minimum parking requirements are squarely within the control of the jurisdiction and could be reduced if the City so decided. The direct link on parking’s costs in relation to housing development in Fresno must be further analyzed, and a reduction in parking requirements is likely required. *C. Risk Analysis and Distribution of Affordable Housing* The Draft’s analysis of at-risk housing is incomplete. under-analyzes the risks to publicly assisted affordable housing and its distribution. There are more than 8,500 publicly assisted affordable housing units in the City of Fresno.[^p715-12] The Draft identified 695 units at risk of conversion to uses other than low-income residential within 10 years from the housing element adoption deadline.[^p715-13] Although the City of Fresno considered the cost of replacing the at-risk units as required under §65583(a)(8), it failed to examine which pathway would be most appropriate for the City and what constraints, if any, would be associated with the pathway chosen. The City’s lack of tenant protections, such as source of income discrimination outreach and education, rent control, just cause protections may operate as a constraint on the maintenance of housing available to lower income people and facilitate the displacement of lower income renters. The lack of these protections should be analyzed as a constraint on the maintenance of housing under Government Code section 65583(a)(5). **III. The Housing Element Fails to Adequately Analyze and Remove Non-Governmental Constraints to Housing Development** In addition to analyzing governmental constraints, the HE must also analyze the potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels. Gov’t Code § 65583(a)(6). To that end, the Draft failed to consider the effect of market forces, availability of financing, environmental concerns, and NIMBY opposition. [^p715-11]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-14 [^p715-12]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-55 [^p715-13]: Fresno Multi-Jurisdictional Housing Element July 2023, Appendix 1E: City of Fresno, 1E-4-55 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 8 of 40 *A. NIMBY Opposition* The Draft must include an analysis of NIMBY opposition to housing development. As a largely sprawling suburban City, Fresno is prone to local opposition to increased density from existing single-family homeowners that have preconceived ideas of the impacts of increased density on their neighborhoods. Further, the zoning code requires conditional use permits for duplexes and multi-family housing in some areas, making them especially susceptible to opposition and defeat from NIMBY residents. The chilling effect of NIMBY opposition to housing development is not a foreign concept to jurisdictions in Fresno County. For example, in the adjacent City of Clovis, the Clovis City Council recently voted to shut down a proposed 40-unit development near Old Town Clovis because neighbors expressed concerns about traffic congestion, overflow parking and the “monolithic” height of the planned apartment building.[^p716-14] NIMBY opposition to housing development is a widespread phenomenon across California but is especially prevalent in areas that have historically been primarily low-density developments. The Draft’s failure to analyze NIMBY opposition as a constraint must be addressed in the City’s next Housing Element draft, and the City should include a program to reduce this type of opposition by ensuring that more than single family developments are permitted by-right and reducing the discretionary review of multi-family housing. *B. Environmental Concerns* The Draft did not consider environmental constraints as part of its analysis under 65583(a)(6). Environmental constraints may include limitations to water supply, nearby pollution, or infrastructure development. The City of Fresno relies heavily on groundwater and surface water. As climate change makes water availability less predictable the City must analyze how an increased population and land use will affect water availability and whether water availability will eventually constrain growth. Further, separate from water availability, the City must consider the infrastructure requirements of delivering water to a denser population. For example, the City estimates that downtown Fresno, where a large portion of new housing development is projected, currently requires significant water and wastewater infrastructure upgrades. Broke Broche, the City’s director of public utilities, estimated that downtown Fresno would require between $160-$180 [^p716-14]: https://www.fresnobee.com/fresnoland/article255749376.html 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 million in water and wastewater upgrades to support planned housing development.[^p717-15] The Draft should analyze the cost of these needed improvements as a possible constraint on development. Finally, the Draft failed to consider industrial and polluting industries’ effect on future housing development. The City of Fresno has evolved as a car dependent City surrounded by heavy industry and highways. Therefore, future housing development will need to carefully consider placement and mitigation measures to avoid perpetuating environmental inequity. ### C. Market Forces and Availability of Financing The Draft failed to include an explanation of current housing development trends and applications across all income levels. Market forces are relevant to the types of housing that are likely to develop in the future. Once this analysis is done it might make it clear what actions the City must take, such as further financing for programs.. Using the example mentioned above, requiring private investment to implement required infrastructure in downtown Fresno would likely make housing development in the area infeasible. Similarly, lower margins or a lack of developer interest in serving lower income portions of the market may require the City to provide incentives to spur greater housing development in the segment. Without a proper analysis such a conclusion is impossible and falls short of the requirements listed in Government Code § 65583(a)(6). For example, Fresno had some of the highest rental price increases in the country, with a 28% increase in one-bedroom rent prices between January 2021 and January 2022.[^p717-16] The spike in rent prices disproportionately affects low-income individuals who are often on fixed incomes or receive low wages that have not kept up with the rapid rise in rents. Further, existing conditions in many rental units in Fresno have failed to keep up with required maintenance and would fail habitability requirements.[^p717-17] The combination of unmaintained housing in Fresno alongside rising rents was not analyzed as a constraint. As a result, the condition of housing stock available to low-income populations must be analyzed and the City must take steps to redress those constraints identified. [^p717-15]: https://www.fresnobee.com/news/local/article275363746.html [^p717-16]: https://www.fresnobee.com/fresnoland/article258073823.html [^p717-17]: https://www.fresnobee.com/fresnoland/article251600613.html Michelle Zumwalt Page 10 of 40 ## IV. Further Revisions and Analysis are needed to determine if the City’s Draft Includes Adequate Sites ### A. Regional Housing Need Allocation (RHNA) The City’s calculation of the RHNA it must accommodate must be revised to exclude units that have not been approved during the projection period. State law permits cities to reduce the number of units they must accommodate in their inventory of adequate sites, by income level, by the number of units approved or permitted since the beginning of the planning period: Projects that have been approved, permitted, or received a certificate of occupancy since the beginning of the RHNA projected period may be credited toward meeting the RHNA allocation based on the affordability and unit count of the development. For these projects, affordability is based on the actual or projected sale prices, rent levels, or other mechanisms establishing affordability in the planning period of the units within the project. See HCD’s Housing Element Sites Inventory Guidebook, p. 5, available at https://www.hcd.ca.gov/community-development/housing-element/housing-element-memos/docs/sites_inventory_memo_final06102020.pdf The City’s Draft Element appears to take credit for units that are still under review and have not yet been approved or permitted. The Draft Element cannot claim credit, meaning reduce the RHNA, with the following projects because project approvals have not been obtained for these units: Villa Baraca Apartments (P-1); DADA Lofts (p-13)(indicates the application is still being reviewed); Lincoln Park Apartments (P-16); Starling Townhomes (P-17); Latitudes at Armstrong (P-18); Helm Tower Office and Lofts (P-19); Elm Avenue Living (P-21); Majestic Palm Apartments (P-22); and, Los Pueblos Apartments (P-23). The Number of sites needed to accommodate the RHNA should reflect the removal of the above-described projects. ### B. Capacity calculation If a site does not have a required minimum density then the City must analyze the development capacity based on the patterns of typical development patterns in the same zone. The City uses a very narrow time frame to assess the development capacity of projects in the City – 2018-2020, it is unclear why the City has chosen such a narrow time frame but in order to assess if the Draft’s capacity calculations truly reflect realistic development patterns the City should use a broader time frame to establish the types of developments and capacity typically achieved. 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 [IMAGE] Michelle Zumwalt Page 11 of 40 Also, the Draft should explain why the capacity calculation for the RM-1 zone was rounded down from 85 percent to 80 percent, while the same calculation was rounded up from 77 percent to 80 percent in the RM-3 zone. The City has chosen not to rely on the minimum density to calculate capacity on some mixed-use zone site (NMX, CMX, RMX) and because there are no maximum densities imposed, the City instead creates a formula that determines what is likely “reasonable density” density that could develop on these sites and then divides that “reasonable density” in half to determine the Capacity for the site. This formula is flawed because it relies on very few submitted projects (that may not be approved) to determine what reasonable density might be during this planning period. It is crucial that the capacity calculation accurately reflects patterns of development especially where the City intends to accommodate a significant portion of the lower income RHNA (72 percent) on mixed-use sites. Two examples are not sufficient to establish a pattern of development. Although the City relies less on the Downtown sites to accommodate the lower income RHNA, a correct calculation of capacity is still crucial in the DTC, DTG, and DTN zones and the DTN-AH overlay. And again, the City relies on very few projects during a very limited time period (2018-2020) to support its calculation for realistic capacity on downtown sites. *C. Non-vacant Sites* Non-vacant sites must demonstrate through the City’s methodology that they are feasible for residential development during the planning period. Government Code section 65583.2(g)(1). The methodology is required to consider certain factors. *Id.* The July Draft Element includes a description of the current use of the sites but the analysis must be revised to apply the required factors[^p719-18] in order to assess the availability and feasibility of these sites for residential development during the planning period beginning in December 2023, including the City’s past experience converting existing uses to higher density residential development. [^p719-18]: The methodology shall consider factors including the extent to which existing uses may constitute an impediment to additional residential development, the city’s or county’s past experience with converting existing uses to higher density residential development, the current market demand for the existing use, an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development, development trends, market conditions, and regulatory or other incentives or standards to encourage additional residential development on these sites. Gov. Code section 65583.2(g)(1). 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 12 of 40 *D. Large Sites and Concentrated Sites* The July Draft requires revisions to provide examples of whether “sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower income housing units as projected for the site…” Gov. Code section 65583.2(c)(2)(B). The Draft must also be revised to specifically identify what portions of the large parcels will accommodate the lower income housing needs in the City. The City is correct to assume that 100 percent of large sites, a site that is over 10 acres, will not likely develop for affordable housing. This is due, in part, to the limitation of available funding mechanisms for projects of over 200 units. But, identifying so many large parcels to accommodate housing for the lower income RHNA in close proximity to each other also acts as a constraint on development as affordable housing due to the same funding limitations. To be clear, identifying a large percentage of the sites to accommodate the lower income RHNA in close proximity to each other is a constraint on obtaining funding for affordable housing, funding which is critical to developing affordable housing, and it will create an obstacle to the development of these sites as affordable housing. In addition, many of these sites are also concentrated in one area of the City and that also prevents the City from meeting its duties to remove patterns of segregation and comply with its duty to affirmatively further fair housing. [As mentioned in the AFFH section above, the over concentration of sites intended to accommodate the lower income housing need in specific areas of the City is inconsistent with the City’s duty to Affirmatively Further Fair Housing.] As noted above the City’s inventory of available sites will need revisions and further analysis in order to determine whether the City has identified adequate sites to accommodate its RHNA for this planning period. **V. The Assessment of Fair Housing Fails to Comply with Section 65583(c)(10)** For generations, local mayors and council members have described Fresno as a “tail of two cities”, an illusion to Charles Dickens’ tragic 1859 novel of pre-revolution France, in acknowledgement of the outstanding disparities in quality of life and access to opportunity that exists between neighborhoods in the Northern and Southern portions of the City and the striking racial and economic differences that underlie them. Studies and data have repeatedly confirmed not only that South Fresno neighborhoods and people of color in Fresno are impacted by a severe lack of access to housing choice and access to opportunity across many indicators compared to North Fresno neighborhoods and White residents, but that the disparities impacting South Fresno, people of color and other protected classes stand out as among the most significant in the state and the country. The City’s duty to AFFH through the Housing Element and to complete an 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 13 of 40 Assessment of Fair Housing in order to do so presents the City with a crucial new opportunity to address the intergenerational disparities and barriers to opportunity that persist in Fresno. Unfortunately, as discussed further below, the AFH lacks information and analysis and fails to incorporate public input as necessary to address the requirements set forth in Section 65583(c)(10) and does not achieve the requirement to ensure that the City AFFHs through its housing element. ### A. Integration and Segregation and R/ECAP and Concentrated Area of Affluence Analyses Lack Required Detail The AFH’s analyses of patterns of integration and segregation and R/ECAPs and Racially Concentrated Areas of Affluence (“RCAAs”) fail to address important factors which must be considered as part of a complete analysis pursuant to section 65583(c)(10)(A)(ii) and HCD’s AFFH Guidelines. See AFFH Guidelines, pp. 30-34. These gaps render the AFH analysis incomplete and include but are not limited to the following: * Failure to provide any data or analyze integration and segregation patterns for racial groups other than Hispanic/Latinos. Table 1:E-3.1, “Population by Race and Hisppanic Origin, Fresno, 2000-2020,” provides data about the share of the population of different racial groups in Fresno in 2000, 2010, and 2020, but no data is included that addresses the spatial composition and segregation or integration status of Black, AAPI, Native American, and other racial and ethnic groups. Similarly, the analysis fails to identify groups experiencing the highest levels of segregation as required. AFFH Guidelines, p. 31. * Failure to accurately or thoroughly analyze distribution of low- and high-income households across Fresno. The Figure 1E-3.4, Median Household Income, Fresno, 2019 indicates median income levels across the City and depicts median incomes of $100,000 or over in some areas West of State Route 99, Northwest Fresno, Northeast Fresno, and in the Sunnyside neighborhood of South Fresno. Yet the AFH’s analysis of the data depicted by the map fails to acknowledge these high-income neighborhoods throughout the City, stating only that “Northwest neighborhoods of the city…have the highest median incomes. Otherwise, most of the remaining census block groups in the city have household incomes that fall below the statewide median indicating high poverty levels.” This analysis washes out important information about relative income levels across Fresno, including concentrations of high-income households and low-income households in specific neighborhoods, which should be used to inform and geographically-target programs and the location of sites included in the inventory to AFFH. See HCD 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 14 of 40 Guidelines, p. 32. For neighborhoods like West Fresno, which experience particularly acute barriers to opportunity linked to policies and practices that created and enforced segregation, an accurate and complete analysis and programs that respond to that analysis are essential. * The AFH’s analysis of R/ECAPs and RCAAs fails to address “public participation, past policies, practices, [and] investments” as required. HCD Guidance, p. 33. The R/ECAP analysis provides only the generic statement that “R/ECAPs generally have less private investment from financial institutions, grocery stores, and other retail outlets,” but does not provide any analysis specific to Fresno City or regional policies, practices, and investments that contributed to the creation and/or perpetuation of R/ECAPs. The RCAA analysis only identifies that 18 RCAAs exist in Fresno, with no analysis at all of the factors giving rise to those RCAAs or their persistence or variation over time nor does it consider any public input on this topic. As a result of these and other deficiencies, the AFH’s analysis of integration and segregation and R/ECAPs and RCAAs is incomplete. The analysis and the Draft Element’s contributing factors, goals and actions must be revised accordingly. *B. Incomplete Analysis of Disproportionate Housing Needs Based on Race, Ethnicity, Familial Status, Disability, and Income* The analysis of disproportionate housing needs must analyze needs relating to cost burden, overcrowding, substandard housing, homelessness and other factors for protected characteristics, including at least race and ethnicity, familial status, persons with disabilities, and income. § 65583(c)(10)(A)(ii); AFFH Guidance, p. 39. Disproportionate housing needs “generally refers to a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing need” compared to the proportion of members of other relevant groups or the total population HCD’s guidance emphasizes that local data and knowledge are particularly important to this analysis. *Id.* The requirement to analyze disproportionate housing needs is fundamental to achieving the purpose of the AFH to ensure that the housing element affirmatively further fair housing by identifying disparities impacting protected classes which have been subject to historic discrimination, describes the factors contributing to those disparities, and adopts meaningful actions that overcome patterns of segregation and address disparities in housing needs and opportunity for protected classes. Yet, the AFH fails to satisfy this requirement. While it provides the percentage of households experiencing any one of four specified housing problems - lack of complete kitchen facilities, lack of complete plumbing facilities, overcrowding, cost burden – by race and ethnicity, the analysis of overcrowding, cost burden, and substandard conditions only addresses 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 15 of 40 the prevalence of those housing issues based on housing tenure (renter or owner) and census tract. The analysis fails to include any information about the separate occurrence of overcrowding, cost burden, and substandard housing conditions based on race or ethnicity and fails to provide any information at all about how these factors disproportionately impact Fresno residents based on familial status and disability. While the AFH includes some data relating to the race, gender, and mental disability of unhoused residents, it fails to include information relating to familial status. Further, the analysis includes no information that reflects “local knowledge” or public input, depriving the analysis of details about specific housing needs within the categories identified above and the scale of those needs in relation to others. The City must supplement its disproportionate needs analysis to include the required demographic information and revise the AFH further to ensure its contributing factors and meaningful actions reflect that information. *C. Displacement Risk Analysis Fails to Consider Relevant Housing Cost, Tenant Protection, Land Use, and Environmental Risks* The AFH evaluation of displacement risk consists of the identification of census tracts which qualify as “sensitive communities” that may be vulnerable to displacement as a result of rising housing costs and market-based displacement pressures based on demographic, tenure, rent burden, and rent change criteria developed by The Urban Displacement Project of UC Berkeley and the University of Toronto. Figure 1E-3.31, Communities Sensitive to Displacement in Fresno, provides useful information indicating that large swaths of the City, including most South Fresno and Central Fresno neighborhoods, as well as the Blackstone Avenue Corridor are vulnerable to displacement, the AFH’s displacement risk analysis falls short by failing to consider other relevant information relating to existing and potential housing cost pressures confronting low-income residents, residents of color, and other protected classes, as well as significant displacement risks associated with tenant protection limitations, City land use policies and practices, environmental hazards, and climate change. A complete displacement risk analysis must consider these and other relevant factors. See AFFH Guidance, pp. 40-43. *1. Displacements Risks Associated with Housing Cost Pressures* As mentioned above, the AFH’s identification of sensitive communities using The Urban Displacement Project’s criteria provides a helpful high-level view of the displacement pressures impacting most of the City of Fresno, and almost all South Fresno and Central Fresno neighborhoods. That mapping alone however is not sufficient to accurately describe displacement risks impacting residents associated with housing cost pressures. 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 First, the criteria used in the analysis rely on data from 2017 and earlier, including data relating to the change in rent between 2012 and 2017. This time period does not capture the sharp and sustained escalation in housing costs (both rental and ownership) that occurred during the COVID-19 pandemic between 2019 and 2022.[^p724-19] Between 2017 and 2021, Fresno experienced the greatest rent increases of all large U.S. cities, with rental prices increasing nearly 39% during that time.[^p724-20] Pandemic-era and ongoing housing price increases disproportionately impact the housing stability of renters, people of color, and other populations that have less disposable income and assets on average and are impacted by discrimina and sustained nature of the housing cost increases which have occurred in Fresno since 2017, the AFH’s displacement risk analysis must be supplemented with and revised based on more recent data. Second, while the AFH’s displacement risk section provides a snapshot of neighborhoods vulnerable to increased housing costs that occurred between 2012 and 2017, the section does not actually discuss housing cost trends over time or analyze the factors driving increased housing costs across the City and certain neighborhoods. The use of census tract level data alone to determine whether an area qualifies as a “sensitive community” or not, without further discussion, also washes out unique vulnerabilities experienced by particular neighborhoods which comprise only a portion of a census tract. The City must supplement the displacement risk section to include this additional information and analysis, using available data and local knowledge, in order to meaningfully identify displacement risks associated with housing cost pressures and on particular neighborhoods and protected classes. Several factors are likely or definitely associated with rising housing costs in Fresno which the AFH does not but must identify and evaluate for their impact on displacement risk. These include but are not limited to the following: * The expiration of affordability covenants attached to Low-Income Housing Tax Credit financed properties during the Planning Period. According to the Draft Housing Element’s At Risk Analysis, three properties consisting of 115 affordable units in the next four to eight years. The expiration of the affordability covenants on these properties creates a direct displacement risk to residents who are unable to pay market-rate rents. [^p724-19]: CalMatters, Real estate prices soar during the pandemic, climbing 25% in parts of California, Dec. 5, 2020, available at https://calmatters.org/california-divide/2020/12/real-estate-climb-pandemic/ [^p724-20]: Los Angeles Times, The Nation’s Hottest Housing Market? Surprise – it’s Fresno, Mar. 31, 2021, available at https://www.latimes.com/homeless-housing/story/2021-03-31/fresno-rent-spike-taps-into-california-covid-housing-trends * Major federal, state, and local investments in public works infrastructure projects in South Fresno neighborhoods, including a $250 million phased budget commitment for downtown revitalization in the 2023/2024 California State Budget[^p725-21]; the June 2023 Federal Railroad Administration and State High Speed Rail Authority $20 million award for the Fresno High-Speed Rail Station Historic Depot Renovation and Plaza Activation Project; and an $80 million July 2023 award from the State’s Transit and Intercity Rail Program[^p725-22] for grade separation and intersection improvements in Central Fresno at McKinley Avenue and Blackstone Avenue. None of these historic awards have requirements attached to them to reduce the risk of displacement as a result of rising rents associated with neighborhood improvements. * The development of the California High Speed Rail project, with a depot in Fresno, which the draft Housing Element recognizes is expected to increase housing demand in Fresno by enabling commuting between Fresno, Coastal California, and/or Sacramento. Draft Housing Element, p. 3-79. The analysis should also consider the impact of speculation associated with HSR on housing availability, prices, and displacement risk. * The conversion of housing units to short-term rentals and their impact on housing cost pressures and displacement risk. The Draft Housing Element indicates that 7% of vacant units in the city are seasonal, short-term rentals, or “other” housing accommodations, but does not state what percentage of total units are seasonal housing or short-term rentals. The Draft states that stakeholders with Llaves De Tu Casa (an initiative involving real estate professionals, banks, the City of Fresno, and affordable housing developers) expressed concern about investors displacing community members to establish short-term rentals. Draft Housing Element, p. 1E-6-15. According to a recent news story, 811 homes were available as short-term rentals in Fresno and Clovis in June 2023, which represents a 27% increase in available rentals since 2020 and almost twice the number of homes listed for sale at that time.[^p725-23] [^p725-21]: YourCentralValley, City of Fresno announced $250 million for downtown, June 28, 2023, available at https://www.yourcentralvalley.com/news/local-news/city-of-fresno-announces-250-million-for-downtown/ [^p725-22]: See Fresno Bee, State will help Fresno rebuild a major railroad crossing. Where is it, and what will it cost?, Jul. 6, 2023, available at https://www.fresnobee.com/news/local/article277074553.html [^p725-23]: GVWire, Is an Airbnb Crisis Looming in Fresno as Demand Plummets?, June 29, 2023, available at https://gvwire.com/2023/06/29/is-an-airbnb-crisis-looming-in-fresno-as-demand-plummets/ Michelle Zumwalt Page 18 of 40 The AFH’s discussion of City “Displacement Avoidance Efforts” does not remedy the need for a complete analysis addressing the displacement risk factors above, including relevant City policies and practices, and the adoption of meaningful actions to address those risks. That section describes certain planning efforts the City undertook to evaluate displacement risks from rising housing prices and consider, but it does not actually provide any information about the findings of that policy recommendations and the policies that the City did or did not adopt. Given the significant stakeholder engagement conducted for the development of the “Here to Stay Report,” the AFH should incorporate and consider relevant information and policy recommendations contained in that report. ### 2. Tenant Protection, Land Use, Environmental, and Climate-Related Displacement Risks Not Considered in the AFH Displacement Risk Analysis A complete analysis of displacement risks considers not only displacement risks associated with housing cost pressures, but also other factors which result in housing instability, including factors relating to the adequacy of tenant protections, disinvestment, local land use policies and practices, environmental hazards, and risks associated with natural disasters and climate change. The Draft Housing Element considers none of these risk categories, yet based on our direct work with tenants and low-income residents and residents of color, they represent real and significant risk factors for Fresno residents. First, the Displacement Risk section does not address the adequacy of policies and resources to protect tenants from displacement as a result of eviction, harassment, and substandard housing. A coalition of residents and community-based organizations have called to the City’s attention the need for and have repeatedly asked the City to adopt additional and stronger policies and programs to protect tenants, including in particular more comprehensive and stringent rent control standards than those established by the state, just cause requirements for eviction, and right to return home for displaced residents. And while the AFH mentions the City’s code enforcement programs, it does not analyze how successful these programs have been in preventing tenant displacement and ensuring residents have a habitable space in which to live. Draft Housing Element, p. 3-79. Second, while the Draft Housing Element recognizes the occurrence of historic disinvestment and describes recent initiatives to increase investment in South Fresno neighborhoods, the AFH does not but should consider the extent to which public and private disinvestment and unequal investment continues to impact low-income neighborhoods, neighborhoods of color, and neighborhoods with a high proportion of tenants and how 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 19 of 40 disinvestment perpetuates and/or increases displacement risk in these areas. See AFFH Guidance, p. 40. Yet even today, many South Fresno neighborhoods lack sidewalks, streetlights, park space, grocery stores and other public and private investments that contribute to neighborhood and housing-stability. Third, the Draft Housing Element fails to consider the displacement risks associated with the City’s land use and permitting decisions which have directed and continue to allow for and promote the concentration of industrial and waste management facilities in and around neighborhoods in Jane Addams, Southwest Fresno, South Central Fresno (referred to by the Draft Housing Element as the “South Industrial Area”), and Southeast Fresno. The City’s General Plan land use map designates thousands of acres of land in these neighborhoods for industrial and business park uses, which encompass warehouse distribution facilities, agricultural processing operations (e.g., slaughterhouses, meat rendering facilities), chemical storage, landfills, waste transfer stations, biomass facilities, and more. Draft Housing Element, p. 1E-3-77. These designations are applied to land adjacent to land designated for and/or developed with residential neighborhoods as well land currently developed with housing. Several General Plan policies direct the City to expedite development on sites designated for industrial land uses by streamlining permitting and making sites “shovel ready” for new development through the installation of infrastructure and connection to services. City of Fresno General Plan, ED-1-d, ED-1-e, ED-1-j. *The General Plan therefore envisions and plans for the conversion of existing housing and neighborhoods to industry* and the continued proliferation of industrial land uses surrounding housing and other sensitive uses, both within existing City limits and within the City’s Sphere of Influence. 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 20 of 40 <
> City of Fresno Official General Plan Land Use and Circulation Map (Excerpt)[^p728-24] [^p728-24]: Portion of City of Fresno Official General Plan Land Use and Circulation Map, available at https://www.fresno.gov/wp-content/uploads/2023/03/Official-General-Plan-Land-Use_20220411-1.pdf 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 21 of 40 <
> **Google Earth Image Depicting S Rose Ave. & E. Kaviland Ave Neighborhood, Zoned Industrial on General Plan Land Use Map, and Adjacent West Fresno** (captured 08/16/2023) 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 22 of 40 <
> **Google Earth Image of Unincorporated Daleville Neighborhood, Zoned Industrial on the General Plan Land Use Map, & Orange Center Elementary School** 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 <
> **San Joaquin Estates Mobile Home Park (“MHP”), Villa Fresno MHP, and Fresno MHP, Adjacent to and/or Surrounded by Industrial Zoning on the General Plan Land Use Map** (captured 08/16/2023) These new warehouse facilities, in combination with existing industrial facilities clustered in South Fresno neighborhoods, have severe negative and destabilizing impacts on nearby housing. Warehouse distribution facilities, such as the Amazon and Ulta Beauty warehouses in South Central Fresno, attract thousands of truck trips that travel on roads shared with homes, schools, and parks every day. This truck traffic creates toxic diesel air emissions, dust, vibration, noise, and light glare which negatively impacts residents in their homes, including their health and well-being, the longevity and potential future occupancy of their housing. The construction and operation of facilities themselves often creates excessive dust, noise, light glare, heat, odors, and other effects which have similar impacts on residents and housing quality and stability. We have attached to this comment letter a declaration from a South Central Fresno resident describing impacts she has experienced due to the proliferation of 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 industrial facilities in her neighborhood. Attachment A, Declaration of Katie Taylor.[^p732-25] The City must revise the AFH’s Displacement Risk analysis to include a full evaluation of the impacts of its policies and practices relating to industrial development on displacement risks, including based on protected class status and income and reflecting the local knowledge of residents impacted by this issue, and incorporate meaningful actions to address those risks. Fourth, the AFH’s Displacement Risk section does not and should be revised to consider displacement risks associated with environmental hazards, environmental disasters, and climate change, pursuant to HCD’s AFFH Guidance. AFFH Guidance, p. 42. For instance, South Fresno neighborhoods have been impacted by a series of fires at warehouse, recycling, and other industrial facilities that have occurred during the increasing number of high and extreme-heat days over the past five years.[^p732-26] Potentially toxic smoke from these fires has at times densely concentrated in South Fresno neighborhoods, which can make breathing difficult and unsafe for residents even within their homes with windows closed. In addition, residents who live in neighborhoods with incomplete sidewalks, stormwater drainage and other infrastructure and in housing without adequate cooling are at greater risk of displacement than other residents from climate-related weather events, including extreme heat and flooding. In Fresno, which recorded temperatures of 100 degrees Fahrenheit or higher on 23 days and a high temperature of 109 degrees in July 2023, extreme heat poses a serious threat of displacement for residents who lack adequate cooling in and/or cannot afford the cost of cooling their homes. The City must revise the AFH to include a complete and accurate Displacement Risk analysis as described above and modify other sections of the Housing Element, including the AFHs contributing factors and meaningful actions to overcome disparities relating to access to a healthy environment associated with these land use patterns. ### VI. The AFH Fails to Consider Significant Disparities in Access to Opportunity to Multi-Modal Transportation Options, a Healthy Environment, and Quality Education [^p732-25]: While the resident, Ms. Katie Taylor lives immediately outside of City of Fresno city limits, she resides within the City’s Sphere of Influence and her experiences of the impacts of industrial development mirror those of many South Fresno residents who reside within the City of Fresno. [^p732-26]: See for example, ABC30, Crews Battling Large Fire at Southwest Fresno Recycling Center, June 18, 2021, available at https://abc30.com/fresno-fire-recycling-center-recycling-timely/10807838/; KSEE24, Massive fire burns industrial building in Fresno. What made the battle difficult for firefighters, June 26, 2021, available at https://www.yourcentralvalley.com/news/local-news/massive-fire-breaks-out-at-warehouse-near-downtown-fresno/; ABC30, Flames break out at warehouse in Southeast Fresno with homes and businesses nearby,” Apr. 3, 2023, available at https://abc30.com/warehouse-fire-southeast-fresno-east-and-florence-homeless-activity/13077246/ Michelle Zumwalt Page 25 of 40 The AFH must include an analysis of disparities in access to opportunity. § 65583(c)(10)(A)(ii). Access to opportunity broadly encompasses the place-based characteristics which are linked to critical life outcomes, including “education, employment, economic development, safe and decent housing, low rates of violent crime, transportation, recreation, food, and a healthy environment (air, water, safety from environmental hazards, social services, and cultural institutions). AFFH Guidance, p. 34. The AFH fails to consider disparities relating to several key components of access to opportunity, including in particular disparities in access to multi-modal transportation opportunities, a healthy environment, and neighborhood investments – issues which residents and CBOs have long raised with the City. *A. Disparities in Access to Multi-Modal Transportation Opportunities* An analysis of access to transportation opportunities must, at minimum, compare concentrations of protected groups with access to transportation options; assess any disproportionate transportation needs for members of protected classes; and analyze combined housing and transportation cost impacts on protected groups. *Id.* at p. 35. Transportation options include personal vehicles and public transportation, as well as options for pedestrians and bicyclists and other forms of group or shared transportation. *See Id.* at 48, 69, 73. The AFH’s Transit Mobility analysis, as indicated by its title, focuses exclusively on the availability of public transit, including the FAX bus system and Handy Ride, through a brief discussion of available routes and programs and policies in place to reduce fares for certain populations. This analysis fails to compare access to transportation opportunities based on protected characteristics; assess any disproportionate transportation needs for members of protected classes; provide important information about the adequacy of public transportation service in different areas of the City, protected classes, and low-income households; and entirely fails to consider access to other forms of transportation, including walking and bicycling. The City must revise the Draft Housing Element to include and analyze this missing information. In addition to the categories identified in the paragraph above, specific issues which must be considered include but are not limited to: * Barriers to access to public transportation based on route limitations, especially for neighborhoods located on the fringes of the City. This includes both disadvantaged neighborhoods which are more strongly reliant on public transportation, such as Jane Addams and areas of West Fresno and South Central Fresno, and high resource neighborhoods in Northeast and Northwest Fresno, which Figure 1E-3.18, Fresno Area Express (FAX) indicates have significant less route access than South Fresno. The housing element must consider how route 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 limitations in these areas impact mobility of residents of disadvantaged communities and their access to various forms of opportunity as well mobility and housing opportunities for low-income residents in North Fresno, considering affordable housing subsidy scoring criteria which often prioritizes public transit accessibility. * Barriers to mobility resulting from lengthy travel times for residents’ using public transportation due to bus wait times, lack of direct routes, and route limitations requiring residents to use other forms of transportation to reach their first and last stop, especially for residents in fringe neighborhoods. * Inadequate and/or absent infrastructure to facilitate safe and efficient active transportation, including but not limited to sidewalks, curbs, stormwater drainage, streetlights, crosswalks, and protected bike lanes. * Inadequate and/or absent protection from extreme weather, including climate-related weather events, such as extreme heat and flooding, that impact walking, biking, and public transportation use. This includes but is not limited to the availability of shade (e.g., trees, structures), shelter, sidewalks, and stormwater drainage. * The presence of high volumes of traffic, including heavy-duty truck traffic, on roadways used by pedestrians or bicyclists, including in and near areas zoned for industrial land uses and along designated truck routes. *B. Disparities in Access to a Healthy Environment* An analysis of access to a healthy environment must describe any disparities in access to environmentally healthy neighborhoods by protected groups, consider available statewide data such as CalEnviroScreen, evaluate consistency with the environmental justice element (if relevant), and discuss policies, practices, and investments that impact access to environmentally healthy neighborhoods. AFFH Guidance, p. 35. A complete analysis should consider any impacts on access to a healthy environment associated with the zoning, siting and operation of polluting or toxic land uses in disadvantaged communities and with climate change. *Id.* at pp. 16, 73. A robust analysis of disparities in access to a healthy environment, informed by public input, is especially important in Fresno given the high concentration of communities in low-income South Fresno neighborhoods of color that rank among the most burdened by multiple sources of pollution in the state and the relatively low-pollution burdens on many indicators born by comparatively affluent and Whiter North Fresno neighborhoods and RCAAs. The AFH’s Healthy Environment analysis includes data demonstrating cumulative pollution burdens impacting Fresno neighborhoods by census tract and provides some 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 information about industrial and waste processing facilities in South Fresno. However, it fails to include *any* discussion of City policies and practices underlying the stark environmental health disparities between South Fresno and North Fresno neighborhoods reflected in the data or any information or analysis about what policies, practices, and investment underlie those disparities. The analysis points to agricultural industry practices as a basis for high pollution indicator scores in Western Fresno County but does not discuss the bases for pollution disparities impacting the City of Fresno itself, including West Fresno, Jane Addams, South East Fresno neighborhoods with high cumulative pollution scores. As discussed above, City policies and practices have intentionally concentrated polluting and noxious industrial and waste management land uses in South Fresno neighborhoods and policies and practices remain in place that all promote the exacerbation of these patterns to the detriment of housing opportunities and quality of life for South Fresno residents. These policies and practices include but are not limited to impact fees for a community benefit fund, public health impact reports, and cargo/freight prohibition and revenue tax. ### *C. Disparities in Access to Educational Opportunity* The AFH’s analysis of educational opportunities must include an evaluation of the presence or lack of policies, practices, and investment to promote proficient schools or that contribute to a disparity in access to opportunity,” among other factors. HCD’s AFFH Guidance, p. 35. Disparities in access to transportation opportunities and environmental health, including those discussed above, significantly impact access to educational opportunity. For instance, a lack of or incomplete sidewalks, stormwater drainage, and streetlights in R/ECAPs; inefficient public transportation options; and the use of local roads by heavy-duty truck traffic may prevent students from traveling to and from school safely and on time, which may in turn have a series of impacts on students’ access to educational opportunity. Likewise, the presence of heavy industrial facilities near and surrounding schools and ongoing construction for the development of new warehouse distribution centers may disrupt learning by exposing students to air, noise and light pollution and increasing temperatures and thereby also undermining opportunities for outdoor recreation during school hours. The City should also consider how policies, practices, and investments or disinvestments relating to access to green space, tree canopy, and climate resiliency (including adequate cooling and wildfire smoke protection) impact educational opportunities at schools, especially in low-income neighborhoods. The City must revise its analysis of educational opportunities to address these and other issues not addressed in the Draft Element and revise and add to its actions accordingly. ### VII. Incomplete Analysis of Housing Element Sites’ Compliance with AFFH Duty 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 28 of 40 Housing Element Law requires that jurisdictions’ sites inventory “identify sites throughout the community” consistent with its duty to AFFH. § 65583.2; 8899.50; HCD AFFH Guidance, p. 45. The AFH must evaluate sites “relative to the full scope of the assessment of fair housing” and provide detailed instructions describing the required components of this evaluation. AFFH Guidance, p. 45. Here, the AFH fails to evaluate important components of whether the distribution of sites in the inventory AFFH and to summarize conclusions and identify specific programs to address fair housing issues associated with the locations of those sites. Deficiencies of the evaluation include but are not limited to the following: * The AFH’s analysis of the sites inventory’s impact on segregation and integration trends, like other sections of the AFH, only briefly considers impacts on the distribution of Hispanic/Latino households and does not consider at all the impact on relative integration and segregation of other races. Critically, it fails to acknowledge how the lack of lower-income sites identified in high-resource areas, including for example Northeast Fresno, will perpetuate patterns of RCAAs and R/ECAPs. *See* AFFH Guidance, p. 45. * The AFH lacks analysis of the impact of its sites locations on access to specific forms of access to opportunity and therefore fails to identify any programs to address fair housing barriers to which its site selection gives rise. The sites inventory includes a large share of sites in low-income neighborhoods of color impacted by poor environmental health indicators, industrial zoning and concentrations of industrial and waste management facilities. The inventory also includes sites located near State Routes 99, 41, and 180 as well as many sites on Blackstone Avenue, a heavily trafficked thoroughfare. The City must analyze these and other impacts on access to a healthy environment implicated in its choice of sites. In addition, the AFH lacks analysis of how absent or incomplete infrastructure, services, and amenities impact access to opportunity on sites included in the inventory and fails to identify programs to address these barriers. The Draft Element includes a significant share of sites in areas West of State Route 99 which are not yet developed and which lack basic infrastructure, services, and amenities, such as sidewalks, streetlights, public transportation, park space, and grocery stores as well as City water and sewer connections. Many of the lower-income sites identified in low-income South Fresno neighborhoods also experience disparities in access to critical infrastructure and services which must be considered in an analysis. * Only 23% of sites included in the inventory to meet the lower-income RHNA are in high and highest resource areas, which the AFH states is due to the predominance of single-family zoning north of Shaw Avenue. 1E-3-109. “Where the analysis of the 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 inventory indicates that the community has insufficient sites appropriately zoned and located to accommodate its lower-income RHNA in a manner that affirmatively further fair housing, the housing element must include a program to address this inconsistency, such as making additional sites available to accommodate its lower-income RHNA in a manner that affirmatively further fair housing.” AFFH Guidance, p. 45. Despite its recognition of the limited number of lower-income inventory sites in high resource areas, the AFH fails to describe a program included in the Draft Element to adequately address this fair housing issue. As further discussed in this letter below, while the AFH points to Program 2 as the Draft Element’s action to address this fair housing issue, the program fails to ensure that it will actually add sites to the inventory to meet the lower-income RHNA in high-resource areas or that it will facilitate development of lower-income housing in high-resource areas at all. The program commits only to “present potential sites or rezoning options for land in high resource areas for Council consideration for higher density development.” 1E-18. While the time frame section indicates that City will rezone sites in high resource areas by 2027, the language in the body of the program does not make the City to actually rezoning sites or to include additional sites located in high-resource areas to the housing element and therefore renders the commitment that the Program is making ambiguous. The Program also makes no commitment to ensure that sites that may or may not be rezoned or impacted by this Program are “suitable” for development pursuant to the Housing Element Law’s standards, including that increased capacity is created on vacant and/or underutilized sites. Further, the City provides no analysis justifying its selection of 750 units of additional capacity as its target or if that quantity is sufficient; if changes to permitting and zoning standards of sites located in the Office District will create sites near amenities and resources and with relatively low environmental burdens within high-resource census tracts; why rezoning of sites within low-density, higher income neighborhoods which is still under development is not proposed and that impact of the failure to include such sites on addressing patterns of segregation and exclusion. The Program also fails to address barriers to housing opportunity for lower-income residents who reside in housing developed in high resource areas, including inadequate public transportation options, affordable fresh food, and cultural and linguistic resources. * The AFH sites inventory analysis includes no discussion of local knowledge and community input, pending development, development potential and other relevant factors which must be discussed in a complete analysis. AFFH Guidance, p. 45-46. 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 30 of 40 The City must address these deficiencies in the AFH’s sites inventory analysis and include additional meaningful actions, with deadlines and clear outcomes, to overcome the fair housing issues associated with the Draft Element’s inventory. **VIII. Failure to Fully Analyze Contributing Factors and Lack of Meaningful Actions to Affirmatively Further Fair Housing Render the Draft Housing Element Noncompliant.** The City has failed to complete an adequate analysis of factors that have contributed to patterns of segregation and as discussed above the program actions included in the draft housing element do not and will not effectively AFFH as required by law. Unless and until the City fully analyzes factors that have contributed to patterns of segregation, identifies which factors it will address along with the programs and policies it will rely on to do so and metrics that demonstrate success, the housing Element will be out of compliance with state mandates. (See Government Code section 65583(c)(10)) **IX. Failure to Adopt Community Identified Programs That Will Result in A Beneficial Impact During the Planning Period and AFFH** Housing Element Law requires that housing elements include programs with a schedule of actions with timelines and specific commitments that will have a “beneficial impact” within the planning period to achieve the housing element’s goals and objectives. As stated in the AFFH guidance “actions implement goals and consist of concrete steps, timelines, and measurable outcomes.” Pursuant to the requirement that housing elements AFFH, housing elements must also include actions to implement priorities and goals identified in an Assessment of Fair Housing (AFH). Those actions must be “meaningful” and go beyond combatting discrimination to “overcome patterns of segregation and foster inclusive, affordable and stable communities.” AFFH Guidance, p. 46; *See* Government Code §§ 65583(c)(5)&(10, 8899.50(a)&(b). The draft element’s Housing Action Plan contains numerous actions that lack concrete steps and measurable outcomes and will not necessarily result in a beneficial impact during the planning period in violation of the Housing Element Law’s standards. Certain programs fail to identify concrete steps, specific actions the city will take to complete each program, use of vague language, and do not provide adequate timelines. Finally, the action plan fails to include community identified programs and solutions collected from public hearings and workshops. Examples of inadequate programs, and some of our recommendations to improve them, include the following: 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 * **Program 1 - Maintain Adequate Sites.** Program 1 states that the City shall continue to maintain a current inventory of Housing Element sites to ensure that it can adequately accommodate the 2023-2031 RHNA” Given the impact of rezoning to the availability of and location of sites suitable for housing, the City should take additional steps to ensure transparency in decision-making related to proposed rezones and take diligent steps to provide notice of the proposed rezone along with an assessment of the potential impacts of the rezone on housing opportunity prior to a decision on the proposal. This includes but is not limited to public hearings and door to door canvassing to facilitate effective notice. Further, the city must conduct a racial equity analysis which would include the benefits and disadvantages of the proposed rezone and whether it would result in displacement of protected racial/ethnic groups, reduce housing opportunities for protected groups, and how it would impact patterns of segregation. Finally, the program should explicitly prohibit the rezoning of sites suitable for lower income households to industrial land use classifications which would bring industrial uses next to or near neighborhoods that include or are planned for housing affordable to lower income residents. This is critical to ensure that the City is compliant with its duty to affirmatively further fair housing. * **Program 2- Variety of Housing Opportunities in High Resource Areas *(identified in the AFH as a Meaningful Action)*.** The program states that the City “will identify and pursue opportunities” with affordable housing developers to promote the development of affordable units in high resource areas. Unfortunately, it does not provide any details on how they will in fact promote the development of affordable units for lower income households in high opportunity areas. There is no clear commitment to zone sites for multi-family development in areas of high opportunity or a commitment to ensure that such units are affordable to all income levels. Further, there is no commitment to match funding opportunties with the identification of available sites to facilitate their development. Notably, the City will not conform with its duty to AFFH if it does not ensure adequate sites for affordable housing for lower income residents in high resource areas. Without clear and enforceable commitments and timelines, this program will not provide a beneficial impact or further fair housing. Furthermore, in order to expeditiously address the lack of housing opportunities accessible to lower-income residents in high resource areas, the timeline of this program should be shortened. 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Accordingly, a specific objectives of this program should be changed to (a) assess the number of sites that must be rezoned in high resource areas (as identified in TCAC/HCD’s Opportunity Maps) to effectively AFFH , and (b) rezone the adequate number of sites pursuant to that analysis by December of 2025. * **Program 3 - Encourage and Facilitate Accessory Dwelling Units (ADUs) (*identified in the AFH as a Meaningful Action*)**. While we support and encourage the development of ADUs, the program does not outline clear commitments that will yield identifiable beneficial outcomes. The program states “a primary objective of this program is to increase the supply of affordable units throughout the city” but fails to identify any specific commitments to take any action on how this objective will be reached. Additionally, building ADUs is generally not an accessible housing option to low income households who cannot afford predevelopment costs associated with ADUs. We recommend additional measures in this program to make ADUs accessible to lower income households such as targeted outreach to low-income homeowners, incentives for landlords to make ADUs affordable, no interest loans for ADU development and waivers for inspection fees Additionally, a dedicated liaison in the Office of Community Affairs should be available for all questions regarding ADUs. * **Program 8 - Use of Sites in Previous Housing Elements**. Program 8 should be updated to clarify that streamlined approval will be available to both vacant and non-vacant sites through a zoning amendment. As written it appears that the zoning amendment will only apply to vacant sites included in the 4th and 5th cycle housing elements. * **Program 9 - Annual Reporting Program**. While we appreciate the sentiment that the City will “engage all members of the Fresno community,” and the specific commitment to use multilingual notices and media, the City should revise this program and avoid using vague language with no commitments. To make the public engagement associated with this program meaningful, we recommend that the program include a commitment and associated timeframe for the City to implement input received through its various outreach efforts such as workshops and surveys in addition to the annual public hearing. The annual report should include specific actions the City will take to overcome identified constraints and barriers to complying with Housing Element programs. * **Program 10 - Incentives for Housing Development (*identified in the AFH as a Meaningful Action*)**. This program does not present a commitment to address housing 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 production for low-income units or actions that will be taken to complete the program. To facilitate and promote the use of available incentives, the city should make a list of incentives, including density bonus incentives and impact fee waivers, available to the public through an accessible database. Additionally, the program’s current language that it will “identify site opportunities in higher resource areas and …improve access to resources” suffers from the same issues hat program 2 does insofar as it fails to identify clear and enforceable commitments and steps that it will take to ensure the availability of sites for lower income households in high opportunity areas. It is critical for this program’s success and the City’s role in AFFH that the housing element includes clear, timebound, and enforceable actions to ensure availability of sites for lower income households in high resource areas, as outlined above. Finally, the City should include enforceable commitments to avoid displacement and gentrification in the Downtown Planning Area, and assess the role that priority processing in the area has on the City’s duty to AFFH. * **Program 11 - Local Housing Trust Fund (*identified in the AFH as a Meaningful Action*).** The Local Housing Trust Fund is a great tool to alleviate the housing crisis and we are glad to see the City’s commitment to leverage State matching funds. We recommend adding the creation of a Community Advisory Board as an action to ensure that projects are driven by a community process and benefit the most impacted residents. Housing advocates have met previously with City staff to develop an equitable Community Advisory Board made up of a diverse group of residents most impacted by housing barriers, legal experts, and small landlords. * **Program 16 - Surplus Public Lands.** The commitment to release surplus sites appears to simply be a commitment to comply with its existing duties under the Surplus Lands Act. The language is ambiguous, non-committal and must be revised. In addition, the program states the City will “consider depositing a portion of up to 100 percent [of sale proceeds] to the LHTF” We recommend instead that the City commit to depositing 100 percent of sale proceeds into the LHTF. * **Program 18 – Home Buyer Assistance (*identified in the AFH as a Meaningful Action*).** While a critical program for many Fresnans, this Program should include 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 additional commitments to ensure that low-income residents, undocumented residents, residents who speak languages other than English, and residents in racially and /ethnically-concentrated areas of poverty (R/ECAPs) have the opportunity to benefit from these funds. During the 5th Cycle planning period, many residents without social security numbers or who faced language access barriers were unable to apply for the City’s homebuyer assistance program. While the City was able to assist nine families with this program, this program must incorporate mechanisms that will allow more families to apply during the next 8-year cycle by addressing barriers and pursuing state funds every year. This program has other deficiencies that must be addressed such as lack of public outreach and lack of interpretation for applicants applying by phone. Solutions include: ensuring that low-income residents are knowledgeable about the programs, undocumented residents are able to successfully apply for this program, including closing costs as part of funding packages. In order to ensure that residents living in R/ECAPs are targeted, we recommend the City create annual reports listing how many applicants were assisted, outreach efforts made and whether they live in R/ECAPs. Due to the concerns outlined above, the program as currently implemented and drafted fails to adhere to HCD’s AFFH Guidance that “actions must be specific with timelines, discrete steps and measurable outcomes to have a ‘beneficial impact’ during the planning period.” * **Program 19 – Housing Choice Voucher Incentive Program (HCV) (*identified in the AFH as a Meaningful Action*).** This action fails to include meaningful actions with specific timelines, and measurable outcomes to have a “beneficial impact” during the planning period. The program should develop and implement a proactive enforcement program housed within that legal department to ensure HCV . The City should revise this program action to include a timeline of one workshop a month (twelve workshops throughout the year) to ensure residents and landlords are able to access housing quickly and better assist residents/landlords going through any issues that prevent them from using/accepting HCV. Additionally, collaborating with and funding CBOs and fair housing organizations to provide information to voucher holders and landlords on California’s source of income discrimination prohibitions. The program should also commit the City of Fresno to finance billboard ads about protections against HCV discrimination and send informational materials to all landlords in Fresno registered in the rental registry regarding HCV. Finally, the program should be revised to include a commitment to actively pursue enforcement against discrimination against voucher-holders and supplementing vouchers with additional subsidies to support voucher use in higher-cost markets in high resource areas. Northeast Fresno has very limited HCV use, with only four census tracts north of Herndon Avenue containing any HCVs, and of those four tracts, no tract exceeds 5 percent HCV use. By revising the program to include the above recommendations would help address fair housing needs in Fresno. * **Program 21 – Housing Rehabilitation (*identified in the AFH as a Meaningful Action*).** Government Code section 8899.50 requires ““meaningful actions” well beyond combating discrimination to overcome patterns of segregation and foster inclusive communities. These actions, as a whole, must address significant disparities in housing needs and in access to opportunity.” The current program has failed to address the needs of extremely low income residents and vulnerable populations such as undocumented residents. As we continue to see the negative effects of Climate Change across the world, it is imperative that the City include weatherization such as cooling mechanisms, like heat pumps, air conditioning, insulation and other cooling assets to increase resilience to extreme heat as part of the rehabilitation program. It is a critical and urgent need given that extreme heat kills thousands per year and impacts disadvantaged communities the most. Additionally, the City must establish an acquisition and rehabilitation fund to purchase older, blighted, and/or abandoned homes/buildings. The City of Fresno can establish a revolving fund to insure that rehabilitated homes are sold back to the community at a low cost.Finally, for the program to have a beneficial impact the timeframe section should include 15 rehabilitation grants annually, and 5 distressed property grants using PLHA and CDBG funding for extremely low and low income residents. * **Program 22 – Comprehensive Code Enforcement.** While we appreciate Code Enforcement’s response and the City’s diligence to keep increasing staff, there are still additional actions that should be taken to create a comprehensive code enforcement. HCD’s AFFH Guidance recommends that “to overcome contributing factors to fair housing and affirmatively further fair housing, actions must consider a wide range of actions across all action areas. The number and scale of actions will depend on the severity of the needs but regardless of need, a cohesive and effective program will consider multiple action areas.” This program as written continues to fail to address critical housing issues since the last housing element cycle. The program should be revised to include actions around legally holding landlords accountable for retaliation, unlawful evictions, and harassment towards tenants who file code enforcement complaints such as a commitment to adopt a tenant anti-harassment ordinance. As stated, 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 36 of 40 we recommend that the City adequately analyze code enforcement's procedures and incorporate tenant feedback for a comprehensive code enforcement program. * **Program 23 - Special Needs Housing *(identified in the AFH as a Meaningful Action)*.** Much of the language in this program is vague, noncommittal, and does not provide adequate actions in order to provide a beneficial outcome. This program states the City “shall advocate for provision of special needs,” “partner with and encourage local and state non profits,” and “provide/encourage.” These actions are not concrete or specific and provide no assurance of a beneficial impact on persons’ with disabilities access to housing. This should be revised to include review and enforcement of compliance with legal requirements for accessibility of multi-family and affordable housing, including in permitting processes, not just “encourage[ing]” accessibility features. Additionally, we recommend that the program add specific actions to remove barriers to housing by special needs groups such as allowing undocumented residents to apply for and receive housing assistance, vouchers and other subsidies unless otherwise required by federal law. * **Program 26 - Equitable Community Investments *(identified in the AFH as a Meaningful Action)*.** Program 26 states it will “seek funding,” “continue to actively seek resources,” and “continue implementing the written policies.” These commitments are vague and non-committal. There are no actions on how these will be completed and is ambiguous and as a result provides no indication that a beneficial outcome will result from the program and further fair housing. The programs continue not to commit the City to take a lead role in planning, funding, and/or constructing projects or indeed any role beyond identifying issues and needs and seeking funding on an annual basis. Additionally, it should not rely on the General Plan’s identification of Priority Areas for Development Incentives in Chapter 12 and should instead use the Urban Displacement Project data to guide investments. * **Program 28 – Opportunity To Purchase Act (OPA) *(identified in the AFH as a Meaningful Action)*.** Although we appreciate the City’s action to initiate research on a local Opportunity to Purchase Act, we strongly recommend that the City implements robust outreach and engagement, in partnership with CBOs that work closely with low-income communities in racially/ethnically-concentrated. Additionally, the program states it “shall research" and “consider establishing an OPA.” These are not commitments 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 and fail to implement any specific, firm, or enforceable commitment such that no beneficial outcome of the action is indicated. * **Program 29 – Mobile Home Parks (identified in the AFH as a Meaningful Action).** Program 29 contains no commitments, actions, or enforceable language that will ensure a beneficial impact throughout the planning period. Additionally, this program repeats verbatim language included in Program 10A of the 2015-2023 without explaining how or why reliance on the same program action will have better results during the next planning period. With residents like Three Palms and Trails End Mobile Home Park experiencing the negative impacts of slumlords, it is crucial that the City make significant improvements to the program actions. Furthermore, the program must address the need for heat resiliency such as weatherization and insulation especially to older mobile home parks by funding a mobile home park renovation fund for all mobile homes. This fund will help low income families with issues that they need to address due to inspection violations or other habitability concerns. Additionally, this program should include a commitment to penalize and fine mobile home park owners who are not providing adequate and safe conditions for their tenants. For example, Three Palms Mobile Home Park had not had safe drinking water for quite some time and the owner was never made responsible for this clear human rights violation. Finally, consistent with the City’s responsibility to AFFH, the program should support quality of life and access to opportunity improvements for all mobilehome parks in Fresno by taking meaningful actions to increase green space, transit, and resources near mobile home parks. * **Program 30 – Emergency Rental Assistance Program (identified in the AFH as a Meaningful Action).** Although we appreciate the City adding this program, it states that the City will “seek additional funding” and fails to commit ongoing funding that can come from the Local Housing Trust Fund, the General Fund, or its own permanent funding source to ensure a beneficial impact during the planning period. Identification and commitment of a permanent local source of funding by 2024 will highlight a commitment to prevent displacement and protect tenants. * **Program 31 - Eviction Protection Program (EPP) (identified in the AFH as a Meaningful Action).** The Eviction Protection Program is a critical anti-displacement and anti-homeless tool. However, the program's current language to “seek additional funding” to support the “EPP” is not a strong commitment and does not provide indication that a beneficial outcome will occur if funding is not replenished. We strongly recommend that 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 the City commit to staffing 5 full-time staff for screening so tenants are able to receive help as soon as possible. We also recommend program expansion to include: * Wide-reaching outreach and education campaigns * Direct legal representation and assistance for low-income tenants encountering legal issues. This includes but is not limited to being served with a notice from their landlord (e.g. 3-day notice, notice of rent increase, etc.) * Evaluation of the Eviction Protection Program to ensure it is effective and address issues to improve the program. * **Program 33 – Homeless Assistance (identified in the AFH as a Meaningful Action).** Program 33 does not commit the City to any concrete action. The program states it will “identify partnership opportunities,” “leverage the homeless assistance response team” and “support the Voucher Incentive Program” none of which commit to any enforceable and actionable items. The city must commit to completing an adequate analysis of needs of unhoused City residents. This should include the completion of an AFH analysis of disproportionate needs. * **Program 34 - At-Risk Housing.** Program 34 includes actions without a clear commitment to take steps that will lessen the severity or impact of the issue in any timeframe. Again, the language is non-committal, vague, and ambiguous in how the program will reach its objective. Additionally, stronger tenant protections should be included as an objective and completed no later than June 2024 for residents facing displacement and an affordable housing resource map for tenants so they have the option to relocate. * * * * * 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 39 of 40 Thank you for your consideration of our comments. We look forward to discussing them with you and continuing to work with the state and the City to ensure that the City adopts a Housing Element that fully complies with the law and addresses the serious housing needs and disparities that impact Fresno City residents. Sincerely, Valerie Feldman Staff Attorney PILP Karla Martinez Policy Advocate LCJA CC: Hillary Prasad, Housing Policy Specialist, California Department of Housing and Community Development Jose Ayala, Housing Policy Specialist, California Department of Housing and Community Development Scott Lichtig, Deputy Attorney General, Bureau of Environmental Justice, Department of Justice Robert Swanson, Deputy Attorney General, Bureau of Environmental Justice, Department of Justice 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 Michelle Zumwalt Page 40 of 40 **Attachment A:** **Resident Katie Taylor’s Declaration of Industrial Impacts** <
> **DECLARATION OF KATIE TAYLOR IN SUPPORT OF** **SOUTH FRESNO COMMUNITY ALLIANCE’S COMMENTS ON THE CITY OF** **FRESNO’S GENERAL PLAN FINAL PROGRAMMATIC** **ENVIRONMENTAL IMPACT REPORT (SCH #2109050005)** I, Ms. Katie Taylor, declare: 1. I am a resident of Fresno, California. For over fifty years, I have lived on Central Avenue near its intersection with Orange Avenue in unincorporated Fresno County, just South of Fresno City limits. 2. The Amazon Fulfillment Center was constructed across the street from my house in 2017. The Ulta Beauty distribution center was built less than half a mile from my house in 2017 as well. There are other large facilities near my house, including the FedEx terminal, that attract traffic. Several other truck terminals and truck stops have been built around my neighborhood in the last few years as well. It seems like there are always new facilities being built nearby. 3. I was never notified that large warehouses were going to be built so close to me. When I saw the orchard trees being plowed down across the street, I did not know why. I thought the property owners were just going to plant more fruit trees. My neighbors thought the same thing. The next thing we knew there were big buildings being constructed. We were not given an opportunity to provide input on whether these projects went forward, the types of impacts they might have on the community, and what types of mitigation to avoid and reduce the projects' impacts might be appropriate. We were not given the opportunity for our voices to be heard. 4. I am not aware of the City ever contacting me or my family to inform us of the City’s development of its current General Plan (“2014 General Plan”), the 2014 General Plan Master Environmental Impact Report, the Programmatic Environmental Impact Report for the 2014 General Plan, the Roosevelt Community Plan, or other action to zone or pre-zone land in my neighborhood for industrial land uses. 5. Three of my family members have passed away from cancer. My husband, daughter, and son all died of cancer. Some of my neighbors have died of cancer too. I have a heart condition and thyroid problems. I have allergies as well. My allergies have gotten worse since the warehouses were built. Some of my neighbors' children have asthma, which they say has gotten worse. 6. The construction of the Amazon facility had major impacts on me and my neighborhood. While construction was ongoing for months, the Amazon construction covered my house with dust. The construction occurred at night as well. The nighttime construction was loud and they used very bright lights. The truck traffic during the construction was also extremely loud. and I could hear the noise from within my home with the windows shut. The construction caused vibrations that were so strong that my house shook on some occasions. 7. Since the Amazon and Ulta facilities began operating, the car and truck traffic in my neighborhood has increased significantly. People who come visit my house are shocked by how much traffic there is now. There is traffic traveling to the facilities 24 hours a day, seven days week. A loud rumbling from the trucks passing can be heard all hours of the day and night. The vibration from the trucks shakes my house. The trucks are so loud sometimes that it sounds like someone is knocking at my door, and it can sometimes be hard to hear visitors talking in my house when trucks pass by. 8. The trucks going to and from the facilities create a lot of dust and fumes, which covers my house and car constantly. I have to clean the dust off the windows of my house and car almost every day. The dust also seeps into my house through cracks in my doors and windows. My neighbors complain about the dust getting inside their houses too. 9. Traffic lights were put up at the intersection of Central and Orange when the Amazon warehouse was constructed. The lights are very bright and blink continuously. They shine into my windows, which disrupts my sleep. My daughter has Down syndrome and autism. The constant flashing of the traffic lights is very disturbing for her because of her condition. 10. I have noticed that my neighborhood has become hotter since the warehouses were constructed, including during the night. I am forced to use my air conditioning more, which increases my energy bill. My neighbors have also noticed that it is hotter, that the neighborhood does not seem to cool down as much in the evening as it used to, and that they have to use their air conditioners more. 11. I have noticed that the traffic from the warehouses affects pedestrians. People I know that walk around the neighborhood have to be very careful because of the traffic. Some of the Amazon employees drive recklessly. I have noticed more accidents because of the traffic from the warehouses. There is frequently congestion from employee vehicles backed onto Orange Avenue near my house. 12. The water pressure at my house has dropped in the last four or five years. I have to pay for a water tank that comes every two weeks. My water is contaminated. One of my family members tested the water and found that it was not safe to drink. A person from UC Davis came and tested my water too and told me not to drink it because of the contamination. 13. I am worried that the value of my house has gone down because of the warehouses and other facilities. I believe that the value of my neighbors' houses has gone down too. This really hurts us because we do not have very much money, my home is my main source of wealth, and we are trying to pass our homes down to our kids to help support them economically. 2210 San Joaquin Street, Fresno, California 93721 Telephone: (599) 369-2790 14. Since about 2017, my neighbors and I have made many efforts to seek that the City stop approving new warehouses and industrial facilities in my neighborhood, that they notify us before studying and approving any new projects and allow us an opportunity to provide input, and that industrial developers and land owners respect these requests. When I and my neighbors have talked to the City and the developers, we tell them about the noise, dust, traffic, health problems, lowered property values, and other impacts from the warehouses and other projects. But they ignore us and keep building projects here without even notifying us first. It feels like we are not being heard. It feels like they are bullying us—like we are being targeted because of our race and because we do not have a lot of money. 15. The traffic, noise, dust, health, and other impacts from the facilities have caused me to suffer from a significant amount of stress and anxiety. For example, the abrupt loud noises and flashing lights are very unnerving and stressful. The heavy traffic from cars and trucks makes me constantly worry about my family's safety. My daughter has also said that she worries about the traffic, noise, and other impacts from the facilities. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration is executed on September 13, 2021, in Fresno, California. ____________________________________ Ms. Katie Taylor 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 2210 San Joaquin Street, Fresno, California 93721 Telephone: (559) 369-2790 August 16, 2023 Mayor Jerry Dyer Fresno City Councilmembers Michelle Zumwalt, Planning and Development Department 2600 Fresno Street, Room Fresno, CA 93721 RE: City of Fresno Draft 6th Cycle Housing Element Dear Councilmembers, Mayor Dyer, and Ms. Zumwalt, The undersigned organizations write to you to advocate for a Housing Element that is equitable, inclusive, and responsive to disadvantaged communities’ needs. We are a group of community-based organizations working alongside community partners and leaders throughout the City of Fresno. Housing Element Law requires that cities and counties make a diligent effort to meaningfully incorporate public input provided on the housing element update, prioritizing input provided by lower-income residents, residents with special housing needs, protected classes, and residents of lower-income and disadvantaged communities. Goals, policies and actions must be aggressively set to overcome those contributing factors to meet the “meaningful impact” requirement in statute and to avoid actions that are materially inconsistent with the obligation to affirmatively further fair housing. Goals and policies must be created with the intention to have a significant impact, well beyond a continuation of past actions, and to provide direction and guidance for meaningful action. AFFH Guidance, p. 52. The draft element’s Housing Action Plan contains numerous actions that lack concrete steps and measurable outcomes and will not necessarily result in a beneficial impact during the planning period in violation of the Housing Element Law’s standards. The following programs are inadequate and include our recommendations to improve them. * **Program 1 - Maintain Adequate Sites.** Program 1 states that the City shall continue to maintain a current inventory of Housing Element sites to ensure that it can adequately accommodate the 2023-2031 RHNA” Given the impact of rezoning to the availability of and location of sites suitable for housing, the City should take additional steps to ensure transparency in decision-making related to proposed rezones and take diligent steps to provide notice of the proposed rezone along with an assessment of the potential impacts of the rezone on housing opportunity prior to a decision on the proposal. This includes but is not limited to public hearings and door to door canvassing to facilitate effective <
> notice. Further, the city must conduct a racial equity analysis which would include the benefits and disadvantages of the proposed rezone and whether it would result in displacement of protected racial/ethnic groups, reduce housing opportunities for protected groups, and how it would impact patterns of segregation. Finally, the program should explicitly prohibit the rezoning of sites suitable for lower income households to industrial land use classifications which would bring industrial uses next to or near neighborhoods that include or are planned for housing affordable to lower income residents. This is critical to ensure that the City is compliant with its duty to affirmatively further fair housing. * **Program 2- Variety of Housing Opportunities in High Resource Areas *(identified in the AFH as a Meaningful Action)*.** The program states that the City “will identify and pursue opportunities” with affordable housing developers to promote the development of affordable units in high resource areas. Unfortunately, it does not provide any details on how they will in fact promote the development of affordable units for lower income households in high opportunity areas. There is no clear commitment to zone sites for multi-family development in areas of high opportunity or a commitment to ensure that such units are affordable to all income levels. Further, there is no commitment to match funding opportunities with the identification of available sites to facilitate their development. Notably, the City will not conform with its duty to AFFH if it does not ensure adequate sites for affordable housing for lower income residents in high resource areas. Without clear and enforceable commitments and timelines, this program will not provide a beneficial impact or further fair housing. Furthermore, in order to expeditiously address the lack of housing opportunities accessible to lower-income residents in high resource areas, the timeline of this program should be shortened. Accordingly, a specific objectives of this program should be changed to (a) assess the number of sites that must be rezoned in high resource areas (as identified in TCAC/ HCD’s Opportunity Maps) to effectively AFFH , and (b) rezone the adequate number of sites pursuant to that analysis by December of 2025. * **Program 3 - Encourage and Facilitate Accessory Dwelling Units (ADUs) *(identified in the AFH as a Meaningful Action)*.** While we support and encourage the development of ADUs, the program does not outline clear commitments that will yield identifiable beneficial outcomes. The program states “a primary objective of this program is to increase the supply of affordable units throughout the city” but fails to identify any specific commitments to take any action on how this objective will be reached. Additionally, building ADUs is generally not an accessible housing option to low income households who cannot afford predevelopment costs associated with ADUs. We recommend additional measures in this program to make ADUs accessible to lower income households such as targeted outreach to low-income homeowners, incentives for landlords to make ADUs affordable, no interest loans for ADU development and waivers for inspection fees Additionally, a dedicated liaison in the Office of Community Affairs should be available for all questions regarding ADUs. * **Program 8 - Use of Sites in Previous Housing Elements.** Program 8 should be updated to clarify that streamlined approval will be available to both vacant and non-vacant sites through a zoning amendment. As written it appears that the zoning amendment will only apply to vacant sites included in the 4th and 5th cycle housing elements. * **Program 9 - Annual Reporting Program.** While we appreciate the sentiment that the City will “engage all members of the Fresno community,” and the specific commitment to use multilingual notices and media, the City should revise this program and avoid using vague language with no commitments. To make the public engagement associated with this program meaningful, we recommend that the program include a commitment and associated timeframe for the City to implement input received through its various outreach efforts such as workshops and surveys in addition to the annual public hearing. The annual report should include specific actions the City will take to overcome identified constraints and barriers to complying with Housing Element programs. * **Program 10 - Incentives for Housing Development (identified in the AFH as a Meaningful Action).** This program does not present a commitment to address housing production for low-income units or actions that will be taken to complete the program. To facilitate and promote the use of available incentives, the city should make a list of incentives, including density bonus incentives and impact fee waivers, available to the public through an accessible database. Additionally, the program’s current language that it will “identify site opportunities in higher resource areas and …improve access to resources” suffers from the same issues hat program 2 does insofar as it fails to identify clear and enforceable commitments and steps that it will take to ensure the availability of sites for lower income households in high opportunity areas. It is critical for this program’s success and the City’s role in AFFH that the housing element includes clear, timebound, and enforceable actions to ensure availability of sites for lower income households in high resource areas, as outlined above. Finally, the City should include enforceable commitments to avoid displacement and gentrification in the Downtown Planning Area, and assess the role that priority processing in the area has on the City’s duty to AFFH. * **Program 11 - Local Housing Trust Fund *(identified in the AFH as a Meaningful Action)***. The Local Housing Trust Fund is a great tool to alleviate the housing crisis and we are glad to see the City’s commitment to leverage State matching funds. We recommend adding the creation of a Community Advisory Board as an action to ensure that projects are driven by a community process and benefit the most impacted residents. Housing advocates have met previously with City staff to develop an equitable Community Advisory Board made up of a diverse group of residents most impacted by housing barriers, legal experts, and small landlords. * **Program 16 - Surplus Public Lands.** The commitment to release surplus sites appears to simply be a commitment to comply with its existing duties under the Surplus Lands Act. The language is ambiguous, non-committal and must be revised. In addition, the program states the City will “consider depositing a portion of up to 100 percent [of sale proceeds] to the LHTF” We recommend instead that the City commit to depositing 100 percent of sale proceeds into the LHTF. * **Program 18 – Home Buyer Assistance *(identified in the AFH as a Meaningful Action)***. While a critical program for many Fresnans, this Program should include additional commitments to ensure that low-income residents, undocumented residents, residents who speak languages other than English, and residents in racially and /ethnically-concentrated areas of poverty (R/ECAPs) have the opportunity to benefit from these funds. During the 5th Cycle planning period, many residents without social security numbers or who faced language access barriers were unable to apply for the City’s homebuyer assistance program. While the City was able to assist nine families with this program, this program must incorporate mechanisms that will allow more families to apply during the next 8-year cycle by addressing barriers and pursuing state funds every year. This program has other deficiencies that must be addressed such as lack of public outreach and lack of interpretation for applicants applying by phone. Solutions include: ensuring that low-income residents are knowledgeable about the programs, undocumented residents are able to successfully apply for this program, including closing costs as part of funding packages. In order to ensure that residents living in R/ECAPs are targeted, we recommend the City create annual reports listing how many applicants were assisted, outreach efforts made and whether they live in R/ECAPs. Due to the concerns outlined above, the program as currently implemented and drafted fails to adhere to HCD’s AFFH Guidance that “actions must be specific with timelines, discrete steps and measurable outcomes to have a ‘beneficial impact’ during the planning period.” * **Program 19 – Housing Choice Voucher Incentive Program (HCV) *(identified in the AFH as a Meaningful Action)***. This action fails to include meaningful actions with specific timelines, and measurable outcomes to have a “beneficial impact” during the planning period. The program should develop and implement a proactive enforcement program housed within that legal department to ensure HCV . The City should revise this program action to include a timeline of one workshop a month (twelve workshops throughout the year) to ensure residents and landlords are able to access housing quickly and better assist residents/landlords going through any issues that prevent them from using/accepting HCV. Additionally, collaborating with and funding CBOs and fair housing organizations to provide information to voucher holders and landlords on California’s source of income discrimination prohibitions. The program should also commit the City of Fresno to finance billboard ads about protections against HCV discrimination and send informational materials to all landlords in Fresno registered in the rental registry regarding HCV. Finally, the program should be revised to include a commitment to actively pursue enforcement against discrimination against voucher-holders and supplementing vouchers with additional subsidies to support voucher use in higher-cost markets in high resource areas. Northeast Fresno has very limited HCV use, with only four census tracts north of Herndon Avenue containing any HCVs, and of those four tracts, no tract exceeds 5 percent HCV use. By revising the program to include the above recommendations would help address fair housing needs in Fresno. * **Program 21 – Housing Rehabilitation *(identified in the AFH as a Meaningful Action)***. Government Code section 8899.50 requires ““meaningful actions” well beyond combating discrimination to overcome patterns of segregation and foster inclusive communities. These actions, as a whole, must address significant disparities in housing needs and in access to opportunity.” The current program has failed to address the needs of extremely low income residents and vulnerable populations such as undocumented residents. As we continue to see the negative effects of Climate Change across the world, it is imperative that the City include weatherization such as cooling mechanisms, like heat pumps, air conditioning, insulation and other cooling assets to increase resilience to extreme heat as part of the rehabilitation program. It is a critical and urgent need given that extreme heat kills thousands per year and impacts disadvantaged communities the most. Additionally, the City must establish an acquisition and rehabilitation fund to purchase older, blighted, and/or abandoned homes/buildings. The City of Fresno can establish a revolving fund to insure that rehabilitated homes are sold back to the community at a low cost.Finally, for the program to have a beneficial impact the timeframe section should include 15 rehabilitation grants annually, and 5 distressed property grants using PLHA and CDBG funding for extremely low and low income residents. * **Program 22 – Comprehensive Code Enforcement.** While we appreciate Code Enforcement’s response and the City’s diligence to keep increasing staff, there are still additional actions that should be taken to create a comprehensive code enforcement. HCD’s AFFH Guidance recommends that “to overcome contributing factors to fair housing and affirmatively further fair housing, actions must consider a wide range of actions across all action areas. The number and scale of actions will depend on the severity of the needs but regardless of need, a cohesive and effective program will consider multiple action areas.” This program as written continues to fail to address critical housing issues since the last housing element cycle. The program should be revised to include actions around legally holding landlords accountable for retaliation, unlawful evictions, and harassment towards tenants who file code enforcement complaints such as a commitment to adopt a tenant anti-harassment ordinance. As stated, we recommend that the City adequately analyze code enforcement’s procedures and incorporate tenant feedback for a comprehensive code enforcement program. * **Program 23 - Special Needs Housing (*identified in the AFH as a Meaningful Action*).** Much of the language in this program is vague, noncommittal, and does not provide adequate actions in order to provide a beneficial outcome. This program states the City “shall advocate for provision of special needs,” “partner with and encourage local and state non profits,” and “provide/encourage.” These actions are not concrete or specific and provide no assurance of a beneficial impact on persons’ with disabilities access to housing. This should be revised to include review and enforcement of compliance with legal requirements for accessibility of multi-family and affordable housing, including in permitting processes, not just “encourage[ing]” accessibility features. Additionally, we recommend that the program add specific actions to remove barriers to housing by special needs groups such as allowing undocumented residents to apply for and receive housing assistance, vouchers and other subsidies unless otherwise required by federal law. * **Program 26 - Equitable Community Investments (*identified in the AFH as a Meaningful Action*).** Program 26 states it will “seek funding,” “continue to actively seek resources,” and “continue implementing the written policies.” These commitments are vague and non-committal. There are no actions on how these will be completed and is ambiguous and as a result provides no indication that a beneficial outcome will result from the program and further fair housing. The programs continue not to commit the City to take a lead role in planning, funding, and/or constructing projects or indeed any role beyond identifying issues and needs and seeking funding on an annual basis. Additionally, it should not rely on the General Plan’s identification of Priority Areas for Development Incentives in Chapter 12 and should instead use the Urban Displacement Project data to guide investments. * **Program 28 – Opportunity To Purchase Act (OPA) (*identified in the AFH as a Meaningful Action*).** Although we appreciate the City’s action to initiate research on a local Opportunity to Purchase Act, we strongly recommend that the City implements robust outreach and engagement, in partnership with CBOs that work closely with low-income communities in racially/ethnically-concentrated. Additionally, the program states it “shall research" and “consider establishing an OPA.” These are not commitments and fail to implement any specific, firm, or enforceable commitment such that no beneficial outcome of the action is indicated. * **Program 29 – Mobile Home Parks (*identified in the AFH as a Meaningful Action*).** Program 29 contains no commitments, actions, or enforceable language that will ensure a beneficial impact throughout the planning period. Additionally, this program repeats verbatim language included in Program 10A of the 2015-2023 without explaining how or why reliance on the same program action will have better results during the next planning period. With residents like Three Palms and Trails End Mobile Home Park experiencing the negative impacts of slumlords, it is crucial that the City make significant improvements to the program actions. Furthermore, the program must address the need for heat resiliency such as weatherization and insulation especially to older mobile home parks by funding a mobile home park renovation fund for all mobile homes. This fund will help low income families with issues that they need to address due to inspection violations or other habitability concerns. Additionally, this program should include a commitment to penalize and fine mobile home park owners who are not providing adequate and safe conditions for their tenants. For example, Three Palms Mobile Home Park had not had safe drinking water for quite some time and the owner was never made responsible for this clear human rights violation. Finally, consistent with the City’s responsibility to AFFH, the program should support quality of life and access to opportunity improvements for all mobilehome parks in Fresno by taking meaningful actions to increase green space, transit, and resources near mobile home parks. * **Program 30 – Emergency Rental Assistance Program (*identified in the AFH as a Meaningful Action*).** Although we appreciate the City adding this program, it states that the City will “seek additional funding” and fails to commit ongoing funding that can come from the Local Housing Trust Fund, the General Fund, or its own permanent funding source to ensure a beneficial impact during the planning period. Identification and commitment of a permanent local source of funding by 2024 will highlight a commitment to prevent displacement and protect tenants. * **Program 31 - Eviction Protection Program (EPP) (*identified in the AFH as a Meaningful Action*).** The Eviction Protection Program is a critical anti-displacement and anti-homeless tool. However, the program's current language to “seek additional funding” to support the “EPP” is not a strong commitment and does not provide indication that a beneficial outcome will occur if funding is not replenished. We strongly recommend that the City commit to staffing 5 full-time staff for screening so tenants are able to receive help as soon as possible. We also recommend program expansion to include: * Wide-reaching outreach and education campaigns * Direct legal representation and assistance for low-income tenants encountering legal issues. This includes but is not limited to being served with a notice from their landlord (e.g. 3-day notice, notice of rent increase, etc.) * Evaluation of the Eviction Protection Program to ensure it is effective and address issues to improve the program. * **Program 33 – Homeless Assistance (*identified in the AFH as a Meaningful Action*).** Program 33 does not commit the City to any concrete action. The program states it will “identify partnership opportunities,” “leverage the homeless assistance response team” and “support the Voucher Incentive Program” none of which commit to any enforceable and actionable items. The city must commit to completing an adequate analysis of needs of unhoused City residents. This should include the completion of an AFH analysis of disproportionate needs. ● **Program 34 - At-Risk Housing.** Program 34 includes actions without a clear commitment to take steps that will lessen the severity or impact of the issue in any timeframe. Again, the language is non-committal, vague, and ambiguous in how the program will reach its objective. Additionally, stronger tenant protections should be included as an objective and completed no later than June 2024 for residents facing displacement and an affordable housing resource map for tenants so they have the option to relocate. Additionally, the draft element lacks policies and programs identified in Leadership Counsel’s February 2023 letter, attached hereto. We incorporate the policies and programs recommended in that letter here by reference. In addition to the policies and programs highlighted in Leadership Counsel’s February 2023 letter, the draft element should also be revised to include the following programs: A. Rent Control and Just Cause Protection Ordinance. The Housing Element draft mentions tenant protection “strategies” but in no way does the draft commit to tangible solutions. City of Fresno tenants, along with advocates, have been demanding rent control and just cause ordinance since 2021. The Here To Stay Report lists this as the communities’ top priorities. Tenants have attended City Council meetings for the past two years asking for this; they have met with every city council member; and have lifted this as a priority in the City’s Housing Element workshops. Yet, the City refuses to acknowledge residents’ need. We strongly recommend that the City incorporate this into the Housing Element. B. Inclusionary Zoning Ordinance. The City should adopt a program to develop and adopt an inclusionary zoning ordinance by a date certain that is no more than three years into the planning period in order to allow the ordinance to result in the production of lower-income units during the planning period. To ensure that the ordinance AFFH and maximizes the production of affordable units, the ordinance should apply to single-family and multi-family housing and require a minimum share of affordable units (approx. 25-30%) and affordability levels of those units, including affordability for very-low and extremely-low income households. The City should develop this ordinance in partnership with lower-income residents and CBOs. C. Urban Greening is used as buffer zones when residential is placed or already placed near existing polluting land uses to mitigate health impacts. D. Citing industrial uses. Programs should explicitly prohibit the rezoning of sites suitable for lower income households to industrial land use classifications which would bring industrial uses next to or near neighborhoods that include or are planned for housing affordable to lower income residents. This is critical to ensure that the City is compliant with its duty to affirmatively further fair housing. E. Impact fees should be placed into a community benefit fund when polluting land uses and practices are placed near housing. The community benefit fund will be managed by the community directly impacted to dictate to who these funds should be allocated. F. Establish local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of a Project Site. This can reduce the length of trips, reduce greenhouse gas emissions and provide localized economic benefits G. Developing Public Health Impact Reports for new development in order to understand existing public health disparities and the potential of those conditions worsening as a result of development. Public health agencies should be resourced to support this analysis. The findings of these reports should be available publicly and be included in permit approval processes and other key decision-making milestones. H. Establish a Cargo/Freight Prohibition and Revenue Tax to directly fund community-based housing and projects in the neighborhoods most negatively impacted by years of environmental toxicity caused by freight. I. Incorporate Complete Streets principles into all transportation projects at all phases of development, including planning and land use decisions, scoping, design, implementation, maintenance, and performance monitoring. J. Establish a Housing Element Implementation Committee to oversee the timelines and implementation of each program and policy. The committee should be composed primarily by tenants, low-income homeowners, and at-risk populations to ensure implementation meets the needs of most at-risk communities. As discussed previously, each program must contain clear action steps, deadlines, and measurable outcomes that will be achieved within the planning period and address housing and fair housing needs prioritized during the public process. * * * * * Thank you for your consideration of our comments. Please contact us if you would like to find a time to discuss them. We look forward to working together to advance access to safe, affordable housing for all City of Fresno residents. Sincerely, Karla Martinez, Policy Advocate Leadership Counsel for Justice and Accountability Edith Rico, Project Director Building Healthy Communities Shar Thompson, Central Valley Regional Coordinator Tenants Together Marisa Moraza, Campaign Director Power California DATE: August 16, 2023 TO: Michelle Zumwalt, Sophia Pagoulatos- City of Fresno FROM: Scott Miller, President/ CEO RE: Multi-Jurisdictional Housing Element (2023 – 2031) Appendix 1-E Fresno On behalf of our board and membership, sincere thanks for the opportunity to provide feedback on this important document. Our chamber recognizes the importance of fostering a balanced and sustainable housing landscape that not only supports the growing needs of our community but also respects the rights and interests of property owners. We appreciate the efforts made to address housing challenges within the county, and we strongly support the administration’s One Fresno Housing Plan in general. Simply put, we believe all of us in Central California should do what we can to aggressively increase the supply of housing and remove the obstacles to getting it done quickly and affordably. With that in mind, we will continue to focus on the following: 1. **Transparent, market driven solutions with measurable outcomes:** We commend the plan for creating new expedited permissions for ADUs, encouraging creative financing strategies and meaningful expansion of public-private partnerships. By implementing measures that encourage affordable housing without burdening developers or property owners, we can stimulate growth while ensuring housing remains within reach for residents of various economic backgrounds. We hope to see even more incentives such as density bonuses and increases in tax relief for favorable projects moving forward. 2. **Reduce impediments:** We applaud the steps taken by programs 5 and 20 in the draft plan and encourage more. To foster a thriving housing ecosystem, we will always advocate locally and at the State level for streamlined regulatory processes that expedite development without compromising safety and quality. We’d like to see the plan go further to create regulatory exemptions for the development of affordable housing. 3. **Respecting Property Owner Rights:** As a matter of principle, we generally oppose rezoning of private property without the consent of the property owner. We ask that language be included in Program 1 (and other sections as appropriate) specifically discouraging forced rezoning except as a last resort in implementation of the RHNA. 4. **Reconsideration of the Opportunity to Purchase Act:** We think this program (28) could have potential pitfalls. While we’d encourage local nonprofit organizations to own and develop housing in partnership with the City, we recommend removal (or clarification) of the language that implies possible intervention in private sales to create a de facto first right of refusal scenario. Since 1885, our Chamber has been committed to the idea that collaboration and creativity are keys to a prosperous Fresno County. We are eager to actively engage in discussions and offer our insights to ensure that the final Housing Element reflects the best interests of our diverse community. As always, we’re grateful for the opportunity to provide feedback and appreciate the positive working relationship. <
> Scott Miller To promote the success of the regional business community through effective advocacy, education and relationship building. 2331 Fresno Street · Fresno, CA 93721 · (559) 495-4800 · www.fresnochamber.com August 16th, 2023 Michelle Zumwalt Planning and Development Department, City of Fresno, 2600 Fresno Street, Room 3065, Fresno, CA 93721 On behalf of the California Apartment Association (CAA), I extend CAA’s support for the Fresno County Multi-Jurisdictional Housing Element Update as currently written. The Housing Element update’s core goals and proposed policies reflect the importance and urgency of developing housing across Fresno County that is affordable and available to families of all income levels. CAA looks forward to working with all jurisdictions in successfully implementing this plan’s goals. CAA participated in many of the workshops during the public outreach period and appreciates that many of the goals and policies referenced in the latest Housing Element draft reflect the input of the community and underscore the importance of building the homes our community needs. The first goal, with good reason, is new housing development. All Fresno County jurisdictions need to significantly increase housing units over the next eight years, and this is especially true in the extremely low, very low, and low economic segments. (Policy 1.2) This cannot be achieved without the rapid implementation of Policy 1.4, which addresses minimizing unnecessary development costs which add to the costs of housing production. Additionally, incentivizing infill housing development, along with promoting higher-density housing, mixed use zoning, and TOD development will significantly add to housing supply while reducing VMT and aligning with the goals set forth in AB 32. Goal 2 relates specifically to affordable housing, and we believe all aspects should be implemented as soon as practicable. CAA is happy to work with the county and cities in sharing best practices from around the state to ensure the policy goals are adopted quickly and as seamlessly as possible. The need for these initiatives is particularly crucial in Fresno County, which has a significant number of economically-challenged households as discussed in the demographic section of the Housing Element Update. CAA is currently working with Fresno Housing to host a series of webinars regarding accepting Housing Choice Vouchers (Policy 2.2) as we have done in many other cities and counties throughout California. Our experience has been that once rental housing providers understand the program, and the benefits of accepting Housing Choice Vouchers, HCV reach is significantly expanded. Goal 3, Improving and maintaining the quality of housing and residential neighborhoods is another area of emphasis for CAA. (Policies 3.3 and 3.4) Our organization was a key stakeholder in the developing and implementing the Anti-Slum Enforcement Team (ASET) and the Rental Housing Improvement Act (RHIA). CAA continues to work with the City of Fresno through the Neighborhood Revitalization Team and the School Area Team to ensure all rental housing providers, CAA members and non-members alike, abide by and embrace these programs. We welcome the opportunity to work with other jurisdictions as well. Goal 5, Fair and Equal Housing Opportunities, reflects a core element of CAA’s mission. CAA offers meetings and webinars throughout the year, to ensure rental housing providers are educated on federal, state, and local laws and to allow our members to be reminded of these laws as well as any changes in the preceding year. CAA has worked in Fresno, and throughout the state, in conjunction with local governments educating rental housing providers on the importance of all Fair Housing laws. CAA aims to be a partner with all cities in the region to help educate housing providers and their residents on their rights and responsibilities under applicable laws. CAA appreciates the work Fresno County, the incorporated cities of Fresno County, and the Council of Governments have done on this Housing Element update. CAA looks forward to working with all stakeholders in the passage and implementation of the Multi-Jurisdictional Housing Element as currently presented. Sincerely, Greg Terzakis Senior Vice President **California Apartment Association** 980 Ninth Street, Suite 1430 Sacramento, CA 95814 (800) 967-4222 • caanet.org The **California Apartment Association** is the largest statewide rental housing trade association in the country, representing over 50,000 rental housing providers offering over 1 million rental homes statewide. <
> August 16, 2023 Michelle Zumwalt Planning and Development Department City of Fresno 2600 Fresno Street, Room 3065 Fresno, CA 93721 Dear Ms. Zumwalt; On behalf of the more than 4,500 members of the Fresno Association of REALTORS® (F.A.R), I am writing to express support for the Fresno County Multi-Jurisdictional Housing Element Update as currently written. The Update’s core goals and policies address the importance and urgency in developing and increasing housing supply in Fresno County. F.A.R looks forward to working with our coalition partners and all jurisdictions in successfully implementing this Update. California is witnessing a historic housing shortage. While this is universally recognized, there is less agreement about how to define and measure it, or even what makes the shortage so intense. Many factors have applied acute pressure in the housing market amid the general shortage conditions. There are many consequences for those living within Fresno County and no one is likely exempt from the effects of this crisis. F.A.R. participated in several of the workshops during the public outreach period and would like to emphasize and extend support for the following goals and policies referenced in the latest Housing Element draft. The first goal is new housing development, and we cannot emphasize this particular goal enough. All jurisdictions within the Element need to significantly increase housing stock over the next eight years, and this is especially true in the extremely low, very low, and low economic segments. (Policy 1.2) This cannot be achieved without the rapid implementation of Policy 1.4, which addresses minimizing unnecessary development costs which adds to the costs of housing production. Additionally, incentivizing infill housing development, along with promoting higher-density housing, mixed use zoning, and TOD development with significantly add to housing supply while reducing VMT and aligning with the goals set forth in AB 32. Goal 2 specifically addresses affordable housing, and we are in support of implementing all aspects as soon as practicable. F.A.R. intends to work closely with our coalition partners, such as the California Apartment Association (CAA) to share and support best practices to ensure public policy goals are achieved as quickly as possible. We understand that the need for these initiatives is particularly crucial in Fresno County, which has a significant number of economically challenged households as indicated in the demographic section of the Housing Element Update. Goal 3, Improving and maintaining the quality of housing and residential neighborhoods is another area of importance and emphasis for F.A.R. (Policies 3.3 and 3.4) Goal 5, Fair and Equal Housing Opportunities, Real estate professionals and consumers depend on strong fair housing laws and practices for our communities and economy to thrive. Discrimination distorts the housing market and closes the door on the American dream of homeownership for qualified buyers. At F.A.R., we advance our commitment to fair housing through policy advocacy, innovative programming, and legal guidance. F.A.R. promotes public policy to advance broader homeownership availability, accessibility, and affordability in all communities. We prioritize efforts to narrow homeownership gaps among demographic groups and promote strong enforcement of anti-discrimination laws in the housing market. F.A.R. promotes awareness, education and understanding to advance fair housing in the industry. F.A.R. commends the work Fresno County, the incorporated cities of Fresno County, and the Council of Governments have done on this Housing Element update. Further, we would like to thank Mayor Dyer and his One Fresno Plan for his leadership, vision, and practical strategy to address the housing crisis we face today and, in the years to come. F.A.R. looks forward to working with all stakeholders in the passage and implementation of the Multi-Jurisdictional Housing Element as currently written. Thank you for the opportunity to provide our feedback and we thank you for your leadership. Sincerely, *Brian Domingos* Brian Domingos, President Fresno Association of REALTORS® EMAIL TO: housingelement@fresno.gov BY AUGUST 15TH! SUBJECT: MJHE Plan 2 and PLAN 3 The following are my reasons for opposing Plans 2 and 3: 1- Your MJHE Plan is a Plan which takes a law passed in Sacramento to address the issues of homelessness and housing shortages and arrives at “A SACRAMENTO SOLUTION”. **Homelessness & housing shortages are conditions that WE IN THIS NEIGHBORHOOD did NOT create!** 2. **ADU’s (Plan 2)**- Most of us chose this neighborhood BECAUSE it is zoned “Single-Family Residential”. AARP cites that “ADUs change the character of a neighborhood and cause problems for a community that was NOT BUILT for higher density”. We SAVED to buy our homes in this lower density neighborhood! 3. Your “Masterpiece Plan” presents a VERY ONE-SIDED VIEW of ADUs. It emphasizes “Make an income/extra money. House extra family or caregivers.” Shame on you for not providing FULL DISCLOSURE of the downside to ADUs to any and all interested parties! 4. In reviewing professional, expert opinions, we are advised “DO NOT COUNT ON ADU INCOME TO LIVE ON… due to the frequent jurisdictional changes [for rentals] that occur”. (Think Covid- property owners were unable to evict for non-payment, unable to collect rent owed, owners are limited to a “Sacramento-fixed” percentage of raising rent depending on how many rentals they owned- just to identify a few issues.) 5. Your Plan states placing ADUs in single-family neighborhoods with higher median incomes is to “facilitate housing mobility opportunities for lower-income households…” (Pg 1E-4-17). ***This is nothing more than a “Calif Social Experiment”!*** Your Plan has no mention of: 6. … the costs and responsibilities involved in rental units that eat into passive rent income. Yet you highlight income… 7. … how extra POLICE or FIRE PROTECTION will be provided at a time when our Mayor and Chiefs of Police & Fire are desperate for recruits to fill CURRENT vacancies. Then there are CITY RENTAL INSPECTIONS! 8. … details like parked cars crowding our streets, about how adding mailboxes or garbage cans will be determined, the disruption to the privacy of neighbors and those in the main home w/ADU renters coming or going. 9. … about a home that is already a rental. Can the property owner simply ADD an ADU if the current renter objects? 10. *Low-Income Housing (Plan 3)*- Fresno’s low-income housing is poorly kept. I OBJECT to what becomes eyesores in my neighborhood! 11. Building low-income, multi-family units in our neighborhood- in your “Infill Opportunity Zones” or ANY "rezoned" property- again brings up the issue of A LACK OF police and fire personnel. 12. In the *Wall Street Journal*, 8/8/23, front page HEADLINES- "*Apartment Landlords Face Peril As Their Debt Costs Skyrocket*". Talk about housing that will be falling apart, will be unattended, and become *OUR NEIGHBORHOOD’S PROBLEM*... 13. Incorporating your Plans 2 & 3 into NEW areas of building homes- NOT IN EXISTING SINGLE-FAMILY, LOW-DENSITY NEIGHBORHOODS- is where these plans need to be enacted. Home buyers will KNOW what they're getting, they'll KNOW what the residential components will be/are, and these buyers will have 100% awareness of the decision they make to buy in such a neighborhood. It is CRUEL to inflict these misguided plans on our neighborhoods! 14. HERE’S TWO IDEAS- A- CONTINUE the outstanding efforts to remodel and repurpose the motels and inns that have fallen into disrepair or been abandoned and use these for low-income/homeless opportunities. B- Bring in the “NECESSARY RESOURCES” to these sites. Thank you Joseph Gugliemo Rachel Gugliemo Concerned Resident’s From: [REDACTED] Sent: Friday, August 11, 2023 11:48 AM To: HousingElement Subject: MJHE Plan 2 & 3 External Email: Use caution with links and attachments The following are my reasons for opposing Plans 2 and 3: 1- Your MJHE Plan is a Plan which takes a law passed in Sacramento to address the issues of homelessness and housing shortages and arrives at “A SACRAMENTO SOLUTION”. Homelessness camps; housing shortages are conditions that WE IN THIS NEIGHBORHOOD did NOT create! 2. ADU’s (Plan 2)- Most of us chose this neighborhood BECAUSE it is zoned “Single-Family Residential”. AARP cites that “ADUs change the character of a neighborhood and cause problems for a community that was NOT BUILT for higher density”. We SAVED to buy our homes in this lower density neighborhood! Nobody, gave us a handout! We created our neighborhood on our own. 3. Your “Masterpiece Plan” presents a VERY ONE-SIDED VIEW of ADUs. It emphasizes “Make an income/extra money. House extra family or caregivers.” Shame on you for not providing FULL DISCLOSURE of the downside to ADUs to any and all interested parties! 4. In reviewing professional, expert opinions, we are advised “DO NOT COUNT ON ADU INCOME TO LIVE ON… due to the frequent jurisdictional changes [for rentals] that occur. (Think Covid- property owners were unable to evict for non-payment, unable to collect rent owed, owners are limited to a “Sacramento-fixed” percentage of raising rent depending on how many rentals they owned- just to identify a few issues.) 5. Your Plan states placing ADUs in single-family neighborhoods with higher median incomes is to “facilitate housing mobility opportunities for lower-income households…” (Pg 1E-4- 17). This is nothing more than a “Calif Social Experiment!” Your Plan has no mention of: 6. … the costs and responsibilities involved in rental units that eat into passive rent income. Yet you highlight income… 7. … how extra POLICE or FIRE PROTECTION will be provided at a time when our Mayor and Chiefs of Police & Fire are desperate for recruits to fill CURRENT vacancies. Then there are CITY RENTAL INSPECTIONS! 8. … details like parked cars crowding our streets, about how adding mailboxes or garbage cans will be determined, the disruption to the privacy of neighbors and those in the main home w/ADU renters coming or going. 9. … about a home that is already a rental. Can the property owner simply ADD an ADU if the current renter objects? 10. Low-Income Housing (Plan 3)- Fresno’s low-income housing is poorly kept. I OBJECT to what becomes eyesores in my neighborhood! Excessive trash litter the streets, yards not kept up, etc. 11. Building low-income, multi-family units in our neighborhood- in your “Infill Opportunity Zones” or ANY "rezoned" property- again brings up the issue of A LACK OF police and fire personnel. 12. In the Wall Street Journal, 8/8/23, front page HEADLINES- “Apartment Landlords Face Peril As Their Debt Costs Skyrocket”. Talk about housing that will be falling apart, will be unattended, and become OUR NEIGHBORHOOD’S PROBLEM… 13. Incorporating your Plans 2 & 3 into NEW areas of building homes- NOT IN EXISTING SINGLE- FAMILY, LOW-DENSITY NEIGHBORHOODS- is where these plans need to be enacted. Home buyers will KNOW what they’re getting, they’ll KNOW what the residential components will be/are, and these buyers will have 100% awareness of the decision they make to buy in such a neighborhood. It is CRUEL to inflict these misguided plans on our neighborhoods! 14. HERE'S TWO IDEAS- A- CONTINUE the outstanding efforts to remodel and repurpose the motels and inns that have fallen into disrepair or been abandoned and use these for low-income/homeless opportunities. B- Bring in the “NECESSARY RESOURCES” to these sites. Thank you, Dennis Statham 559-779-4779 From: Sarah A <[REDACTED]> Sent: Wednesday, August 09, 2023 11:16 AM To: HousingElement ; Sophia Pagoulatos ; Veronica Martinez ; Michelle Zumwalt Cc: Sarah A <[REDACTED]> Subject: Following up about Multi-Jurisdictional Housing in our Fresno 93711 bluff area External Email: Use caution with links and attachments To: M.Zumwalt, Room 3065, Planning & Development Department Dear Planning department representatives, Thank you, thank you for all the good work you do. I know it's difficult dealing with NIMBYism and you remained perfectly calm. Thank you for listening to my concerns. I've copied the note I sent to our District 2 Councilman, mostly due to my lack of time to repeat it. Please consider my comments. In addition to the comments below, I'm in support of the new and restorative planning within City limits, as opposed to urban sprawl and leapfrog development. Maybe design/infrastructure committees exist to give Developers advice/boundaries on building attractive, green, sustainable communities that will add long-term value to our beautiful city. And wouldn't it be great to have more shady green spaces and urban farms throughout Fresno? Please let me know if there is anyway I can help your efforts here. Thank you in advance for all you do! Sarah Adams [REDACTED] Dear Councilman Karbassi, I attended the jurisdictional housing meeting last night at Nelson Elementary. The planning department staff had a challenging time giving an overview of the City's projects last night. The residents in the Bluff area seemed most concerned about the large piece of land at east end of Alluvial Ave; as well, the lot at SW corner of Van Ness and Alluvial; and in general, the trauma and de-valuation of neighborhood properties that could happen to the existing established high-end homes in our area, IF flanked by super dense apartment style housing or a high-travelled Alluvial Ave somehow connecting to Palm.... Some residents in the room also expressed concern about parking issues related to ADU additions. It seems to me ADUs might fit better on larger lots, minimum of 1/2 acre, with mandatory off- street parking planned/enforced, to avoid congestion concerns. Also, by keeping Alluvial blocked on the East end, the high-end neighborhood would be preserved, and not opened up to through- traffic, or wandering transient folks. ....... Maybe there was some consensus last night (?) that high density, MEDIUM-INCOME housing could fit into NEW undeveloped areas, as opposed to existing areas. Also, it seems there was some approval of less-dense density, and housing FOR SALE instead of for RENT. If there are individual homeowners, there is shared long term interest and responsibility for the neighborhood. Other comments included the need for thoughtful open space planning, landscaping, infrastructure, pedestrian and bike pathways........ On a personal note, I walked around the large lot east of Alluvial Ave this morning--maybe 40 acres?--which is zoned for office buildings apparently. Why is this not zoned for medium-income, dense, townhouse 2-story housing with green space, paths to the ParkPlace shopping center with gym, cafes, restaurants? These businesses would be patronized by local community and there would be less turnover. As well, having access to the river on existing paths and views, is a super extension of the San Joaquin River Parkway and Conservation Trust's mission. This would allow home buying opportunities for young professionals, families, and retired; therefore, creating diversity. There is even a private pre-school in the neighborhood and Nelson elementary school not far away. If I were looking for new community housing, more affordable, as a working person, I'd be interested in this north Fresno location! It sounds like the City doesn't need more office buildings in the area, due to plenty of existing office space....so why not use this acreage to build a wonderful dense townhouse development, and to keep existing Bluff residents to its west happy, don't connect Alluvial. It appears that it could easily be accessed off Palm. We hope you can consider and support these ideas. Best wishes, *Sarah J. Adams* tel. 760/937-6581 From: Mike C. <[REDACTED]> Sent: Wednesday, August 09, 2023 7:54 AM To: HousingElement Subject: #Program External Email: Use caution with links and attachments Program(s)are effective but there's not enough of them. and the ones that there are, are only for families.. There are single people that need just as much help as people that have families.. Wish I had a program now. #needone Sent from Yahoo Mail on Android From: Lynette S. <[REDACTED]> Sent: Wednesday, August 09, 2023 1:06 PM To: HousingElement Subject: MJHA PLAN 2 and Plan 3 External Email: Use caution with links and attachments I attended last night's meeting at Nelson Elementary. I would like to emphatically "go on the record" as being in opposition to Plan 2 (ADUs) and Plan 3 (multi-family, low income housing)! I am a life-long Fresno County resident and have resided the past 31 years at my current address- 7264 N Brooks Ave, Fresno, 93711 (Herndon/West/Alluvial). The following are my reasons for opposing Plans 2 and 3: 1- Your MJHE Plan- this is a Plan which takes a law passed in Sacramento to address the issues of homelessness and housing shortages and arrives at "A SACRAMENTO SOLUTION". (Homelessness & housing shortages are conditions that WE IN THIS NEIGHBORHOOD did NOT create!) 2. ADU's (Plan 2)- Most of us chose this neighborhood BECAUSE it is zoned "Single-Family Residential". AARP cites that "ADUs change the character of a neighborhood and cause problems for a community that was NOT BUILT for higher density". We SAVED to buy our homes in a lower density neighborhood! 3. Your "Masterpiece Plan" presents a VERY ONE-SIDED VIEW of ADUs. It emphasizes "Make an income/extra money. House extra family or caregivers." Shame On You for not providing FULL DISCLOSURE of the downside to ADUs! 4. Reviewing professional, expert opinions, we are advised "DO NOT COUNT ON ADU INCOME TO LIVE ON... due to the frequent jurisdictional changes [for rentals] that occur". (Think Covid- property owners wereunable to evict for non-payment, unable to collect rent owed, owners are limited to a "Sacramento-fixed" percentage of raising rent depending on how many rentals they owned.) 5. Your Plan states placing ADUs in single-family neighborhoods with higher median incomes is to "facilitate housing mobility opportunities for lower-income households..." (Pg 1E-4-17). This is nothing more than a "Calif Social Experiment"! Your Plan has no mention of: 6. ... the costs and responsibilities involved in rental units that eat into passive rent income. Yet you hilight income... 7. ... how extra POLICE or FIRE PROTECTION will be provided at a time when our Mayor and Chiefs of Police & Fire are desperate for recruits to fill CURRENT vacancies. Then there are CITY RENTAL INSPECTIONS! 8. ... details like parked cars crowding our streets, about how adding mailboxes or garbage cans will be determined, the disruption to the privacy of neighbors and those in the main home w/ADU renters coming or going. 9. ... about a home that is already a rental. Can the property owner simply ADD an ADU if the current renter objects? 10. **Low-Income Housing (Plan 3)**- Fresno’s low-income housing is poorly kept. I OBJECT to what becomes eyesores in my neighborhood! 11. Building low-income, multi-family units in our neighborhood- in your “Infill Opportunity Zones” or ANY “rezoned” property- again brings up the issue of A LACK OF police and fire personnel. 12. WSJ, 8/8/23, Front Page HEADLINES- “*Apartment Landlords Face Peril As Their Debt Costs Skyrocket*”. Talk about housing that will be falling apart, will be unattended, and become *OUR NEIGHBORHOOD’S PROBLEM*... 13. Incorporating your Plans 2 & 3 into NEW areas of building homes- NOT IN EXISTING SINGLE-FAMILY, LOW DENSITY NEIGHBORHOODS- is where these plans need to be enacted. Home buyers will KNOW what they're getting, they'll KNOW what the residential components will be/are, and will have 100% awareness of the decision they make to buy in such a neighborhood. It is CRUEL to inflict these misguided plans on our neighborhoods! 14. HERE’S TWO IDEAS- A- CONTINUE the outstanding efforts to remodel and repurpose the motels and inns that have fallen into disrepair or been abandoned as housing solutions for the low-income and homeless populations. B- Increase “NECESSARY RESOURCES” in those areas! Thank you, Lynette Statham, LCSW 559.284.7092 <
> # United Brotherhood of Carpenters & Joiners of America August 9, 2023 Via Email: housingelement@fresno.gov; michelle.zumwalt@fresno.gov Planning and Development Department, City of Fresno, 2600 Fresno Street, Room 3065, Fresno, CA 93721 (559) 313-9735 or ATTN: Michelle Zumwalt, Architect, Re: 6th Cycle Housing Element Update (2023-2031) Dear Michelle Zumwalt Please accept these comments on the above referenced Housing Element Update on behalf of the members of Carpenters Local 701, which represents working men and women in the City of Fresno. Local 701 has long been at the forefront of training the next generation of construction workers, opening pathways to the industry for diverse and traditionally underserved populations, and embracing new technologies and delivery methods to expedite the construction of much needed housing. We appreciate the opportunity and look forward to working together on this important endeavor. To meet the urgent need for housing units outlined in the State’s Regional Housing Needs Allocation (RHNA), as well as the policy goals outlined in the City of Fresno Housing Element, it is vital that the City of Fresno support efforts to build the local construction workforce. However, the City of Fresno current housing element draft fails to address a major impediment to housing production that other cities have acknowledged and committed to addressing in their own, now-finalized housing elements. Namely, neither Fresno County nor the City of Fresno have enough skilled, highly productive residential construction workers to build the nearly 36,866 units that the City of Fresno is supposed to produce over an 8 year time period. 1 As part of the 6th Cycle Housing Element process, the City of Fresno must seek to build 36,866 units over an eight year period. However, as the housing crisis in our communities has continued to deteriorate in recent years, the number of workers employed in residential building construction in Fresno has actually decreased by 10% since 2007.[^p780-1] A continuously shrinking residential construction workforce cannot build 36,866 units of housing in 8 years. As such, the City should commit to developing local residential construction labor policy in its Housing Element. This policy should seek to alleviate the labor shortage impediment to housing in the City by investing in the development and retention of workers in the local residential construction labor supply. To support the policy goals of the Housing Element, Local 701 is therefore requesting that the City add local hire and apprenticeship requirements to the General Plan and Housing Element for all residential construction projects larger than 10 units. The standards Local 701 is proposing in this comment letter would help to ensure greater benefits for the broader community, help ensure that construction labor needs are met, and guarantee that new residential development projects within the City are making needed investments in the region’s skilled construction industry workforce. The City Should Bar Issuance of Building Permits Unless Each Future Residential Development of 10 units or Above has a Viable Apprenticeship Program and Local Hiring Requirements The Carpenters propose the following additions to the Municipal Code of the City of Fresno for any residential project larger than 10 units Permitting requirements in the Municipal Code of the City of Fresno. A person, firm, corporation, or other entity applying for a building permit under the relevant section of the Municipal Code of the City of Fresno, California shall be required to comply with the apprenticeship, healthcare, and local hire requirements of the Housing Element and General Plan. Failure to comply with the requirements set forth in this section shall be deemed a violation of this article. Apprenticeship: For every apprenticeable craft, each general contractor and each subcontractor (at every tier for the project) will sign a certified statement under penalty of perjury that it participates in a Joint Apprenticeship Program Approved by the State of California, Division of Apprenticeship Standards OR in an apprenticeship program approved by the State of California Division of Apprenticeship Standards that has a graduation rate of 50% or higher and has graduated at least thirty (30) apprentices each consecutive year for the five (5) years immediately preceding submission of the pre- [^p780-1]: QCEW data: Difference between YEAR2007 employment (3482) and YEAR 2022 (3121) in Private NAICS 2361 Residential building construction for All establishment sizes in Fresno, California, NSA. qualification documents. The contractor or subcontractor will also maintain at least the ratio of apprentices required by California Labor Code section 1777.5. Local Hire Policy: Contractor will be required to provide documentation that the contractor will hire a minimum of twenty-five percent (25%) of staff for any job classification with more than four (4) employees employed whose primary residence, which is not a post office box, is, and has been, within Fresno county within 180 days of the expected date of issuance of the Notice to Proceed for the project. As part of making these proposals, Local 701 wishes to make the City of Fresno aware that other cities in the wider region have incorporated language into their finalized housing elements that does commit to the development of residential construction labor policy: Cities including Redwood City, Menlo Park, and Foster City, example, have included the following language as part of the policy goals in their respective housing elements: **Adopted Housing Element policy goal (Redwood City and Menlo Park):** “Encourage developers and contractors to evaluate hiring local labor, hiring from or contributing to apprenticeship programs, increasing resources for labor compliance, and providing living wages.”[^p781-2] **Adopted Housing Element policy goal (Foster City):** “Encourage Local Hiring. Encourage developers and contractors to evaluate hiring local labor, hiring from, or contributing to apprenticeship programs, increasing resources for labor compliance, and providing living wages. Local Labor Program List. Establish and post a list of local labor unions and apprenticeship programs on City’s website and encourage the developers and contractors to hire local labor. Responsible Agency: Community Development Department, City Attorney Timeframe: Establish the list by December 2023. Bi-annually update the list or upon requests from the local unions to be added to the list.”[^p781-3] At a minimum, Local 701 strongly calls on the City of Fresno to incorporate a similar commitment to develop residential labor policy in their own housing element. This will help alleviate a major impediment to housing production: the labor shortage crisis in the residential construction. [^p781-2]: See, page 322: City of Menlo Park 2023-31 Housing Element. Available at city-of-menlo-park-2023-2031-housing-element.pdf (menlopark.gov) See, page 52: City of Redwood City 2023-31 Housing Element. Available at REDWOOD-CITY-HE-ADOPTED-2-13-23.pdf (welcomehomerwc.org) [^p781-3]: See, page 82: City of Foster City 2023-31 Housing Element. Available at https://engagefostercity.org/housing-element In addition to the above examples, other cities have also identified the utility of new legislative tools such as AB 2011,[^p782-4] which both streamlines housing production while also raising labor standards for local workers. The Carpenters encourage the City of Fresno to also make use of and lead in taking advantage of the opportunity presented by such legislative developments. While there has been a remarkable economic expansion in Fresno in recent years, rising inequality and displacement adds to the City’s affordability crisis and threatens to undermine the region’s strong economy. Local 701 has a strong track record of developing many programs that will enable the City to meet the General Plan and Housing Element goals. These programs include a robust Joint Apprenticeship Training Committee, vigorous utilization of apprentices in the City of Fresno, healthcare coverage for all members and their families, and innovation within the construction industry. Joint Apprenticeship Training Committees (JATC’s), such as the Carpenters Training Committee for Northern California (CTCNC), are a proven method of career training built around a strong partnership between employers, training programs and the government. This tripartite system is financially beneficial not only for the apprentice, but is a major benefit for the employer and the overall economy of the City of Fresno. The CTCNC monitors current market conditions and adjusts the workflow of apprentices to meet the needs of the community, heading off any shortage of skilled workers. History has demonstrated that strong utilization of apprentices throughout the private sector helped California builders produce millions of units of housing. CTCNC recruitment strategies include robust diversity and inclusionary outreach programs, such as pre-apprenticeship, with proven results in representative workplaces and strong local economies. It is imperative that our underserved populations have supportive and effective pathways to viable construction careers, while ensuring that employers are able to find and develop the best and brightest talent needed to thrive in a competitive economy. Employer-paid health insurance plans for our members and their families provides preventative services to stay healthy and prevent serious illness. Timely care reduces the fiscal burden for our members and their families, and significantly reduces the utilization of safety-net programs administered by the City of Fresno and Fresno. Embracing new technologies and delivery systems will have a significant impact on the construction industry, particularly the residential sector. Increasing housing delivery methods reduces project durations and provides City of Fresno residents housing sooner. Local 701 is at the forefront of ensuring that new construction technologies deliver those benefits while also creating work opportunities for those already in the trades as well as those looking to begin a construction career. Local 701 is in a unique position to address many of the key ideas outline in the City of Fresno Housing Element Update. By investing in the training and utilization of apprentices, performing [^p782-4]: See, page 28: County of Santa Cruz 2023-31 Housing Element. Available at 2023 Housing Element (sccoplanning.com) outreach to ensure that the workforce closely mirrors the demographics of our local community, providing employer-paid healthcare for our members and their families, and promoting innovation in the residential construction sector, Local 701 is prepared to assist in closing the affordability gap in the City of Fresno and Fresno area. We look forward to engaging City staff and elected leaders as the Housing Element moves forward and working cooperatively to bridge the needs of the City with the skills and tools of Local 701. Sincerely, Jayson Martinez Senior Field Representative Carpenters Local 701 From: Valarie Armstrong Sent: Tuesday, August 08, 2023 9:59 AM To: HousingElement Subject: Multi_Jurisdictional Housing Element Public Comment External Email: Use caution with links and attachments City planning and ordinances need to adopt special caveats for tiny homes. Lenders need to be encouraged to provide longer term loans. Tiny homes ($80-160K) and RV park model homes ($59-120k) are less expensive to build and maintain and yield a reduced environmental impact. Tiny home communities foster a stronger sense of community and belonging. Providing affordable options in a housing market that has outpaced wages. If a committed developer could create tiny home subdivisions on smaller plots of land, the options to reduce carbon footprints and still maintain affordable purchase prices are endless. Thank you Valarie Armstrong Human Resources Director Comprehensive Youth Services of Fresno Inc. 4545 N. West Ave. Fresno CA 93705 (559) 229-3561 xt122 | Direct (559) 230-6322 | Fax (559) 229-3681 www.cysfresno.org / varmstrong@cysfresno.org CONFIDENTIALITY NOTICE: This e-mail is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you have received this communication in error, please do not distribute it. Please notify the sender by e-mail at the address shown and delete the original message. Thank you. From: Martha Gonzalez <[REDACTED]> Sent: Tuesday, August 08, 2023 10:44 AM To: HousingElement Subject: The City need to do more for homeless people. I had call and left several messages about a homeless couple living next to our property for over a year and nothing has been done by the City. They have 2 poor dogs tied up all day and the smell is terribl... **External Email: Use caution with links and attachments** -----Original Message----- From: Patrick C. <[REDACTED]> Sent: Tuesday, August 08, 2023 12:34 PM To: HousingElement Subject: Public comment for housing element External Email: Use caution with links and attachments [REDACTED] I understand that the housing element is basically a number report to the State. And agree more affordable housing in different styles is needed around the City. However, one strategy I feel is missing in this report is the deliberate planning that’s needed to build a community with services that are needed within walking distance that would include medical, food, public transit and green space to help clean the air and provide space for play and exercise. City planners have called them catalytic corridors in meetings I’ve attended. I think there needs to be a goal to work collaboratively with parks, arts commission, public works. the Planning commission should not be allowed to make changes to a well thought out plan just because a developer asks. There needs to be a moratorium on changes. Thank you Sent from my iPhone From: Vanesa Donangtavanh Sent: Monday, July 31, 2023 9:11 AM To: Betsy McGovern-Garcia ; Sophia Pagoulatos Cc: Michelle Zumwalt ; HousingElement Subject: RE: City of Fresno Housing Element Public Draft Available External Email: Use caution with links and attachments Good morning Sophia, Following up on this item. Is there anything else we need to do on our end to get this issue addressed in the Housing Element? Thanks, Vanesa VANESA DONANGTAVANH PROJECT MANAGER Self-Help Enterprises <
> 8445 W. Elowin Court P.O. Box 6520 Visalia, CA 93290 559-931-2479 Office 559-651-3634 Fax: vanesad@selfhelpenterprises.org Http://www.selfhelpenterprises.org <
> From: Betsy McGovern-Garcia Sent: Monday, July 17, 2023 2:10 PM To: Sophia Pagoulatos Cc: Michelle Zumwalt ; HousingElement ; Vanesa Donangtavanh Subject: RE: City of Fresno Housing Element Public Draft Available Importance: High Sophia, We are concerned that any housing project over 1 unit requires a discretionary approval in the City of Fresno. Would the City consider adding a program to create a process wherein any affordable housing project of 100 units or less, in a zone which allows multifamily housing, would be by-right? This is a MAJOR barrier in Fresno. Thanks. Betsy From: Sean Z. <[REDACTED]> Sent: Sunday, July 30, 2023 7:19 PM To: HousingElement Subject: Housing element public comment **External Email: Use caution with links and attachments** Housing is way too expensive in Fresno and getting worse. Specifically I think Fresno needs a lot more apartments, particularly tall apartment buildings built near transit lines. We are way too sprawled out and need to focus on building some density around the downtown core. I would really love to see Fresno use a social housing program similar to Vienna, where the city government builds and owns lots of apartment buildings, keeping rent low. I say this as a homeowner that housing prices are out of control and something needs to be done to bring it down. I would also love to see very strict rent control. In addition we need to be building way more housing for the homeless, as its both cruel and unconscionable to have so many people sleeping on the streets, and lessens everyone's enjoyment of the city. From: Jeffrey M. <[REDACTED]> Sent: Thursday, July 27, 2023 5:52 PM To: HousingElement Subject: Please don,t meddle in things that aren't your purview. Government great at creating additional problems doing things that are free market in nature don't trust you or your motives. Stop meddling: **External Email: Use caution with links and attachments** From: Amber F. <[REDACTED]> Sent: Thursday, July 27, 2023 11:31 AM To: HousingElement Subject: External Email: Use caution with links and attachments What part of town are they going to be located in? How much will our taxes go up to pay for this shit? Don't we pay enough already? This state and county is sucking us dry! Soon there will be no one left working and paying taxes, all homeless and welfare, who'll pay then? From: rudemaq <[REDACTED]> Sent: Thursday, July 20, 2023 11:36 AM To: HousingElement Subject: Rental Housing Rehad Assistance External Email: Use caution with links and attachments Hello, I am a owner investor. I have a rental property that recently got inspected by the City for health and safety. The unit pass the inspection with only a couple of minor corrects. Since this inspection was done by the City. I was wondering if the City has any programs or know of any other agencies or programs to assist with energy window replacement for energy saving purposes? Such as a loan program or rebates? Thank you, Rudy Quintana From: Kathleen O. <[REDACTED]> Sent: Thursday, July 20, 2023 12:02 PM To: HousingElement Subject: attention: M. Zumwalt, Community Discussion External Email: Use caution with links and attachments The city needs to take professionals who are low-income into account. Many people work for entities like Fresno Unified School District but do not make a living wage that lets them afford an apartment or a house. It is absolutely insane that we expect people to teach our children in daycares, preschools, elementary, middle, and high schools, and yet they cannot afford housing because there is no regulation. When an apartment costs nearly $2000, the monthly take-home for many of these workers, and the landlord or management company demands 2x, 3x, even 4x rent in income requirements, you are demanding that homeless teachers teach your children. From: Glenn Miller <[REDACTED]> Sent: Thursday, July 20, 2023 1:38 PM To: Veronica Martinez Subject: Re: Multi-Jurisdictional Housing Element External Email: Use caution with links and attachments WE HAVE HAPPILY MOVED OUT OF THE FAST DECLINING LIVING CONDITIONS IN FRESNO AND CALIFORNIA. WE HAVE LIVED THERE 70 YEARS AND GREW SICK OF IT. SORRY BUT I SEE NO FIXING IT UNDER CURRENT POLITICAL CONDITIONS, WE ARE IN EAST TN. AND HAVE NEVER FELT SO FREE. GOOD BYE FOREVER. P.S. there 300k others who have done the same just last year. On Thursday, July 20, 2023 at 10:06:18 AM PDT, City of Fresno wrote: From: Cheyenne J. [REDACTED] Sent: Thursday, July 20, 2023 9:36 PM To: Sophia Pagoulatos Cc: Cheyenne J. [REDACTED] Subject: SW Planning Meeting Response 7-20-23 External Email: Use caution with links and attachments Dear Sophia, You saw how upset I got tonight. I’m not ashamed, maybe a little embarrassed I cursed & made people uncomfortable but oh well! This needs to make people uncomfortable! I am with UU church of Fresno, Social Justice committee, and sub- committee IAF, Industrial Areas Foundation. We fight for people's rights and justice for all! The city is lying through their teeth. You know that the affordable housing isn’t for us locals, it’s for all the commuters living here for cheap & working in LA, SF or Bay Area. Affordable housing means for the outsiders coming into Fresno & buying up stuff. They have no interest in Fresno. They don’t shop here or eat here. They just sleep here & occupy space! The city knows the potential here to be the next LA. They don’t care about us locals or that they are shortening front yards/backyards for stupid bike lanes & more traffic to come. Yet you deny this. More pollution. More traffic. More noise. And not a single resident being affected is notified! The city knows & has already deemed these people to be uneducated & so you intimate folks with big words & fancy confusing sentences & spreadsheets so people won’t engage. The people will give in! And the city wins. I sat next to three people who are poor & were waiting for their keys to get into their home tonight. Keys they were promised but nope, city had other plans! These people don’t deserve to be lied to and strung along! They were so confused by all the big talk language. It’s no wonder the city is getting away with this. I look at ALL the pamphlets given from tonight! My god. I’m looking at all this information from tonight’s meeting and it’s BS! The lowest income to qualify for an elderly person is $43,650 & for mortgage assistance it’s $46,200. I barely make $43,680 and I have a job! Most people are on welfare, fixed incomes of SSI/SDI/Retirement/etc. or homeless. There’s no way for them to qualify for a home. I wouldn’t even qualify. Then there’s “borrow up to $100,000 and no monthly fees on the loan”, For who??? Certainly not me or those more poor. We certainly won’t qualify for that. The City of Fresno knows what they are doing. The water issue is besides the point. This has always been an issue here in Fresno with our water as a wager to gain more power. But the point is the City of Fresno is robbing people of their homes. Their land. Their neighborhoods. Their peace of mind & living. And not telling them the truth! No notice! My contacts tonight since we are to connect from these events are: -Alysonn Walker/SW Rep & formed SW -The pastor of Westside Church of God -Tasha Jones/Talk2Tasha-Social media site 559-246-7000. Knows Alysonn really well I wrote my input on the white boards. Doubt it’ll go anywhere but land on deaf ears. And hope you all understand that I’m just super passionate about standing up for what’s right! I’m in this mix of people. I sit right in this with them. I’ll never have a home of my own. I’ll always be stuck in Apt living. And it’s NOT ok! $850/month used to get someone rent on a 1-bedroom home. Now it’s $1600 a month. Please stop this! Thank you! Live Vertically, Cheyenne Sophia, We are concerned that any housing project over 1 unit requires a discretionary approval in the City of Fresno. Would the City consider adding a program to create a process wherein any affordable housing project of 100 units or less, in a zone which allows multifamily housing, would be by-right? This is a MAJOR barrier in Fresno. Thanks. Betsy **BETSY MCGOVERN-GARCIA** **VICE PRESIDENT** Self-Help Enterprises <
> 8445 W. Elowin Court P.O. Box 6520 Visalia, CA 93290 559-802-1653 Office 559-651-3634 Fax: betsyg@selfhelpenterprises.org [Http://www.selfhelpenterprises.org](Http://www.selfhelpenterprises.org) Sophia, We are concerned that any housing project over 1 unit requires a discretionary approval in the City of Fresno. Would the City consider adding a program to create a process wherein any affordable housing project of 100 units or less, in a zone which allows multifamily housing, would be by-right? This is a MAJOR barrier in Fresno. Thanks. Betsy **BETSY MCGOVERN-GARCIA** **VICE PRESIDENT** Self-Help Enterprises <
> 8445 W. Elowin Court P.O. Box 6520 Visalia, CA 93290 559-802-1653 Office 559-651-3634 Fax: betsyg@selfhelpenterprises.org http://www.selfhelpenterprises.org <
