Riverbank council authorizes submission of draft 6‑cycle Housing Element to state for compliance review

City Council of Riverbank voted unanimously on Nov. 12 to authorize staff to submit the city’s draft six‑cycle Housing Element to the California Department of Housing and Community Development (HCD) for a 90‑day compliance review.

The resolution approved (Item 11.1) directs staff to send the draft document to HCD and continue to accept public comments as the city works through HCD’s review and any subsequent redline revisions. David Niskinen of JB Anderson Land Use Planning presented the draft and said the housing element covers the planning period from June 30, 2023, through Dec. 31, 2031, and is required under state law. “The draft housing element that’s before you tonight has been available for public review from Oct. 15, 2024,” Niskinen said, adding staff plans to transmit the document to HCD on Dec. 2, 2024, for a 90‑day compliance review expected to conclude about March 2, 2025.

Niskinen described the city’s Regional Housing Needs Allocation (RHNA) for the eight‑year cycle and the candidate site inventory used to demonstrate capacity. He told council members the RHNA number the presentation cited for the city over the planning period is 3,591 units and that staff identified a variety of potential sources to meet that obligation, including vacant and underutilized land, accessory dwelling units and pipeline projects.

Public commenters at the council meeting urged closer scrutiny of site lists and of whether certain specific plans remain suitable. Evelyn, a downtown resident, said the draft still relies on older environmental review and warned that shrinking the downtown planning area while retaining the same housing target “doesn’t make any sense,” citing infrastructure and service shortfalls. Matt Beekman of the Farmland Working Group said his group’s review found some candidate sites were omitted from the inventory and recommended using additional downtown parcels and infill tools to achieve compliance. The clerk read a written submission from the law firm Solorrie Mazur on behalf of residents that argued the Riverwalk specific plan carries environmental, infrastructure and Williamson Act constraints and requested removal of the Riverwalk plan from the housing element prior to submission to HCD.

Niskinen responded to these concerns by saying HCD’s review process is the mechanism for determining compliance and that the draft will be updated in redline to reflect comments and any required changes. He noted that development since the downtown specific plan’s adoption has changed available unit counts in some areas and that candidate sites included in the housing element are intended to bring the city into compliance pending HCD’s formal comments.

Council members discussed options such as investigating an inclusionary housing program and adjusting development fees to support infill. One council member urged caution about realistic lot sizes for developers and highlighted state rules on site qualification (e.g., adequate size and water/sewer connections). After discussion, a council member moved to adopt the resolution authorizing submission; a second was made and the motion passed 4–0 (Council Member Hernandez: yes; Council Member Barbara Martinez: yes; Vice Mayor Uribe: yes; Mayor O’Brien: yes).

Next steps outlined on the record: the city will accept public comments through Nov. 14, 2024 (public review period noted during the presentation), incorporate comments for the Dec. 2 transmittal to HCD, and then address any HCD comment letter during the 90‑day review before returning to the planning commission and council with revised drafts and public hearings for formal adoption.