Planning Commission forwards 2023–2031 housing element to council after state pre‑clearance

The City of Tracy Planning Commission recommended that City Council adopt the 2023–2031 Housing Element — the state‑required component of the General Plan that identifies existing housing needs, available sites, and programs to meet the city’s Regional Housing Needs Allocation (RHNA).

Staff and consultant teams described the sixth‑cycle housing element as unusually complex due to a large RHNA allocation and multiple recent state law changes requiring jurisdictions not only to identify sites but to demonstrate those sites’ feasibility. The city’s allocation for the 2023–2031 cycle was cited as 8,800 units (San Joaquin County distribution shown in staff slides), producing a major rezoning and implementation program of roughly 200 acres requiring higher density to meet low and very‑low income requirements.

Consultant Veronica Tam (Tam & Associates) and Michael Baker International staff described the legal and programmatic changes since the last cycle, notably expanded site adequacy rules and requirements to demonstrate that rezoned sites are feasible for redevelopment and can accommodate units over the eight‑year planning period. Staff emphasized that the housing element includes implementation measures requiring future rezones, adoption of updated elements (circulation, safety, land use, environmental justice) and other actions to meet the state’s certification standards.

Commissioners asked how the implementation process will be sequenced and how the city will track and complete rezones and program actions. Staff answered that the city must adopt the housing element and then implement rezones (roughly 200 acres mapped in the draft) and related general plan amendments; staff indicated the rezonings and environmental review (EIR) for implementation measures will proceed with public hearings this summer and later in the approval process. The consultant and city staff explained that while the draft housing element does not itself change parcel zoning it does require subsequent mapped rezones; the state will certify the adopted housing element if it meets HCD requirements and staff indicated HCD had provided pre‑certification guidance.

During public comment, the Building Industry Association registered opposition unless the city resolves an unrelated CFD processing issue for a separate Ellis project (BIA asked the city to either process the CFD, remove the CFD requirement, delay adoption until resolved, or exclude the Ellis units from the RHNA count). Staff acknowledged the BIA’s letter and asked for resolution through administrative channels. Several public speakers urged adoption to unlock development and job opportunities; others raised concern about feasibility of meeting RHNA goals and the city’s capacity to implement the required rezones.

The Planning Commission voted to recommend City Council: (1) determine the housing element exempt from CEQA under the common‑sense exemption (CEQA Guidelines §15061(b)(3)); (2) direct the city manager to file a Notice of Exemption with the County Recorder; (3) adopt the 2023–2031 Housing Element; and (4) direct staff to submit the adopted element to HCD for certification. The roll‑call vote was unanimous in favor.

Why it matters: The housing element sets city policy and creates legally binding obligations to zone for sufficient capacity to meet RHNA. Staff noted the implementation work will include rezoning about 200 acres to accommodate higher densities, updates to other General Plan elements, and continued negotiation with HCD. While there is no immediate penalty for not meeting construction targets, staff and the city attorney explained that once the element is certified by HCD projects that meet the new zoning and affordability standards will be difficult to deny under state law.

What’s next: If City Council adopts the element, staff will proceed with rezoning and the required implementation measures (public hearings, draft EIR for the rezones and amendments). Staff recommended returning to commissioners and council with rezoning packages and environmental review later this year.