> October 3rd, 2022 Board of Supervisors, Fresno County City Councils, Cities of Fresno County Deputy Director Kristine Cai, Fresno Council of Governments **Re: Fresno COG Multi-Jurisdictional Housing Element Update 2023-2031** Dear Supervisors, Councilmembers, and Kristine Cai: The undersigned organizations write to you to advocate for a Housing Element process and update that is equitable, inclusive, and responsive to disadvantaged communities’ needs. We are a group of community-based organizations working hand-in-hand with community partners and leaders throughout the City and County of Fresno. The following recommendations are based on our experience to push for transformative community-led and identified solutions to elevate and advance their priorities for safe, affordable housing options and fair housing choices. We thank you for taking the time to read the following memo and welcome the opportunity to discuss our letter in further detail. As the Housing Element process begins, it is important and necessary to start the process correctly and with strong community engagement. The Housing Element is an important piece of planning our communities and solving our housing crisis together. Further, the State of California has recently strengthened the laws governing the Housing Element. The Fresno Council of Governments (FCOG), jurisdictions participating in this multi-jurisdictional housing element, and city leaders must apply these laws conscientiously and diligently. With laws such as AB 686 and AB 1397, we expect this Housing Element to be robust, meaningful, and indicative of solving our housing crisis. As always, we are willing to partner and work alongside you all to ensure that these requirements are fulfilled and even exceeded in order to create the change we want to see in the Valley. We look forward to working alongside the Fresno COG, city leaders, and staff in the multijurisdiction Housing Element update (collectively referred to herein as “Fresno jurisdictions” or “jurisdictions”) and solving our housing crisis together. # I. Jurisdictions Must Meaningfully Engage the Public in their Housing Element Updates Practices, Including Lower-Income Residents and Protected Classes As Fresno jurisdiction begins the 6th Cycle Multi-Jurisdictional Housing Element Update, the jurisdictions must meaningfully engage the public, including in particular lower-income residents, members of protected classes under civil rights statutes, residents of disadvantaged communities, and racially and ethnically concentrated areas of poverty (“R/ECAPs”), and community-based organizations that work closely with these groups over the course of the housing element update. Gov. Code Sec. 65583(c)(9); HCD Affirmatively Furthering Fair Housing Guidance (“AFFH Guidance”), p.21. The jurisdictions must engage the public throughout the housing element update process, and engagement must support “meaningful, frequent, and ongoing community participation, consultation, and coordination.”[^p800-1] HCD, Building Blocks, Public Participation. Pursuant to HCD’s AFFH Guidance, public participation efforts should be proactively and broadly conducted through various methods to ensure access and participation. Key stakeholders that jurisdictions seek to engage directly must include community-based organizations and advocacy groups which work directly with lower-income households and protected classes; lower-income and extremely-low income households; persons and households with special housing needs, including but not limited to farmworkers, seniors, single-parent households, and persons with disabilities; tenants, including residents of publicly-subsidized housing; members of protected classes, residents of disadvantaged communities and R/ECAPs; and fair housing agencies.[^p800-2] Outreach plans should include “in-person meetings in various locations to ensure residents from [^p800-1]: HCD AFFH Guidance, p. 10; Gov. Code §8899.50(a),(b),(c); see also AFFH Final Rule and Commentary (AFFH Rule), 80 Fed. Reg. 42271, 4253-42360 (July 16, 2015) [^p800-2]: HCD AFFH Guidance, p. 21 across the jurisdiction have the opportunity to participate.”³ As the process begins, we ask that jurisdictions plan in-person workshops in all parts of the jurisdictions, especially in rural areas where internet access is scarce, and virtual options are impractical. To satisfy Government Code § 65583(c)(9) and its duties to Affirmatively Further Fair Housing, some specific public outreach efforts that we recommend that jurisdictions undertake to achieve the above-referenced objectives include but are not limited to the following: * holding interactive housing element workshops in at least three disadvantaged unincorporated communities (DUCs) in areas across the jurisdictions, including fringe and island communities located adjacent to or near participating cities and legacy communities as defined by Government Code § 65302.10. Residents living in DUCs, as well as other lower-income communities and neighborhoods, are most likely to attend workshops held in their own communities because many low-income residents in these communities lack personal vehicles and many DUCs are not served by efficient or reliable public transportation. The jurisdictions should partner with community residents and/or community-based organizations with ties to the community to plan and perform effective outreach for the workshops; * conducting targeted outreach to and stakeholder interviews with members of special needs populations and protected classes, including but not limited to farm workers, the elderly, members of large families and single-headed households, people of color, and non-English speakers; * soliciting completion of the community survey performed by the jurisdictions by low income and special needs residents, including by the jurisdictions’ housing division and other city and County staff during their interaction with residents in the course of performance of their duties. * advertising opportunities to participate in and provide feedback on the housing element update in non-English language print media, radio, and television, including media in Spanish, Hmong, and other languages spoken by Fresno County residents. Examples of non-English media outlets include Univision, Radio Bilingue, Hmong TV, and the Vida en el Valle publication among others. Many of these media outlets offer free advertising [^p801-3]: HCD AFFH Guidance, p. 10 space for public service announcements. The housing element should document these additional efforts to achieve public participation by all economic segments of the community and explain how input received through those efforts is incorporated therein. Leadership Counsel is willing to support the jurisdictions in planning these additional public outreach efforts. In addition, and importantly, the Draft Amendments must meaningfully incorporate public input provided on the housing element update, prioritizing input provided by lower-income residents, residents with special housing needs, protected classes, and residents of lower-income and disadvantaged communities. The housing needs analysis sites inventory analysis, assessment of fair housing, including discussion of fair housing issues in R/ECAPs and impacting protected classes, displacement risks, disparities in access to opportunity impacting protected classes, meaningful actions, and programs must all incorporate, reflect, and respond to resident input and priorities. The Multi-Jurisdictional Housing Element must incorporate input from residents from all participating jurisdictions to tailor the analysis, sites inventories, actions, and programs applicable to specific jurisdictions accordingly.[^p802-4] The jurisdictions, cities, and the Fresno COG can start to gain public trust if steps to proactively engage the public, including on an ongoing basis, in the multi-jurisdictional housing element update and incorporate and significantly reflect public input provided. Jurisdictions must ensure that strong public engagement efforts are maintained following jurisdictions’ adoption of the element, including, for example, through the incorporation into the housing element of actions committing to the establishment and facilitation of a housing element oversight advisory committee to assist the jurisdictions in obtaining community feedback on housing element implementation from lower-income residents and protected classes. ## II. The Multi-Jurisdictional Housing Element Update Must Comply with Cities’ and the County’s duties under AB 686 [^p802-4]: HCD AFFH Guidance, p. 21 To avoid the continuation of past and current discriminatory practices and to overcome their legacy, the State of California enacted AB 686 (2018). AB 686 requires the state, cities, counties, and other public agencies to affirmatively further fair housing (“AFFH”) in all programs and activities relating to housing and community development. AFFH means taking meaningful actions, in addition to combating discrimination, that overcomes patterns of segregation and fosters inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. It means taking meaningful actions that, taken together, addresses significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws. AB 686 also amended the Housing Element Law to require that housing elements include an assessment of fair housing (“AFH”) and identify sites throughout the jurisdiction to satisfy its regional housing needs allocation. We recommend that jurisdictions and FCOG carefully review HCD’s AFFH Guidance which contains a detailed discussion of AB 686’s requirements, including the requirements for a complete AFH. The AFH Some of these requirements include: * **Summary of Fair Housing Issues.**[^p803-5] The Housing Element must analyze and address patterns of integration and segregation; racially or ethnically concentrated areas of poverty; racially concentrated areas of affluence, disparities in access to opportunity for lower-income residents and protected classes,; and disproportionate housing needs impacting lower-income residents and protected classes, including displacement risk. The analysis of disparities in access to opportunity must include disparities in access to educational, employment, transportation, and environmental opportunity and cover the specific topics identified in HCD's AFFH guidance for each opportunity category. HCD’s AFFH Guidance, pp. 35-36. The disproportionate housing needs analysis must consider disparities in housing cost burdens, overcrowding, substandard housing, homelessness, and other issues and must evaluate displacement risks holistically, considering the impacts of rising rents, infrastructure and service deficiencies, [^p803-5]: https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27-2021.pdf, pg.11 <
> climate change, and other displacement risks that may disproportionately impact lower-income households and protected classes. The analysis must incorporate local data and knowledge, including the input of lower-income households and protected classes, and discuss the fair housing issues specific to distinct jurisdictions, R/ECAPs, and lower-income communities. * **Identification and Prioritization of Contributing Factors.** The AFH must analyze and prioritize factors that contribute to identified fair housing issues and prioritize factors that limit or deny fair housing choice or access to opportunity or negatively impact fair housing or civil rights. * **Sites Inventory AFFH Analysis.**[^p804-6] The housing element must not only demonstrate site capacity to accommodate each jurisdiction’s RHNA, but also that the identified sites are consistent with the duty to AFFH, serving the purpose of replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity.[^p804-7] This evaluation must include the specific components described in the AFH Guidance, including how sites better integrate the community considering historical patterns and trends; the extent to which sites may exacerbate existing patterns of segregation; whether the RHNA by income group is concentrated in areas of the community; and local data, knowledge, and community input. Based on the outcome of the analysis, the site inventory must be modified, and/or actions must be included to overcome patterns of segregation and barriers to opportunity in relation to the sites contained in the inventory. * **Meaningful Goals and Actions.** Existing Housing Element Law requires programs with a schedule of actions with timelines and specific commitment to have a “beneficial impact” within the planning period to achieve the goals and objectives of the housing element. As stated in the AFH guidelines “actions implement goals and consist of *concrete steps, timelines, and measurable outcomes.*” [^p804-6]: https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27-2021.pdf, pg.12 [^p804-7]: 24 Gov. Code, § 8890.50. subd. (b). As the draft Housing Element is produced, we will be looking for these components and compliance with jurisdictions’ duties under AB 686 to ensure that drafts reflect residents’ input and priorities. Further, suppose barriers are identified that impede the application and implementation of programs, policies, and production of housing. In that case, the City should analyzealso analyze these barrierstempt to make a good-faith effort to find alternative solutions. ### III. The Housing Element Must Analyze and Incorporate Programs and Policies That Adequately Respond to our Housing Crisis As discussed above, the housing element must include programs and actions prioritized by lower-income residents, protected classes, and residents of lower-income communities and R/ECAPs during the housing element update to solve our housing crisis. Below are community-identified programs and policies which residents from South Fresno neighborhoods and disadvantaged unincorporated communities across the jurisdictions have repeatedly identified as priorities to solve our housing crisis and AFFH which we ask jurisdictions consider: a. County of Fresno * Create or support expansion of local funding opportunities for farmworker housing. Farmworker housing should be accessible for migrant farmworkers and affordable. b. City of Fresno and County of Fresno: * Adopt a local rent stabilization ordinance, to protect tenants from continuously rising rents, including a rent stabilization board to hear and approve rental increases submitted by landlords. This would apply to the City of Fresno and Fresno County. * Adoption of tenant protections to reduce displacement risks, including just cause eviction that address gaps in protections afforded under the 2019 Tenant Protection Act and a right to counsel guaranteeing access to affordable legal counsel for low-income tenants in housing matters; * Establish a permanent emergency rental assistance program to assist residents at risk of homelessness due to rent increases and changed circumstances and ability to pay. Identification of a permanent local source of funding will ensure continuous funding and that the program can be used to prevent displacement. *The City of Fresno can leverage the Local Housing Trust Fund dollars and the State is continuing to grant monies for rental assistance programs* * Establish a **permanent first-time homeownership assistance program** to help tenants become first-time homeowners. Closing costs and downpayment assistance for low-income, first-time homebuyers can help close the housing gap. Residents with ITIN numbers should be eligible for this program. * Investments in **improvements to mobile home parks** to address the needs, including needs from the mobile park assessment study. Further, it should address weatherization and climate resiliency needs, to improve indoor and outdoor air quality, and to expand access to green space. * Pursue an **Inclusionary Zoning ordinance** in the County of Fresno and the City of Fresno once a General Plan Update has occurred. * **Extreme heat and weatherization programs** to address climate change. This includes funding for weatherization upgrades to homes and rental units, specifically in census tracts that rank the highest on CalEnviroScreen for pollution and poor health outcomes and are most vulnerable to climate change. * Establish an **acquisition and rehabilitation fund** to purchase older, blighted, and/or abandoned homes/buildings. The County and the City of Fresno can establish a revolving fund to insure that rehabilitated homes are sold back to the community at a low cost. * Grants for residents who want to develop **affordable accessory dwelling units** on their land in both the City and County of Fresno. Some residents are willing to sell parcels of land to the County to develop affordable housing and increase housing supply. * **Urban Greening is used** as buffer zones when residential is placed or already placed near existing polluting land uses to mitigate health impacts. * **Citing industrial uses** cannot be sited next to Housing Element sites and compliance with placing housing sites away from heavy, light industrial uses or phasing out light/heavy industrial zones * Suitable Vacant Land should be prioritized for affordable housing in order to bring Very Low Income and Low Income RHNA allocations into compliance * Impact fees should be placed into a community benefit fund when polluting land uses and practices are placed near housing. The community benefit fund will be managed by the community directly impacted to dictate to who these funds should be allocated. c. All Jurisdictions: * Establish local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of a Project Site. This can reduce the length of trips, reduce greenhouse gas emissions and provide localized economic benefits * Developing Public Health Impact Reports for new development in order to understand existing public health disparities and the potential of those conditions worsening as a result of development. Public health agencies should be resourced to support this analysis. The findings of these reports should be available publicly and be included in permit approval processes and other key decision-making milestones. * Establish a Cargo/Freight Prohibition and Revenue Tax to directly fund community-based housing and projects in the neighborhoods most negatively impacted by years of environmental toxicity caused by freight. * Incorporate Complete Streets principles into all transportation projects at all phases of development, including planning and land use decisions, scoping, design, implementation, maintenance, and performance monitoring. * Establish a Housing Element Implementation Committee to oversee the timelines and implementation of each program and policy. The committee should be comprised primarily by tenants, low-income homeowners, and at-risk populations to ensure implementation meets the needs of most at-risk communities. IV. The Sites Inventory Must Comply with New Housing Element Law Requirements, Including Requirements for Access to Infrastructure and Services Under AB 1397 As aforementioned, the State of California has added further requirements and specificity to the obligation of the Housing Element to identify adequate sites for further development of affordable housing. Under AB 1397, for all sites in the inventory, the jurisdiction must determine the number of units “that can be realistically accommodated.[^p808-8]” These requirements do not include “current or planned availability and accessibility of sufficient water, sewer and dry utilities.[^p808-9]” In other words, sites that are served by water, sewer, and other dry utilities available and accessible within three years of the beginning of the planning period will be considered suitable for residential development. In addition, jurisdictions may not reuse on-vacant sites identified in a prior housing element or vacant sites identified in the last two housing element updates to meet lower-income RHNA requirements. Finally, we recommend FCOG and the jurisdictions ensure that sites chosen conform to HCD’s site inventory guidance. Following HCD’s guidance would increase planning efficiency for local agencies, while ensuring compliance with housing element requirements. We look forward to seeing local compliance. * * * * * Thank you for taking our comments into consideration. We look forward to continuing to work with the Fresno jurisdictions on developing a compliant Housing Element that responds to the needs of participating Fresno Jurisdiction Residents and ensures access to safe and affordable housing for all. [^p808-8]: Cal Gov Code 65583.2(c) [^p808-9]: Cal Gov Code 65583.2(c)(2) <
> Sincerely, Karla Martinez, Policy Advocate Leadership Counsel for Justice and Accountability Alexandra Alvarado, Community Organizer Faith in the Valley Marisa Moraza, Senior Campaign Strategist PowerCA Action Shar Thompson, CV Regional Coordinator Tenants Together Josefa Vega, Central Valley Regional Organizer ACLU Northern California Ruben Espinoza, Policy Advocate Fresno Barrios Unidos Guadalupe Ramos, Project Specialist Fresno Building Healthy Communities <
> <
> # A Regional Plan for Addressing Housing Needs Fresno County • Coalinga • Firebaugh • Fowler • Fresno City • Huron • Kerman Kingsburg • Mendota • Orange Cove • Parlier • Reedley • San Joaquin • Sanger • Selma --- ## Conservation — Fresno General Plan, Chapter 7: Resource Conservation and Resilience Element - Source: https://www.fresno.gov/wp-content/uploads/2023/03/General-Plan-7-Resources-Conservation-and-Resilience-7-19.pdf - Pages: 48 - Covers: conservation # 7 RESOURCE CONSERVATION AND RESILIENCE The Resource Conservation and Resilience Element establishes objectives and policies for the conservation of natural resources in Fresno. The Element addresses air resources, including air quality and greenhouse gas emissions; water resources, including groundwater and waterways; energy resources; and land resources, including farmland and mineral resources. The overarching theme is "resiliency," meaning the ability to withstand temporary and permanent disruptions in resources that will affect everyday ways of life. ## 7.1 CONTEXT A conservation element for the conservation, development, and utilization of natural resources including water, forests, soils, rivers, wildlife, minerals, and other natural resources is required to be included in a general plan by State law (California Government Code Section 65302). The conservation element must consider the effect of development within the jurisdiction, as described in the land use element, on natural resources located on public lands. Assembly Bill (AB) 32—the Global Warming Solutions Act of 2006 requires California to reduce statewide greenhouse gas emissions to 1990 levels by the year 2020 and Executive Order S-03-05 calls for a reduction of 80 percent below 1990 levels by 2050. In support of these State goals the City has committed through the General Plan and Greenhouse Gas (GHG) Reduction Plan to reduce community-related and City operations-related greenhouse gas emissions to a degree that would not hinder or delay implementation of AB 32 and would lay the framework to help meet future goals. The primary benefit to the City, and to the development community, of having a citywide GHG Reduction Plan is that it will assist development by streamlining the approval process. The CEQA streamlining provisions of the CEQA Guidelines (SB 97 updates) require local governments to define the extent of GHG production and identify ways to substantially reduce GHGs in the future in order to minimize a potentially significant environmental impact. If a GHG Reduction Plan reduces community-wide emissions to a level that is less than significant, then a later project that complies with the requirements in such a GHG Reduction Plan may be found to have a less than significant impact. This will allow the applicant to complete a GHG Reduction Plan consistency analysis for their project instead of a project specific analysis for greenhouse gases. Potential improvements in air quality and water supply security are additional benefits to pursuing GHG reductions for Fresno. The factors that contribute to GHG increases also impact air quality and water supply in the San Joaquin Valley. As discussed in later sections of this element, the accelerating climate change could have adverse impacts in the Fresno region such as: increased temperature and extreme weather events, increased risk of large wildfires, exacerbation of air quality problems, reduction in the quality and supply of water from the Sierra snowpack, decreased electricity supply, reductions in the quality and quantity of certain agricultural products, decreased health and productivity of California's forests, and increased flood risk. Resiliency in City Planning Resiliency, in terms of city planning, refers to creating infrastructure and implementing policies and programs to ensure that the residents, businesses, and government of a city can withstand temporary and permanent disruptions in resources that affect daily activities. A resilient city is not dependent on certain sources of energy, is able to adapt to shifts in weather patterns, has a plan to respond to emergencies such as earthquakes and floods, and has secured a long-term source of food and water. These ideas are presented in this element in relation to resource conservation concepts; details on infrastructure planning are in the Public Utilities and Services Element and the Transportation and Mobility Element, while emergency preparedness is addressed in the Noise and Safety Element. Protection of biological resources such as native plant communities and wildlife habitats is addressed in the Parks, Open Space, and Schools Element. Relationship to General Plan Goals This Element provides objectives and policies that support a wide range of General Plan goals, in particular the following: 3. Emphasize conservation, successful adaptation to climate and changing resource conditions, and performance effectiveness in the use of energy, water, land, buildings, natural resources, and fiscal resources required for the long-term sustainability of Fresno. 4. Emphasize achieving healthy air quality and reduced greenhouse gas emissions. 5. Support agriculture and food production as an integral industry. *Emphasize the economic and cultural role of Fresno as a center of agriculture and food production systems by conserving farmland through a focus on developing vacant and underutilized land within the established Sphere of Influence of the City, limiting any further urban boundary expansion, and developing urban agriculture within the city and designated growth areas.* 12. Resolve existing public infrastructure and service deficiencies, make full use of existing infrastructure, and invest in improvements to increase competitiveness and promote economic growth. *Emphasize the fair and necessary costs of maintaining sustainable water, sewer, streets, and other public infrastructure and service systems in rates, fees, financing and public investments to implement the General Plan. Adequately address accumulated deferred maintenance, aging infrastructure, risks to service continuity, desired standards of service to meet quality-of-life* goals, and required infrastructure to support growth, economic competitiveness and business development. 13. Emphasize the City as a role model for good growth management planning, efficient processing and permit streamlining, effective urban development policies, environmental quality, and a strong economy. Work collaboratively with other jurisdictions and institutions to further these values throughout the region. Positively influence the same attributes in other jurisdictions of the San Joaquin Valley –and thus the potential for regional sustainability - and improve the standing and credibility of the City to pursue appropriate State, LAFCo, and other regional policies that would curb sprawl and prevent new unincorporated community development which compete with and threaten the success of sustainable policies and development practices in Fresno. 16. Protect and improve public health and safety. 17. Recognize, respect, and plan for Fresno's cultural, social, and ethnic diversity, and foster an informed and engaged citizenry. Emphasize shared community values and genuine engagement with and across different neighborhoods, communities, institutions, businesses and sectors to solve difficult problems and achieve shared goals for the success of Fresno and all its residents. ### Fresno Green – The City’s Strategy for Achieving Sustainability In 2008, the Fresno Green Strategies were presented to a previous mayor and City Council. They were accepted as the City’s first attempt to articulate a direction for achieving a sustainable future through green conservation efforts, including those that could be made by the City. These strategies addressed a wide range of issues organized around five “visions” for Fresno and its future growth areas: New City Beautiful, Sierra View 2025, Solar Valley, Green Enterprise and Economic Development, and City as Good Steward. The City won an award from the U.S. Environmental Protection Agency (EPA) for these strategies. Most of the objectives and programs that support these strategies and ideas have been or are in the process of being implemented. The majority are incorporated into policies in this General Plan. Those that are not should not be considered objectives or policies of this Plan. Key ideas from the Fresno Green Strategies are described below. Chapter 7: Resource Conservation and Resilience # New City Beautiful The New City Beautiful vision showcases good urban design, with priority given to public health, open spaces, public art, historic preservation, urban forests, and the protection of natural habitats. The main initiatives are: * Develop and implement compact, transit- and pedestrian-oriented development principles and green building standards. * Build municipal buildings to a green building rating system and adopt green technology for the retrofit of existing City buildings. * Plan new residential areas and retrofit established neighborhoods to be within one half mile of public parks, school playgrounds and/or recreational open space. * Plant and maintain trees in order to achieve shading of at least 50 percent of all hardscaped parking and pedestrian surfaces. * Protect critical habitat corridors and key habitat characteristics from unsuitable development. * Reduce the use of disposable toxic or non-renewable products through environmentally preferred purchasing policies. # Sierra View 2025 The Sierra View 2025 initiatives focus on making the Sierra Nevada mountain range clearly visible to all Valley residents by 2025. The aim of the initiatives is to improve public health with cleaner air, enhance public transportation, and increase opportunities for walking and cycling: * Implement enhanced public transit and traffic light synchronization programs to reduce commute time. * Reduce City fleets' air pollutant emissions and City greenhouse gas emissions. * Reduce the number of commute trips by single occupancy vehicles. * Meet federal clean air standards. # Solar Valley This initiative envisions Fresno as becoming a leader in renewable energy use by maximizing new renewable sources. With its abundant sunshine, the opportunity exists to improve air quality, reduce dependence on foreign energy, and provide attractive new jobs by harnessing solar power. Three initiatives work toward this vision: * Increase use of renewable energy to meet 50 percent of annual electrical consumption for City operations. * Reduce the city's peak electrical load by 10 percent through energy efficiency and conservation measures and shifting the timing of energy demands. * Reduce citywide greenhouse gas emissions to meet requirements of State AB 32. ## Green Enterprises and Economic Development These initatives set the stage for Fresno to become the Valley center for innovative business enterprises with a focus on the "triple bottom line" of providing environmental, economic and social benefits: * Position Fresno as a regional center for green enterprises. * Create environmentally beneficial jobs in low-income neighborhoods. * Promote and support locally grown and organic foods. ## City as Good Steward The City as Good Steward vision puts forth Fresno as a city that leads by example in greening up its facilities and practices, embracing a zero waste initiative, providing appropriate staff resources, and collaborating with other municipalities and agencies to develop regionally-based green programs. Seven initiatives comprise the program for this vision: * Achieve 75 percent diversion of solid waste that otherwise would go to landfills by 2012 and zero waste to landfills by 2025. * Develop and implement an Integrated Pest Management program. * Protect integrity of Fresno's primary drinking water sources through an update of the General Plan. * Develop and implement environmentally responsible policies and practices. * Market the Fresno Green Strategies (New City Beautiful, Sierra View 2025, Solar Valley, Green Enterprises and Economic Development, and City as a Good Steward) throughout the community. * Incorporate sustainable policies into the General Plan. * Measure successes of Fresno Green Strategies and present a periodic report to the Council, which could be integrated into the General Plan annual report. ## Relation between Urban Form and Resource Conservation Making efficient use of public infrastructure and reducing the financial resources devoted to energy use will save money for residents, businesses, and the City government. By strategically regulating urban form elements through this Plan, such as development types, intensity, building massing and orientation, landscaping size and type, and the mix of land uses, the city can produce significant energy and water savings. The Plan also seeks to prevent an overextension of its developable area and manage land use impacts on municipal revenues more effectively. Low-density residential developments on the urban fringe in county areas that require annexation are expensive for the City to serve with both physical infrastructure (roads, water, and sewer) and public services (fire and police). In addition, because of tax sharing arrangements with the County of Fresno, these annexed areas contribute significantly less revenue to the City’s general fund than land developed within the city limits. Meanwhile, Fresno has vacant and undervalued parcels located in its urban core, particularly along key transit corridors. In established neighborhoods, infrastructure and services are already provided, and tax benefits are much greater for the City than those generated by newly annexed land. Ultimately, the amount of land available to the City for future growth is finite, as further expansion of the City’s SOI is blocked in certain directions by the Madera/Fresno county line and the city of Clovis, is contingent on County of Fresno plans, and may consume valuable farmland. Infill development is also important to other aims of the Plan, including ensuring that the cost of doing business goes down, revenues are maximized, and scarce financial resources are used efficiently. ## 7.2 USE OF INFRASTRUCTURE AND RESOURCES Continued growth outwards creates transportation and air quality issues, as well. The continued siting of major retail and commercial uses, as well as jobs, at Fresno’s urban fringe is lengthening travel times and increasing traffic levels (and air pollution) disproportionately faster than the rate of population growth, due to inefficient location selection. Given the restrictions on and impacts of increasing Fresno’s land area, the Plan promotes the highest and best use of land within Fresno’s current city limits, phases growth into unincorporated areas of the SOI, and avoids de-investment in Downtown and established neighborhoods. Furthermore, certain patterns of land development can increase costs to the City in excess of related revenues and essentially reduce fiscal resources. The Plan seeks to discourage this type of development and, at the least, ensure that all development covers its fair share of public costs. ### Communication and Broadband Making efficient use of public infrastructure and reducing the financial resources devoted to energy use will save money for residents, businesses, and the City. This section addresses broadband and telecommunications infrastructure opportunities as they relate to the progression, redevelopment of the inner city and development of additional services to constituents. Broadband has become an important part of the lives of every citizen as it is used for social interaction, education, business, and healthcare, and has been a key factor in economic development for many cities. As technology evolves and content becomes more readily available, the need for higher communication speeds and access to the technology has also increased. The City of Fresno Information Services Department (ISD) has used excess fiber of the Intelligent Transportation System, as well as its own implemented fiber, for data transport and connectivity. The City’s Intelligent Traffic System is designed and implemented by the Public Works Department with ISD as a partner from a technology aspect. Most of the fiber implemented was funded through grants in order to install conduit and fiber to synchronize traffic signals. To date, most of the construction has been in major thoroughfares where there is a need to control traffic for ease of congestion and improve air quality. Utilizing the excess fiber, the City has been able to realize a cooperative effort between the region’s biggest agencies – the City of Fresno, the County of Fresno and the City of Clovis, as they share data services. In 2003, these three agencies entered into the Fresno Regional E-Government System agreement. Since the initiation of this agreement, ISD has been able to connect multiple agencies (including educational institutions) together to provide shared services such as GIS sharing, public safety data sharing, educational services, data services, as well as video broadcast services. Through this process, the City has been a good steward of taxpayer funds in that they have been able to connect other agencies via this same fiber allowing higher connection speeds without monthly communication fees while realizing additional savings in construction costs. The fiber is also used for other regional services such as video policing and radio services for public safety. In essence, the concept of using excess and additional fiber is a cost savings to the City and its constituents because fiber was installed in trenches while streets were open, thereby digging once. Construction costs for installing a fiber network to allow high speed broadband for City operations, as well as to reach the City’s constituents is costly. While there are costs in purchasing and installing fiber, the most costly portion of installing a fiber optic network is the trenching and installation of conduit. For this reason, many agencies have considered or have adopted a “dig once” policy. While a trench is open for any reason, one or more conduits are placed in the trench either with fiber installed or it is left empty for future fiber installation. The fiber is then used for a multitude of purposes including connecting locations, video surveillance (video policing), wireless services, or it is opened up to the communication carriers who may lease the conduit space for their build outs, thereby offsetting construction costs. Not only will this cut costs of fiber implementation, it will pave the way to ensure that there is a pathway for higher speed broadband as the needs increase. Chapter 7: Resource Conservation and Resilience In areas of development, where there is a need, fiber can be installed to connect facilities and agencies. This can include many City Fire Department and Police Department stations as many of these have been built near neighborhoods or in locations where City fiber does not exist. Additionally, as the Video Policing program evolves and the need arises for high-tech strategies for the City Fire and Police Departments, the foundation will be in place for a cost effective means of providing connections. If the City ever decides to provide Internet or other services to the public or expand services at City parks, the connectivity can either be installed while construction is commencing or the means will be there for a cost effective implementation at a later date. In the case where the City will allow private communication companies to lease the conduit, the conduit will remain a City asset with the potential to receive lease revenues consistent with the requirements of the California Public Utilities Commission's regulations and State laws. If other agencies or institutions would like to connect, they may do so under the current Fresno Regional E-Government System Agreement, which covers data sharing and not Internet transport where the City provides Internet connectivity in competition with other carriers. OBJECTIVE RC-1 Make efficient use of existing and future public infrastructure. IMPLEMENTING POLICIES RC-1-a **Setting Service Standards.** Set service delivery standards at existing levels or formulate and commit the City to an investment program that will meet an improved standard of service. *Commentary: Implementation of this policy will be coordinated with the policies and strategies for fiscal sustainability presented in the Economic Development and Fiscal Sustainability Element.* RC-1-b **Capital Improvement Program.** Prepare and adopt a long-term Capital Improvement Program (CIP) that describes City-sponsored capital projects related to General Plan implementation. *Commentary: The CIP will define what areas or projects it would enable and include funding sources covering the complete cost of the projects, as well as intended phasing. It will be updated annually and comprehensively reviewed every five years so that it accurately reflects the City's priorities, community needs, fiscal realities, and State mandates. It also will include an analysis of how improvements* implement the General Plan and how they reflect the City's commitment to environmental justice and fair share issues relative to individual neighborhood needs. Implementation of this policy will be coordinated with the policies and strategies for fiscal sustainability presented in the Economic Development and Fiscal Sustainability Element and with technical work on service standards and infrastructure improvements mandated by policies in the Public Utilities and Services Element. **RC-1-c** | **Prioritize Revenues.** Prioritize revenues by supporting, streamlining, and providing incentives to projects that create the largest positive impacts on property values, the city's retail base, and, to the extent feasible, Downtown and established neighborhoods. | | | | **Commentary:** These incentives could include giving priority to supporting redevelopment of vacant and underutilized land, particularly in mixed use and higher density corridors and Downtown, over the conversion of active farmland to urban uses. **RC-1-d** | **Coordinate Public Construction.** Coordinate public construction with other public and private agencies, particularly with respect to streets, sewerage, water, gas, electric, irrigation improvements, flood control facilities, and communication to seek the greatest public benefit and efficiencies at the least public cost. **RC-1-e** | **Dig Once.** Whenever a suitable trench is dug, one or more telecommunication conduits shall be placed in the trench, either with fiber installed or with space available for future fiber installation, to expand or upgrade the fiber optic network as appropriate. | | | | **Commentary:** Implementation of this policy will require identification of funding sources. **RC-1-f** | **Telecommunications Strategy.** Develop a process for communication carriers to use excess fiber optic conduit with the City in a manner that will allow for appropriate cost recovery and that is consistent with State and federal law. **RC-1-g** | **Grant Funding.** Seek grant funds for the construction or implementation of the fiber optic system to provide expanded public services (such as services for educational, economic, public safety, or underserved communities). Chapter 7: Resource Conservation and Resilience **RC-1-h** | **Public-Private Partnerships.** Foster opportunities for public-private partnerships that leverage infrastructure, encourage pooling of resources, and promote shared-use activities. |---|---| OBJECTIVE **RC-2** | Promote land uses that conserve resources. IMPLEMENTING POLICIES **RC-2-a** | **Link Land Use to Transportation.** Promote mixed-use, higher density infill development in multi-modal corridors. Support land use patterns that make more efficient use of the transportation system and plan future transportation investments in areas of higher-intensity development. Discourage investment in infrastructure that would not meet these criteria. **RC-2-b** | **Provide Infrastructure for Mixed-Use and Infill.** Promote investment in the public infrastructure needed to allow mixed-use and denser infill development to occur in targeted locations, such as expanded water and wastewater conveyance systems, complete streetscapes, parks and open space amenities, and trails. Discourage investment in infrastructure that would not meet these criteria. OBJECTIVE **RC-3** | Actively engage, listen to, educate, and enlist the support of the Fresno community on the need and strategies for resource conservation. IMPLEMENTING POLICIES **RC-3-a** | **Track Trends in Resource Consumption.** Provide and periodically update written materials and information on the City’s website that tracks public and private rates of resource consumption in Fresno and related fiscal and environmental costs. *Commentary: The City of Fresno Department of Public Utilities will work with the San Joaquin Valley Air Pollution Control District and other resource agencies to determine and publish such information, with the frequency of updates dependent on budgetary resources.* RC-3-b | **Community Outreach and Joint Solution Making.** Host an ongoing education and listening session series with the public to inform them of public and private rates of resource consumption, costs, impacts, and projected future constraints. RC-3-c | **Multi-Jurisdictional Efforts.** Work actively with the public to develop and champion realistic, effective solutions to conserve resources at the local, regional, and state levels. *Commentary: The City will forge partnerships with other resource agencies, time and resources permitting, to provide information, answer questions, and suggest solutions.* # 7.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS Fresno is located in the center of the San Joaquin Valley Air (SJVA) Basin. The air quality in the SJVA Basin is among the worst in the nation, and routinely exceeds federal and State air quality health standards for ozone and particulates. The poor air quality contributes to high levels of asthma, sinus infections, and cardiovascular disease. The SJVA Basin’s poor air quality is caused by natural geographic and climatic conditions, as well as local and regional development, transportation, and land use practices. The federal Clean Air Act required the U.S. EPA to set standards, which state that certain pollutants should not exceed specified levels. California has adopted its own set of stricter standards under the California Clean Air Act. Transportation conformity is required under the federal Clean Air Act to ensure that federally supported highway and transportation project activities are consistent with State implementation programs. Conformity means that transportation activities should not cause new air quality violations, worsen existing violations, or delay timely attainment of federal air quality standards. Conformity requires demonstration that State and regional transportation control measures in ozone nonattainment areas are implemented in a timely fashion. These measures are expected to be given funding priority and to be implemented on schedule. The California Clean Air Act requires nonattainment areas to achieve and maintain the State ambient air quality standards by the earliest practicable date and local air districts to develop plans for attaining the State ozone, carbon monoxide, sulfur dioxide, and nitrogen dioxide standards. In 2003, the Legislature enacted a bill to reduce public exposure to particulates and established a process for achieving near-term reductions in particulates throughout California ahead of federally required deadlines. Chapter 7: Resource Conservation and Resilience Under the California Health and Safety Code, the Air Resources Board is authorized to adopt regulations to protect public health and the environment through the mobile and stationary source airborne toxic control measures. These measures focus on reducing public exposure to diesel particulates and other toxic air contaminants, particularly for children riding in and playing near school buses and other commercial motor vehicles, who are disproportionately exposed to pollutants from these sources. Emissions from cars and trucks are being reduced by State and federal standards, which are based not only on air quality considerations but also on energy use. In California, the Pavley Clean Car Standard and the Low Carbon Fuel standard will have dramatic impacts on vehicle emissions in coming years, as will implementation of the newest national fuel standards for current and future model years. Fresno’s air quality management programs are administered by the San Joaquin Valley Air Pollution Control District (SJVAPCD), which covers eight counties, from the San Joaquin County in the north to Kern County in the south. Within this region, the SJVAPCD is responsible for ensuring compliance with federal air quality standards, but it cannot regulate all the pollution sources. The SJVAPCD only has authority to regulate stationary sources for air pollution; its incentive programs to help reduce mobile source emissions are purely voluntary. This lack of authority to regulate mobile source emissions has restricted the SJVAPCD’s ability to reduce emissions in the Valley and to achieve compliance timelines for federal air quality standards. Its regulations include dust reduction during construction and stationary source requirements. Incentives, which are paid for by collected fees, include programs to replace or retrofit certain vehicle and engine types (trucks, lawn mowers, and school buses) and the Burn Cleaner Program (wood stove change out). ### The City’s Role in Improving Air Quality Given the SJVAPCD’s limited authority, any local efforts to directly and indirectly reduce mobile source emissions and thereby improve air quality fall to the City and its transportation and land use policies. Over 81 percent of the region’s summer ozone pollution comes from mobile vehicle sources. Reducing ozone pollution is therefore highly contingent on reducing the number of vehicles miles traveled in the city. Fresno residents, like the residents of other neighboring cities, are highly dependent on automobiles and trucks for day-to-day operations due to low-density development patterns. The City can reduce the vehicle miles traveled by planning for and providing feasible and convenient alternative travel facilities and modes that emit fewer pollutants per person. The City can also reduce vehicle miles traveled by striving to ensure that trip generators (such as homes) and destinations (shops and businesses) are located near one another to allow for shorter trips. The reduction in vehicle miles traveled can be realized through transit-oriented development (TOD) and higher density, mixed-use development. The land use objectives and policies of this Plan are designed to decrease the generation of air pollution and greenhouse gases through the reduction of vehicle miles traveled by supporting infill development, encouraging Complete Neighborhoods, requiring more compact development in infill areas and growth areas, and tying mixed-land uses and high-density development to existing and probable high-capacity urban corridor transit routes. This pattern of development will allow for a more resilient and sustainable community, preserving valued agricultural land. Infill development relies on the pre-existing public road and utility infrastructure, but may require site cleanup and may burden the existing utility infrastructure to the point that it may need to be upgraded. Mixed-use development allows for a diversity of land uses and activities to be located on the same site or in the same building, including residential uses, retail, professional offices, and commercial uses. Ultimately, higher-density infill and mixed-use development encourages people to drive less because destinations are closer together and easier to reach. Another type of development that can improve the air quality is TOD, which locates residential and commercial districts around a public transit station or transit corridor. It attempts to encourage walking through a compact pattern of development, mixed land uses, and a location near good transit options such as train lines or bus rapid transit (BRT) corridors. TOD is often characterized by frequent and high-quality transit service, good walkability, parking management, and other design features that facilitate transit use and maximize overall accessibility. It can reduce vehicle miles traveled by offering reliable access to other forms of transportation and mobility. The availability and reliability of transit service to users is another critical method by which local infrastructure can affect regional air quality. Public transit can play an important role in reducing air pollution by offering an alternative mode of transportation around the city beyond the private vehicle. When individuals opt to use public transportation instead of private vehicles, fewer cars are on the road, which decreases congestion, results in less pollution, and improves air quality. Street networks can also affect air quality based on the length of trips that they require, as more distance travelled and more time on the road is likely to coincide with more air pollution. With shorter trips needed around the city, the vehicle miles traveled are reduced and fewer pollutants are released into the air, thus improving the air quality. The term Complete Streets means that streets are designed so all users—pedestrians, bicyclists, motorists and transit riders—of all ages and abilities may safely move along and across them. Since 2011, the Complete Streets Act has required California cities to Chapter 7: Resource Conservation and Resilience account for the needs of all roadway users when updating their General Plans. There is no single design for a Complete Street, but components include sidewalks, curb extensions, accessible pedestrian signals, roundabouts, bike lanes, accessible public transportation stops, and pedestrian-scaled lighting. Complete Street policies often have the effect of encouraging walking and use of public transit, thereby reducing automobile traffic congestion and improving air quality. The Mobility and Transportation Element further discusses street patterns and Complete Street systems. The Plan also supports modes of travel beyond the private automobile through its circulation policies designed to expand and connect the city’s existing sidewalk and bike route network, consider multiple modes of transportation to reduce reliance on single- driver automobile transportation and level of service measurement, and consider context in roadway design. Other transportation measures that are part of the City’s effort, and that have been determined to reduce air pollution include: * Investing in BRT, express bus, limited stop bus and high frequency bus routes on principal transit corridors, transit corridors, and transit routes as determined feasible by appropriate transportation infrastructure studies. * Support and promote employer implementation of staggered work hours and employee incentives to use carpools, public transit, and other measures to reduce vehicular use and traffic congestion. Lastly, the use of hybrid, electric and alternative fuel vehicles can improve the air quality, as these vehicles emit fewer pollutants into the air. The Plan supports low emission vehicles through policies and infrastructure, such as providing electric and CNG (compressed natural gas) fueling stations, preferential parking spots for these vehicles, and using these vehicles for the City fleet. Greenhouse Gas Emissions Gases that trap heat in the earth’s atmosphere are called greenhouse gases (GHGs). These gases play a critical role in determining the earth’s surface temperature. Part of the solar radiation that enters earth’s atmosphere from space is absorbed by the earth’s surface. The other part of it is reflected off the earth and radiated back toward space, but GHGs absorb some of this radiation. As a result, radiation that otherwise would have escaped back into space is retained, resulting in a warming of the atmosphere. Without natural GHGs, the earth’s surface would be about 61°F cooler. This phenomenon is known as the greenhouse effect. However, many scientists have determined that emissions from human activities—such as electricity generation, vehicle emissions, and even farming and forestry practices—have elevated the concentration of GHGs in the atmosphere beyond naturally-occurring concentrations, contributing to the larger process of global climate change. # Global Climate Change Global climate change (GCC) refers to a change in the average weather of the earth that may be measured by wind patterns, storms, precipitation, and temperature. Historically, the rate of temperature change has typically been incremental, with warming and cooling occurring over the course of thousands of years. In the past 10,000 years the earth has experienced incremental warming as glaciers retreated across the globe. However, scientists have observed an unprecedented increase in the rate of warming over the past 150 years, roughly coinciding with the global industrial revolution. Although GCC is now widely accepted as a concept, the extent and speed of change to be expected, and the exact contribution from human sources, remains in debate. In its 2013 report, the Intergovernmental Panel on Climate Change (IPCC) predicted that the increase in global mean temperature in 2100 relative to 1850 to 1900 is likely to exceed 2.7 degrees Fahrenheit. The same report projects a sea level rise of 10.3 to 21.7 inches by 2100, relative to 1986-2005, with greater rise possible depending on the rate of polar ice sheet melting. A 2012 report done by the National Research Council (NRC) assessed historic and projected sea level rise for specific locations along the open Pacific coasts of California, Oregon, and Washington. Along the California coast south of Cape Mendocino, the committee projected that sea level will rise 1.57 to 11.8 inches by 2030, 4.72 to 24 inches by 2050, and 16.5 to 65.7 inches by 2100. Accelerating GCC has the potential to cause a number of adverse impacts in California, including but not limited to: * A reduction in the quality and supply of water from the Sierra snowpack. If heat-trapping emissions continue unabated, more precipitation will fall as rain instead of snow, and the snow that does fall will melt earlier, reducing the Sierra Nevada spring snowpack by as much as 70 to 90 percent. This can lead to challenges in securing adequate water supplies. It can also lead to a potential reduction in hydropower. * Increased risk of large wildfires. If rain increases as temperatures rise, wildfires in the grasslands and chaparral ecosystems of southern California are estimated to increase by approximately 30 percent toward the end of the twenty-first century because more winter rain will stimulate the growth of more plant “fuel” available to burn in the fall. In contrast, a hotter, drier climate could promote up to 90 percent more northern California fires by the end of the century by drying out and increasing the flammability of forest vegetation. * Reductions in the quality and quantity of certain agricultural products. The crops and products likely to be adversely affected include wine grapes, fruit, nuts, and milk. Chapter 7: Resource Conservation and Resilience * **Decreased electricity supply.** Decreased water availability for hydropower generation (due to less Sierra snowpack and consequently lower reservoir levels) and decreased transmission efficiencies will increase the risk of brown-outs and black-outs and will affect agricultural and industrial productivity. * **Increased flood risk.** Climate change is anticipated to cause a 20 to 30 percent increase in precipitation in the spring and fall in California. More frequent and heavier precipitation events cause flooding and mudslides, which would incur considerable costs in damages to property, agricultural productivity, infrastructure and even human life. * **Exacerbation of air quality problems.** If temperatures rise to the medium warming range, there could be 75 to 85 percent more days with weather conducive to ozone formation in Los Angeles and the San Joaquin Valley, relative to today's conditions. This is more than twice the increase expected if rising temperatures remain in the lower warming range. This increase in air quality problems could result in an increase in asthma and other health-related problems. * **An increase in temperature and extreme weather events.** Climate change is expected to lead to increases in the frequency, intensity, and duration of extreme heat events and heat waves in California. More heat waves can exacerbate chronic disease or heat-related illness. * **A decrease in the health and productivity of California’s forests.** Climate change can cause an increase in wildfires, an enhanced insect population, and establishment of non-native species. By identifying and addressing underlying vulnerabilities due to climate change in this Plan, the City of Fresno will increase the resilience of the community and the resources it depends on. ### Responding to Climate Change Legislation The City will continue to comply with applicable State climate change legislation. It will also take into consideration settlements by the Governor's Office of Planning and Research (OPR) Technical Advisories and Attorney General with other jurisdictions related to the California Environmental Quality Act (CEQA), GHG emissions, and General Plan updates. By proactively addressing climate change issues and requirements through the Plan, the City has the opportunity to create streamlined application processes for conforming local development. The issue of climate change is closely related to other resource issues and opportunities, particularly air quality and water supply. The State's GHG legislation (AB 32 – California Global Warming Solutions Act of 2006 and SB 375 – Sustainable Communities and Climate Protection Act of 2008) and the amended CEQA and CEQA Guidelines require local governments to define the extent of GHG production and identify ways to substantially reduce GHGs in the future in order to minimize a potentially significant environmental impact. Of particular importance to the Plan is SB 375’s requirement that all regional transportation planning organizations (locally, the Fresno Council of Governments) develop a Sustainable Community Strategy (SCS) designed to coordinate regional transportation plans with land use intensities and densities in order to reduce future GHG emissions. Local adherence to SB 375 and the regional SCS is not mandatory; however, the aim is to motivate local governments to align their land use planning with the adopted SCS to capitalize on the new CEQA streamlining opportunities discussed below. For instance, the County of Fresno has a State-mandated target of reducing its GHG emissions from automobile and light trucks (primarily NOₓ – nitrogen oxides) by 5 percent by 2020 and 10 percent by 2035. SB 375 provides financial and regulatory incentives to achieve the target GHG reductions, including streamlined environmental review for projects that conform to an adopted SCS. The Plan includes policies to reduce vehicle miles traveled by increasing land development densities so that more trips (such as to jobs, schools, and personal services) can be accommodated by shorter drives, transit, walking, or biking, and it is likely that such policies would be consistent with an adopted SCS. The Fresno Council of Governments adopted its SCS in 2014. This General Plan complies with the adopted SCS. Senate Bill 97 (Chapter 185, Statutes of 2007) amended the California Environmental Quality Act statute to establish how GHG emissions and the effects of GHG emissions are appropriately analyzed under CEQA. The amendments stipulate that environmental documents for certain residential and mixed-use projects that are consistent with a General Plan designation, density, SCS, or alternative planning strategy need not analyze global warming impacts resulting from cars and light duty trucks. SB 97 also allows streamlined environmental review for projects in transit corridors that are consistent with an SCS and a City or County's General Plan. ### CEQA Tiering and Streamlining Analysis of Greenhouse Gas Emissions A Climate Action Plan (CAP) to reduce GHG emissions is being prepared concurrently with this Plan. The CAP will allow the City to streamline environmental review for later projects. This is because CEQA and CEQA Guidelines will allow the City to determine that a project's incremental contribution to a cumulative effect is not cumulatively considerable if the project complies with the requirements in a previously adopted CAP or mitigation program under specified circumstances. An environmental document that Chapter 7: Resource Conservation and Resilience relies on a GHG reduction plan for a cumulative impacts analysis must identify those requirements specified in the CAP that apply to the project, and, if those requirements are not otherwise binding and enforceable, incorporate those requirements as mitigation measures applicable to the project. If there is substantial evidence that the effects of a particular project may be cumulatively considerable notwithstanding the project's compliance with the specified requirements in the CAP for the reduction of GHG emissions, an EIR must be prepared for the project. OBJECTIVE RC-4 In cooperation with other jurisdictions and agencies in the San Joaquin Valley Air Basin, take necessary actions to achieve and maintain compliance with State and federal air quality standards for criteria pollutants. Commentary: This includes compliance with California Government Code Section 65302.1 for the San Joaquin Valley. IMPLEMENTING POLICIES RC-4-a Support Regional Efforts. Support and lead, where appropriate, regional, State and federal programs and actions for the improvement of air quality, especially the SJVAPCD’s efforts to monitor and control air pollutants from both stationary and mobile sources and implement Reasonably Available Control Measures in the Ozone Attainment Plan. Commentary: A list of Reasonably Available Control Measures was submitted by the SJVAPCD to the U.S. Environmental Protection Agency as part of the Ozone Attainment Plan designed to reduce ozone-forming emissions. The City is responsible for implementing measures related to operations and/or services that the City controls. RC-4-b Conditions of Approval. Develop and incorporate air quality maintenance requirements, compatible with Air Quality Attainment and Maintenance Plans, as conditions of approval for General Plan amendments, community plans, Specific Plans, neighborhood plans, Concept Plans, and development proposals. RC-4-c Evaluate Impacts with Models. Continue to require the use of computer models used by SJVAPCD to evaluate the air quality impacts of plans and projects that require such environmental review by the City. RC-4-d | **Forward Information.** Forward information regarding proposed General Plan amendments, community plans, Specific Plans, neighborhood plans, Concept Plans, and development proposals that require air quality evaluation, and amendments to development regulations to the SJVAPCD for their review of potential air quality and health impacts. --- | --- RC-4-e | **Support Employer-Based Efforts.** Support and promote employer implementation of staggered work hours and employee incentives to use carpools, public transit, and other measures to reduce vehicular use and traffic congestion. RC-4-f | **Municipal Operations and Fleet Actions.** Continue to control and reduce air pollution emissions from vehicles owned by the City and municipal operations and facilities by undertaking the following: | | • Expand the use of alternative fuel, electric, and hybrid vehicles in City fleets. | | • Create preventive maintenance schedules that will ensure efficient engine operation. | | • Include air conditioning recycling and charging stations in the City vehicle maintenance facilities, to reduce Freon gases being released into the atmosphere and electrostatic filtering systems in City maintenance shops, when feasible or when required by health regulations. | | • Use satellite corporation yards for decentralized storage and vehicle maintenance. | | • Convert City-owned emergency backup generators to natural gas fuels whenever possible, and create an advanced energy storage system. RC-4-g | **FAX Actions.** Continue to improve Fresno Area Express (FAX) bus transit system technical performance, reduce emission levels, streamline system operations, and implement BRT where supportive land uses are proposed by Figure LU-1: Land Use Diagram. RC-4-h | **Airport Actions.** Support Airport efforts to develop and maintain programs and policies to support City, State and federal efforts to achieve and maintain air quality standards. RC-4-i | **Methane Capture.** Continue to pursue opportunities to reduce air pollution by using methane gas from the old City landfill and the City’s wastewater treatment process. Chapter 7: Resource Conservation and Resilience **RC-4-j** | **All Departments.** Continue to develop and implement in all City departments, operational policies to reduce air pollution. --- | --- **RC-4-k** | **Electric Vehicle Charging.** Develop standards to facilitate electric vehicle charging infrastructure in both new and existing public and private buildings, in order to accommodate these vehicles as the technology becomes more widespread. OBJECTIVE **RC-5** | In cooperation with other jurisdictions and agencies in the San Joaquin Valley Air Basin, take timely, necessary, and the most cost-effective actions to achieve and maintain reductions in greenhouse gas emissions and all strategies that reduce the causes of climate change in order to limit and prevent the related potential detrimental effects upon public health and welfare of present and future residents of the Fresno community. IMPLEMENTING POLICIES **RC-5-a** | **Support State Goal to Reduce Statewide GHG Emissions.** As is consistent with State law, strive to meet AB 32 goal to reduce greenhouse gas emissions to 1990 levels by 2020 and strive to meet a reduction of 80 percent below 1990 levels by 2050 as stated in Executive Order S-03-05. As new statewide GHG reduction targets and dates are set by the State update the City's Greenhouse Gas Reduction Plan to include a comprehensive strategy to achieve consistency with those targets by the dates established. **RC-5-b** | **Greenhouse Gas Reduction Plan.** As is consistent with State law, prepare and adopt a Greenhouse Gas Reduction Plan as part of the Master Environmental Impact Report to be concurrently approved with the Fresno General Plan in order to achieve compliance with State mandates, assist development by streamlining the approval process, and focus on feasible actions the City can take to minimize the adverse impacts of growth and development on global climate change. The Greenhouse Gas Reduction Plan shall include, but not be limited to: * A baseline inventory of all known or reasonably discoverable sources of GHGs that currently exist in the city and sources that existed in 1990. * A projected inventory of the GHGs that can reasonably be expected to be emitted from those sources in the year 2035 with implementation of this General Plan and foreseeable communitywide and municipal operations. * A target for the reduction of emissions from those identified sources. * A list of feasible GHG reduction measures to meet the reduction target, including energy conservation and “green building” requirements in municipal buildings and private development. * Periodically update municipal and community-wide GHG emissions inventories to determine the efficacy of adopted measures and to guide future policy formulation needed to achieve and maintain GHG emissions reduction targets. **RC-5-c** **GHG Reduction through Design and Operations.** Increase efforts to incorporate requirements for GHG emission reductions in land use entitlement decisions, facility design, and operational measures subject to City regulation through the following measures and strategies: * Promote the expansion of incentive-based programs that involve certification of projects for energy and water efficiency and resiliency. These certification programs and scoring systems may include public agency “Green” and conservation criteria, Energy Star™ certification, CALGreen Tier 1 or Tier 2, Leadership in Energy Efficient Design (LEED™) certification, etc. * Promote appropriate energy and water conservation standards and facilitate mixed-use projects, new incentives for infill development, and the incorporation of mass transit, bicycle and pedestrian amenities into public and private projects. * Require energy and water audits and upgrades for water conservation, energy efficiency, and mass transit, pedestrian, and bicycle amenities at the time of renovation, change in use, change in occupancy, and change in ownership for major projects meeting review thresholds specified in an implementing ordinance. * Incorporate the City’s “Guidelines for Ponding Basin/Pond Construction and Management to Control Mosquito Breeding” as conditions of approval for any project using an on-site stormwater basin to prevent possible increases in vector-borne illnesses associated with global climate change. * Periodically evaluate the City’s facility maintenance practices to determine whether there are additional opportunities to reduce GHGs through facility cleaning and painting, parks maintenance, road maintenance, and utility system maintenance. * Periodically evaluate standards and mitigation strategies for highly vehicle-dependent land uses and facilities, such as drive-through facilities and auto-oriented development. **RC-5-d** SCS and CAP Conformity Analysis. Ensure that the City includes analysis of a project’s conformity to an adopted regional Sustainable Community Strategy or Alternative Planning Strategy (APS), an adopted Climate Action Plan (CAP), and any other applicable City and regional greenhouse gas reduction strategies in affect at the time of project review. **RC-5-e** Ensure Compliance. Ensure ongoing compliance with GHG emissions reduction plans and programs by requiring that air quality measures are incorporated into projects’ design, conditions of approval, and mitigation measures. **RC-5-f** Toolkit. Provide residents and project applicants with a “toolkit” of generally feasible measures that can be used to reduce GHG emissions, including educational materials on energy-efficient and “climate-friendly” products. **RC-5-g** Evaluate Impacts with Models. Continue to use computer models such as those used by SJVAPCD to evaluate greenhouse gas impacts of plans and projects that require such review. ### 7.4 WATER RESOURCES Population and economic growth of Fresno will be determined, in part, by the availability of water. Fresno’s water supply faces challenges and requires strategic decisions to secure its long-term availability and affordability, in light of several pressures: * Fresno’s water supply currently depends on hundreds of deep wells, which draw on a declining aquifer (See the Public Utilities and Services Element for more information). * The City has the opportunity to use substantial surface water resources, but these require funding and construction of costly new treatment and distribution infrastructure. * Fresno has one of the highest per capita water consumption rates in California, more than twice that of Los Angeles. More than 50 percent of water consumption in Fresno is used for landscaping, rising to 70 percent in summer months. * The costs of wastewater treatment, both for the City and industrial users, are relatively high. * Running groundwater pumps and conveyance systems uses a tremendous amount of energy. Both the amount and cost of energy are rising in spite of technological innovation and efforts to reduce energy demands related to the City’s water supply. ## Water Sources Fresno relies on two sources for its water: groundwater and surface water. With its dry climate and low annual rainfall (11 inches), Fresno is dependent on the Sierra snowpack, two rivers, and a groundwater basin for its water needs. Fresno’s primary source of water is groundwater that is located within the existing Kings Sub-basin groundwater aquifer and watershed area, as shown in Figure RC-2. The DPU Water Division currently uses 270 wells to pump about 146 million gallons of water per day (mgd). Since the 1940s, Fresno has taken out more water from the aquifer than has naturally and intentionally seeped back in. This has created an overdraft on the system, resulting in a declining water table (approximately 100 feet in the past 80 years). This increase in the depth to the water table has contributed to water quality problems, deeper well construction, and additional energy costs (due to additional pumping required) and treatment costs. The City currently spends about $20 million on electricity annually, of which 56 percent, or $11.2 million, is for water and wastewater services. The vast majority of that expenditure, $9 million, is for electricity to run groundwater pumps and conveyance. As the groundwater level decreases, the City will be forced to continue drilling deeper wells, which will result in increased power costs to lift the deeper water from the aquifer. The groundwater level will continue to decline, possibly increasing in its rate of decline as the population drawing water from the basin increases, as shown in Figure RC-1. Other jurisdictions access the Kings Sub-basin groundwater aquifer, and so the rate of drawdown is not solely under the control of the City. Fresno is the biggest user of the aquifer, however, and thus has a large degree of influence on its condition. As it is in a position to lead, the Plan supports efforts to improve regional standards of groundwater usage and recharge. Fresno does have other sources of water available from the San Joaquin River to the north and the Kings River to the southeast, as shown in Figure RC-2. Snow melt from the Sierras makes its way to Millerton Lake, where it is stored behind Friant Dam and released to the San Joaquin River, and to Pine Flat Reservoir, where it is stored behind Pine Flat Dam and released to the Kings River. Fresno’s access to this natural surface water has been established through contracts with the United States Bureau of Reclamation (USBR) for the San Joaquin River and the Fresno Irrigation District (FID) for the Kings River. The FID contract is renewed annually and the USBR contract is permanent. ### Figure RC-1: Population Growth vs Depth to Groundwater <
> As the City’s population has grown, the demand on the City’s groundwater supplies has increased. In the 1930s, groundwater was accessible at a depth of 30 feet, while in the 2000s, groundwater was accessible at depths of more than 120 feet in the ground. Between both sources, 156,100 acre feet[^p25-1] (af) of surface water was available to Fresno in 2010. The City diverted 79,000 af for use within the city and allowed the remaining 77,100 af to be used by California State University, Fresno and local farmers for irrigation purposes. This practice is termed in-lieu recharge, whereby groundwater pumping is offset by the use of surplus surface water, thereby leaving groundwater in storage for later use. Another advantage to this practice is that the irrigated surface water seeps through the soil to replenish the aquifer. [^p25-1]: An acre-foot is enough water to cover an acre of land with one foot of water. It equates to about 326,000 gallons of water. The City's Northeast Surface Water Treatment Facility (NESWTF) opened in 2004. By 2009, it helped to offset demand for groundwater by 12 percent. Because of the depth of the groundwater table in Fresno, it costs less to treat water at a surface water treatment facility than it does to pump water from the aquifer. The City of Fresno Urban Water Management Plan (UWMP) and the City of Fresno Metropolitan Water Resources Management Plan provide recommendations to increase surface water treatment capacity with phased infrastructure improvements that could shift the burden away from groundwater and allow water levels in the aquifer to balance and potentially recover over time. This will also allow the City to make use of available surface water that is not being used within the city. If the city continues to use primarily groundwater and does not increase surface water treatment and recycled water supply capacity, the groundwater table will decrease at an increasingly higher rate as Fresno grows and the population increases. According to modeling done for Phase 2 of the City of Fresno Metro Plan, continuing to operate “status quo” will cause the groundwater table to decline an additional 85 feet below 2005 conditions by 2025. Under these conditions, 26 percent of the City's wells (69 wells) would have groundwater levels below the current pump bowl intake elevations and would not be operational, and another 13 percent of the wells (36 wells) would have groundwater levels of 15 feet or less above the pump bowl elevations, which may result in inadequate water coverage over the top of the pump bowl. <
> As part of the Kings Sub-basin groundwater aquifer, the Kings River, pictured here, is an important natural resource for the City of Fresno. Photo: Fresno/Clovis Convention & Visitors Bureau. Figure RC-2: Kings Subasin Groundwater Aquifer and Watershed Area <
> Source: City of Fresno, 2014; Provost & Pritchard Consulting Group; California Department of Water Resources Existing Plans and Initiatives As noted previously, Fresno's future relies on being able to provide a dependable supply of potable water to the community. The City has adopted long-range capital and strategic programs through its City of Fresno Metro Plan, City of Fresno Recycled Water Master Plan, and City of Fresno Wastewater Master Plan. The City has also adopted the State's 2013 CalGreen Building Code, Model Water Efficient Landscape Ordinance, and Graywater Standards, which combine for a 10 to 20 percent reduction in water use in most new construction. 2010 City of Fresno Urban Water Management Plan (UWMP) The City of Fresno UWMP sets water management goals and strategies to supply water to Fresno's population through 2030. These goals and strategies include reducing the consumption of gallons per capita per day from 300 to 243 by 2020 as mandated by the State and balancing the City's groundwater operations by 2025. To accomplish these targets will require ongoing and new conservation measures; the maximization of available surface water supplies for direct treatment and use, and intentional groundwater recharge; and the incorporation of tertiary-treated recycled water into the future water supply portfolio to meet non-potable demands in new growth areas and existing parts of the city. Implementation of the City's future water supply plan will result in a significant shift and increase in diversity in the City's water supply mix, which will enhance overall water supply reliability. Water Conservation Efforts The city depends on reduced consumption due to conservation as a part of its future water supply. Educating the public to reduce usage also directly affects water delivery costs. Power and treatment costs increase as the City pumps more water, so higher water use would mean higher water and sewer rates. Many of the City's water conservation measures respond to requirements in the City's United States Bureau of Reclamation (USBR) contract for 60,000 acre feet of surface water. In fact, one of the contract conditions is that the city follows USBR Best Management Practices, which were used to create the City's Water Conservation Program. This Program includes watering restrictions in the form of a required winter and summer watering schedule; customer education on the need to conserve water and how to do so; free residential plumbing retrofits such as low flow shower heads and aerators; free system water audits, leak detection and repair; metering for all new connections and retrofits of existing connections; rebate programs for high efficiency clothes washing machines, ultra-low flush or high efficiency toilets, and urinal replacement; public information outreach programs; and water waste prohibition through watering regulations and enforcement. Demonstration gardens and drip Chapter 7: Resource Conservation and Resilience irrigation demonstration plots have been installed as resources to provide examples to customers. ## Groundwater Recharge An important process in a viable groundwater management plan is groundwater recharge. One source is the natural subsurface inflow recharge, which occurs when water flows from areas where the water table is higher to areas where it is lower. The Water Division has estimated that the average rate of subsurface inflow to the aquifer is 22,500 acre feet/year (af/yr). The aquifer is also recharged naturally by rainfall, unlined canals and rivers, as well as irrigation water seeping through the soil at an average estimated rate of 24,400 af/yr. Natural recharge can be impeded somewhat by human activities including pavement and buildings, which can result in enhanced surface runoff and reduction in recharge. <
> The Kings Sub-basin groundwater aquifer is recharged naturally by rainfall, unlined canals and rivers, and irrigation water, but human activities can impede this natural process with pavement and buildings. Photo credit: Karana Hattersley-Drayton. To capture surface water runoff, also known as stormwater, the Fresno Metropolitan Flood Control District (FMFCD) has developed an urban drainage design concept that collects, detains and retains surface water runoff for intentional groundwater recharge in ponding basins dispersed throughout the city. FMFCD estimates they collect more than 95 percent of Fresno's urban runoff, though the percentage that actually gets recharged and the part that is discharged to FID canals and the San Joaquin River is unknown. The FMFCD also partners with the FID and the City in a cooperative groundwater recharge program. This program provides for dry season (generally March through October) delivery of City contract imported surface water from the San Joaquin and Kings Rivers into many of the FMFCD's local ponding basins and the City-owned Leaky Acres recharge basin. Intentional recharge can vary due to a number of factors, which could include pond availability, water delivery season, pond maintenance, or length of wet season. Intentional recharge in Fresno has averaged 48,900 af/yr from 1990 to 2011. In 2010, intentional recharge was 53,100 af for a total groundwater recharge of 100,000 af. Groundwater pumpage in 2010 was 128,578 af which created a 28,578 af overdraft on the aquifer that year alone. This overdraft is not maintainable. The City also recharges treated wastewater into the ground at the Fresno-Clovis Regional Water Reclamation Facility (RWRF). Around 55,000 af is percolated for recharge into the aquifer, with 30,000 af subsequently pumped out by the FID in exchange for 13,800 af of fresh surface water from the Kings River. ## Stormwater Best Management Practices The FMFCD captures approximately 100 percent of the stormwater runoff from new development and approximately 95 percent of the stormwater runoff from existing development. Capturing the runoff allows for groundwater recharge and also protects surface water quality by not allowing urban runoff, which often contains contaminants from roadways and lawns, to flow into natural creeks, rivers, and irrigation ditches. The runoff is collected in retention basins (also known as ponding basins), allowing for filtration through the soil. On average, retention basins remove 50 to 80 percent of stormwater pollutants. Additional sediment and ground water studies show that the majority of stormwater pollutant are absorbed to the top 4cm of soil and do not exceed background levels beyond 16cm. The same studies did not detect any stormwater pollutants in ground water tested beneath a retention basin serving an industrial catchment. The FMFCD’s stormwater quality management program includes specific pollution prevention and control practices for urban drainage system planning, design, construction, and maintenance. The program also includes public education to prevent stormwater pollution; commercial, industrial, and new development stormwater quality control practices; monitoring to assess stormwater impacts on receiving water and to evaluate the effectiveness of best management practices; and development and implementation of ordinances to effect and enforce stormwater quality controls. # Water Conservation Fresno's average total per capita water consumption was 295 gallons per capita per day (gpcd) from 1991 to 2011, making Fresno one of the highest water consuming cities in California. The total per capita water production has varied between 1991 to 2011, from a low of 246 gpcd in 2011 to a high of 329 gpcd in 2001. By comparison, Clovis averages 247 gpcd, Los Angeles is 150, Phoenix is 184, and Tucson is 110. The California Water Conservation Act of 2009 requires a statewide 20 percent reduction in urban water usage by 2020. The methodology chosen by a jurisdiction must be documented in their Urban Water Management Plan (UWMP). The City's adopted target of 250 gpcd to meet State law is a 20 percent reduction from the 313 gpcd average annual gpcd water use for the 10-year period from 1996 to 2005. The City of Fresno Metro Plan recommends a further reduction to 243 gpcd to help balance the groundwater table by 2020. This General Plan incorporates a comprehensive conservation program that has a reduction target of per capita water usage in the city's water service area of 243 gpcd by 2020 and 190 by 2035. To meet a consumption reduction target of 243 gpcd by 2020 and 190 by 2035 will require a combination of conservation measures, including among other possible actions: incentives, appliance rebates, outreach programs and education, fixture swap, prioritized leak detection program, retrofit upon resale ordinance, as well as partnering with commercial, industrial, and institutional customers to reduce their water demand through operational improvements. The recent installation of residential water meters is anticipated to reduce water consumption, however additional water conservation measured should be explored. In the future, the City may develop a tiered water rate structure to further encourage water conservation. The biggest opportunities for water conservation are related to the reduction of outdoor water uses, particularly landscape and turf irrigation, by all customers. Measures related to outdoor water use reduction include rebates for xeriscape (drought-tolerant) landscaping for new homes, programmable irrigation, weather-based irrigation control, and turf replacement, and landscape water audit and budget program. # Recycled Water Use Water recycling is using treated wastewater for beneficial purposes such as agricultural and landscape irrigation, industrial processes, toilet flushing, and replenishing a ground water basin (referred to as ground water recharge). Water recycling offers resource and financial savings, as potable water does not need to be used for non-drinking purposes. Wastewater treatment can be tailored to meet the water quality requirements of a planned reuse. Recycled water for landscape irrigation requires less treatment than recycled water for drinking water. Wastewater generated from homes, businesses, and industry in the city is conveyed to the Fresno-Clovis Regional Wastewater Reclamation Facility (RWRF). The RWRF is operated by the City of Fresno and has the capacity to treat 80 million gallons a day (mgd) of wastewater. On an average day, the RWRF receives 68 million gallons of wastewater. The RWRF recycles nearly every component of influent wastewater (water, solids, and natural gas). The City releases up to 65,100 af of recycled water per year. * 10,000 af/yr is sent directly to irrigate non-food agricultural land downstream. * 55,100 af/yr is directed to 1,660 acres of ponds for percolation into the aquifer. * 30,000 af/yr is then pumped from the aquifer into FID canals for reuse downstream from Fresno to nearby farmers for unrestricted irrigation use. In exchange for this recycled water, FID provides Fresno with 13,800 af of Kings River surface water. The City does not presently have the infrastructure to route recycled water from the RWRF to existing or new development. The retrofit of existing residential uses is considered economically infeasible and impractical to implement. The use of recycled water should focus on new and existing large green spaces, industrial uses, and new development. However, the development of a gray water policy for the residential reuse of wastewater for household gardening and landscape irrigation on site may be feasible. The City also operates a satellite facility in North Fresno called the Wastewater Reclamation Facilities (WRF) Satellite Plant. It was built to serve the Copper River development and golf course. In 2010, the plant was capable of irrigating the golf course at about 750 af/yr and future total capacity will ultimately reach about 1,000 af/yr when the surrounding development builds out. ## Key Opportunities With strategic planning and investments, Fresno will have a dependable water supply system that, in turn, will create a competitive economic advantage. Below are some considerations that are noted with regards to the City’s efforts to create a viable water supply system, and many are supported by General Plan policies. * The geologic structure of the aquifer underneath Fresno is capable of recharging to levels sufficient to support the city during drought periods if the proper infrastructure were in place. * Conversion to conjunctive use of surface and ground water could reduce energy usage for water delivery purposes by 18 to 20 percent. The reduction in power demand for pumping water would be a reduction in both the total demand and, more significantly, during peak usage periods (a reduction in both production and Chapter 7: Resource Conservation and Resilience grid capacity demand). This reduction could also reduce the city's carbon footprint, potentially eliminating the equivalent of 670,000 gallons of gasoline or one year of electricity for 745 homes. * Fresno has developed a Property Assessed Clean Energy (PACE) district that can finance water efficiency and energy efficiency upgrades. * Fresno has the water resources available to balance the groundwater aquifer and create storage for dry years. This can be accomplished by implementing the UWMP and the City of Fresno Metro Plan. These plans call for increased surface water treatment facility capacity, increased intentional recharge, a local groundwater banking program, use of recycle water for non-potable water demands and aggressive water conservation measures. * Available recycled water and untreated surface water can be used by industrial facilities for cooling systems and other uses without having to meet the drinking water standards for the rest of the city. This water supply could be distributed directly to future industrial facilities or parks to encourage new businesses to relocate to Fresno. * Changing the practice of lining canals with concrete, or piping them through residential neighborhood developments, will allow for additional natural recharge. * Outdoor water demand can be significantly reduced through climate-appropriate landscape design and more efficient irrigation technology, while indoor water demand can be reduced by efficient fixtures and appliances. * Citywide, infrastructure costs and water demand can be minimized through efficient land use. Compact and infill development generally requires significantly less pipe and lower water per capita demand equating to significant per capita cost savings as compared to low density developments. * Where infill development substantially increases density, or increases the building height, due to both the age and size of the distribution system, the distribution system may require upgrading to avoid negative impacts from suction created by booster pumps, or to provide adequate flows and pressures for increased demands. In addition to those discussed below, the Public Utilities and Services Element contains additional objectives and policies on water supply, water quality, and reclaimed water. | OBJECTIVE | | | :--- | :--- | | **RC-6** | Ensure that Fresno has a reliable, long-range source of drinkable water. | IMPLEMENTING POLICIES **RC-6-a** Regional Efforts. Support cooperative, multi-agency regional water resource planning efforts and activities on developing and implementing the Upper Kings Basin Integrated Regional Water Management Plan. **RC-6-b** Water Plans. Adopt and implement ordinances, standards, and policies to achieve the intent of the City of Fresno Urban Water Management Plan, Fresno-Area Regional Groundwater Management Plan, and City of Fresno Metropolitan Water Resources Management Plan to ensure a dependable supply of water. **RC-6-c** Land Use and Development Compliance. Ensure that land use and development projects adhere to the objective of the Fresno Metropolitan Water Resources Management Plan to provide sustainable and reliable water supplies to meet the demand of existing and future customers through 2025. **RC-6-d** Recycled Water. Prepare, Adopt, and implement a City of Fresno Recycled Water Master Plan. *Commentary:* This plan will expand the City’s wastewater recycling program by developing treatment, delivery, and users. **RC-6-e** Protect Aquifer. Oppose urban development in unincorporated areas that are not served by a wastewater treatment/management system capable of preventing the buildup of compounds that would degrade the aquifer. **RC-6-f** Regulate Sewage Disposal Facilities. Oppose development of new sewage disposal facilities either within the Planning Area or upgradient (north and east) of the Planning Area, unless the treatment facilities produce effluent that: * Will not degrade the aquifer in the long term; * Will not introduce contaminants into surface water that would negatively affect its potential economic use for drinking water; * Will not deleteriously affect downstream agricultural and urban uses; and * Will not degrade sensitive riparian habitat. Chapter 7: Resource Conservation and Resilience RC-6-g | **Protect Recharge Areas.** Continue to protect areas of beneficial natural groundwater recharge by preventing uses that can contaminate soil or groundwater. RC-6-h | **Conditions of Approval.** Include in the Development Code standards for imposing conditions of approval for development projects to ensure long-term maintenance of adequate clean water resources. Require findings that adequate water supply must exist prior to any discretionary project approval for residential and commercial development requiring annexation, as required by law. RC-6-i | **Natural Recharge.** Support removal of concrete from existing canals and change the practice of lining new and existing canals with concrete to allow for natural recharge. OBJECTIVE RC-7 | Promote water conservation through standards, incentives and capital investments. IMPLEMENTING POLICIES RC-7-a | **Water Conservation Program Target.** Maintain a comprehensive conservation program to help reduce per capita water usage in the city’s water service area to 243 gallons per capita per day (gpcd) by 2020 and 190 gpcd by 2035, by adopting conservation standards and implementing a program of incentives, design and operation standards, and user fees. * Support programs that result in decreased water demand, such as landscaping standards that require drought-tolerant plants, rebates for water conserving devices and systems, turf replacement, xeriscape landscape for new homes, irrigation controllers, commercial/industrial/institutional water conserving programs, prioritized leak detection program, complete water system audit, landscape water audit and budget program, and retrofit upon resale ordinance. * Implement the U.S. Bureau of Reclamation Best Management Practices for water conservation as necessary to maintain the City’s surface water entitlements. * Adopt and implement policies in the event that an artificial lake is proposed for development. * Work cooperatively toward effective uniform water conservation measures that would apply throughout the Planning Area. * Expand efforts to educate the public about water supply issues and water conservation techniques. **RC-7-b** | **Water Pricing and Metering.** Develop a tiered water cost structure for both residential and commercial users that will properly price water based on its true cost; require all new development to be metered for water use; and charge all customers the true, full cost of their water supply, including costs of acquisition, initial treatment, conveyance, wastewater treatment, operations, maintenance, and remediation. **RC-7-c** | **Best Practices for Conservation.** Require all City facilities and all new private development to follow U.S. Bureau of Reclamation Best Management Practices for water conservation, as warranted and appropriate. **RC-7-d** | **Update Standards for New Development.** Continue to refine water saving and conservation standards for new development. **RC-7-e** | **Retrofit City Facilities, and Consider Incentives Programs to Encourage Retrofitting of Other Existing Public and Private Residential and Non-Residential Facilities and Sites.** Reduce water use in municipal buildings and City operations by developing a schedule and budget for the retrofit of existing municipal buildings with water conservation features, such as auto shut-off faucets and water saving irrigation systems. Prepare a comprehensive incentive program for other existing public and private residential and non-residential buildings and irrigation systems. **RC-7-f** | **Implementation and Update Conservation Program.** Continue to implement the City of Fresno Water Conservation Program, as may be updated, and periodically update restrictions on water uses, such as lawn and landscape watering and the filling of fountains and swimming pools, and penalties for violations. Evaluate the feasibility of a 2035 conservation target of 190 gpcd in the next comprehensive update of the City of Fresno Water Conservation Program. **RC-7-g** | **Educate on State Requirements.** Educate the residents and businesses of Fresno on the requirements of the California Water Conservation Act of 2009. RC-7-h | **Landscape Water Conservation Standards.** Refine landscape water conservation standards that will apply to new development installed landscapes, building on the State Model Water Efficient Landscape Ordinance and other State regulations. -- | -- | • Evaluate and apply, as appropriate, augmented xeriscape, “water-wise,” and “green gardening” practices to be implemented in public and private landscaping design and maintenance. | • Facilitate implementation of the State’s Water Efficient Landscape Ordinance by developing alternative compliance measures that are easy to understand and observe. RC-7-i | **PACE Financing.** Develop a residential Property Assessed Clean Energy (PACE) program, if it is determined to be a feasible option, to help finance water efficiency and energy efficiency upgrades for property owners. | *Commentary: The program would be administered by private parties.* ## 7.5 ENERGY RESOURCES Pacific Gas and Electric (PG&E) provides almost all the energy for the city of Fresno. The cost of energy services provided by PG&E is among the highest in the State. Meanwhile, the city has abundant solar resources that could be expanded to reduce dependence on costly purchased electricity, but this will take time and financial resources to implement. Green building practices can be one of the main energy savings strategies encouraged, or required, as Fresno continues to develop. How the City can develop an energy-efficient infrastructure and reduce dependence on the energy grid is a prominent issue for the Plan. The PG&E electrical grid was established decades ago. It’s been at least 30 years since a large transmission line has been built in the Central Valley. Demand for electricity in Fresno has increased 5.4 percent since 2005, placing an increased load on a finite capacity grid system. In April of 2014, PG&E disclosed plans to build a 70-mile transmission line meant to meet the Valley’s growing demand for electricity. The route for this power line is proposed to the west of Fresno SOI and is expected to go into operation by 2020. The PG&E natural gas pipeline system was established decades ago and has had limited upgrade. In 1993, a massive expansion of the natural gas pipeline that runs from Idaho’s border with British Columbia to the county of Fresno was completed. Natural gas usage in Fresno has increased 9.2 percent since 2005, adding increased load on the system. Newer development in Fresno uses energy at higher rates than older land uses, despite having newer, more efficient technology available. Also, the average single-family home consumes 40 percent more electricity than a multi-family home. According to PG&E, the highest amount of residential energy usage in Fresno appears to be in the newer, more affluent areas on the north, west, and southeast edges of Fresno. Cost data from the recent retrofits done in Fresno shows the average investment necessary to achieve a 28 to 30 percent reduction in energy usage on a typical Fresno home is about $25,000. Taking the 76,000 homeowners that have a need and multiplying that by the average cost per retrofit, equates to $1.9 billion in economic activity potential in Fresno, if fully developed. When combined with the estimated $103 million in annual energy savings through a fully deployed and subscribed existing-home retrofit program, the economic potential of comprehensively reducing energy consumption in Fresno is staggering. The City has been active since the mid-1990s in taking steps to invest and deploy renewable energy technology and improve the energy efficiency of City-owned facilities and the community at large. Notable actions include: * Adopting the 2013 California Energy Code; * Developing a comprehensive free residential energy efficiency survey program (by April 2014, the City has conducted a little over 2,500 residential energy efficiency surveys to Fresno homes); * Implementing the Fresno Energy Watch Program as part of the Fresno Small Business Energy Makeover; * Using renewable biogas to produce electric power at the Fresno-Clovis Regional Wastewater Reclamation Facility; * Installing solar panels at City-owned facilities (As of April 2014, the City had deployed over 4.85 megawatts of solar power on City-owned facilities, including the largest single solar farm at any airport in the nation while a 2 megawatt solar array is planned for the Fresno-Clovis Regional Wastewater Reclamation Facility); and * Requiring installation of solar energy systems in construction of any new City-owned buildings containing at least 7,500 square feet, and a mandate to use a green building rating system standard for all new municipal buildings over 10,000 square feet. PG&E also has energy efficiency programs operating in the Fresno area. Many of these programs are geared towards on-income families, such as the Energy Partners Chapter 7: Resource Conservation and Resilience program and Middle Income Direct Install (MIDI) program. Other programs are focused on local businesses, such as the Direct Install program of the Fresno Energy Watch, the Air-Care Plus program, and numerous others. The Fresno County Equal Opportunities Commission (FCEOC) administers the federally-funded weatherization programs focused on low-income homeowners in Fresno. These programs are designed to work in collaboration with utility funded programs operated by PG&E. There are several areas of overlap with these programs. Private organizations, businesses, and individuals are also taking important steps locally. Fresno has the third highest deployment level for solar power among cities in California with 1,056 sites that total 12 MW of power generation capacity. The level of investment in solar power in Fresno has seen a rapid increase since 2006 with over 532 systems installed in 2010 compared with only two systems installed in 2006. In July 2009, Environment California ranked Fresno third in the State for number of kilowatts its solar projects produce and fifth for projects on roofs, with Clovis close behind at seventh. California State University, Fresno, developed sheltered parking canopies on campus, protecting nearly 700 vehicles from the elements and supporting 3,872 photovoltaic cell panels, which generate 20 percent of the campuses electricity demand. The $11.9 million project—the largest of its kind on a university campus—was completed in fall 2007. ### Key Opportunities Under this Plan, the City will promote household conservation of electricity, and strive to change current trends of higher energy use in newer development in order to conserve resources for future growth. Fresno also has enormous potential for solar power and will continue investing in solar energy for public facilities. Some of the key opportunities include: ALTERNATIVE ENERGY Current viable alternative energy sources for buildings and transportation in Fresno include solar photovoltaic electricity, solar thermal electricity, solar thermal heating, low-speed wind generated electricity, hydroelectricity, natural gas for vehicles, electricity for vehicles, and bio-methane generated electricity. ENERGY STAR To earn the ENERGY STAR, a home must meet strict guidelines for energy efficiency set by the U.S. Environmental Protection Agency (EPA), making them 20 to 30 percent more efficient than standard homes. Homes achieve this level of performance through a combination of energy-efficient improvements including insulation systems, high- performance windows, efficient heating and cooling equipment, and qualified lighting and appliances. In Fresno, 4,441 Energy Star qualified homes have been built, which is equivalent to eliminating 124 vehicles from the roadway, planting 205 acres of trees, or saving the environment from 1.5 million pounds of CO2. OBJECTIVE **RC-8** | Reduce the consumption of non-renewable energy resources by --- | --- | requiring and encouraging conservation measures and the use of | alternative energy sources. IMPLEMENTING POLICIES **RC-8-a** | **Existing Standards and Programs.** Continue existing beneficial energy --- | --- | conservation programs, including adhering to the California Energy | Code in new construction and major renovations. **RC-8-b** | **Energy Reduction Targets.** Strive to reduce per capita residential --- | --- | electricity use to 1,800 kWh per year and non-residential electricity | use to 2,700 kWh per year per capita by developing and | implementing incentives, design and operation standards, promoting | alternative energy sources, and cost-effective savings. | | *Commentary:* These targets represent 28 and 30 percent reductions | respectively, from the 2010 rate of consumption. **RC-8-c** | **Energy Conservation in New Development.** Consider providing an --- | --- | incentive program for new buildings that exceed California Energy | Code requirements by fifteen percent. **RC-8-d** | **Incentives.** Establish an incentive program for residential developers --- | --- | who commit to building all of their homes to ENERGY STAR | performance guidelines. | | *Commentary:* See also Policy RC-7-j on PACE financing for energy | efficient retrofits. **RC-8-e** | **Energy Use Disclosure.** Promote compliance with State law mandating --- | --- | disclosure of a building’s energy data and rating of the previous year | to prospective buyers and lessees of the entire building or lenders | financing the entire building. Chapter 7: Resource Conservation and Resilience **RC-8-f** City Heating and Cooling. Reduce energy use at City facilities by updating heating and cooling equipment and installing “smart lighting” where feasible and economically viable. **RC-8-g** Revolving Energy Fund. Create a City Energy Fund which uses first year savings and rebates from completed City-owned energy efficiency projects to provide resources for additional energy projects. Dedicate this revolving fund to the sole use of energy efficiency projects that will pay back into the fund. **RC-8-h** Solar Assistance. Identify and publicize information about financial mechanisms for private solar installations and provide over-the-counter permitting for solar installations meeting specified standards, which may include maximum size (in kV) of units that can be so approved. **RC-8-i** Renewable Target. Adopt and implement a program to increase the use of renewable energy to meet a given percentage of the city’s peak electrical load within a given time frame. **RC-8-j** Alternative Fuel Network. Support the development of a network of integrated charging and alternate fuel station for both public and private vehicles, and if feasible, open up municipal stations to the public as part of network development. **RC-8-k** Energy Efficiency Education. Provide long-term and on-going education of homeowners and businesses as to the value of energy efficiency and the need to upgrade existing structures on the regular basis as technology improves and structures age. ## 7.6 FARMLAND Central California is one of the world’s premier growing regions, with Fresno at its heart. The San Joaquin Valley is a mature agricultural area, with a well-defined pattern of farming activities. Much of the arable land is devoted to relatively stable crops, such as orchards, vineyards, and other commercial crops. The conversion of farmland to urban uses is not the only threat to agriculture. When “leapfrog” development (development that is not contiguous to the existing urbanized area) occurs in the midst of agriculture uses, optimal crop production is precluded due to urban/agriculture conflicts. It is common for farmland to suffer disruptions and economic losses, while urban uses also suffer negative effects, such as farm-generated dust, noise and odors. Another problem exists with premature disinvestment of farmland where future growth is anticipated but development may not occur for several years. Farmland may be purchased or held for its possible urban development value, rather than continue in agriculture production. Policies in the Plan will help preserve farmland by incentivizing new development within and adjacent to already-urbanized land, only extending public utilities to new development that adheres to the Plan, and not expanding the City’s SOI. Additional objectives and policies in this element address the broader planning issues of farmland preservation. The Healthy Communities Element also has more information on urban agriculture and expanding access to fresh, healthy foods. <
