Ignacio “nash” Gonzalez, Interim Director County of Mendocino Julia Krog, Assistant Director

The areas around cities have the best developed sewer and water systems for new housing in Mendocino County. Rural areas of the County do not have adequate public infrastructure and amenities to meet HCD projections. Agree. In general, a larger minimum lot size (40,000 square feet) is required outside public water and sewer district boundaries and for lots not served by public water and the sewer district. For lots where either water or sewer service is available, the minimum lot size is generally 12,000 square feet, with a 6,000 square-foot minimum when both services are available and used. Multi-family housing is not permissible in areas that lack public or state regulated water and sewer systems, which often creates a constraint for meeting HCD projections particularly for very-low and low income levels.

Due to COVID-19 restrictions, PBS has developed more efficient digital options for routine matters which has created a more streamlined process to free PBS to pursue new opportunities for solving departmental issues and verifying State regulations and statistics. Partially Agree. Due to COVID-19, PBS has created more digital pathways for submittal of building permits and some discretionary permits. COVID-19 stay at home orders coupled with the allowance for cannabis cultivation under County Code Chapter 10A.17 have resulted in an unprecedented number of building permits. Between 2017 and today, the number of building permits has more than doubled; however, the staffing levels at PBS have largely remained the same or been reduced due to COVID-19. This year, as part of the Budget process, PBS was approved to add additional positions and PBS has been filling vacancies in an effort to streamline more permitting processes. In addition, PBS is embarking on an update to the Inland Zoning Code (Division I of Title 20 of Mendocino County Code), which will improve the readability and usability of the Inland Zoning Code. It is hoped this effort to update the Inland Zoning Code will also allow for inclusion of updated State regulations.

MCOG is designated by the State of California Department of Housing and Community Development to coordinate the housing need allocation process for Mendocino County. By default, this has become the regional planning agency. Agree. MCOG does not typically deal with housing issues; however, they have been designated by the State of California Department of Housing and Community Development as the appropriate regional agency to coordinate the housing need allocation process. The political jurisdictions that comprise the region consist of the Mendocino County unincorporated area and the Cities of Ukiah, Fort Bragg, Willits and Point Arena.

Lack of housing forces the price of existing housing to be unaffordable for working families as well as preventing new potential employees to choose to work in Mendocino County. Agree. When hiring new employees, our office has found that housing availability is one of the primary constraints to bringing on new employees. Often employees live in hotels or short-term rentals during their first weeks or months working for PBS before they are able to secure housing. Our office has found, as noted in Chapter/Section 5.3 of the 2019-2027 Housing Element, that many factors can constrain residential development—market constraints, such as development costs and interest rates, and governmental constraints, which include land use controls, fees, processing times, and development standards. Environmental and infrastructure issues also impede residential development. It should be noted that many of the regulatory controls originate at the state level (Building Code, Health and Safety, and the California Environmental Quality Act). The County of Mendocino has no control over these regulatory constraints.

The Median income of county residents and the higher cost of goods and services does not keep pace with the cost of new single-family homes, which discourages contractors from building here when they can profit from building in other areas. Partially Agree. As noted above, many factors can constrain residential development. Development costs include both the price of land as well as the cost of construction. A number of factors affect the price of land, such as parcel size, necessary improvements, and supply. Land prices vary greatly throughout the County. In general, residential-zoned lots are much more expensive along the coast than in inland areas, and the price of land is typically higher in the central and south than in the far north. The availability of infrastructure is another major factor affecting the price of land in the County. Lots with water and sewer service are usually more expensive. Construction costs exhibit a high degree of variability depending on the type of amenities included. Custom homes are generally more expensive than tract home development.

The current shortage of affordable housing will continue without Mendocino County hiring qualified housing and community development planners. Such assets would assist in locating funding sources for infrastructure improvements, attracting appropriate developers, and informing the BOS what effect proposed regulations may have on the development of new housing. Partially Agree. It is unclear what is meant by “qualified housing and community development planners”. PBS would need clarity as to what these qualifications would include. One of the only available certifications for planners is the American Institute of Certified Planners (AICP), which provides the only nationwide, independent verification of planners' qualifications. AICP certified planners pledge to uphold high standards of practice, ethics, and professional conduct, and to keep their skills sharp and up to date by continuously pursuing advanced professional education. We agree that our role or that of a housing related planner is to inform the Board of Supervisors on what effect proposed regulations may have on the development of new housing, within the scope of those that affect Planning regulations. Our office is presently hiring an individual to handle housing compliance particularly compliance with Housing Element action items and annual reporting requirements. Locating funding sources for infrastructure improvements and attracting appropriate developers would be most appropriately handled by an Economic Development Coordinator but is not a role typically held by the Planning Division. Presently our office handles Community Development Block Grants but this is the only funding source that PBS assists with that relates to development of housing and/or supportive infrastructure. The Planning Division processes entitlements and it would be inappropriate for staff to locate funding, attract developers and then process the entitlements for those same projects. It would be a conflict of interest for the Planning Division to undertake such activities. It should be noted that Finding F6 is somewhat misleading, as it is creating the assumption that the Planning Division would or should take on the role of a developer. Additionally, in 2011, the State of California did away with “redevelopment” which was a tool that many cities and counties utilized in partnership with developers to provide affordable housing as well as infrastructure improvements. This has resulted in further constraints at the local level.

There is no formal or consistent communication between PBS and its counterparts in the cities of Fort Bragg, Point Arena, Ukiah and Willits which is indicative of the lack of planning on a regional basis in this County. Agree. PBS will initiate holding quarterly meetings between the County staff and counterparts in the cities of Fort Bragg, Point Arena, Ukiah and Willits. This would be initiated in January 2022 with meetings held quarterly thereafter.

The prohibitive cost of new construction and limited income of most area residents makes new market-rate projects risky for builders. Partially Agree. PBS cannot opine on this as it is speculative as to what types of projects may be considered “risky for builders” and PBS does not construct housing. It should also be noted that this is strictly driven by market forces outside of the control of PBS.

The activation of a Mendocino County Building Trust Fund (In-Lieu fund) would give Mendocino County leverage in encouraging proactive development to meet the county’s needs for infrastructure and housing projects. Agree. PBS is embarking on an update to the Inland Zoning Code and part of the scope of that project is to review and restructure the County’s Inclusionary Housing Ordinance (Chapter 20.238 of County Code). Presently there is limited funding in the Building Trust Fund (In-Lieu fund), partially related to limited subdivisions and projects that require payment into the fund.

Federal and State funding is targeted to urban areas and the BOS does not direct PBS to actively seek mitigations on these restrictions to acquire funding for housing projects when State & Federal funds become available. Partially Agree. PBS agrees that Federal and State funding does typically benefit urban areas over rural areas, as this is driven by population, but PBS does not pursue changes to legislation and funding sources. This would be addressed by direction given from the Board of Supervisors on the legislative platform and working with CSAC and RCRC representatives.

As a result of restrictions on the use of local budget monies, Mendocino County’s Native American Tribes may only be invited to the table when discretionary funds for housing are available through Federal sources. Disagree. Planning and Building Services does not administer discretionary funds for housing. Finding F11 is also misleading as it appears that the authors may not completely understand that local jurisdictions do not typically administer funds on behalf of the Bureau of Indian Affairs or the Federal Government. Response to Recommendations: