Half Moon Bay planning panel recommends submitting draft Cycle 6 housing element to state despite Measure D guidance pending

The Half Moon Bay Planning Commission voted 4-0 on Feb. 11 to recommend that the City Council submit the city’s fourth draft of the 2023–2031 housing element (Cycle 6) to the California Department of Housing and Community Development (HCD) without waiting for pending guidance about the city’s residential dwelling unit allocation system (Measure D).

The housing element is one of seven general plan elements that California requires cities to maintain; it establishes goals, policies and “measurable, deliverable” actions for meeting regional housing needs, the city’s housing programs manager, Mike Noce, told the commission. Noce said HCD enforces certification and that the department “has ramped up” scrutiny in Cycle 6, prompting multiple rounds of review.

Why it matters: A certified housing element can be a precondition for certain state grants and infrastructure funding and is tied to other enforcement tools the state may use for noncompliance, commissioners and consultants said. HCD’s recent comments for Half Moon Bay focused largely on required program language and monitoring steps rather than removing or changing the city’s identified housing sites, Noce said.

Key details and debate - RHNA totals: Noce and staff described the city’s Regional Housing Needs Allocation (RHNA) for Cycle 6 as 480 units; about 285 of those are targeted to very low- and low-income households and the remainder to moderate and above-moderate income bands. - HCD review and letters: Noce said the city is on its fourth draft, a normal number of reviews, and that the most recent HCD letter received Nov. 5 raised several items the state expects the city to address. Staff told the commission they had not yet received a third, Measure D–specific HCD letter referenced in prior correspondence. - Measure D and Coastal Commission tension: Staff and the commission discussed a cross-jurisdictional complication: HCD has requested the city consider alternatives related to Measure D, and SB 1077 now requires coordination between HCD and the California Coastal Commission. Asher Cohn, the city’s consultant from M Group, said the situation is “a unique situation” and that the city does not yet have a definitive explanation of how HCD/Coastal Commission guidance will resolve the tension for coastal jurisdictions. - CEQA and the MND: Staff and M Group said the city has prepared a draft mitigated negative declaration (MND) under the California Environmental Quality Act and recommended releasing that draft for a minimum 30-day public comment period; staff said they had delayed release while awaiting HCD feedback but that HCD’s most recent letter did not require site removals, so the MND could now be released. - Specific program questions: Commissioners asked about program-level items HCD flagged, including a requirement to allow permanent supportive housing in all zones, garage-parking requirements for multifamily projects, geographic targeting for home-sharing programs (staff proposed targeting north of Highway 92), and whether 555 Kelly — a planned senior housing project — qualifies as a multi-generational development for HCD’s purposes. Noce and Asher said 555 Kelly is primarily senior housing with mostly studio and one-bedroom units and would not meet HCD’s multi-generation bedroom-count thresholds for that specific request. - Sites and alternatives: Commissioners raised whether sites the city has listed as opportunity sites (including 300 Church Street and other privately owned properties) should be retained if owners object. Staff reiterated that state law requires a thorough sites inventory and that identified developments that arise during the cycle count toward RHNA even if they were not originally listed as opportunity sites.

Commission action and vote The commission approved a resolution recommending City Council direct staff to submit the fourth HCD draft of the housing element for state review “independent of the pending guidance regarding the city’s residential dwelling unit allocation system.” The roll-call vote recorded Commissioners Grama, Redick, Gorn and Gossett as voting yes; the motion passed unanimously. The motion text and supporting materials are in the staff report packet attached to this meeting record.

What the city said next Noce said public comment on the draft remains open and that the draft housing element and background materials are posted at hmbcity.com/housingelement; written public comment can be submitted to housingelement@hmbcity.com. Staff said they expect City Council review in March and that, following council action, the city would submit the draft to HCD for the required 60-day review period.

Context and next steps Staff and the consultant recommended moving forward on revisions that do not involve Measure D while holding back several specific Measure D–related items pending the forthcoming HCD/Coastal Commission guidance. Commissioners generally supported forwarding the draft to city council to avoid further delay and potential state enforcement consequences, while also asking staff to continue outreach and to clarify program language where HCD requested more specificity.

Ending The commission’s recommendation sends the draft housing element and supporting environmental document toward council review; the record shows staff intend to release the draft MND for public comment and to continue coordinating with HCD and the Coastal Commission as further guidance arrives.