> *Fresno is at the heart of one the premier agricultural areas in the world, and the General Plan policies will help preserve farmland.* | OBJECTIVE | | | :--- | :--- | | **RC-9** | Preserve agricultural land outside of the area planned for urbanization under this General Plan. | Chapter 7: Resource Conservation and Resilience IMPLEMENTING POLICIES **RC-9-a** Regional Cooperation. Work to establish a cooperative research and planning program with the Counties of Fresno and Madera, City of Clovis, and other public agencies to conserve agricultural land resources. **RC-9-b** Unincorporated Land in the Planning Area. Express opposition to residential and commercial development proposals in unincorporated areas within or adjacent to the Planning Area when these proposals would do any of the following: * Make it difficult or infeasible to implement the General Plan; * Contribute to the premature conversion of agricultural, open space, or grazing lands; or * Constitute a detriment to the management of resources and/or facilities important to the region (such as air quality, water quantity and quality, traffic circulation, and riparian habitat). **RC-9-c** Farmland Preservation Program. In coordination with regional partners or independently, establish a Farmland Preservation Program. When Prime Farmland, Unique Farmland, or Farmland of Statewide Importance is converted to urban uses outside City limits, this program would require that the developer of such a project mitigate the loss of such farmland consistent with the requirements of CEQA. The Farmland Preservation Program shall provide several mitigation options that may include, but are not limited to the following: Restrictive Covenants or Deeds, In Lieu Fees, Mitigation Banks, Fee Title Acquisition, Conservation Easements, Land Use Regulations, or any other mitigation method that is in compliance with the requirements of CEQA. The Farmland Preservation Program may be modeled after some of all of the programs described by the California Council of Land Trusts. ### 7.7 MINERAL RESOURCES This section of the Resource Conservation and Resilience Element is intended to assure that cost-effective locally available mineral resources (such as rock, gravel, and sand for concrete aggregate) are protected for future use by the construction industry, and that extraction of these resources is done in a responsible manner that provides for beneficial end uses of surface mining sites, as required by the California’s Surface Mining and Reclamation Act. Aggregate mineral resources are critical to supporting urban development, as all public and private projects utilize this material for roadway paving, structural elements (foundations), and hardscape (sidewalks, curbing, gutters). Because of the demands that will be made on these mineral resources due to Fresno’s projected growth, and because the City has land use authority over designated mineral resource areas, the Plan contains policies relating to mineral resource land and direction for managing mining and post-mining rehabilitation of the land. Naturally occurring deposits of aggregate minerals must be of sufficient quality to meet engineering material specifications and must be sufficiently concentrated to justify the investment in an extraction and processing site. High-quality aggregate minerals are required for proper formulation of concrete to attain sufficient strength through the curing process. Existing and ancient riverbeds and streambeds are prime areas to look for such high-quality concrete aggregate materials, which consist of sand, gravel, and certain types of rock. Lower-quality aggregate materials, used for base rock and asphaltic mixtures, also can be recovered from riparian corridors, but may be available in other areas as well. For instance, surface mining for base rock is common on the alluvial fans of the Coast Range along the western edge of the San Joaquin Valley. Recycling (re-crushing) of concrete extends the available supply of mineral resources but cannot replace mining as a source of these materials. The primary reason for this is that virgin minerals are needed for formulation of concrete. Once minerals undergo the curing reaction once, they are only suited for lower-quality uses such as base rock or asphalt mixtures. Another reason that recycling cannot replace mining is that in a growing area such as Fresno, more new durable structures are created each year than are demolished. Surface mining operations need to locate in areas where these minerals are sufficiently concentrated—where most of the material excavated consists of the desired materials, and where the mineral deposits can be easily accessed (i.e., there is relatively little “overburden” covering the deposits). The California Surface Mining and Reclamation Act of 1975 mandates that a “classification/designation” analysis be done to provide information on the availability of mineral resource for construction and growth. The objective is to ensure that raw material will be available when needed—that this raw material will not become inaccessible for mining as the result of inappropriate land use decisions involving mineral resource areas. Chapter 7: Resource Conservation and Resilience The California Department of Conservation Division of Mines and Geology periodically maps high-quality concrete aggregate deposits and compiles statistics on the amount of aggregate minerals available, and consumed, within designated Production-Consumption (P-C) Regions of the State. The Department uses an “MRZ-2” designation for regionally significant deposits of high-grade sand and gravel aggregate (i.e., material suitable for making Portland Cement Concrete). Potential, but presently unproven, mineral resource areas are mapped as MRZ-3. Most of the area outside of the San Joaquin and Kings River Resource Areas has an MRZ-3 designation, and may contain economically recoverable mineral resources. However, those resources may not be of the high quality needed to formulate concrete. The City keeps these maps on file for use in development review and decision-making. OBJECTIVE RC-10 Conserve aggregate mineral resources within the Planning Area, as identified by the Division of Mines and Geology, and allow for responsible extraction to meet Fresno’s needs. IMPLEMENTING POLICIES RC-10-a Meet Future Needs. Adopt land use and resource protection regulations that support mining of the high-quality, close-to-market aggregate resources to meet the needs of the Fresno Production-Consumption Region. RC-10-b Zoning in San Joaquin Riverbottom. Maintain zoning consistent with on-going mineral extraction in the San Joaquin Riverbottom that also allows multiple open space uses in conformance with State law and the City's Surface Mining Ordinance. RC-10-c Processing-Mining Link. Accommodate only those mineral processing activities in the San Joaquin Riverbottom that are associated and co-located with mining operations when such industrial activities will sunset with the mining operation and do not stimulate unplanned growth or conversion of multi-use open space to urban uses. RC-10-d Manage MRZ-2 Areas. Prohibit land uses and development projects that preclude mineral extraction in potential high-quality mineral resource areas designated MRZ-2 by the California Department of Conservation Division of Mines and Geology. RC-10-e | **Existing Permits.** Honor surface mining permits approved by the County of Fresno upon annexation, provided that the mining operation is in compliance with the terms of its current permit(s) and State law. Require new permit applications in the event of noncompliance, permit expiration, or permit revocation, and ensure compliance with law or regulations. RC-10-f | **Cooperate on Uniform Criteria.** Work with the County of Fresno, the County of Madera, and the City of Clovis to develop uniform criteria applicable to existing, new, and altered mineral extraction sites in the San Joaquin Riverbottom. ## 7.8 WASTE REDUCTION The Public Utilities and Services Element has background information on solid waste collection and disposal and policies related to these systems. This section of the Resource Conservation and Resilience Element contains policies addressing waste reduction. OBJECTIVE RC-11 | Strive to reduce the solid waste going to landfills to zero by 2035. IMPLEMENTING POLICIES RC-11-a | **Waste Reduction Strategies.** Maintain current targets for recycling and re-use of all types of waste material in the city and enhance waste and wastewater management practices to reduce natural resource consumption, including the following measures: * Continue to require recyclable material collection and storage areas in all residential development. * Establish recycling collection and storage area standards for commercial and industrial facilities to size the recycling areas according to the anticipated types and amounts of recyclable material generated. * Provide educational materials to residents on how and what to recycle and how to dispose of hazardous waste. * Provide recycling canisters and collection in public areas where trash cans are also provided. * Institute a program to evaluate major waste generators and identify recycling opportunities for their facilities and operations. Chapter 7: Resource Conservation and Resilience * Continue to partner with the California Integrated Waste Management Board on waste diversion and recycling programs and the CalMax (California Materials Exchange) program. * Evaluate the feasibility of a residential, restaurant, and institutional food waste segregation and recycling program, to reduce the amount of organic material sent to landfill and minimize the emissions generated by decomposing organic material. * Evaluate the feasibility of “carbon footprinting” for the City’s wastewater treatment facilities, biomass and composting operations, solid waste collection and recycling programs. * Expand yard waste collection to divert compostable waste from landfills. * Study the feasibility and cost-benefit analysis of a municipal composting program to collect and compost food and yard waste, including institutional food and yard waste, using the resulting compost matter for City park and median maintenance. **RC-11-b** Zero Waste Strategy. Create a strategic and operations plan for fulfilling the City Council resolution committing the City to a Zero Waste goal. **RC-11-c** Industry Efforts. Support industry efforts to collect and recycle electronics, mattresses, carpets and any other recyclable products to help the region meet goals consistent with the statewide goal of at least 75 percent of all solid waste recycled by January 2020. *This page intentionally left blank.* --- ## Open Space — Fresno General Plan, Chapter 5: Parks, Open Space, and Schools Element - Source: https://www.fresno.gov/wp-content/uploads/2023/03/General-Plan-5-Parks-Open-Space-and-Schools-7-19.pdf - Pages: 44 - Covers: open_space # 5 PARKS, OPEN SPACE, AND SCHOOLS The Parks, Open Space, and Schools Element sets forth policy guidance for a broad spectrum of open spaces and community facilities in Fresno. These spaces will provide areas appropriate for agricultural or resource production and conservation; parks and open spaces for recreation; areas for protection of natural resources; and school sites which support neighborhood identity and cohesion. A key need addressed in the element is the shortage of parks and recreation space, particularly in established areas of the city, and a lack of access to these facilities for all Fresnans. This element aims to provide those special places that support a sense of community and are vital to creating a livable and sustainable Fresno. ## 5.1 CONTEXT Open space is one of the seven general plan elements required by California’s Planning and Zoning Law, Government Code section 65302(e). While a city is required to address the mandatory seven topics or elements, State law allows a general plan format that best fits the unique circumstances of the city. The City of Fresno has chosen to combine the required components of a local open space plan within the larger context of a Parks, Open Space, and Schools Element because of the close relation that these topics have to one another in Fresno. ### Relationship to General Plan Goals The objectives and policies in the Parks, Open Space, and Schools Element support the following General Plan goals: 6. Protect, preserve, and enhance natural, historic, and cultural resources. *Emphasize the continued protection of important natural, historic and cultural resources in the future development of Fresno. This includes both designated historic structures and neighborhoods, but also "urban artifacts" and neighborhoods that create the character of Fresno.* 7. Provide for a diversity of districts, neighborhoods, housing types (including affordable housing), residential densities, job opportunities, recreation, open space, and educational venues that appeal to a broad range of people throughout the city. 8. Develop Complete Neighborhoods and districts with an efficient and diverse mix of residential densities, building types, and affordability which are designed to be healthy, attractive, and centered by schools, parks, and public and commercial services to provide a sense of place and provide as many services as possible within walking distance. *Intentionally plan for Complete Neighborhoods as an outcome, and not a collection of subdivisions which do not result in Complete Neighborhoods.* 9. Promote a city of healthy communities and improve quality of life in established neighborhoods. *Emphasize supporting established neighborhoods in Fresno with safe, well maintained, and accessible streets, public utilities, education and job training, proximity to jobs, retail services, healthy food, health care, affordable housing, youth development opportunities, open space and parks, transportation options, and opportunities for home grown businesses.* Chapter 5: Parks, Open Space, and Schools 12. Resolve existing public infrastructure and service deficiencies, make full use of existing infrastructure, and invest in improvements to increase competitiveness and promote economic growth. Emphasize the fair and necessary costs of maintaining sustainable water, sewer, streets, and other public infrastructure and service systems in rates, fees, financing and public investments to implement the General Plan. Adequately address accumulated deferred maintenance, aging infrastructure, risks to service continuity, desired standards of service to meet quality-of-life goals, and required infrastructure to support growth, economic competitiveness and business development. 13. Emphasize the City as a role model for good growth management planning, efficient processing and permit streamlining, effective urban development policies, environmental quality, and a strong economy. Work collaboratively with other jurisdictions and institutions to further these values throughout the region. Positively influence the same attributes in other jurisdictions of the San Joaquin Valley –and thus the potential for regional sustainability - and improve the standing and credibility of the City to pursue appropriate State, LAFCO, and other regional policies that would curb sprawl and prevent new unincorporated community development which compete with and threaten the success of sustainable policies and development practices in Fresno. 14. Provide a network of safe well-maintained parks, open spaces, athletic facilities, and walking and biking trails connecting the city’s districts and neighborhoods to attract and retain a broad range of individuals, benefit the health of residents, and provide the level of public amenities required to encourage and support development of higher density urban living and transit use. Sufficient parks and recreation spaces are also needed in support of the higher residential densities associated with the Bus Rapid Transit (BRT) corridors and Activity Centers and in the new Complete Neighborhoods planned for Fresno and addressed in the Urban Form, Land Use and Design Element. Parks, open spaces, and schools also critical to residents’ physical activity levels are central to the public health strategy, as discussed in the Healthy Communities element. ### Of Special Note, Parks Master Plan Update on December 14, 2017 On December 14, 2017, the City of Fresno adopted the Fresno Parks Master Plan (PMP) which was an update to the previously adopted 1989 Parks Master Plan. In comparison to this chapter of the General Plan, the Fresno Parks Master provides updated data and system overview, revised park classifications, additional goals, recommendations and strategies, and new design guidelines that support and enhance the objectives and policies found in this chapter. As a result, policy POSS-1-a has been revised and the PMP park classifications are to take precedence over the park classifications in this chapter which means that the goal of 2 acres/1,000 residences is to be achieved through Regional Parks, Open Space/Natural Areas, and Special Use Parks/Facilities. ## 5.2 PARKS AND RECREATION Parks, natural open spaces, and greenways are an important component to urban form, and they provide both recreational and aesthetic assets that contribute to the creation of a desirable visual character. The City has devoted substantial resources over the past several decades to provide parks and greenways, including the adoption of an Urban Growth Management (UGM) policy that helped establish a park impact development fee in 1976. In 2008, the City Council approved the UGM Impact Fee and Reimbursement policy. Additionally, other agencies and entities, such as school districts, the Fresno Metropolitan Flood Control District (FMFCD), the San Joaquin River and Parkway Conservation Trust, and the San Joaquin River Conservancy, have made significant contributions to the provision of recreational and natural areas. Despite these efforts, Fresno, in 2012 and 2013 was ranked last out of the 40 and then 50 largest U.S. cities, respectively, for ParkScore, a measure that takes into account public open space acreage, services, investment, and access.[^p4-1] City Staff, through diligent efforts, increased the City's ParkScore by 6.5 points from 2012 to 2013, and additional programs such as the City's Residential Guidelines for Open Space have increased the amount of recreational open space within the Planning Area without adding costs to the General Fund. This General Plan affirms Fresno's commitment to creating and maintaining a park system that meets residents' recreational needs, maximizes landscapes endowed by the natural environment, contributes to Fresno's quality of life, and supports urban living. Adoption of this element will guide the subsequent planning and implementation of the City's parks and open space program. [^p4-1]: "ParkScore Index." Trust for Public Land. . Chapter 5: Parks, Open Space, and Schools <
> Parks provide a variety of important social, environmental, and health benefits for the Fresno community, and the City has devoted substantial resources over the past several decades to provide and improve parks and greenways. ## Park Classifications The City provides Fresno residents with several types of parks and facilities.[^p5-2] Parks are defined as land owned, leased, or provided to the City and used for public recreational purposes. In addition, several FMFCD storm water detention basins also serve as passive and active parks (from April to November); and, there are joint use planning and operation of school district playgrounds and athletic facilities for public recreation. In addition to the public parks discussed here, there are many private parks and public lands that provide similar services such as along the San Joaquin River.[^p5-3] Park types in the General Plan are classified as follows and summarized in Table 5-1: * **Pocket Park.** A park up to 0.5 to 2.0 acres in size, which is intended to serve the needs of a smaller, specific neighborhood located within a half-mile radius of the pocket park. Pocket Parks should include amenities to draw neighbors to the park such as a tot lot, picnic bench, or shade structure. New Pocket Parks developed [^p5-2]: General Plan park standards and types may differ from PARCS Department operational classifications for existing facilities with various passive and active recreational facilities and features. [^p5-3]: The banks of the San Joaquin River are under the jurisdiction of the State Lands Commission and open to the public for recreational use. within new subdivisions are maintained as part of a Home Owners Association (HOA) or Community Facilities District (CFD). Fresno currently is served by 93 pocket parks. * **Neighborhood Park.** A park of more than 2 and up to 10 acres in size, which provides basic recreational activities for neighborhoods located generally within a one-mile radius. There are two types of Neighborhood Parks, active and passive. These parks contribute to neighborhood identity and accommodate a range of facilities, such as play fields and courts, children's play structures, picnic tables, restrooms, and may include a small center with a multi-purpose room, but also passive recreational features such as walking trails, community gardens, or nature areas. Fresno has 62 neighborhood parks. * **Community Park.** A park of more than 10 and up to 40 acres in size (typically at least 20 acres), which helps define a community or district and is intended to serve the more active recreational needs of persons who live or work up to a two to four-mile radius. These parks typically include facilities such as lighted sport fields and a community center building with a gym, meeting rooms, and restrooms. Other features may include swimming pools, tennis courts, concession stands, community defining public art, courtyard or plaza. Fresno has 13 community parks. * **Regional Park.** A large park of more than 40 acres in size, which is meant to serve a large number of residents across a broad area of the city, or around 100,000 residents. Regional parks typically include community park features that allow for a variety of sports and active recreation. Some are large enough to enable Fresno to host local and regional tournaments or events that bring revenue to the City and local businesses in the form of additional patrons and tax revenue generated. Regional parks also provide unique public facilities, such as the Shinzen Japanese Garden, the Chaffee Zoological Gardens, or natural areas with hiking trails, fishing opportunities, and access to the San Joaquin River. Parks that provide unique opportunities, such as river access, have been categorized as a regional park, even though they are less than 40 acres in size. Fresno presently has three City owned regional parks: Woodward, Roeding, and the Regional Sports Complex; and two regional parks owned by other public entities, Camp Pashayan (San Joaquin River Conservancy), and Clovis North High School play fields and facilities (Clovis Unified School District). * **Trail/Greenway/Parkway.** A network of linear open spaces of varying size, typically intended to accommodate walking and bicycling opportunities for leisure, exercise and commuting purposes. These parkways typically include paved surfaces for bicyclists and walkers, and in appropriate locations may include equestrian trails. Fresno has 19 paths and trails, which are planned to be expanded and eventually form a substantial portion of the Valley Arboretum. Fresno's trail network is described in the Transportation and Mobility Element. Chapter 5: Parks, Open Space, and Schools | TABLE 5-1: DESIRABLE PARK FACILITY STANDARDS | | | | :--- | :--- | :--- | | **Park Type** | **Typical Size** | **Service Area** | | Pocket | 0.5 to 2 acres | Up to ½ mile | | Neighborhood | 2.01 to 10 acres | Up to 1 mile radius | | Community | 10.01 to 40 acres | Up to 4 mile radius | | Regional | More than 40 acres[^p7-1] | 100K residents | | Trail/Greenway/Parkway | Varies | Entire city | [^p7-1]: Some parks with less than 40 acres may be classified as Regional if they provide a unique opportunity such as river access. Source: City of Fresno. The function and desirability of smaller open spaces, such as pocket parks, has been an ongoing issue for the City. These smaller spaces are often popular with residential developers because of their appeal to homeowners, and they may be the most realistic option to correct deficiencies within already-developed areas. However, the smaller size and scattered location of these sites had tended to increase maintenance costs, pose potential supervision and attractive nuisance challenges, and limit the range of recreational amenities and services that can be offered. In the past, the City has even occasionally decommissioned a pocket park for these or similar reasons. Requiring new pocket parks to have secure maintenance funds through an HOA or CFD provides three benefits: set maintenance funding for each pocket park; local control of the park; and does not add additional burden to the City’s PARCS Department maintenance program, allowing them to focus on the City’s neighborhood, community, and regional parks. This change in how pocket parks are managed, and including amenities that attract local residents, has made them an attractive option to increase recreational space in the city with minimal to no impact on PARCS resources. ### Existing Parks and Recreation Facilities The City maintains approximately 1,617 acres of open space, nearly 230,000 square feet of building space dedicated to recreational/educational purposes distributed among 104 sites. Other facilities include 9 community pools, 4 splash parks, 518 picnic tables, 153 barbeque grills, 3 amphitheaters, 54 baseball/softball fields, 53 football/soccer fields, 40 basketball courts, 11 volleyball courts, 40 tennis courts, 7 skate parks, and 5 dog parks. The park system also provides and maintains 115 acres of paths and trails for pedestrians and bicyclists. The FMFCD and the City partner in the use of portions of storm water detention basins as park and open space features. These include trees and turf for passive recreation and play equipment or sports fields where flood control design parameters allow. There are currently 16 basins, totaling over 143 acres, which are open to the public from April to November, when they are not in use for stormwater detention. These basins are often designed with two floor levels. The upper floor is available for recreational uses during the dry weather seasons, while the lower level may be used for ground water recharge purposes and to accommodate rainwater runoff from smaller storm events. The adaptation of stormwater detention basins for park use must be carefully balanced with the critical need to use these facilities to perform groundwater recharge. ## Park Demand and Proposed Park Land The City’s 2025 General Plan standard called for at least 3.0 acres of parkland to be provided per 1,000 residents (comprised of 0.75 acres neighborhood parks, 0.25 acres community parks, 2.0 acres regional parks). This standard is among the lowest in the Central Valley, where many cities have a standard of 4.0 or 5.0 acres per 1,000 residents. Under the Quimby Act, California State law sets a generally applicable standard of 3.0 acres of parkland per 1,000 residents as the maximum that can typically be required by a city or county as a condition of approval of a residential subdivision. However, a city or county can exceed this limitation and require dedication and improvement of parkland up to a ratio of 5.0 acres per 1,000 residents if it can be demonstrated that the developed portion of the community meets or exceeds the higher standard. The Quimby Act limits do not preclude a city from establishing a higher parkland standard, just the amount that can be charged to a new residential development. The current citywide park fee is based upon a ratio of 3.0 acres per 1,000 residents; this was established under the City’s previous Urban Growth Management Program and 1989 Master Plan for Parks and Recreation. This 3.0 acre parkland standard was maintained through the adoption of the 2025 Fresno General Plan, the subsequent Park Facilities Impact Fee & Parkland Dedication Study, and the adoption of the citywide Park Facilities Fee ordinance. In addition to public parks, the Park Facilities Impact Fee study also identified and examined additional open spaces that are publicly owned but have limited access, recreation, or leisure uses, such as golf courses, school playgrounds, or sports fields. Citywide, Fresno has a current supply of 3.28 acres of City Park Space per 1,000 residents, which exceeds the City’s minimum standard by 0.28 acre. Including All Park Space in the City’s SOI increases that ratio to 4.65 acres per 1,000 residents.[^p8-4] The [^p8-4]: For this General Plan, Park categories include All Park Space within the City’s SOI: parks owned and maintained by an HOA that are publicly accessible (no gate), public golf courses, SJRC parkland open to the public and directly accessible from the City; pocket parks maintained through Community Facility Districts (CFD); ponding basins with park improvements (excludes fenced-off flood areas); Clovis and Central Unified School District playgrounds, Fresno Unified’s Burroughs Elementary and Yosemite Middle School (grass fields and courts, Kindergarten play areas, and parking areas only). City Park Space excludes golf courses and school lands because of their use limitations and where the City lacks jurisdiction over the park. Chapter 5: Parks, Open Space, and Schools breakdown of these figures is shown in Table 5-2. The difference is due to the inclusion of the City's two golf courses and school playgrounds and play fields. Since school district policies are not within the City's control, those lands have been excluded from the City's inventory. Nevertheless, Clovis and Central Unified's policies for open playgrounds provide a very significant amount of recreational area for residents in those school districts. Including Fresno Unified's Burroughs Elementary and Yosemite Middle School open space, city schools provide over 450 acres of recreational land. This could be greatly increased with the inclusion of additional Fresno Unified School facilities located in the central areas of the city, areas severely lacking in available park space. Although overall the City exceeds the minimum standard of 3.0 acres per 1,000 residents, the provision of parkland is uneven across the city. The inclusion of open campus schools as parkland increases the disparity of park space in the established neighborhoods north and south of Shaw Avenue. Newer neighborhoods with larger amounts of parkland increase the citywide average and obscure the parkland deficiencies of many Fresno neighborhoods. In particular, many of the central neighborhoods in Fresno lack convenient access to parkland and fall well below the 3.0 acre standard, as shown in Table 5-3 and Figure POSS-1. The discrepancy between developments north and south of Shaw Avenue also demonstrates the effectiveness of park and open space fees and other policies in providing park space to the residents of newer residential developments as compared to past policies, although the city as a whole still remains well below other similar-sized cities. | TABLE 5-2: CITY PARK SPACE AND RATIO PER 1,000 RESIDENTS BY PARK CATEGORY | | | | | | | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | Park Category | City Park Space¹ | | | All Park Space in SOI² | | | | | Acres | Number of Parks | Acres per 1,000 Residents³ | Acres | Number of Parks | Acres per 1,000 Residents³ | | Community | 198.32⁴ | 13 | 0.40 | 557.69 | 33 | 1.13 | | Neighborhood | 372.45⁵ | 62 | 0.75 | 401.57 | 66 | 0.81 | | Pocket | 61.57⁴ | 93 | 0.12 | 61.57 | 93 | 0.12 | | Trail-Greenway-Parkway | 115.19⁴ | 19 | 0.23 | 115.19 | 19 | 0.23 | | Regional | 877.05 | 5 | 1.77 | 940.11 | 6 | 1.90 | | Golf | | | | 223.62 | 2 | 0.45 | | Total | 1,624.58 | 192 | 3.28 | 2,299.75 | 219 | 4.65 | 1. City Park Space includes parks owned and/or maintained by the City or parks where there is little likelihood that the use or access will change. City Park Space does not include lands controlled by other jurisdictions where policy changes could limit or eliminate those lands from use as parkland, such as school district properties. Parks under the jurisdiction of the San Joaquin River Conservancy currently open directly to city residents (Camp Pashayan, Jensen River Ranch) and Fresno Metropolitan Flood Control Basins improved for park use are included. Golf courses are not included because their use is limited to golf. 2. In addition, mutual-use agreements with schools provide 451.54 acres of Regional, Neighborhood, and Community Park space for Fresnans, which is not included in the total acres of City Park Space. Golf courses provide an additional 223.62 acres of open space. 3. Based on 2010 city population of 495,000. 4. Homeowners Associations account for 9.17 acres of the Pocket parks, 4.10 acres of Trail-Greenway-Parkway, and 7.74 acres of the Neighborhood parks under the City Park Space. 5. Ponding basins comprise 74.46 acres of the Neighborhood parks and 57.76 acres of the Community Parks under the City Park Space. Source: City of Fresno. | TABLE 5-3: PARK ACREAGE IN DEVELOPMENT AREAS | | | | | | | :--- | :--- | :--- | :--- | :--- | :--- | | Area | Population[^p10-2] | City Park Space[^p10-1] | | Pocket/Neighborhood/ Community Parks | | | | | Total Acres | Acres per 1,000 Residents[^p10-2] | Total Acres | Acres per 1,000 Residents[^p10-2] | | Downtown Planning Area | 65,509 | 235.84 | 3.60 | 72.91 | 1.11 | | Established Neighborhoods South of Shaw | 238,116 | 242.73 | 1.02 | 231.78 | 0.97 | | Established Neighborhoods North of Shaw | 165,534 | 764.43 | 4.62 | 194.96 | 1.18 | | Combined Development Areas NW[^p10-3] | 47,122 | 43.56 | 0.92 | 42.30 | 0.90 | | DA-1 South | 15,056 | 296.55 | 19.70 | 48.92 | 3.25 | | Combined Development Areas East[^p10-4] | 15,385 | 21.25 | 1.38 | 21.25 | 1.38 | | South Industrial Area | 11,316 | 20.23 | 1.79 | 20.23 | 1.79 | | Total | 558,038 | 1,625 | 2.91 | 632 | 1.13 | | Using 2010 City Population | 495,000 | 1,625 | 3.28 | 632 | 1.28 | [^p10-1]: City Park Space includes parks owned and/or maintained by the City or parks where there is little likelihood that the use or access will change. City Park Space does not include lands controlled by other jurisdictions where policy changes could limit or eliminate those lands from use as parkland, such as school district properties. Parks under the jurisdiction of the San Joaquin River Conservancy currently open directly to city residents (Camp Pashayan, Jensen River Ranch) and Fresno Metropolitan Flood Control Basins improved for park use are included. Golf courses are not included because their use is limited to golf. [^p10-2]: Based on Census Tract population totals that include population outside the 2010 City SOI and Planning Area. [^p10-3]: Includes West Development areas north of SR 180 (DA-1 North, DA-4 West). [^p10-4]: Includes East Development areas (DA-2 North & South, DA-3, DA-4 East). Source: City of Fresno. Chapter 5: Parks, Open Space, and Schools In Fresno, the neighborhood and community, and pocket parks are the backbone of the urban park system. They are large enough for play fields and programmed activities and may include sport courts and community centers. They provide open and accessible active and passive open space to neighborhoods, typically within walking or biking distance of many residences. Given the important role these facilities play in Fresno’s communities, it is appropriate for the City to achieve 3.0 acres of neighborhood, community, and pocket parks per 1,000 residents. In Fresno, regional park facilities include trails, paths, and greenways that provide linear connections through and between communities. In addition, regional park facilities include an amphitheater, zoo, a regional sports park, and river access. These facilities provide walking and biking connectivity for the larger community, as well as spaces for leisurely enjoyment of the surrounding neighborhoods. Regional parks provide active and passive recreation and leisure activities at a larger scale, and it is appropriate for the City to continue to provide them at a ratio of 2 acres per 1,000 residents, the standard from the City’s 2025 General Plan. To meet the standard of 3.0 acres of neighborhood, community, and pocket parks per 1,000 residents, a total of 2,313 acres of new parks will be needed to serve the estimated 771,000 residents in the city at General Plan Horizon. To achieve parity with other Valley cities, the City would need to increase the parkland ratio standard to 5.0 acres per 1,000 residents, and the City would need an additional 3,855 acres of parks from all categories. The overall ratio for parkland under this General Plan is 5 acres per 1,000 residents of which 3 acres per 1,000 residents is for Community, Neighborhood, and Pocket Parks. As shown in Table 5-4, the established neighborhoods south of Shaw and the south industrial area have a deficit of 984 acres in City park space. Using provisions in the Quimby Act, which apply to new residential subdivisions, the City could provide an additional 1,275 acres of parkland and accomplish the overall City goal of providing parkland at a similar rate as other Valley cities. However, State laws concerning parkland dedication and fee limitations require that the open space facilities be proximate to the developments generating these fee revenues. The existing deficit of pocket, neighborhood, and community parks within the established neighborhoods south of Shaw, including the South Industrial Area, may not be considered proximate to developing areas. Thus, additional funding is needed to provide parks in these areas with deficits to equitably distribute the City’s parks and open space among all Fresnans. Recent revisions to the Quimby Act through AB 1359 (2013) allows fees, paid pursuant to the act, to be used in a neighborhood other than the neighborhood being developed if specific conditions can be met. This may allow some flexibility but will not resolve the ongoing issue of limited park space in established neighborhoods. A number of approaches will be pursued to meet both future and existing needs for parks: * Focus funding efforts on increasing the number of Neighborhood and Community Parks, especially within the areas south of Shaw Avenue; * Increasing the City’s standard to 3.0 acres of usable parkland per 1,000 residents for combined Pocket, Neighborhood, and Community parks while striving for 5.0 acres or more of usable parkland per 1,000 residents for total City Park Space for the SOI; * Seek dedicated funding sources for parkland acquisition, improvement, and ongoing maintenance costs, in both growth areas and established neighborhoods; * Strategically locate neighborhood and community parks along BRT corridors, in Activity Centers, and in established neighborhoods to support urban densities; * Allow flexibility in siting and sizing neighborhood parks; * Identify the sites of future regional parks, 40 to 100 acres in size, in the City’s Development Areas; * Continue to evaluate and update the City’s Citywide Park Fee as applied to new residential development to assure priority park areas are acquired in existing and new residential neighborhoods; * Identify underutilized and vacant land within the city that can be acquired and developed as parks to meet the needs of existing residents and cure deficiencies in established neighborhoods; * Secure more joint use facilities, particularly with public schools; * Pursue joint use facilities with Police and Fire when siting new parks or police/fire stations. These joint facilities will provide added security for the parks and provide greater opportunity for police and fire personnel to interact with the public and neighborhood children; * Add security measures to parks to protect facilities and patrons; * Identify opportunities to provide cultural parks consistent with the neighborhood; * Develop parks that meet specialized needs, such as certain sports activities or recreational facilities not provided elsewhere in the city; * Encourage development of recreation facilities that are open to the public and free of charge such as trails, greenways, and drainage basins developed with the intent of being predominantly used as a park; and * Use low-impact design and landscaping strategies, including use of climatized and drought-resistant plants, for new and existing parks to minimize water demand Chapter 5: Parks, Open Space, and Schools and increase capacity for passive water storage and conservation that also provides scenic and recreational opportunities for users. <
> *The General Plan aims to provide more neighborhood, community, and pocket parks, such as the skate park pictured above, throughout the city to improve access to parks, open spaces, and recreational areas for all Fresnans.* ### Planned Parks, Trails and Open Space The General Plan proposes over 1,100 acres of land for new City parks by the General Plan 2035 build-out stage for development in the Fresno SOI. All new development will include neighborhood, community, trails, and regional scale parks, where feasible, meeting a minimum combined standard of three acres per 1,000 new residents for Pocket, Neighborhood, and Community Parks.[^p13-5] Other funding sources will be sought for the additional two acres per 1,000 residents for Regional Parks, trails, and greenways. These parks are not all mapped on the Figure LU-1: Land Use Diagram, but will be identified through subsequent implementation planning after adoption of this General Plan. Implementation and ongoing maintenance of all park facilities will require new sources of dedicated ongoing revenue. [^p13-5]: See Figure MT-2: Paths and Trails in Chapter 4, Mobility and Transportation. Park maintenance in Development Areas can be funded with CFDs or landscaping and lighting districts. A new funding source for citywide parks maintenance may be needed, as discussed in the Economic Development and Fiscal Sustainability Element. Figure POSS-1: Parks and Open Space, shows the location of the major new parks that are proposed. These include regional parks with some neighborhood and community parks sited in key locations such as in Activity Centers or infill locations. San Joaquin River Parkway paths and trail access points are shown in Figure POSS-2. Inspiration Park. Set on eight acres near Polk and Gettysburg Avenues, Inspiration Park (formerly referred to as Universally Accessible Park) will provide a Miracle League special-needs baseball field with special-needs designed children play areas, along with a sensory garden and wall, wheelchair accessible dog park, and rubberized basketball court in addition to other features. <
> Chapter 5: Parks, Open Space, and Schools | TABLE 5-4: EXISTING CITY PARK SPACE AND POCKET/NEIGHBORHOOD/COMMUNITY PARK SPACE | | | | | | | | :--- | :--- | :--- | :--- | :--- | :--- | :--- | | **NEEDS BASED ON 5 ACRES AND 3 ACRES PER 1,000 RESIDENTS RATIOS** | | | | | | | | Area | City Park Space | | | Pocket, Neighborhood, and Community Park | | | | | Existing Park Acres | Target Park Acres to Reach Ratio of 5 acres per 1,000 Residents | Acres Needed to Reach 5 Acres per 1,000 Residents Ratio | Existing Park Acres | Target Park Acres to Reach Ratio of 3 acres per 1,000 Residents | Acres Needed to Reach Ratio of 3 acres per 1,000 Residents | | Downtown (DNCP) | 235.84 | 327.55 | 91.70 | 72.91 | 196.53 | 123.62 | | Established Neighborhoods South of Shaw | 242.73 | 1190.58 | 947.85 | 231.78 | 714.35 | 482.57 | | Established Neighborhoods North of Shaw | 764.43 | 827.67 | 63.24 | 194.96 | 496.60 | 301.65 | | Combined DA Northwest | 43.56 | 235.61 | 192.05 | 42.30 | 141.37 | 99.06 | | Combined DA Southwest | 296.55 | 75.28 | -221.27 | 48.92 | 45.17 | -3.76 | | Combined DA East | 21.25 | 76.93 | 55.68 | 21.25 | 46.16 | 24.91 | | South Industrial Area | 20.23 | 56.58 | 36.35 | 20.23 | 33.95 | 13.72 | | **Total** | **1,625** | **2,725** | **1,100** | **632** | **1,635** | **1,003** | 1. Total based on 2010 SOI population of 545,000, Area ratios based on Census Tract populations within each area. City Park Space includes Regional, Trails, Neighborhood, Pocket, and Community Parks not including school properties. Source: City of Fresno. As summarized in Table 5-5, the amount of new parkland expected under the General Plan Horizon (2035) is around 1,100 acres of new parkland. It is both mapped and assumed to be provided by new development and added on infill sites in established neighborhoods. | TABLE 5-5: TOTAL EXISTING AND FUTURE PARK NEEDS SCENARIOS | | | | | :--- | :--- | :--- | :--- | | Park Space Categories | Based on 2010 Population[^p16-1] | Based on Additional Future Population at General Plan Horizon | Total | | All City Park Spaces at Ratio of 5 Acres per 1,000 Residents | 2,725 | 1,130 | 3,855 | | Pocket, Neighborhood, and Community Parks at Ratio of 3 Acres per 1,000 Residents | 1,635 | 678 | 2,313 | [^p16-1]: Based on Table 5-4 SOI Population and Acreage Need at 3 and 5 acres per 1,000 residents. Source: City of Fresno. Subsequent implementation planning for parks following the General Plan adoption will be designed as a guiding blueprint for the City Council, City administration, and the public. It will strive to ensure the cohesive development of a parks and open space system that upholds the standards and goals set forth in the General Plan, and include a range of programs for all ages, interests, and neighborhoods. It will also help determine which parks and recreation facilities will be shared with school programs. ### 5.3 OPEN SPACE ACTION PLAN Fresno's Open Space Action Plan consists of the objectives, and policies presented in this element. These include policy direction for specific programs and which the City Council intends to pursue to implement the ideas for open space systems contained in this element. Additional detail on how the action plan will be implemented is in the Implementation Element, in the Table 12-1, “Summary of Implementation Actions for Plan Policies”. Taken together, these initiatives specifically respond to and are consistent with the Government Code’s requirements for an Open Space Action Plan that is to include “specific programs which the legislative body intends to pursue in implementing its open space plan” (Government Code Section 65564). Figure POSS-1: Parks and Open Space Existing Parks Pocket Park Neighborhood Park Community Park Regional Park Golf Course Future Parks Neighborhood Park Community Park Regional Park Open Space SEDA School/Park Open Space Multi-Use s School Y Vista Point 1/4 Mile radius from existing park 1/4 Mile radius from future park ---- Planning Area Boundary Sphere of Influence ......... City Limits <
> Notes: This figure does not include all Homeowner Association parks, only those that provide public access. This figure includes County of Fresno Parks located within the City of Fresno Planning Area Boundary. See Figure MT-2 for path and trail locations. Source: City of Fresno, DARM Dept. 2014. This page intentionally left blank. Figure POSS-2: San Joaquin River Parkway Path & Trail Access Points **Access Points:** * Existing * Planned * Vista Point * San Joaquin River Parkway Path & Trail[^p19-1] * Class I Bicycle/Pedestrian Path * Class I or III Bicycle Facility * County/City Trail[^p19-2] **Open Space** * Multi-Use * Regional Park * Golf Course * Planning Area Boundary <
> 1. Pedestrian Access 2. Multi-Modal Access with Parking 3. Multi-Modal Access with Parking 4. Multi-Modal Access with Parking 5. Pedestrian, Bicycle, Managment, and Emergency Access 6. Existing Golf Course Access, Future Multi-Modal Access with Parking 7. Pedestrian and Bicycle Access 8. Pedestrian and Bicycle Access 9. Existing Scout Island Access, Future Pedestrian and Bicycle Access 10. Pedestrian and Bicycle Access 11. Existing Parking, Planned Pedestrian Access 12. Multi-Modal Access with Parking 13. Pedestrian, Bicycle, Managment, and Emergency Access 14. Multi-Modal Access with Parking 15. Multi-Modal Access with Parking 16. Multi-Modal Access with Parking 17. Pedestrian and Bicycle Access 18. Pedestrian and Bicycle Access 19. Multi-Modal Access with Parking 20. Multi-Modal Access with Parking 21. Multi-Modal Access with Parking 22. Multi-Modal Access with Parking 23. Multi-Modal Access with Parking 24. Pedestrian and Bicycle Access 25. Multi-Modal Access with Parking 26. Multi-Modal Access with Parking [^p19-1]: Conceptual alignment of proposed path and trail. All planned Parkway access and projects, their features, uses, and locations, are subject to the acquisition of lands and/or easements from willing sellers, and project-specific, site-specific environmental review. [^p19-2]: Conceptual alignment, subject to City/County cooperative planning adoption, and implementation. City preferred location depicted. Source: City of Fresno, DARM Dept 2013 Base Map San Joaquin River Conservancy, 2013 Access Points. OBJECTIVE POSS-1 Provide an expanded, high quality and diversified park system, allowing for varied recreational opportunities for the entire Fresno community. *Commentary:* The park system will be comprehensive; include greenways, trails and open space; allow for athletic, leisure and mobility opportunities; support planned land use intensities and patterns and buffers along transportation corridors; and accommodate groundwater and other resource management objectives. IMPLEMENTING POLICIES POSS-1-a Parkland standard. Implement a standard of at least three acres of public parkland per 1,000 residents for Pocket, Neighborhood, and Community parks throughout the city, while striving for five acres per 1,000 residents for all parks throughout the city, subject to identifying additional funding for Regional Parks, Open Space/Natural Areas, and Special Use Parks/Facilities. POSS-1-b Parks Implementation Planning. Conduct ongoing planning to implement park policies established in this General Plan and continue to strive for well-maintained and fully accessible playgrounds, with accessible amenities, throughout the city. * Keep an up-to-date inventory of existing and planned parks, including locations mapped on the Parks and Open Space Diagram; * Plan for acquiring new parkland designated in the General Plan, as shown in Figure POSS-1; * Establish a standard protocol for working with new development to arrange for parkland acquisition and dedication; * Establish a protocol for working with established neighborhoods to provide needed parks, including the fostering of neighborhood and district associations to help plan, acquire, improve and care for public parks, and coordinating new City service facilities to provide new open space; * Establish detailed design, construction, and maintenance standards; * Prepare an assessment of the recreation needs of existing and future residents; Chapter 5: Parks, Open Space, and Schools * Create an action plan defining priorities, timeframes, and responsibilities; * Adopt and implement a comprehensive financing strategy for land acquisition, park development, operations, and maintenance; * Identify opportunities for using existing or planned park space as passive stormwater storage, treatment, and conservation areas that also provide scenic and/or recreational opportunities; * Identify opportunities for siting and using existing or planned park space as passive “purple pipe” waste water storage, treatment, and conservation areas that also provide scenic and/or recreational opportunities; and * Update the Parks Master Plan. **POSS-1-c** Public Input in Park Planning. Continue to provide opportunities for public participation in the planning and development of park facilities and in creation of social, cultural, and recreational activities in the community. **POSS-1-d** Additional parkland in certain areas. Strive to obtain additional parkland of sufficient size to adequately serve underserved neighborhood areas and along BRT corridors in support of new and intense residential and mixed use infill development. * Identify, where appropriate, joint use opportunities in siting parks with other City service facility needs. **POSS-1-e** Criteria for Parks in Development Areas. Continue to use park size and service area criteria for siting new parks and planning for parks in Development Areas: | Park Type | Size Range (Acreage) | Population Served | Service Area Radius | | :--- | :--- | :--- | :--- | | Neighborhood | 2.01 to 10 | 10,000 - 15,000 | Up to 1 mile | | Community | 10.01 to 40 | 50,000 - 80,000 | Up to 4 miles | | Regional | More than 40[^p21-1] | 100,000 | 100,000 residents | [^p21-1]: Or when amenities provide regional service. **POSS-1-f** Parks and Open Space Diagram. Require parks to be sited and sized as shown on the Parks and Open Space Diagram (Figure POSS-1) of the General Plan, subject to the following: * All new park designations carry dual land use designations, so that if a park is not needed, private development consistent with zoning and development standards may be approved. (See Figure LU-2: Dual Designation Diagram in the Urban Form, Land Use, and Design Element); * Revised and/or additional park sites will be identified through subsequent implementation and planning in established neighborhoods and Development Areas; * Locations for future park sites as shown on Figure POSS-1 are schematic to the extent that park sites may be relocated as necessity and opportunity dictate, and a General Plan amendment is not required if the park continues to serve the target areas as determined by the Planning Director; and * A park may be located on any suitable land in the general vicinity of the sites depicted. However, the zoning of potential park sites must be made consistent with the General Plan. **POSS-1-g** Regional Urban Forest. Maintain and implement incrementally, through new development projects, additions to Fresno's urban forest to delineate corridors and the boundaries of urban areas, and to provide tree canopy for bike lanes, sidewalks, parking lots, and trails. OBJECTIVE **POSS-2** Ensure that adequate land, in appropriate locations, is designated and acquired for park and recreation uses in infill and growth areas. IMPLEMENTING POLICIES **POSS-2-a** Identify opportunities to site, develop and co-locate Fire and Police stations with needed parks and open space as joint-use facilities. * Capital Improvement Plans should be updated to reflect this policy. *Commentary:* Co-location of public safety with parks provides added security for the park and creates an opportunity for public safety personnel to interact with the neighborhood. **POSS-2-b** Park and Recreation Priorities. Use the following priorities and guidelines in acquiring and developing parks and recreation facilities: * Acquire and develop neighborhood park space in existing developed neighborhoods that are deficient of such space and in Chapter 5: Parks, Open Space, and Schools areas along BRT corridors that are designated as priorities for encouraging new mixed-use transit-oriented development; * Provide accessible recreation facilities in established neighborhoods with emphasis on those neighborhoods currently underserved by recreation facilities; *Commentary:* As funding permits, the City will strive to make all recreation facilities universally accessible for all residents. Guidelines should also consider the provision for universally accessible facilities in established neighborhoods. * Improve established neighborhood parks with emphasis on those neighborhoods with the greatest need; * Acquire and develop neighborhood and community parks in new Development Areas; * Recognize community parks as a special need in areas that lack these facilities or are planned for transit supportive urban densities, and explore all potential sources of revenue to secure and develop appropriate sites including joint use facilities; * Develop new special purpose parks, such as outdoor gym equipment, natural resource based trail parks, equestrian centers, dog parks, and amphitheaters, as well as alternative recreation facilities, such as community recreation centers, passive wildlife observation park, cultural heritage and diversity park, military veterans memorial park, and universal access open space park; and * Acquire and develop park and open space in established neighborhoods and Development Areas, prioritizing existing neighborhoods with the greatest deficiencies, so that all residents have access to park or open space within one-half mile of their residence. Develop these facilities to be fully accessible to individuals with disabilities as required by law. POSS-2-c Review of Development Applications. Coordinate review of all development applications (i.e., site plans, conditional use permits, and subdivision maps) in order to implement the parks and open space standards of this Plan. * Assure the provision of adequate active and passive open spaces and facilities as appropriate within residential subdivisions through Development Code requirements for mandatory dedication and improvement of land and/or development fees. *Commentary:* Revisions to the Quimby Act by AB 1359, allows fees paid pursuant to the act to be used in a neighborhood other than the neighborhood being developed if specific conditions can be met. * Require the provision of appropriate outdoor living areas or private open space in multi-family residential developments not subject to the Subdivision Map Act. * Request open space easements where feasible and warranted to secure appropriate public use of sensitive areas with scenic or recreation values, and for buffering space for sensitive areas. * Require provision of appropriate open space areas in private projects, in the form of trails, enhanced landscaped setbacks, parks, and water features. * Evaluate the merits of establishing a development bonus entitlement program in which development incentives (i.e., bonus densities, bonus floor area square footage) are provided for contributions to public recreational facilities on-site or in the vicinity of the development project. **POSS-2-d** **Recreation Opportunities near Freeway Corridors.** Negotiate with Caltrans, other public agencies, and private property owners to develop remnant parcels along freeway corridors for appropriate recreational uses. **POSS-2-e** **Open Space Dedication for Residential Development.** Ensure new residential developments provide adequate land for parks, open space, landscaping, and trails through the dedication of land or otherwise providing for Pocket Parks, planned trails, and other recreational space, maintained by an HOA, CFD, or other such entity. *Commentary:* Thresholds for this requirement will be established when the Development Code is adopted. **POSS-2-f** **Freeway Landscaping.** Support the expansion of the State Route 99 Beautification Association to the Fresno County Highway Beautification Association with related updates and implementation of the master landscape plans for each freeway. Chapter 5: Parks, Open Space, and Schools ### OBJECTIVE **POSS-3** Ensure that park and recreational facilities make the most efficient use of land; that they are designed and managed to provide for the entire Fresno community; and that they represent positive examples of design and energy conservation. ### IMPLEMENTING POLICIES **POSS-3-a** **Centralized Park Locations.** Site parks central and accessible to the population served, while preserving the integrity of the surrounding neighborhood. **POSS-3-b** **Park Location and Walking Distance.** Site Pocket and Neighborhood Parks within a half-mile walking distance of new residential development. **POSS-3-c** **Link Parks with Walkways.** Link public open space to adjacent, schools, and residential uses and Activity Centers through a series of landscaped linear walkways and bikeways that enhance and encourage pedestrian use. **POSS-3-d** **Sidewalks to Connect Neighborhoods.** Sidewalks should be designed for internal neighborhood circulation, and to connect neighborhoods to other residential areas, parks, community trails, shopping, and major streets. **POSS-3-e** **Minimum Park Size for Active Recreation.** Minimize City acquisition or acceptance of dedication of park sites less than two acres in size for active recreational uses, except where maintenance costs are secured through a CFD, HOA, or other such mechanism. **POSS-3-f** **Park Design Guidelines.** Create, maintain, and apply park design guidelines, with provisions for appropriate amenities for each park type, which may include: * Minimum and maximum shade. * Protections from shading by adjacent buildings. * Accessibility to persons with disabilities. * Street trees and landscaped median strips in adjacent arterial roads. * Art and points of attraction. * Landscape and hardscape features. * Street furniture, signage, and lighting. * Food sales and entertainment. * Restroom facilities, play structures, and picnic shelters. * Landscape design synthesis with input from civil engineers and hydrologists, educators and daycare providers, fitness trainers and coaches, police officers and experts in crime prevention through environmental design, as appropriate. * Solar panels, new LED lighting, and water efficiency improvements. Sports field areas designed to allow periodic changes in field locations to minimize wear areas and provide sufficient fields to host regional, state, or national tournaments. * Using topography to create interesting and visually appealing spaces and forms. * Use of waterways as a key design influence, a focus of restoration, and an opportunity to provide for public enjoyment of views. * Reflecting the agricultural and horticultural heritage of the site or area. * Connecting with surrounding areas in a way that encourages expanded pedestrian activity. * Creating individual places within a park that respond to the needs of a broad range of park users, from youth to the elderly. * Creating places of delight that engage the senses. * Creating places that engage the mind, by treating park features as opportunities for interpretation and questioning. * Using sustainable design practices, and highlighting these as opportunities for learning. **POSS-3-g** Park Security and Design. Promote safety, attractiveness, and compatibility between parks and adjacent residential areas through design, maintenance, and enforcement of park regulations * Require the installation of security lighting for parking, points of access, and building areas at all public recreation and park sites. * Keep neighborhood eyes on parks to increase security. **POSS-3-h** Coordination with School Districts. Continue to coordinate with school districts to explore opportunities for joint use of both outdoor Chapter 5: Parks, Open Space, and Schools and indoor recreation facilities, such as playgrounds, play fields, and gymnasiums, for City recreation programs. **POSS-3-i** Joint Use with Drainage Facilities. Continue to seek joint use agreements for use of FMFCD stormwater drainage facilities. *Commentary:* Proposals to use ponding basins (or parts of ponding basins) for recreation will need to be approved by the Department of Public Utilities to ensure minimal loss of capacity for groundwater recharge. OBJECTIVE **POSS-4** Pursue sufficient and dedicated funding for parks acquisition, operations, and maintenance. IMPLEMENTING POLICIES **POSS-4-a** Supplemental Revenue. Seek revenue sources to supplement General Fund support for basic park maintenance and basic recreational services. **POSS-4-b** Operation and Maintenance Financing. Continue to require new residential development to form lighting and landscaping maintenance districts or community facility districts or ensure other means of financing to pay for park operations and maintenance. **POSS-4-c** Improvements in Established Neighborhoods. Seek agreements with formal neighborhood associations and institutions for improvements and ongoing maintenance of parks in established neighborhoods. **POSS-4-d** Maintain *Adopt-A-Park* Program. Continue promoting the City's *Adopt-A-Park* program that utilizes partnerships with local organizations to preserve, beautify and maintain Fresno's neighborhood parks. 5.4 VALLEY ARBORETUM The concept of a Valley Arboretum was introduced by the Tree Fresno organization in 2012. An arboretum is defined as a place where trees, shrubs, and plants are grown in order to be observed scientifically and/or seen by the public for educational and ornamental purposes. The Tree Fresno organization presented the City with a description of 14 arboretum segments and a preliminary diagram, shown below, connecting these segments through Fresno and into adjoining parts of Fresno County and Clovis. Their vision is to establish a signature amenity for the region: a system of linear parks, like the Sugar Pine Trail, with different development standards, to improve Fresno’s quality-of-life and ParkScore and help make the region more investment-worthy to families and businesses. ## Valley Arboretum <
> The vision of the Valley Arboretum[^p28-6] is to establish a link between the “botanical brothers” in the region: the Fresno State campus arboretum and horticulture center, the Clovis Botanical Gardens at Dry Creek Park, the Shinzen Garden at Woodward Park, and the Chaffee Zoological Gardens at Roeding Park with a potential expansion to include Kearney Park, Avocado Park, Lost Lake Park, and other trails in the four county region. In concept, a Valley Arboretum complements and enhances a number of goals, objectives and policies in this General Plan: expanding Fresno’s urban forest; reducing [^p28-6]: Diagram as presented to the City by Tree Fresno. Chapter 5: Parks, Open Space, and Schools heat island effect; establishing green streets, Complete Streets, and Complete Neighborhoods; beautifying trails; connecting a network of paths with parks, greenways and parkways as well as neighborhoods and Activity Centers for recreation and transportation purposes; and increasing the attractiveness of the city to existing and potential residents, visitors, employers and employees. Some of the items that need analysis prior to City consideration include the following: * Segment locations and possible alternatives may be reviewed by City Departments, neighboring jurisdictions, local agencies and organizations, universities, school districts, and the public. * The proposed Greenbelt Trails located along the periphery of Fresno’s SOI may not be as functional as alternative routes located in closer proximity to more populated areas of the city. The Valley Arboretum could provide much needed open space to communities that are underserved by parks and open space. * Additional routes may be needed in the older parts of the city that have a fair amount of pedestrian activity and would benefit from an improved street experience. Some of the Valley Arboretum could be located in such a way as to provide a sense of place in smaller segments to enhance potential main streets in Fresno. * Some segments of the concept Arboretum may need to be adjusted to accommodate other community needs. * Substituting some or all major street segments for local street segments may be advantageous. Relocating segments of the Valley Arboretum along local streets could provide a more enjoyable experience for recreational walkers and cyclists, while reserving major streets for transportation and commuter oriented cyclists. * The Valley Arboretum design needs to be further clarified to guarantee that there are neither conflicts with nor opportunities taken away from cyclists that have been represented in the General Plan. * Representation of the Valley Arboretum design diversity and street cross sections for the various conditions found throughout the many segments identified and for those that may be proposed through a vetting process need to be shown. Street crossing design, safety features and the interface with abutting residential and commercial properties will also vary. The range in overall widths; the type and location of trees and other landscaping; landscaping buffer widths; trail width, location and type; and educational amenities and gateway locations need to be determined. ## 5.5 OPEN SPACE AND BIOLOGICAL RESOURCES Overall, there are more than 4,000 acres of existing open space in the Planning Area. Open space is distinguished here from parkland as discussed above. More than half of the existing open space, including private golf courses and parks in gated communities, is not accessible to the general public. Ponding/recharge basins, owned by the FMFCD, account for 1,273 acres; all serve as ponding basins for storm drainage while some also act as year-round groundwater recharge basins. Six types of open space land are defined by the Government Code for General Plan purposes: * **Open space for public health and safety,** including but not limited to, areas which require special management or regulation because of hazardous or special conditions such as earthquake fault zones, unstable soil areas, flood plains, watersheds, areas presenting high fire risks, areas required for the protection of water quality and water reservoirs and areas required for the protection and enhancement of air quality. * **Open space for the preservation of natural resources,** including but not limited to, areas required for the preservation of plant and animal life, including habitat for fish and wildlife species; areas required for ecologic and other scientific study purposes; rivers, streams, bays and estuaries; and coastal beaches, lakeshores, banks of rivers and streams, and watershed lands. * **Open space used for the managed production of resources,** including but not limited to, forest lands, rangeland, agricultural lands and areas of economic importance for the production of food or fiber; areas required for recharge of groundwater basins; bays, estuaries, marshes, rivers and streams which are important for the management of commercial fisheries; and areas containing major mineral deposits, including those in short supply. * **Open space for outdoor recreation,** including but not limited to, areas of outstanding scenic, historic and cultural value; areas particularly suited for park and recreation purposes, including access to lakeshores, beaches, and rivers and streams; and areas which serve as links between major recreation and open space reservations, including utility easements, banks of rivers and streams, trails, and scenic highway corridors. * **Open space in support of the mission of military installations** that comprises of areas adjacent to military installations, military training routes, and underlying restricted airspace that can provide additional buffer zones to military activities and complement the resource values of the military lands. * **Open space for the protection of places, features, and objects** for the preservation of Native American artifacts, sites and remains. Chapter 5: Parks, Open Space, and Schools Central California is a unique biological enclave, with a rich diversity of flora and fauna. This region's climate, soils, hydrology, and geographic isolation fostered resident species found nowhere else on earth. Through agriculture, rural residential and urban development, these species and their habitats are being diminished and marginalized. In collaboration with federal, State, and local flood control and natural resource agencies, the City is striving to protect native plants by providing greater setbacks near sensitive environments; however, continued urbanization may reduce these species’ opportunities. ### Special Status Species The Planning Area includes a variety of rare plants and wildlife species, particularly along the San Joaquin River, which provides a concentrated riparian plant and animal sanctuary. This area of natural habitat is recognized as unique and scenic given its topographic variation in the characteristically flat San Joaquin Valley. It is a sensitive environment hosting a diversity of wildlife, fish, and plant species, and it contains the last remnants of a true riparian environment, due to the year-round presence of flowing water, which supports aquatic life. This riparian community provides nesting and roosting sites for raptors, herons, egrets, and other bird species (resident and migratory). It also contains special status species, such as the Valley Elderberry Long Horn Beetle (potential to be de-listed), as well as non-special status vegetation, such as cottonwood and willow trees. In short, this segment of the river provides habitat diversity of great value to wildlife. Aside from the San Joaquin River, there are several canals that traverse the Planning Area that provide opportunities for both vegetation and wildlife; however, such opportunities are limited. | OBJECTIVE | | | :--- | :--- | | **POSS-5** | Provide for long-term preservation, enhancement, and enjoyment of plant, wildlife, and aquatic habitat. | | IMPLEMENTING POLICIES | | | :--- | :--- | | **POSS-5-a** | **Habitat Area Acquisition.** Support federal, State, and local programs to acquire significant habitat areas for permanent protection and/or conjunctive educational and recreational use. | | **POSS-5-b** | **Habitat Conservation Plans.** Participate in cooperative, multi-jurisdictional approaches for area-wide habitat conservation plans to preserve and protect rare, threatened, and endangered species. | POSS-5-c **Buffers for Natural Areas.** Require development projects, where appropriate and warranted, to incorporate natural features (such as ponds, hedgerows, and wooded strips) to serve as buffers for adjacent natural areas with high ecological value. POSS-5-d **Guidelines for Habitat Conservation.** Establish guidelines for habitat conservation and mitigation programs, including: * Protocols for the evaluation of a site's environmental setting and proposed design and operating parameters of proposed mitigation measures. * Methodology for the analysis depiction of land to be acquired or set aside for mitigation activities. * Parameters for specification of the types and sources of plant material used for any re-vegetation, irrigation requirements, and post-planting maintenance and other operational measures to ensure successful mitigation. * Monitoring at an appropriate frequency by qualified personnel and reporting of data collected to permitting agencies. POSS-5-e Pursue development of conjunctive habitat and recreational trail uses in flood control and drainage projects. *Commentary:* Establishment of wildlife and aquatic habitat is unsuitable along primary conveyance systems to existing and future water treatment facilities. Certain waterways may be excluded from habitat development for this reason. POSS-5-f **Regional Mitigation and Habitat Restoration.** Coordinate habitat restoration programs with responsible agencies to take advantage of opportunities for a coordinated regional mitigation program. POSS-5-g **Assistance in Valley Arboretum Master Planning.** Assist community organizations that have raised grant funds to pursue the preparation of a Valley Arboretum Master Plan and Implementation Program, including funding, to be coordinated with community groups, as well as related plans and policies for established neighborhoods and other areas with park deficiencies. *Commentary:* It is anticipated that when completed, the Valley Arboretum Master Plan will be presented to the City Council for consideration as an amendment to the General Plan. See discussion at the end of this Element, Section 5.4 Valley Arboretum. Chapter 5: Parks, Open Space, and Schools OBJECTIVE POSS-6 Maintain and restore, where feasible, the ecological values of the San Joaquin River corridor. IMPLEMENTING POLICIES POSS-6-a San Joaquin River Parkway Master Plan. Support the San Joaquin River Conservancy in its efforts to update the San Joaquin River Parkway Master Plan by working with the other jurisdictions and the River Conservancy to create a comprehensive and feasible plan for preservation, conservation, and Parkway development. POSS-6-b Effects of Stormwater Discharge. Support efforts to identify and mitigate cumulative adverse effects on aquatic life from stormwater discharge to the San Joaquin River. * Avoid discharge of runoff from urban uses to the San Joaquin River or other riparian corridors. * Approve development on sites having drainage (directly or indirectly) to the San Joaquin River or other riparian areas only upon a finding that adequate measures for preventing pollution of natural bodies of water from their runoff will be implemented. * Periodically monitor water quality and sediments near drainage outfalls to riparian areas. Institute remedial measures promptly if unacceptable levels of contaminant(s) occur. OBJECTIVE POSS-7 Support the San Joaquin River Conservancy in its collaborative, multiagency efforts to develop the San Joaquin River Parkway. IMPLEMENTING POLICIES POSS-7-a Preserve Wildlife Corridors. Acquire and expand natural reserves and wildlife corridors through purchase, easements, mitigation for proposed activities, or other mutually satisfactory transactions. POSS-7-b Wildlife Corridor along San Joaquin River. Create a wildlife corridor to provide continuous open space land and water areas parallel to the San Joaquin River within the jurisdiction of the City. * Preserve a minimum width of 200 feet of riparian vegetation on both sides of the river. * Require the corridor to be wider when possible and/or necessary to protect additional areas of native plants and critical habitat (such as wildlife breeding areas). Re-establishment of a 200-foot or wider band of native plants is recommended in areas where 200 feet of riparian vegetation no longer exists along the river bank, to the maximum extent feasible from topologic and hydrologic standpoints. * Allow exceptions where the minimum-width corridor is infeasible due to topography, hydrology, or other constraints. An offsetting expansion may be approved in those instances on the opposite side of the river. Incorporate the bluff face into the wildlife corridor where steep bluffs drop directly into or close to the river. **POSS-7-c** **Monitoring River Corridor Conditions.** Undertake periodic monitoring to determine the status of conditions and mitigation measures required for projects within, and in the vicinity of, the river corridor. * Pursue a Memorandum of Understanding (MOU) or other agreement so that the San Joaquin River Conservancy can perform, or participate in, this monitoring program in order to furnish additional expertise, provide for cost efficiency, and to ensure consistency throughout the river corridor. * Based on information obtained from monitoring, modifications in special permits, reclamation plans, and other documents, operating parameters for uses may be necessary to insure human health and safety and the well-being of riparian plants and wildlife. **POSS-7-d** **Buffer Zones near Intensive Uses.** Protect natural reserve areas and wildlife corridor areas in the San Joaquin River corridor whenever more intensive human uses exist or are proposed on adjacent lands. Use buffer zones to allow multiple uses on parts of the parkway while still protecting wildlife and native plants. * Require studies of appropriate buffer widths to be approved by State and federal wildlife agencies before variances from standard buffer zone widths are granted. * Maintain natural riparian buffer zones with appropriate native plants (seed material and cuttings locally derived). * Incorporate open space uses such as pasture, low-intensity agricultural activities, and the "rough" or marginal areas of golf Chapter 5: Parks, Open Space, and Schools courses, into buffer zones when they constitute an improvement in habitat over a previous use or degraded area. Evaluate and address the potential impacts of construction, cultural, and operational practices (such as grading, number of livestock per acre, lighting, and use of pesticides, herbicides, and fertilizers) before these uses are be approved for buffering. * For nearby areas of the San Joaquin River corridor outside of the exclusive jurisdiction of the City, support efforts to work with other jurisdictions to achieve this policy. **POSS-7-e** Natural Habitats and Historic Resources. Continue to protect and enhance the San Joaquin River Parkway environs’ unique and irreplaceable natural habitats and historic resources (including archaeological sites). Continue to maintain standards to protect public health, and provide for development of substantial recreational opportunities for all segments of the community by preserving open space on the bluffs and riverbottom while allowing appropriate recreational development respectful of private property rights. * In conjunction with other land use jurisdictions along the river corridor, determine whether to create a new or modified open space zone district applicable to the San Joaquin riverbottom environs, with provisions that would allow and support the multiple open space uses consistent with the multi-use open space plan designation in this area, and to minimize or prohibit new residential construction. * Require existing undeveloped areas of the riverbottom to remain non-urbanized and establish controls to preserve and enhance the remaining riparian areas and minimize or prohibit new residential uses. **POSS-7-f** River Bluffs. Preserve the river bluffs as a unique geological feature in the San Joaquin Valley by maintaining and enforcing the requirements of the "BP" Bluff Preservation Overlay Zone District, maintaining the bluff area setback for buildings, structures, decks, pools and spas (which may be above or below grade), fencing, and steps, and maintaining designated vista points. * Strive to assure that development of the parkway and other uses within the San Joaquin riverbottom environs are consistent with the mineral resources conservation zones; honor flood, environmental, recreational and aesthetic issues; protect natural habitats and historic resources; and consider adjacent property owners. * Take an active role in establishing park entrances. Provide all gates, trails and roads adequate access by emergency vehicles such as fire trucks, police cars, and ambulances. * For safety reasons, access may be limited to points that have controlled access gates. Cooperation of private parties having legal control of riverbottom access shall be sought in this effort. * Continue to work toward the adoption of official plan lines for new segments of the San Joaquin River Trails and actively pursue completion of these segments to ensure that adequate and appropriate public access to the San Joaquin River and the Parkway is provided. * Refer to Policy NS-2-d (Chapter 9, Noise and Safety) for additional information for sites within the BP Overlay District. **POSS-7-g** **San Joaquin River Parkway - River West Fresno Project Area.** Support the extension of the Lewis Eaton Trail into the River West Fresno Project Area consistent with the San Joaquin River Parkway Master Plan and the following criteria: * Public access into the River View Drive Area/Neighborhoods should be limited to cyclists and pedestrians with the exception of public safety, circulation, and/or other governmental/support service provider vehicles. *Commentary:* Limitations on vehicular access through the River View Drive Area/Neighborhoods are not intended to restrict vehicular access to the neighborhoods themselves. Public right-of-way held by the City for public street purposes will remain accessible to the public consistent with the requirements of the California Vehicle Code. * Proposed public parking facilities should be designed in order to accommodate as many vehicles as possible. * Additional public parking should be located under and/or adjacent to the old San Joaquin Bridge and State Route 41 corridor. * The feasibility of additional public parking and equestrian trailer parking near Spano Park should be considered and fully evaluated. Chapter 5: Parks, Open Space, and Schools * The location of public parking should not conflict with other recommendations in this policy. * The trail alignment should, at the greatest extent possible, be located along and/or near the river for maximum public enjoyment, view and access to the river by all users, and to allow for the best possible fire and public safety buffer for adjacent property owners while also taking into consideration environmental impacts, design and maintenance costs, historical and required water flows and flooding, and/or other events that result in increases to water levels. * Full development or public access should be avoided until adequate and sustainable funding needed to support annual operations and maintenance has been identified. * The San Joaquin River Bluff and Protection Ordinance should be implemented prior to the completion of the project. **POSS-7-h** Interlink City and San Joaquin River Parkway Trail Networks. Strive to connect the parkway trail network to other trails in the vicinity, in order to create a community and regional trail system that offers a variety of different route combinations and enhances public access to the parkway. **POSS-7-i** Public Access to San Joaquin River Parkway Trail Networks. Strive to provide public access to the parkway from public streets, roads, and rights-of-way immediately adjacent to parkway properties, facilities, and trails such as those proposed in Figure POSS-2: San Joaquin River Parkway Path and Trail Access Points, Figure MT-2: Paths and Trails, as well as several public right-of-way alignments identified in Figure MT-1: Major Street Circulation Diagram, which could serve as public access points for vehicles, bicycles, equestrians and/or pedestrians: 1. Herndon and Parkway Avenues: pedestrian access 2. Weber Avenue: multi-modal access with parking 3. Riverside Avenue: multi-modal access with parking 4. Santa Fe and Bluff Avenues: multi-modal access with parking 5. Polk Avenue: pedestrian, bicycle, management, and emergency access 6. Milburn Avenue: existing golf course access and future multi-modal access with parking 7. Valentine Avenue: pedestrian and bicycle access 8. Marks Avenue: pedestrian and bicycle access 9. Van Ness Boulevard: existing Scout Island access, future pedestrian and bicycle access 10. Harrison Avenue: pedestrian and bicycle access 11. Palm and Nees Avenues: multi-modal access with parking 12. Palm Avenue: existing parking and planned pedestrian access 13. Riverview and Bluff Avenue: pedestrian, bicycle, management, and emergency access 14. Perrin Alignment at State Route 41: multi-modal access with parking 15. Woodward Park Audubon Avenue Entrance: multi-modal access with parking 16. Woodward Park Friant Road Entrance: multi-modal access with parking 17. Shepherd Avenue and Friant Road: pedestrian and bicycle access 18. Champlain Avenue and Friant Road: pedestrian and bicycle access 19. Rice Road: multi-modal access with parking 20. Lanes Road: multi-modal access with parking 21. Copper Avenue and Friant Road: multi-modal access with parking 22. Old Friant Road: multi-modal access with parking 23. Old Friant Road: multi-modal access with parking 24. Old Friant Road and Copper River Drive: pedestrian and bicycle access 25. Old Friant Road at River Center: multi-modal access with parking 26. Old Friant Road: multi-modal access with parking ## 5.6 SCHOOLS Schools often act as focal points for neighborhoods and can serve as gathering places and provide open space and recreation opportunities. The City does not operate any of the public schools in Fresno, but it does maintain a collaborative relationship with the school districts, reviewing and approving sites through the subdivision process to ensure that they are consistent with and supportive of the General Plan. The City can also make land use and urban form choices that enhance the role of school facilities in the community. Chapter 5: Parks, Open Space, and Schools ## Existing Public Schools Fresno is served by several school districts, and the school boundaries do not mirror the city limits. The City coordinates land use plans and subdivision approvals with local districts and cooperates with them to ensure that school fees are collected prior to the issuance of building permits. However, substantial population growth, changing demographic characteristics, and funding constraints have made it difficult for school districts to meet growing student capacity demands. Most of the city is served by the Fresno Unified School District (FUSD), the fourth largest school district in the state, operating 95 schools with an enrollment of 70,704 students. FUSD adopted a District Facilities Master Plan in 2009 to revise and improve feeder patterns, adjust school boundaries to balance enrollment, improve building and site conditions, reduce the use of portable classrooms, and build new classrooms and facilities where needed. In accordance with the Master Plan, the District constructed a new middle school in southwest Fresno (Rutherford B. Gaston Sr.), which opened in 2014. The District Facilities Master Plan also calls for a new high school in the southeast area of the District, which would help accommodate new growth and help lessen overcrowding at existing high schools. <
> While the City does not operate any of the schools in Fresno, it works closely with the local school districts to coordinate land use plans and subdivision approvals. Photo Courtesy of Karana Hattersley-Drayton. Clovis Unified School District (CUSD) currently serves areas in Fresno north of Herndon Avenue and east of FYI Airport, and it will serve areas in the Southeast Development Area generally north of the Tulare Avenue alignment. It is the second largest school district in the city serving 40,677 students in 43 schools with approximately 40 percent of students in CUSD being Fresno residents. CUSD has one educational complex in Fresno that houses a middle and a high school. CUSD is in the early planning stages of its newest educational complex in the northern portion of SEDA. Central Unified School District (Central USD) serves the northwestern and west portions of the city serving 14,547 students in 19 schools, and it will serve most of the new development in the Development Areas west of State Route 99. Fueled by residential construction in these areas since 2000, Central USD has experienced an influx of students and as a consequence they have constructed new schools. Fortunately, the Central area contains large parcels of undeveloped land that provide the district flexibility when identifying new school sites. Sanger Unified School District (Sanger USD) serves the southeast portion of the city serving 10,917 students in 20 schools, and at a 7.8 percent increase in enrollment over 5 years has experienced comparable growth to Central USD and slightly lower than Clovis USD at 8.4 percent. As Fresno experiences new development in the eastern fringe, student populations will undoubtedly increase. High school students living in Fresno and within the Sanger USD currently attend Sanger High School located several miles to the east of Fresno. A new Sanger Unified High School and Middle School are planned in the vicinity of a new Sanger Elementary School north of Jensen and west of Temperance Avenue. The southwest portion of the city was served by the West Fresno School District, which contains an elementary school and a middle school. In July 2011, West Fresno USD merged into and became a part of the Washington Unified School District that serves 2,560 students in 4 schools. A large portion of the area south of Church Avenue in southwest Fresno is now within the Washington Unified School District. Combined, the public school districts have the capacity to serve 144,000 school aged children between the grades of K-12, and private schools can serve another 4,200 students. With 136,000 students currently in the public school districts, there remains space for up to 8,000 additional students. Clovis, Fresno, Central and Sanger USDs are planning new schools to increase student capacities as they plan for future growth in the Fresno Planning Area. ### Future Schools Development under the General Plan by 2035 is expected to result in around 35,000 new school-aged students who would require another 28 elementary schools, 6 middle schools, and 4 high schools. The actual school need will depend on the location and phasing of new development, the capacity of existing schools, other growth within Chapter 5: Parks, Open Space, and Schools school districts outside of Fresno, and demographic shifts within existing residential neighborhoods. The City is aware of several planned or proposed school sites and has designated these on Figure LU-1: Land Use Diagram, and Figure POSS-3: Schools and School Districts Diagram. Otherwise, future school facilities are permitted in a variety of land use and zoning districts. The State’s school facility size and service area characteristics will aid preparing master plans for Development Areas, supporting districts’ needs. ## Higher Education Fresno is home to a major four-year public university, California State University, Fresno, commonly known as Fresno State. It is located in the northeastern area of the city. Fresno State is one of the largest and best known of the 23 CSU campuses. It has one of the five public agricultural colleges in the state and maintains research farms within the city limits. Fresno State is largely a commuter campus, with relatively few students living on campus. The university is surrounded by urbanized land, generally low density residential neighborhoods; there are concentrations of apartment complexes west and south of the campus, as well as in the new Campus Pointe development on campus. The residential uses surrounding the university limit its potential for expansion and for the adjacent development of complementary uses, such as research and development, retail, and student housing. Fresno is also home to Fresno Pacific University (FPU), the Central Valley's only accredited Christian university; San Joaquin Valley College; Heald College; UCSF Fresno Center for Medical Education and Research; UEI College; and other professional and technical training centers. Another key institution for higher education and training is the State Center Community College District (SCCCD), which operates Fresno City College in the center of the city and offers associates degrees and vocational training, as well as the Willow International College Center, a satellite campus on the northeastern edge of the city. The District is planning to add a satellite campus focused on vocational training in the southeastern corner of the city in SEDA. Figure POSS-3: Schools and School District[^p42-1] PUBLIC FACILITIES E Elementary School M Middle School H High School E/M Elementary/Middle School E/M/H Elementary/Middle/High School M/H Middle/High School SS Special School[^p42-2] P School with Park C College <
> [^p42-1]: Includes existing and future schools [^p42-2]: Special School is a future school as defined by School District Source: City of Fresno, 2014 Chapter 5: Parks, Open Space, and Schools OBJECTIVE POSS-8 Work cooperatively with school districts to find appropriate locations for schools to meet the needs of students and neighborhoods. IMPLEMENTING POLICIES POSS-8-a **Support School Districts’ Programs.** Support strategies and programs of school districts and the Fresno County Office of Education to provide access to and use of the highest quality educational programs and support services. POSS-8-b **Appropriate School Locations.** Support school locations that facilitate safe and convenient access by pedestrian and bicycle routes, are compatible with surrounding land uses, and contribute to a positive neighborhood identity and Complete Neighborhoods. Commit to the following: * Work with representatives of public and private schools during the preparation and amendment of plans and the processing of development proposals to ensure that General Plan policies are implemented. * Require school districts to provide necessary street improvements, pedestrian facilities, public facilities, and public services at each new school site as authorized by law. * Continue to designate known school sites on the Land Use Diagram (Figure LU-1), and in community plans, Specific Plans, and other plans compatible with the locational criteria of each school district, and to facilitate safe and convenient walking and biking to schools in neighborhoods. * Meet regularly with school district staff and trustees to provide ongoing communication and coordination of plans, projects, and priorities. * Collaborate with school districts to plan and implement new school sites in a manner that supports and reinforces objectives to develop walkable Complete Neighborhoods. POSS-8-c **Park and School Site Coordination.** Pursue the cooperative development and use of school sites with adjacent neighborhood parks for both school activities and non-school related recreational activities. OBJECTIVE POSS-9 | Work with California State University, Fresno, and other institutions of higher learning in Fresno, to enhance the City's workforce, job creation, and economic development, as well as its image and desirability as a place to live. IMPLEMENTING POLICIES POSS-9-a | **Economic Potential of Institutions of Higher Education in Fresno.** Seek to leverage the human capital, research pursuits, and economic potential of California State University, Fresno (Fresno State), and all of Fresno's institutions of higher education, whenever possible in economic development and land use decisions. POSS-9-b | **Regular Coordination with Institutions of Higher Education in Fresno.** Encourage regular meetings with Fresno State, FPU and SCCCD leadership, including the Facilities Planning and Housing divisions. POSS-9-c | **University Neighborhood Planning.** Partner with Fresno State, FPU and SCCCD leadership to find funding for, develop, and implement a Specific Plan for the neighborhoods around the primary campuses of these and other higher education institutions in Fresno. | | *Commentary:* Using Fresno State as an example, the Specific Plans will focus on updating land use designations, zoning, and infrastructure investments along Cedar Avenue, Shaw Avenue, and other city/school interface zones. The plan also will provide a framework for coordinating jointly beneficial actions, such as development of a research park near the campus and enhanced bus service connections. --- ## Noise — Fresno General Plan, Chapter 9: Noise and Safety Element (amended February 2021) - Source: https://www.fresno.gov/wp-content/uploads/2023/03/9-Noise-and-Safety-02-03-21.pdf - Pages: 42 - Covers: noise, safety - **Transcription findings were recorded for this document;** check figures against the source. # 9 NOISE AND SAFETY The purpose of the Noise and Safety Element is to identify the natural and man-made public health and safety hazards that exist within the Planning Area, and to establish preventative and responsive objectives and policies and programs to mitigate their potential impacts. Specifically included are strategies to mitigate noise impacts from new development and direction for noise mitigation. Hazards that are addressed include geologic and seismic hazards, flooding, wildland fires, hazardous materials, and airport safety. ## 9.1 CONTEXT The noise section of this element identifies existing noise sources within the Planning Area and establishes policies, standards and programs to mitigate potential impacts through design and performance measures. This element contains policies that guide the location of industrial land uses and transportation facilities, since they are common sources of excessive noise levels, as well as the location of noise sensitive uses, such as residences, schools, churches, and hospitals. This element also addresses safety issues, including seismic and geologic hazards, flood hazards, wildfire hazards, hazardous materials, airport safety, emergency response, and safety services. It includes policies on natural hazards mitigation planning, which respond to the Federal Disaster Mitigation Act of 2000 and the Federal Emergency Management Agency's implementing regulations and support the County's Multi-Jurisdictional Local Hazard Mitigation Plan, which the City has adopted. ### Relationship to General Plan Goals The objectives and policies of this element support the following General Plan goals: 9. Promote a city of healthy communities and improve quality of life in established neighborhoods. *Emphasize supporting established neighborhoods in Fresno with safe, well maintained, and accessible streets, public utilities, education and job training, proximity to jobs, retail services, health care, affordable housing, youth development opportunities, open space and parks, transportation options, and opportunities for home grown businesses.* 16. Protect and improve public health and safety. ## 9.2 NOISE California Government Code Section 65302(f) requires that general plans contain a Noise Element to identify and quantify potential noise problems and to provide effective policies for noise control and mitigation. Chapter 9: Noise and Safety # Noise Characteristics and Measurement Noise is commonly defined as undesirable or unwanted sound. Noises vary widely in their scope, source, and volume, ranging from individual occurrences such as leaf blowers, to the intermittent disturbances of overhead aircraft, to the fairly constant noise generated by traffic on freeways. Three aspects of community noise are used in assessing the noise environment: * *Level* (e.g., magnitude or loudness). Sound levels are measured and expressed in decibels (dB) with 10 dB roughly equal to the threshold of hearing. Figure NS-1 shows the decibel levels associated with different common sounds. Transient noise events may be described by their maximum A-weighted noise level (dBA). * *Frequency* composition or spectrum. Frequency is a measure of the pressure fluctuations per second, measured in units of hertz (Hz). The characterization of sound level magnitude with respect to frequency is the sound spectrum, often described in octave bands, which divide the audible human frequency range (e.g., from 20 to 20,000 Hz) into ten segments. * *Variation* in sound level with time, measured as noise exposure. Most community noise is produced by many noise sources that change gradually throughout the day and produce a relatively steady background noise having no identifiable source. People may become habituated to moderate continuous transportation-generated noise, such as that generated by roadways. Identifiable events of brief duration, such as aircraft flyovers and the passage of freight trains, are more noticeable because they cause the community noise level to vary episodically instead of gradually. A single number called the equivalent sound level or “L$_{eq}$” describes the average noise exposure level over a period of time. Analysis of noise for planning purposes uses descriptors which emphasize the effect of night time noise, because during that time noise is perceived as more disruptive because background noise levels are generally lower than in the daytime, making outside noise intrusions more noticeable. These weighted noise descriptors include: * Community Noise Equivalent Level (CNEL) which reflects a 24-hour average of ambient sound but adds a five percent weighting factor for both evening (7 to 10 p.m.) and night-time (10 p.m. to 7 a.m.) sound; and * Day-Night Average Level ( Ldn) which reflects a 24-hour average of ambient sound but adds a 10 percent weighting factor for sound occurring during night-time hours (10 p.m. to 7 a.m.). Both CNEL and Ldn reflect noise exposure over an average day with weighting to reflect the increased sensitivity to noise during the evening and night. The two descriptors are roughly equivalent. The CNEL descriptor is used in relation to major continuous noise sources, such as aircraft or traffic, and is the reference level for the Noise Element under State planning law. The general practice is to identify noise contours around transportation facilities such as airports, rail lines, highways, and major streets, and to identify noise levels at property lines from stationary sources such as industrial equipment. Knowledge of the following relationships is helpful in understanding how changes in noise and noise exposure are perceived: * Except under special conditions, a change in sound level of 1 dB cannot be perceived; * A 3 dB change is considered a just-noticeable difference; * A 5 dB change is required before any noticeable change in community response would be expected. A 5 dB increase is often considered a significant impact; and * A 10 dB increase is subjectively heard as an approximate doubling in loudness and almost always causes an adverse community response. Forty-five dBA is usually set as the limit on indoor noise detectable from outdoor sound sources. Sixty dBA is considered to be the sound level of normal conversation and levels within this range are often used as a limit on outdoor ambient noise levels for suburban residential areas. Outdoor ambient noise levels are permitted to be higher for urban areas and commercial sites, and higher still for industrial areas. ### Noise Generation in Fresno In the urban environment, noise generators, such as transportation corridors and industrial uses, occur in close proximity to sensitive noise receivers, such as residential uses. Some land uses potentially constitute both a noise generator and a simultaneous noise receiver, e.g., recreational sites. Fresno has special noise considerations because it has grown up around two major rail corridors, and many freight trains run through the heart of the city daily. Fresno contains three airports and has four State highways that traverse it, as well as major streets at half-mile and one-mile grid intervals, carrying large volumes of passenger vehicle and truck traffic. Industrial and public facilities in and around the city also generate noise from processing materials and from the operation of equipment such as large pumps and backup generators. Residential and commercial uses also contribute noise from smaller equipment, such as swimming pool pumps, air conditioning units, and compressors for refrigeration. <
> Industrial and public facilities in and around Fresno can generate noise, and the City requires enclosure, muffling, and/or extra setbacks for stationary noise sources so that nearby properties are not exposed to excessive noise levels. Longstanding City policy for stationary sources has been to require enclosure, muffling, and/or greater setbacks so that adjacent properties are not exposed to excessive noise levels. Nuisance noise abatement has been accomplished through the City’s Noise Ordinance. Noise from transportation facilities has been controlled primarily by State and federal standards but also by distancing sensitive uses from these facilities, and by use of sound-proofing construction measures, such as masonry walls and sealed buildings. Title 24 of the California Building Code sets out energy conservation requirements, which have also greatly helped mitigate indoor noise levels by requiring dual-pane windows and additional insulation in buildings. Federal Aviation Administration regulations for airports have supported planning and zoning designations, which have kept sensitive uses away from the noise attendant upon flight paths. Each of the three airports in Fresno has its own noise policies and land use compatibility criteria, all of which are incorporated into this Plan. Figure NS-1: Typical Sound Levels **Outdoor Sound Levels** | | **Indoor Sound Levels** --- | --- | --- | 140 | Threshold of Pain Threshold of Pain | | Military Jet Takeoff with Afterburner at 50 feet | | <
> | 130 | | 120 | Ambulance Siren at 10 feet | 110 | Rock Band Concert Pile Driver at 50 feet | 100 | Night Club with Live Music Gas Lawnmower at 3 feet | 90 | Sports Boat at 100 feet | | Diesel Truck at 50 feet | 80 | Food Blender at 3 feet Concrete Mixer at 50 feet | | Noisy Restaurant Leaf Blower at 50 feet | 70 | Garbage Disposal at 3 feet | | Vaccuum Cleaner at 10 feet Commercial / Urban Area, Daytime | 60 | Normal Conversation at 3 feet Urban Expressway at 300 feet | | Active Office Environment Suburban Area, Daytime | 50 | <
> | 40 | Quiet Office Environment | | Dishwasher, Next Room Quiet Urban Area, Nighttime | | Quiet Suburban Area, Nighttime | 30 | Library Quiet Rural Area, Nighttime | | Quiet Bedroom, Nighttime | | Concert Hall, Background Leaves Rustling | 20 | Quiet Wilderness Area, No Wind | 10 | Recording Studio <
> | | Threshold of Human Hearing | 0 | Threshold of Human Hearing Decibels (dBA) Source: URS, 2010. ### Existing Noise Levels The existing noise conditions in the City were measured at nine locations from May 30 to June 1, 2012. Noise monitoring sites were selected to be representative of typical residential, commercial, and industrial sites within the Planning Area, as well as arterial roadways, elevated and below-grade freeways, and railroad crossings with and without train horn soundings. At each of the nine long-term 24-hour noise monitoring sites, day-night statistical noise level trends were recorded to develop Ldn values. Descriptions of each location and the measured noise levels are listed in Table 9-1. | TABLE 9-1: MEASURED EXISTING NOISE LEVELS¹ | | | :--- | :--- | | | Noise Level (dBA Ldn) | | Railroad crossing at Shields Ave. | 84 | | Along Railroad near W. Barstow Ave. | 74 | | SR 41 between W. Barstow & W. Shaw Ave. | 76 | | SR 180 near N. Peach Ave. | 76 | | E. Shaw Ave. near N. Cedar Ave. | 72 | | N. Blackstone Ave. near E. Ashlan Ave. | 70 | | S. Elm Ave. near E. Jensen Ave. | 68 | | N. Valentine Ave. between W. Ashlan & W. Holland Ave. | 67 | | S .Fruit Ave. north of Church Ave. | 65 | [^p8-1]: Values provided have been normalized to the reference distance of 100 feet. Existing noise levels in the city are principally generated by transportation noise sources (refer to Figure NS-2: Existing Noise Contours). Vehicular traffic noise is the dominant source in most areas, but aircraft and rail activity are also significant sources of environmental noise in the local areas surrounding these operations. In several locations, industrial noise was clearly audible. However, overall average daily noise levels at existing nearby noise-sensitive receptors (e.g., residential areas) typically consist of traffic noise primarily and industrial noise secondarily. New noise-sensitive developments in close proximity to industrial land uses could be exposed to greater industrial noise levels. ### Traffic Noise The level of highway traffic noise depends on three factors: (1) the volume of the traffic, (2) the speed of the traffic, and (3) the number of trucks in the flow of traffic. Vehicle noise is a combination of the noises produced by the engine, exhaust, tires, and wind generated by taller vehicles. Other factors that affect the perception of traffic noise include: distance from the highway, terrain, vegetation, pavement type and condition, and natural and structural obstacles. While tire noise from autos is generally located at ground level, truck noise sources can be located as high as 10 to 15 feet above the roadbed due to tall exhaust stacks and higher engines. Future noise exposure contours for Fresno’s major roadways were modeled by applying the Federal Highway Administration’s noise modeling procedure, using roadway, speed, and traffic mix data from the City and projected traffic volumes based on anticipated development under the General Plan. In establishing noise contours for land use planning, it is customary to ignore noise attenuation afforded by buildings, roadway elevations, and depressions, and the barrier effect of natural terrain features. The result is a worst-case estimate of the existing and future (projected) noise environment. The assumption is that it is more desirable to overestimate the potential noise at a future noise-sensitive development site than to underestimate the noise environment and allow for potentially incompatible land-use development. The developed noise contours for the City are conservative, meaning that the contours are modeled with minimal noise attenuation by natural barriers, buildings, with the exception of significantly depressed sections of highways. Future development within the Planning Area will result in increased traffic volumes, thus increasing noise levels in some areas (refer to Figure NS-3: Future Noise Contours). For example, future noise levels along highways are projected to increase by two to five decibels, while noise levels along most existing roadways are projected to increase by one to five decibels. New roadways, significantly expanded roadways, or sparsely populated areas where significant new development may also experience an increase in noise levels by more than five decibels. While there will be increases in some noise levels, efforts can be taken to help minimize such instances. For example, siting noise sensitive uses away from high-noise areas (e.g., major transportation routes) and buffering noise through design will help minimize future noise-related land use conflicts. Railroad Operations Noise Railroad activity in Fresno primarily occurs along two rail corridors, however there are also several spur lines. Warning horns generally are signaled within one-quarter mile of a grade crossing, although the area around the Community Regional Medical Center in downtown is designated as a quiet zone. Where grade crossings exist, and warning horns and crossing alarms are signaled, individual single event noise levels associated with a train generally reach 105 dBA to 110 dBA at a distance of 100 feet from the track centerline. Away from grade crossings, train pass-by noise levels are lower, typically 85 dBA to 90 dBA at a distance of 100 feet. Airport Noise There are two public airports in the Planning Area, Fresno-Yosemite International Airport and Fresno Chandler Executive Airport, and one private airport open to public use, Sierra Sky Park. In conjunction with Fresno-Yosemite International Airport, the Air National Guard maintains an airbase for military flight and training operations. Each airport has its own City of Fresno airport land use plan designed to provide for public safety. In addition, the Fresno County Airport Land Use Commission (ALUC) must prepare an Airport Land Use Compatibility Plan (ALUCP) as required by the Caltrans Division of Aeronautics for each airport. ALUC and the Federal Aviation Administration (FAA) provide guidance to local jurisdictions on determining appropriate and compatible adjacent land uses through the detailed findings and policies of ALUCPs. Among other objectives, these airport plans strive to minimize the effects of aircraft noise on communities adjacent to airports and prevent uses incompatible with airport operations from locating near the airport. This General Plan and all other City land use plans must either be compatible with the adopted ALUCP or make a statement of overriding consideration justifying its incompatibility. Figures NS-4 through 6 depict each airport’s noise and safety zones that have been established to identify the compatibility criteria to apply to any given project proposed within the airport’s compatibility zones. The noise contours shown on the maps are developed following Federal Aviation Regulation (FAR) Part 150 *Airport Noise Compatibility Planning*. The Part 150 program is designed to lessen the effect of airport noise on the surrounding community as development is proposed around an airport or the airport is modified or expanded. The specific criteria applied for each contour can be found in each airport’s ALUCP, both the City’s and the one prepared by the ALUC. ### Major Stationary Noise Sources Noise can result from many industrial processes, even when the best available noise control technology is applied. Noise exposures within industrial facilities are controlled by federal and State employee health and safety regulations set by the Occupational Safety and Health Administration (OSHA) and Cal-OSHA, but exterior noise levels may exceed locally acceptable standards. Commercial, recreational, and public service facility activities can also produce noise that affects adjacent sensitive land uses. These noise sources can be continuous and may contain tonal components that may be annoying to individuals who live nearby. In addition, noise generation from fixed noise sources may vary based upon climatic conditions, time of day and existing ambient noise levels. Industrial uses in Fresno are typically located in industrial districts near freeways and commercial uses, away from residences and other sensitive noise receptors. Noise sources associated with service commercial uses such as automotive repair facilities, wrecking yards, tire installation centers, car washes, loading docks, etc., are found at various locations within the city. The noise emissions of these types of uses are dependent on many factors and are therefore difficult to quantify precisely. Nonetheless, noise generated by the these uses contributes to the ambient noise environment in immediate vicinity of these uses and should be considered where either new noise-sensitive uses are proposed nearby or where similar uses are proposed in existing residential areas. Figure NS-2: Existing Noise Contours (Vehicle) 60 to 65 dB 65 to 70 dB 70 to 75 dB 75 to 80 dB over 80 dB Railroad Planning Area Boundary Sphere of Influence City Limits <
