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HomeMy WebLinkAboutAgenda Statement 1985/08/06 Item 13a C COUNCIL AGENDA STATEMENT Item 31 134.' 3 Meeting Date 7/t6/85 ITEM TITLE: Resolution Approving density bonus for housing project providing Low and Moderate-Income Housing by Starboard Investment Company and approving a Housing Cooperation Agreement SUBMITTED BY: Community Development Direct Director of Planning -' �ld REVIEWED BY: City Manager (4/5ths Vote: Yes No x ) Under density bonus provisions of the State Government Code, a developer had requested City approval of a 53-unit family apartment project at 54-66 Fourth Avenue. The request included a density bonus of 9 units over the allowed density for the property. In exchange for the density bonus, the applicant offered to provide 20% of the project units as affordable to low and moderate-income households for 20 years and to enter into a Housing Cooperation Agreement regarding those units. Since its request, the applicant has withdrawn from escrow as a result of concern for the financial feasibility of the project. Starboard Investment Company, the property owner, is now pursuing the same project and density bonus request, although they request a reduced term of affordability commitment. RECOMMENDATION: That the Council adopt the resolution approving the density bonus for the Starboard Investment Company project at 54-66 Fourth Avenue and approving the Housing Cooperation Agreement, which includes a 20-year commitment of affordable units. BOARDS/COMMISSIONS RECOMMENDATION: On May 23, 1985, the Design Review Committee recommended approval of the project subject to the conditions attached in Exhibit A. DISCUSSION: Project Description The site consists of three existing lots fronting on Fourth Avenue (54-66) with a total area of 1 .43 acres. Each lot presently contains a single family dwelling which will be removed to provide the construction of 53 apartments. The units will be located in two separate buildings, three stories high. 92 off-street parking spaces will be provided in accordance with Ordinance standards. The building design features a stucco exterior and a red tile roof. The project was approved by the Design Review Committee on May 16 subject to modifications of the roof design. • C 72-3) by the City Council of by the City C a:il of Chula Vista, California Chula Vista, Ca'.iforni1 / — Dated — Dated 7` -! S -_, i Page 2, Item -3t (3"-- Meeting Date City' s Options Government Code Section 65915 requires a jurisdiction to grant a density bonus or other incentive of equivalent financial value to a requesting developer who agrees to provide a percentage of the project units for low and moderate-income housing. The City is not required to waive any of its development standards; therefore, lot coverage, setback, and parking requirements protect the City from clearly inappropriate development of specific sites. The City does have the alternative of granting incentives of equivalent financial value to the developer in lieu of the requested density bonus. However, State law is not specific regarding the calculation of such incentives, and their calculation could be subject to considerable analysis and dispute. The use of an equivalency is not recommended in light of the positive perception of this particular project, provided that the developer agrees to deliver the degree and duration of housing affordability desired by the City and recommended below. Developer Requirement To satisfy the State Law requirement for the density bonus, the developer must provide one of the following: 1 . Ten percent of the pre-density bonus units for occupancy by lower income households (below 80% of median income). 2. Twenty-five percent of the pre-density bonus units for an undetermined mix of occupancy by moderate and low-income households (below 120% of median income). The first exaction represents some housing benefit to low-income households. Using the State calculation for affordability, that households not pay more than 25% of monthly income for rent (the federal standard being 30%), the set aside units would rent somewhat below the market rent and would be occupied by low-income households. However, ten percent affordability is not that significant compared to 100%-affordability in Senior Housing Development Policy projects and 20%-affordability in tax-exempt mortgage revenue bond financed projects. The second exaction represents no appreciable housing benefit. The developer could choose to rent all 25% affordable units to moderate-income households at market rent, the moderate-income rent ceiling based on affordability being much higher than prevailing market rents. This condition results from the failure of the law to stipulate any particular mix of moderate, low, and very low income households within that 20% requirement. The State Law does not speak to the issue of term of affordability. Page 3, Item -3-t 13a-- Meeting Date Recommended Commitment and Developer Request Negotiations with the original applicant regarding delivery of low-income housing benefit in response to the incentive of a density bonus led to the agreement on the following set-aside conditions for the project: 1. Twenty percent, or 9, of the pre-density bonus units would be affordable to low-income households. Those units would be occupied only by low-income households and rents would not exceed 25% of the monthly income of a household at 80% of median income. 2. The set-aside units would be reserved for rental occupancy for a minimum term of 20 years. Subsequently, the original applicant withdrew over concerns about overall project feasibility. The current property owner/applicant, Starboard Investment Company, wishes to continue with the project proposal and density bonus request. However, they request that the reservation of affordable units be for a period of 10 years, rather than 20 years. Given the significance of the land use exception requested by the developer, the recommendation remains the same as above, with 20 years being the period of reservation. The attached Housing Cooperation Agreement reflects that recommendation. If this recommendation remains unacceptable to the applicant, it would be recommended that the Council refer the applicant' s request to the Redevelopment Agency's Housing Consultant, Daniel Grady, for an evaluation of appropriate incentives of equivalent financial value which could be offered to the developer in lieu of a density bonus. The Housing Cooperation Agreement, which would be recorded and run with the land, is substantially similar inform to that recently executed in connection with the Terra Nova Villas Apartment Project. Prior Requests The City has received only one prior request for a density bonus under the State law. That request was from Morgan-Gardner Subdivision for the Eucalyptus Apartments project. In addition to the State law density bonus, the project also entailed a general plan amendment and a rezoning, as well as tax-exempt mortgage revenue bond financing. Conditions exceeding the State law set-aside requirements were negotiated with the developer which satisfied both the State law and the Treasury and local requirements regarding tax-exempt financing. Because of those two assistance programs, the conditions imposed do not necessarily provide a model to be applied to projects such as the subject project. I ., Page 4, Item *21= 130- Meeti ng Date-479-M'' FISCAL IMPACT: The proposed action has no significant fiscal impact aside from the generation of property tax revenue. If the Council chose to provide an "incentive of equivalent financial value," expenditures would result from waivers of fees or possible direct financial contribution to the project. No specific calculation of financial equivalence has been made, although the original applicant estimated it to be in excess of $100,000. DKG:as WPC 1163X El 772 11 I ' r tt P. c 11 COUNCIL AGENDA STATEMENT / +, Item Meeting Date 7/16/85 ITEM TITLE: Resolution Approving density bonus for housing project providing Low and Moderate-Income Housing by Starboard Investment Company and approving a Housing Cooperation Agreement SUBMITTED BY: Community Development Direct Director of Planning. REVIEWED BY: City Manager (4/5ths Vote: Yes No x ) Under density bonus provisions of the State Government Code, a developer had requested City approval of a 53-unit family apartment project at 54-66 Fourth Avenue. The request included a density bonus of 9 units over the allowed density for the property. In exchange for the density bonus, the applicant offered to provide 20% of the project units as affordable to low and moderate-income households for 20 years and to enter into a Housing Cooperation Agreement regarding those units. Since its request, the applicant has withdrawn from escrow as a result of concern for the financial feasibility of the project. Starboard Investment Company, the property owner, is now pursuing the same project and density bonus request, although they request a reduced term of affordability commitment. RECOMMENDATION: That the Council adopt the resolution approving the density bonus for the Starboard Investment Company project at 54-66 Fourth Avenue and approving the Housing Cooperation Agreement, which includes a 20-year commitment of affordable units. BOARDS/COMMISSIONS RECOMMENDATION: On May 23, 1985, the Design Review Committee recommended approval of the project subject to the conditions attached in Exhibit A. - DISCUSSION: Project Description The site consists of three existing lots fronting on Fourth Avenue (54-66) with a total area of 1 .43 acres. Each lot presently contains a single family dwelling which will be removed to provide the construction of 53 apartments. The units will be located in two separate buildings, three stories high. 92 off-street parking spaces will be provided in accordance with Ordinance standards. The building design features a stucco exterior and a red tile roof. The project was approved by the Design Review Committee on May 16 subject to modifications of the roof design. Page 2, Item Meeting Date 7/16/85 City's Options Government Code Section 65915 requires a jurisdiction to grant a density bonus or other incentive of equivalent financial value to a requesting developer who agrees to provide a percentage of the project units for low and moderate-income housing. The City is not required to waive any of its development standards; therefore, lot coverage, setback, and parking requirements protect the City from clearly inappropriate development of specific sites. The City does have the alternative of granting incentives of equivalent financial value to the developer in lieu of the requested density bonus. However, State law is not specific regarding the calculation of such incentives, and their calculation could be subject to considerable analysis and dispute. The use of an equivalency is not recommended in light of the positive perception of this particular project, provided that the developer agrees to deliver the degree and duration of housing affordability desired by the City and recommended below. Developer Requirement To satisfy the State Law requirement for the density bonus, the developer must provide one of the following: 1. Ten percent of the pre-density bonus units for occupancy by lower income households (below 80% of median income). 