> Note: The Fresno Air National Guard Base, a military airport, and the Fresno Yosemite International Airport are located in the area represented as Fresno Yosemite International Airport. Source: City of Fresno, 2011; Salter Associates, 2012 Dyett & Bhatia, 2012. Figure NS-3 : Future Noise Contours (Vehicle) 60 to 65 dB 65 to 70 dB 70 to 75 dB 75 to 80 dB over 80 dB Railroad ---- Planning Area Boundary —— Sphere of Influence ....... CityLimits <
> Note: The Fresno Air National Guard Base, a military airport, and the Fresno Yosemite International Airport are located in the area represented as Fresno Yosemite International Airport. Source: City of Fresno, 2011; Salter Associates, 2012 Dyett & Bhatia, 2012. Figure NS-4: Existing Fresno Yosemite International Airport Noise and Safety Zones <
> **Safety Zones** * Zone 1 RPZ * Zone 2 Inner Approach/Departure * Zone 3 Inner Turning * Zone 4 Outer Approach/Departure * Zone 5 Sideline * Zone 6 Traffic Pattern **Noise Contours** * 75 dB * Planning Area * Sphere of Influence * City Limits Source: City of Fresno, 2014. Figure NS-5: Existing Fresno Chandler Executive Airport Noise And Safety Zones <
> **Safety Zones** |||| |---|---|---| | | | Primary Surface | | | | Runway Proction Zone | | | | Inner Approach Zone | | | | Inner Turning Zone | | | | Outer Approach Zone | | | | Sideline Zone | | | | Traffic Pattern Zone | **Noise Contours** | | | |---|---| | | Planning Area | | | Sphere of Influence | | | City Limits | | | Downtown Planning Area | Source: City of Fresno, 2014. Figure NS-6: Existing Sierra Skypark Airport Noise and Safety Zones <
> **Safety Zones** | | | | :--- | :--- | | ▨▨▨▨ | Primary Surface | | | Clear Zone | | | Inner Approach Zone | | | Outer Approach | | --------- | Horizontal Surface | | --------- | Conical Surface | | - - - - - | Traffic Pattern | | -.-.-.- | Primary Review Area Boundary | | | Noise Contours | | --------- | Planning Area | | --------- | Sphere of Influence | | ............. | City Limits | Source: City of Fresno, 2014. Chapter 9: Noise and Safety There are numerous park and school uses within the city. Noise generated by these uses depends on the age and number of people utilizing the respective facility at a given time and the types of activities they are engaged in. School playing field activities tend to generate more noise than those of neighborhood parks, as the intensity of school playground usage tends to be higher. At a distance of 100 feet from an elementary school playground being used by 100 students, average and maximum noise levels of 60 and 75 dB, respectively, can be expected. At organized events such as high-school football games with large crowds and public address systems, the noise generation is often significantly higher. As with service commercial uses, the noise generation of parks and school playing fields is variable. Noise Control – Maximum Noise Level Standards With the proposed intensification of land uses in the city, noise control will be an increasing consideration for infrastructure and new development, particularly for infill residential projects. Major cities in California commonly consider maximum noise levels of 65 dB to be considered “normally acceptable” for unshielded residential development including outdoor space in an urban environment. Suburban and rural jurisdictions tend to prefer a 60 dB or lower threshold for residential areas. Noise levels from 65 dB to 70 dB fall within the “conditionally unacceptable” range, and those in the 70 to 75 dB range are considered “normally unacceptable.” The General Plan is consistent with noise control practice in urban areas, employing 60 dB as being a desirable level, but accepting 65 dB as being in the “normally acceptable” range for noise due to the number of transportation sources located in proximity to urban residential areas. This policy supports the development of infill residential projects, as well as non-residential infill projects by setting a realistic, achievable threshold of impact for new development. Section 10-101 of the City’s Municipal Code contains the City’s Noise Ordinance, which establishes excessive noise guidelines and exemptions. Standards are set for ambient noise based on district type (residential, commercial, and industrial) and time of day. Upon adoption of the new noise limits and policies proposed in this General Plan Update, the City will commence an update of its Noise Ordinance to provide regulatory consistency with adopted policies. Acceptable ranges for exterior noise levels in the Noise Ordinance will be updated to be consistent with this General Plan. This update will need to increase the threshold in residential districts to 65 decibels and adjust noise limits for other planned uses. The updated Noise Ordinance will also specify maximum hourly noise levels for outdoor activity areas and indoor spaces measurement standards; uniform guidelines for acoustical studies based on current professional standards; required noise mitigation standards and enforcement procedures for stationary noise sources which cause the allowable noise limits to be exceeded. Finally, the Noise Ordinance will establish performance standards for noise reduction for new developed property that may be exposed to community noise levels exceeding target acceptable noise levels for outdoor activity levels and interior spaces. ### TABLE 9-2: TRANSPORTATION (NON-AIRCRAFT) NOISE SOURCES | | | | | | :--- | :--- | :--- | :--- | | | | | | | Residential | 65 | 45 | - | | Transient Lodging | 65 | 45 | - | | Hospitals, Nursing Homes | 65 | 45 | - | | Theaters, Auditoriums, Music Halls | - | - | 35 | | Churches, Meeting Halls | 65 | - | 45 | | Office Buildings | - | - | 45 | | Schools, Libraries, Museums | - | - | 45 | 1. Where the location of outdoor activity areas is unknown or is not applicable, the exterior noise level standard shall be applied to the property line of the receiving land use. 2. As determined for a typical worst-case hour during periods of use. ### TABLE 9-3: STATIONARY NOISE SOURCES[^p18-1] | | Daytime (7:00 a.m. – 10:00 p.m.) | Nighttime (10:00 p.m. – 7:00 a.m.) | | :--- | :--- | :--- | | Hourly Equivalent Sound Level (Leq), dBA | 50 | 45 | | Maximum Sound Level (Lmax), dBA | 70 | 60 | [^p18-1]: The Department of Development and Resource Management Director, on a case-by-case basis, may designate land uses other than those shown in this table to be noise-sensitive, and may require appropriate noise mitigation measures. [^p18-2]: As determined at outdoor activity areas. Where the location of outdoor activity areas is unknown or not applicable, the noise exposure standard shall be applied at the property line of the receiving land use. When ambient noise levels exceed or equal the levels in this table, mitigation shall only be required to limit noise to the ambient plus five dB. Chapter 9: Noise and Safety OBJECTIVE NS-1 Protect the citizens of the City from the harmful and annoying effects of exposure to excessive noise. IMPLEMENTING POLICIES NS-1-a Desirable and Generally Acceptable Exterior Noise Environment. Establish 65 dBA Ldn or CNEL as the standard for the desirable maximum average exterior noise levels for defined usable exterior areas of residential and noise-sensitive uses for noise, but designate 60 dBA Ldn or CNEL (measured at the property line) for noise generated by stationary sources impinging upon residential and noise-sensitive uses. Maintain 65 dBA Ldn or CNEL as the maximum average exterior noise levels for non-sensitive commercial land uses, and maintain 70 dBA Ldn or CNEL as maximum average exterior noise level for industrial land uses, both to be measured at the property line of parcels where noise is generated which may impinge on neighboring properties. Commentary: The Noise Ordinance will define usable exterior areas for single family and multiple family residential and noise sensitive uses to include rear yards and other outdoor areas intended to accommodate leisure or active use, excluding front or side yard areas, and front or side porches. Balconies or roof decks facing front and side yards shall be included in designated areas to be protected from noise where these spaces are used to calculate compliance with required outdoor living area as required by adopted development standards. NS-1-b Conditionally Acceptable Exterior Noise Exposure Range. Establish the conditionally acceptable noise exposure level range for residential and other noise sensitive uses to be 65 dB Ldn or require appropriate noise reducing mitigation measures as determined by a site specific acoustical analysis to comply with the desirable and conditionally acceptable exterior noise level and the required interior noise level standards set in Table 9-2. NS-1-c Generally Unacceptable Exterior Noise Exposure Range. Establish the exterior noise exposure of greater than 65 dB Ldn or CNEL to be generally unacceptable for residential and other noise sensitive uses for noise generated by sources in Policy NS-1-a, and study alternative less noise-sensitive uses for these areas if otherwise appropriate. Require appropriate noise reducing mitigation measures as determined by a site specific acoustical analysis to comply with the generally desirable or generally acceptable exterior noise level and the required 45 dB interior noise level standards set in Table 9-2 as conditions of permit approval. **NS-1-d** Allowable Exterior Noise Environment for BRT and Activity Centers. Exclude residential and noise sensitive uses located along Bus Rapid Transit corridors or within Activity Centers identified by this General Plan, from exterior noise standards in Policies NS-1-a through NS-1-c where it is determined application of noise mitigation measures will be detrimental to the realization of the General Plan's mixed use policies. *Commentary: Interior noise level standards of Table 9-2 will still apply.* **NS-1-e** Update Noise Ordinance. Update the Noise Ordinance to ensure that noise exposure information and specific standards for both exterior and interior noise and measurement criteria are consistent with this General Plan and changing conditions within the city and with noise control regulations or policies enacted after the adoption of this element. **NS-1-f** Performance Standards. Implement performance standards for noise reduction for new residential and noise sensitive uses exposed to exterior community noise levels from transportation sources above 65 dB Ldn or CNEL, as shown on Figure NS-3: Future Noise Contours, or as identified by a project-specific acoustical analysis based on the target acceptable noise levels set in Tables 9-2 and Policies NS-1-a through NS-1-c. **NS-1-g** Noise mitigation measures which help achieve the noise level targets of this plan include, but are not limited to, the following: Chapter 9: Noise and Safety * Façades with substantial weight and insulation; * Installation of sound-rated windows for primary sleeping and activity areas; * Installation of sound-rated doors for all exterior entries at primary sleeping and activity areas; * Greater building setbacks and exterior barriers; * Acoustic baffling of vents for chimneys, attic and gable ends; * Installation of mechanical ventilation systems that provide fresh air under closed window conditions. The aforementioned measures are not exhaustive and alternative designs may be approved by the City, provided that a qualified Acoustical Consultant submits information demonstrating that the alternative design(s) will achieve and maintain the specific targets for outdoor activity areas and interior spaces. **NS-1-h** **Interior Noise Level Requirement.** Comply with the State Code requirement that any new multifamily residential, hotel, or dorm buildings must be designed to incorporate noise reduction measures to meet the 45 dB Ldn interior noise criterion, and apply this standard as well to all new single-family residential and noise sensitive uses. **NS-1-i** **Mitigation by New Development.** Require an acoustical analysis where new development of industrial, commercial or other noise generating land uses (including transportation facilities such as roadways, railroads, and airports) may result in noise levels that exceed the noise level exposure criteria established by Tables 9-2 and 9-3 to determine impacts, and require developers to mitigate these impacts in conformance with Tables 9-2 and 9-3 as a condition of permit approval through appropriate means. Noise mitigation measures may include: * The screening of noise sources such as parking and loading facilities, outdoor activities, and mechanical equipment; * Providing increased setbacks for noise sources from adjacent dwellings; * Installation of walls and landscaping that serve as noise buffers; * Installation of soundproofing materials and double-glazed windows; and * Regulating operations, such as hours of operation, including deliveries and trash pickup. Alternative acoustical designs that achieve the prescribed noise level reduction may be approved by the City, provided a qualified Acoustical Consultant submits information demonstrating that the alternative designs will achieve and maintain the specific targets for outdoor activity areas and interior spaces. As a last resort, developers may propose to construct noise walls along roadways when compatible with aesthetic concerns and neighborhood character. This would be a developer responsibility, with no City funding. **NS-1-j** **Significance Threshold.** Establish, as a threshold of significance for the City's environmental review process, that a significant increase in ambient noise levels is assumed if the project would increase noise levels in the immediate vicinity by 3 dB Ldn or CNEL or more above the ambient noise limits established in this General Plan Update. **Commentary:** When an increase in noise would result in a “significant” impact (increase of three dBA or more) to residents or businesses, then noise mitigation would be required to reduce noise exposure. If the increase in noise is less than three dBA, then the noise impact is considered insignificant and no noise mitigation is needed. By setting a specific threshold of significance in the General Plan, this policy facilitates making a determination of environmental impact, as required by the California Environmental Quality Act. It helps the City determine whether (1) the potential impact of a development project on the noise environment warrants mitigation, or (2) a statement of overriding considerations will be required. Chapter 9: Noise and Safety **NS-1-k** **Proposal Review.** Review all new public and private development proposals that may potentially be affected by or cause a significant increase in noise levels, per Policy NS-1-i, to determine conformance with the policies of this Noise Element. Require developers to reduce the noise impacts of new development on adjacent properties through appropriate means. **NS-1-l** **Enforcement.** Continue to enforce applicable State Noise Insulation Standards and Uniform Building Code noise requirements, as adopted by the City. **NS-1-m** **Transportation Related Noise Impacts.** For projects subject to City approval, require that the project sponsor mitigate noise created by new transportation and transportation-related stationary noise sources, including roadway improvement projects, so that resulting noise levels do not exceed the City's adopted standards for noise-sensitive land uses. **NS-1-n** **Best Available Technology.** Require new noise sources to use best available control technology to minimize noise emissions. **Commentary:** *Noise from mechanical equipment can be reduced by soundproofing materials and sound-deadening installation; controlling hours of operation will also reduce noise impacts during the morning or evening.* **NS-1-o** **Sound Wall Guidelines.** Acoustical studies and noise mitigation measures for projects shall specify the heights, materials, and design for sound walls and other noise barriers. Aesthetic considerations shall also be addressed in these studies and mitigation measures such as variable noise barrier heights, a combination of a landscaped berm with wall, and reduced barrier height in combination with increased distance or elevation differences between noise source and noise receptor, with a maximum allowable height of 15 feet. The City will develop guidelines for aesthetic design measures of sound walls, and may commission area wide noise mitigation studies that can serve as templates for acoustical treatment that can be applied to similar situations in the urban area. **Commentary:** While acoustical studies need to be site-specific in order to appropriately assess particular settings, having prototypical design measures and noise control templates that can be applied for similar situations and contexts can facilitate infill and other development. **NS-1-p** **Airport Noise Compatibility.** Implement the land use and noise exposure compatibility provisions of the adopted Fresno Yosemite International Airport Land Use Compatibility Plan, the Fresno-Chandler Executive Airport Master and Environs Specific Plan, and the Sierra Sky Park Land Use Policy Plan to assess noise compatibility of proposed uses and improvements within airport influence and environs areas. ## 9.3 SEISMIC AND GEOLOGIC HAZARDS ### Seismicity Fresno is in one of the more geologically stable areas of California and does not lie within a known active earthquake fault zone. Although a number of faults are located within the Sierra Nevada Mountain Range, none are considered active. The nearest active fault is located by Independence, CA, approximately 100 miles to the east along the Fresno County-Inyo County boundary. Overall, seismic-related concerns (including liquefaction and subsidence) are considered fairly minor for the Planning Area. The city is not located in an Alquist-Priolo Special Fault Study Zone, that is, it has not been identified as a zone of special study around active faults. Hidden faulting in Western Fresno County did manifest itself in the Coalinga Earthquake of 1983, causing ground shaking in Fresno, but minimal damage. In the future, Fresno could be affected by major seismic events from the following active fault systems in other regions of California: * The San Andreas Fault paralleling the Coast Ranges in western Fresno County; * The Owens Valley Fault system in the Eastern Sierra Region of California; * The White Wolf Fault paralleling the Tehachapi range southeast of Bakersfield * Hidden thrust fault(s) in the west side of the San Joaquin Valley; and * The Long Valley Caldera, a seismic and volcanic area in the Eastern Sierra that lies between Mono Lake and Crowley Lake. The principal potential earthquake hazard for Fresno is ground shaking, which could cause damage to buildings and infrastructure elements such as bridges and pipes. The distance between Fresno and major faults minimizes this potential hazard. ## Soil Hazards Expansive soils, soil erosion, and water infiltration are issues that can cause safety concerns in Fresno. Expansive soils are largely comprised of clays, which expand in volume when water is absorbed and shrink as the soil dries. Expansion is measured by shrink-swell potential, which is the volume change in soil with a gain in moisture. If the shrink-swell potential is rated moderate to high, then damage to buildings, roads, structural foundations, and pipes can occur. In the northern portion of Fresno’s SOI, there are some areas of expansive clay soil that require special construction standards for foundations and infrastructure. Expansive clay problems can be surmounted by appropriate engineering design and construction techniques. Highly erodible soils are those that are easily carried by water and, to a lesser extent, by wind. Surface erosion is more commonly visible, but subsurface erosion can lead to damage to pipes, roads, foundations, and other structural elements. Soil erosion potential is identified by a specific soil’s “K Factor,” which provides an indication of a soil’s inherent susceptibility to erosion, absent of slope and groundcover factors. Values of K range from 0.05 to 0.43, and the higher the value, the more susceptible the soil is to sheet erosion by water. The addition of weight, such as pools and decks, onto susceptible soil, as well as private irrigation systems and the action of burrowing rodents, are factors that may aggravate land slippage. Fresno is not susceptible to soil erosion with the exception of land within 300 feet of the toe of the San Joaquin River bluffs, where the steep slopes and soil composition predispose it to instability and erosion. Soils are also defined by their rainfall runoff potential, which is the degree to which soil allows or disallows rainfall water to infiltrate and transmit down to the groundwater table. Groups of soils having similar runoff potential under similar storm and cover conditions, absent of slope, are placed into one of four hydrologic group classifications: A, B, C or D. Definitions of the classes are as follows: * **Soil Group A. High Infiltration (Low runoff potential)**—Soils having high infiltration rates, even when thoroughly wetted and consisting chiefly of deep, well drained sands or gravels. These soils have a high rate of water transmission. * **Soil Group B. Moderate Infiltration**—Soils having moderate infiltration rates, even when thoroughly wetted and consisting chiefly of moderately deep to deep, moderately fine to moderately course textures. These soils have a moderate rate of transmission. * **Soil Group C. Slow Infiltration**—Soils having slow infiltration rates, even when thoroughly wetted and consisting chiefly of soils with a layer that impedes downward movement of water, or soils with moderately fine to fine textures. These soils have a slow rate of transmission. * **Soil Group D. Very Slow Infiltration (High runoff potential)**—Soils having very slow infiltration rates, even when thoroughly wetted and consisting chiefly of clay soils with a high swelling potential, soils with a permanent high water table, soils with a clay pan or clay layer at or near the surface, and shallow soils over nearly impervious material. These soils have a very slow rate of transmission. Hydrological groups are used in equations that estimate runoff from rainfall. These estimates are needed for solving hydrologic problems that arise in planning watershed protection and flood prevention projects and for designing structures for the use, control, and disposal of water. | OBJECTIVE | | | :--- | :--- | | **NS-2** | Minimize risks of property damage and personal injury posed by geologic and seismic risks. | | IMPLEMENTING POLICIES | | | :--- | :--- | | **NS-2-a** | **Seismic Protection.** Ensure seismic protection is incorporated into new and existing construction, consistent with the Fresno Municipal Code. | | **NS-2-b** | **Soil Analysis Requirement.** Identify areas with potential geologic and/or soils hazards, and require development in these areas to conduct a soil analysis and mitigation plan by a registered civil engineer (or engineering geologist | specializing in soil geology) prior to allowing on-site drainage or disposal for wastewater, stormwater runoff, or swimming pool/spa water. **NS-2-c** Landfill Areas. Require proposed land uses on or near landfill areas to be designed and maintained to comply with California Code of Regulations, Title 27, Section 21190, Post Closure Land Use. **NS-2-d** Bluff Preservation Overlay Zone. Per the requirements of the Bluff Preservation Overlay Zone District and Policy POSS-7-f (Chapter 5, Parks and Open Space), the following standards shall be applicable for property located within the Bluff Preservation zone: * Require proposed development within 300 feet of the toe of the San Joaquin River bluffs to undertake an engineering soils investigation and evaluation report that demonstrates that the site is sufficiently stable to support the proposed development, or provide mitigations to provide sufficient stability; and * Establish a minimum setback of 30 feet from the San Joaquin River bluff edge for all buildings, structures, decks, pools and spas (which may be above or below grade), fencing, lighting, steps, etc. * An applicant may request to reduce the minimum setback to 20 feet from the bluff edge if it can be demonstrated, to the satisfaction of the City's Building Official and the Planning Director, that the proposed building, structure, deck, pool and/or spas (which may be above or below grade), fencing, steps, etc., will meet the objectives of the Bluff Preservation Overlay Ordinance. In no case shall the setback be reduced to less than 20 feet. ## 9.4 STORM DRAINAGE AND FLOOD CONTROL Fresno’s precipitation comes in episodic storm events, which may be severe and may cause localized flooding. The Fresno area receives inflows of regional runoff from a large watershed to the east, and is in the path of natural drainage from the valley floor, foothills and Sierra Nevada range. The San Joaquin River, confined between bluffs, comprises the northern boundary of Fresno. Figure NS-7: Flood Plains shows the locations of the existing 100-year floodplains in the Planning Area, as mapped by FEMA’s National Flood Insurance Maps. The Fresno Metropolitan Flood Control District (FMFCD) is responsible for flood control and storm water planning and management. It was authorized as a “special act” district and established by voter approval in 1956 to serve a 54-square mile area. Since its creation the district boundaries have been expanded several times and now include approximately 400 square miles—almost the entire portion of the Fresno-Clovis Metropolitan Area, with the exception of 6.5 square miles of SEDA which has yet to be annexed to the District. Once all of SEDA is annexed, FMFCD will develop and adopt Storm Water Master Plans for SEDA based on this General Plan. The District was formed for the purpose of acquiring and constructing flood control and drainage facilities to safely convey, discharge, store and conserve storm water received on land within the District boundaries or which flows through the District. Eight flood control reservoirs and major basin facilities have been constructed along the Big Dry Creek, Redbank Creek, Dog Creek, Pup Creek, and Fancher Creek, comprising the Fresno Stream Group. The District also serves as the local sponsor of the U.S. Army Corps of Engineers for five the flood control facilities within the Redbank-Fancher Creeks Flood Control Project. Figure NS-7: **Existing Floodplains** <
> 100 Year Flood Zones ---- Planning Area Boundary Sphere of Influence City Limits Source: FEMA, 2014. The urban storm water drainage program provides a system comprised of storm drainage collection, conveyance, detention and retention serving planned urban and rural areas within the Fresno-Clovis environs. The adopted Storm Drainage and Flood Control Master Plan divides the service area into 163 local drainage areas. Collectively, the system has in excess of 600 miles of storm drainage pipeline and 154 local stormwater management basins together with ancillary facilities, such as storm water lift pump stations. This system expands as the area of urbanization expands. Facilities are funded and constructed by owners/developers of properties pursuant to the City's drainage fee requirements in Fresno Municipal Code section 12-1901 et. seq., or constructed by FMFCD under publicly awarded contracts. The City also requires drainage to be directed to public streets, so that storm water travels along paved surface areas to inlets per the Fresno Municipal Code. The inlets accept the water into the storm drainage pipelines which convey water to stormwater management basins. The pipeline system is designed with a peak flow capacity to accommodate a two-year intensity storm event (50 percent probability of occurring in any given year). The basin capacity utilizes the percentage of runoff from the two-year pipeline data, but with a volume from six inches of rainfall. All basins are designed with relief systems so that additional capacity can be created by dewatering between rainfall events. The District’s drainage services program includes topographic mapping; master plan engineering and facility design; system construction; and operation and maintenance. Any infill project that increases the amount of impervious surfacing, changes the existing drainage pattern(s), and/or generates storm flows faster or greater than the existing condition could result in the existing pipeline collection system being overburdened. Typically, infill projects are required to mitigate any increase in runoff by either increasing the capacity of the existing system (i.e., build more infrastructure) or holding storm runoff on site to ensure offsite runoff does not increase. As the owner and operator of the storm water drainage system, the District has primary responsibility for implementing the U.S. Clean Water Act requirements through a National Pollutant Discharge Elimination System discharge permit issued by the Regional Water Quality Control Board (RWQCB). This program is comprised of pollutant removal in the stormwater basins and education to avoid storm water pollution; best management practices for commercial, industrial and new development storm water quality control; monitoring to assess storm water impacts upon Chapter 9: Noise and Safety the quality of receiving water; and the preparation of ordinances for adoption by local governments to enforce storm water quality control measures. The District’s programs include water conservation efforts through its design and operation of storm water drainage facilities to detain and retain water from storm events as well as receive dry season surface water supplies for groundwater recharge. Approximately 90 basins are intertied with Fresno Irrigation District (FID) canals and receive surface water through contracts with the irrigation district and the cities of Fresno and Clovis. Storm water drainage basins serving primarily residential areas are also designed to accommodate passive and active recreational activities. Recreational use of 27 basins has been accommodated by improvements including baseball and playground areas, and two basins have been specifically designed to accommodate use by individuals with disabilities, while a third accommodates a high quality little league baseball facility. District flood control and drainage facilities also provide important open space in the urban area and areas for wildlife habitat. Through a memorandum of understanding, which serves as a Section 1601 Master Streambed Alteration Agreement with the California Department of Fish and Wildlife, restoration and protection of rural streams for flood control purposes also brings long-term net benefits for fish, wildlife, water quality, native plants, and stream habitats. To address the risks of damaging floods, the City of Fresno adopted and recently updated a Flood Plain Ordinance that meets the standards imposed by California Government Code Section 65302(g)(2). The Government Code specifies that cities should include either directly, or through adoption by reference to a flood plain ordinance (65302(g)(6)), flood hazards zones and maps on flooding in the area (65302(g)(2)(A)), goals to protect new development against flooding (65302(g)(2)(B)), and implementation measures to achieve the stated goals (65302(g)(2)(C)). The City of Fresno Flood Plain Ordinance incorporates by reference flood hazard zones established by the Federal Emergency Management Agency (FEMA), Federal Insurance Rate Maps completed for Fresno County, and other maps as are needed to review flood risk (FMC 11-607). The Flood Plain Ordinance protects against risk to new and existing development by requiring any building proposed within a special flood hazard area to obtain a building permit and provide information specifically related to flood risk (11-613). The permit is reviewed by the Building Official, who has been designated as the Flood Plain Administrator, to ensure that the project will be reasonably safe from flooding and will not adversely increase flood risk elsewhere (11-614, 11-616). The Ordinance also includes specific development and construction standards to minimize flood risk (11-623 to 11-636). This permit review process and the applicable standards help to implement the goals found within the Flood Plain Ordinance Statement of Purpose (11=603) and also serve to both implement and complement the Goals, Objectives, and Implementing Policies found within this General Plan. | OBJECTIVE | | | :--- | :--- | | **NS-3** | Minimize the risks to property, life, and the environment due to flooding and stormwater runoff hazards. | | IMPLEMENTING POLICIES | | | :--- | :--- | | **NS-3-a** | **Stormwater Drainage and Flood Control Master Plan.** Support the full implementation of the FMFCD Storm Drainage and Flood Control Master Plan, the completion of planned flood control and drainage system facilities, and the continued maintenance of stormwater and flood water retention and conveyance facilities and capacities. Work with the FMFCD to make sure that its Storm Drainage and Flood Control Master Plan is consistent with the General Plan. | | **NS-3-b** | **Curb and Gutter Installation.** Coordinate with Fresno Metropolitan Flood Control District (FMFCD) to install curbing, gutters, and other drainage facilities with priority to existing neighborhoods with the greatest deficiencies and consistent with the Storm Drainage and Flood Control Master Plan. | | **NS-3-c** | **Dual Use Facilities.** Support multiple uses of flood control and drainage facilities as follows: | | | • Use, wherever practical, FMFCD facilities for groundwater management and recharge; and | | | • Promote recreational development of ponding basin facilities located within or near residential areas, compatible with the stormwater and groundwater recharge functions. | NS-3-d **Landscaped Buffer.** City will support the development of FMFCD ponding basins including the landscaping and irrigation for the top one third of the side sloped areas consistent with the FMFCD Basin Design Criteria. NS-3-e **Pollutants.** Work with FMFCD to prevent and reduce the existence of urban stormwater pollutants pursuant to the requirements of the National Pollution Discharge Elimination Systems Act. NS-3-f **Flooding Emergency Response Plans.** Work with responsible agencies to update emergency dam failure inundation plans, evacuation plans and other emergency response plans for designated flood-prone areas, including the San Joaquin riverbottom. NS-3-g **Essential Facilities Siting Outside of Floodplains.** Avoid siting emergency response and essential public facilities, such as fire and police stations, within a 100-year floodplain, unless it can be demonstrated that the facility can be safely operated and accessed during flood events. NS-3-h **Runoff Controls.** Implement grading regulations and related development policies that protect area residents from flooding caused by urban runoff produced from events that exceed the capacity of the Storm Drainage and Flood Control Master Plan system of facilities. Place all structures and/or flood-proofing in a manner that does not cause floodwaters to be diverted onto adjacent property, increase flood hazards to other property, or otherwise adversely affect other property. NS-3-i **New Development Must Mitigate Impact.** Require new development to not significantly impact the existing storm drainage and flood control system by imposing conditions of approval as project mitigation, as authorized by law. As part of this process, closely coordinate and consult with the FMFCD to identify appropriate conditions that will result in mitigation acceptable and preferred by FMFCD for each project. **Commentary:** The City recognizes the expertise and significant role of the FMFCD, and will give the highest deference to its recommendations for mitigation measures, consistent with applicable law. **NS-3-j** **National Flood Insurance Program.** Continue to participate in the National Flood Insurance Program (NFIP) by ensuring compliance with applicable requirements. Review NFIP maps periodically to determine if areas subject to flooding have been added or removed and make adjustments to the Land Use Diagram Figure LU-1. **NS-3-k** **100-Year Floodplain Policy.** Require developers of residential subdivisions to preserve those portions of development sites as open space that may be subject to 100-year flood events, unless the flood hazard can be substantially mitigated by development project design. **NS-3-l** **200-Year Floodplain Protection.** Promote flood control measures that maintain natural conditions within the 200- year floodplain of rivers and streams and, to the extent possible, combine flood control, recreation, water quality, and open space functions. Discourage construction of permanent improvements that would be adversely affected by periodic floods within the 200-year floodplain, particularly in the San Joaquin riverbottom. **NS-3-m** **Flood Risk Public Awareness.** Continue public awareness programs to inform the general public and potentially affected property owners of flood hazards and potential dam failure inundation. Remind households and businesses located in flood-prone areas of opportunities to purchase flood insurance. **NS-3-n** **Precipitation Changes.** Work with FMFCD to evaluate the planned and existing stormwater conveyance system in light of possible changes to precipitation patterns in the future. ### 9.5 WILDLAND FIRE HAZARDS Fresno’s high summer temperatures, intense sunlight, and low rainfall could encourage wildland fires by drying and pre-heating combustible material and fostering spontaneous combustion of flammable material. Fresno’s estimated maximum wind speed is 70 mph, which could fan blazes to a high intensity. Fire hazards are typically highest in heavily wooded areas, as trees are a great source of fuel, as are grasslands. Given that the Planning Area is largely urbanized or working agricultural land and lacks steep topographies, wildfire threats are minimal. Although Fresno is proximate to high and very high fire hazard designated areas, the city is largely categorized as little or no threat or moderate fire hazard, which is largely attributed to paved areas. Small areas along the San Joaquin River Bluff area in northern Fresno are prone to wildfire due to relatively steep terrain and vegetation and therefore classified as high fire hazard. Policies related to fire protection and response are located in the Public Utilities and Services Element. ## 9.6 HAZARDOUS MATERIALS A material is considered hazardous if it appears on a list of hazardous materials prepared by a federal, State, or local agency, or if it has characteristics defined as hazardous by such an agency. The California Code of Regulation defines a hazardous material as a substance that, because of physical or chemical properties, quantity, concentration, or other characteristics, may either (1) cause an increase in mortality or an increase in serious, irreversible, or incapacitating illness, or (2) pose a substantial present or potential hazard to human health or environment when improperly treated, stored, transported or disposed of, or otherwise managed. Hazardous materials have been and are commonly used in commercial, agricultural, and industrial applications and, to a limited extent, in residential areas. Hazardous wastes are defined in the same manner. Hazardous wastes are hazardous materials that no longer have practical use, such as substances that have been discarded, discharged, spilled, contaminated, or are being stored prior to proper disposal. Hazardous materials and hazardous wastes are classified according to four properties: toxic (causes human health effects), ignitable (has the ability to burn), corrosive (causes severe burns or damage to materials), and reactive (causes explosions or generates toxic gases). Sites previously contaminated by hazardous materials are required to be identified and cleaned up. The contaminated sites in Fresno are largely associated with leaking underground storage tanks and are predominately clustered south of Downtown, near Fresno Yosemite International Airport and Palm Bluffs Corporate Center (northwest Fresno), and along the Union Pacific Railroad Tracks as shown on Figure PU-3: Regional Groundwater Contamination shows the locations of known leaking underground storage tanks and known hazardous waste sites requiring cleanup under federal or State direction. Releases, leaks, or disposal of chemical compounds, such as petroleum hydrocarbons, on or below the ground surface can lead to contamination of underlying soil and groundwater. Depending of the conditions and intensity of the release, groundwater contamination can migrate beyond the property boundary of the original release site. Disturbance of a previously contaminated area through grading or excavation operations could expose the public to health hazards from physical contact with contaminated materials or hazardous vapors. Improper handling or storage of contaminated soil and groundwater can further expose the public to these hazards, or potentially spread contamination through surface water runoff or air-borne dust. In addition, contaminated groundwater can spread down gradient, potentially contaminating subsurface areas of surrounding properties. This also poses a threat due to the high number of private water wells and the City’s reliance on groundwater as the principal potable water source. Groundwater quality is discussed in the Public Utilities and Services Element. OBJECTIVE NS-4 Minimize the risk of loss of life, injury, serious illness, and damage to property resulting from the use, transport, treatment, and disposal of hazardous materials and hazardous wastes. IMPLEMENTING POLICIES NS-4-a Processing and Storage. Require safe processing and storage of hazardous materials, consistent with the California Building Code and the Uniform Fire Code, as adopted by the City. NS-4-b Coordination. Maintain a close liaison with the Fresno County Environmental Health Department, Cal-EPA Division of Toxics, and the State Office of Emergency Services to assist in developing and maintaining hazardous material business plans, inventory statements, risk management prevention plans, and contingency/emergency response action plans. **NS-4-c** | **Soil and Groundwater Contamination Reports.** Require an investigation of potential soil or groundwater contamination whenever justified by past site uses. Require appropriate mitigation as a condition of project approval in the event soil or groundwater contamination is identified or could be encountered during site development. **NS-4-d** | **Site Identification.** Continue to aid federal, State, and County agencies in the identification and mapping of waste disposal sites (including abandoned waste sites), and to assist in the survey of the kinds, amounts, and locations of hazardous wastes. **NS-4-e** | **Compliance with County Program.** Require that the production, use, storage, disposal, and transport of hazardous materials conform to the standards and procedures established by the County Division of Environmental Health. Require compliance with the County’s Hazardous Waste Generator Program, including the submittal and implementation of a Hazardous Materials Business Plan, when applicable. **NS-4-f** | **Hazardous Materials Facilities.** Require facilities that handle hazardous materials or hazardous wastes to be designed, constructed, and operated in accordance with applicable hazardous materials and waste management laws and regulations. **NS-4-g** | **Hazmat Response.** Include policies and procedures appropriate to hazardous materials in the City’s disaster and emergency response preparedness and planning, coordinating with implementation of Fresno County’s Hazardous Materials Incident Response Plan. **NS-4-h** | **Household Collection.** Continue to support and assist with Fresno County’s special household hazardous waste collection activities, to reduce the amount of this material being improperly discarded. **NS-4-i** | **Public Information.** Continue to assist in providing information to the public on hazardous materials. ## 9.7 AIRPORT SAFETY There are two public airports in the Planning Area, Fresno-Yosemite International Airport (FYI) and Chandler Executive Airport (FCH), and one private airport open to public use, Sierra Sky Park. In conjunction with Fresno-Yosemite International Airport, the Air National Guard maintains an airbase for military flight and training operations. Each airport has its own airport land use plan designed to provide for public safety. The Fresno County Airport Land Use Commission (ALUC) provides guidance to local jurisdictions on adjacent land uses through Airport Land Use Compatibility Plans (ALUCPs). This General Plan and all other City land use plans must be compatible with the ALUCPs. Airports may impact public safety due to the potential for aircraft crashes. Policies in this section are designed to minimize public exposure to risks associated with airport operations and to minimize the siting of land uses near airports that might interfere with airport operations. As shown earlier in this chapter, Figures NS-4 through NS-6 show each airport’s safety zones, which are established to identify the land or water area surrounding the airport runways that could be impacted by an airport hazard. <
> Fresno Yosemite International Airport is one of two public airports in Fresno, and it has its own land use plan. Chapter 9: Noise and Safety OBJECTIVE NS-5 Protect the safety, health, and welfare of persons and property on the ground and in aircraft by minimizing exposure to airport-related hazards. IMPLEMENTING POLICIES NS-5-a Land Use and Height. Incorporate and enforce all applicable Airport Land Use Compatibility Plans (ALUCPs) through land use designations, zoning, and development standards to support the continued viability and flight operations of Fresno’s airports and to protect public safety, health, and general welfare. * Limit land uses in airport safety zones to those uses listed in the applicable ALUCPs as compatible uses, and regulate compatibility in terms of location, height, and noise. * Ensure that development, including public infrastructure projects, within the airport approach and departure zones complies with Part 77 of the Federal Aviation Administration Regulations (Objects Affecting Navigable Airspace), particularly in terms of height. NS-5-b Airport Safety Hazards. Ensure that new development, including public infrastructure projects, does not create safety hazards such as glare from direct or reflective sources, smoke, electrical interference, hazardous chemicals, fuel storage, or from wildlife, in violation of adopted safety standards. NS-5-c Avigation Easements. Employ avigation easements in order to secure and protect airspace required for unimpeded operation of publicly owned airports. Commentary: Avigation easements are established in the form of land use covenants and are binding upon present and subsequent property owners. NS-5-d Disclosure. As a condition of approval for residential development projects, require sellers to prepare and provide State Department of Real Estate Disclosure statements to property buyers notifying of noise and safety issues related to airport operations. **NS-5-e** **Planned Expansion.** Allow for the orderly expansion and improvement of publicly-owned airports, while minimizing adverse environmental impacts associated with these facilities. * Periodically update airport facility master plans in accordance with FAA regulations. * Require land use within the boundaries of the Fresno-Yosemite International Airport and Chandler Downtown Airport to conform to designations and policies specified in adopted City of Fresno compatible land use plans. * Provide local jurisdictions surrounding the City's publicly owned airports with specific guidelines for effectively dealing with the presence and operation of these airports. ## 9.8 EMERGENCY RESPONSE Police and fire protection services are addressed in the Public Utilities and Services Element. ### Emergency Planning The California Emergency Services Act requires cities to prepare and maintain an Emergency Plan for natural, manmade, or war-caused emergencies that result in conditions of disaster or in extreme peril to life. The City does have an adopted Emergency Operations Plan (EOP). The EOP does not designate evacuation routes, which may not be necessary since Fresno does not face any expected natural hazards from likely sources or locations. ### Local Hazard Mitigation Planning The purpose of a Local Hazard Mitigation Plan is to reduce or eliminate long term risk to human life and property resulting from hazards, by identifying risks before they occur and putting together resources, information, and strategies for emergency response. Fresno County is the lead agency on the Multi-Jurisdictional Local Hazard Mitigation Plan (MHMP) for the county. The Fresno County Board of Supervisors has adopted the Fresno County MHMP. It includes a City of Fresno annex which lists information most relevant to Fresno in the areas of health, infrastructure, housing, government, environment, and land use. The MHMP meets the requirements of the Disaster Mitigation Act of 2000 (DMA). A federally-approved hazard mitigation plan enables Fresno County to apply for federal pre-disaster hazard mitigation grant funds to support mitigation projects. The DMA establishes a national hazard mitigation program to reduce the loss of life and property, human suffering, economic disruption and disaster assistance costs resulting from natural disasters. The DMA also provides a source of pre-disaster hazard mitigation funding to assist local governments in implementing effective hazard mitigation measures to ensure the continued functionality of critical services and facilities after a natural disaster. | OBJECTIVE | | | :--- | :--- | | **NS-6** | Foster an efficient and coordinated response to emergencies and natural disasters. | | IMPLEMENTING POLICIES | | | :--- | :--- | | **NS-6-a** | **County Multi-Jurisdiction Hazard Mitigation Plan.** Adopt and implement the Fresno County Multi-Jurisdiction Hazard Mitigation Plan and City of Fresno Local Hazard Mitigation Plan Annex. | | | *Commentary: The federal Disaster Mitigation Act of 2000 requires that cities, counties, and special districts have a Local Hazard Mitigation Plan to be eligible to receive FEMA hazard mitigation funds. Cities and counties can adopt and use all or part of a regional multi-jurisdictional plan, such as the one prepared by Fresno County, in lieu of preparing all or part of a Local Hazard Mitigation Plan.* | | **NS-6-b** | **Disaster Response Coordination.** Maintain coordination with other local, State, and Federal agencies to provide coordinated disaster response. | | **NS-6-c** | **Emergency Operations Plan.** Update the City’s Emergency Operations Plan periodically, using a whole community approach which integrates considerations for | People with access and functional needs in all aspects of planning. **NS-6-d** | **Evacuation Planning.** Maintain an emergency evacuation plan in consultation with the Police and Fire Departments and other emergency service providers, which shows potential evacuation routes and a list of emergency shelters to be used in case of catastrophic emergencies. : | : | *Commentary: The evacuation plan will be flexible in order to consider many scenarios and multiple modes of transportation beyond private automobiles. It will provide special provisions for disadvantaged populations, such as those with physical disabilities or those with low or very low incomes, and for areas with fewer resources through neighborhood emergency preparedness programs.* **NS-6-e** | **Critical Use Facilities.** Ensure critical use facilities (e.g. City Hall, police and fire stations, schools, hospitals, public assembly facilities, transportation services) and other structures that are important to protecting health and safety in the community remain operational during an emergency. : | : | • Site and design these facilities to minimize their exposure and susceptibility to flooding, seismic and geological effects, fire, and explosions. | • Work with the owners and operators of critical use facilities to ensure they can provide alternate sources of electricity, water, and sewerage in the event that regular utilities are interrupted in a disaster. **NS-6-f** | **Emergency Vehicle Access.** Require adequate access for emergency vehicles in all new development, including adequate widths, turning radii, hard standing areas, and vertical clearance. **NS-6-g** | **Emergency Preparedness Public Awareness Programs.** Continue to conduct programs to inform the general public, including people with access and functional needs, of the City’s emergency preparedness and disaster response procedures.