2. Twenty-five percent of the pre-density bonus units for an undetermined mix of occupancy by moderate and low-income households (below 120% of median income). The first exaction represents some housing benefit to low-income households. Using the State calculation for affordability, that households not pay more than 25% of monthly income for rent (the federal standard being 30%), . the set aside units would rent somewhat below the market rent and would be occupied by low-income households. However, ten percent affordability is not that significant compared to 100%-affordability in Senior Housing Development Policy projects and 20%-affordability in tax-exempt mortgage revenue bond financed projects. The second exaction represents no appreciable housing benefit. The developer could choose to rent all 25% affordable units to moderate-income households at market rent, the moderate-income rent ceiling based on affordability being much higher than prevailing market rents. This condition results from the failure of the law to stipulate any particular mix of moderate, low, and very low income households within that 20% requirement. The State Law does not speak to the issue of term of affordability. Page 3, Item Meeting Date 7/16/85 Recommended Commitment and Developer Request Negotiations with the original applicant regarding delivery of low-income housing benefit in response to the incentive of a density bonus led to the agreement on the following set-aside conditions for the project: 1. Twenty percent, or 9, of the pre-density bonus units would be affordable to low-income households. Those units would be occupied only by low-income households and rents would not exceed 25% of the monthly income of a household at 80% of median income. 2. The set-aside units would be reserved for rental occupancy for a minimum term of 20 years. Subsequently, the original applicant withdrew over concerns about overall project feasibility. The current property owner/applicant, Starboard Investment Company, wishes to continue with the project proposal and density bonus request. However, they request that the reservation of affordable units be for a period of 10 years,. rather than 20 years. Given the significance of the land use exception requested by the developer, the recommendation remains the same as above, with 20 years being the period of reservation. The attached Housing Cooperation Agreement reflects that recommendation. If this recommendation remains unacceptable to the applicant, it would be recommended that the Council refer the applicant's request to the Redevelopment Agency's Housing Consultant, Daniel Grady, for an evaluation of appropriate incentives of equivalent financial value which could be offered to the developer in lieu of a density bonus. The Housing Cooperation Agreement, which would be recorded and run with the land, is substantially similar inform to that recently executed in connection with the Terra Nova Villas Apartment Project. Prior Requests The City has received only one prior request for a density bonus under the State law. That request was from Morgan-Gardner Subdivision for the Eucalyptus Apartments project. In addition to the State law density bonus, the project also entailed a general plan amendment and a rezoning, as well as tax-exempt mortgage revenue bond financing. Conditions exceeding the State law set-aside requirements were negotiated with the developer which satisfied both the State law and the Treasury and local requirements regarding tax-exempt financing. Because of those two assistance programs, the conditions imposed do not necessarily provide a model to be applied to projects such as the subject project. Page 4, Item Meeting Date 7/16/85 FISCAL IMPACT: The proposed action has no significant fiscal impact aside from the generation of property tax revenue. If the Council chose to provide an "incentive of equivalent financial value," expenditures would result from waivers of fees or possible direct financial contribution to the project. No specific calculation of financial equivalence has been made, although the original applicant estimated it to be in excess of $100,000. DKG:as WPC 1163X (7 ( EXHIBIT "A" CONDITIONS OF APPROVAL s • a. The design shall be approved as conditions for 53 units with 92 parking spaces. The design for 53 units is subject to the applicant receiving approval and an agreement with Chula Vista City Council authorizing a bonus density of eight units as provided in State law to accommodate low and moderate-income families. b. Additional landscaping shall be provided within the west and south parking areas. The loss of two parking spaces will likely result, in addition to the loss of at least one unit. c. The sidewalk adjacent to the central parking lot area shall be widened • to seven feet and the proposed 22 foot wide landscape strip deleted. d. Front yard slope areas shall be smooth and rounded subject to approval of the City's Landscape Architect. One and one-half-to-one slope adjacent to City sidewalk is unacceptable. Combination of retaining walls and protective wrought iron railing will be required as part of approved site plan. e. The rear fence shall be constructed of chain link, painted or treated green. f. The south and side yard fence shall be extended up to the 30 ft. front setback. g. Direct pedestrian access shall be provided from Fourth Avenue to the central parking lot. The open space provided for unit "E" shall be shifted to the west side of the building and the floor plan changed appropriately. h. An acoustical analysts shall be prepared that shows compliance with State of California minimum interior noise levels in addition to a maximum noise level of 65 decibels within all required private open space areas. This analysis shall be submitted in conjunction with building permits. i . All retaining walls shall be treated with stucco to match exterior building walls. j . The trash enclosure shall be deepened to provide enough space for two trash dumpsters. ( k. The applicant shall pursue adjacent slope rights in order to reduce the need for additional retaining walls. 1 . A minimum of 4x4 wood posts shall be utilized as support members for proposed stairways. m. Support posts located within the front or sideyard setbacks shall be relocated behind the setbacks or removed. n. Except for the north-facing units , all ground floor private patios shall be provided. o. The :roof design shall be modified to create a more prominent roof line. The redesign shall be returned for Design Review Committee approval. • -2- The City of Chula Vista Li(H Office of the City Attorney (619) 691-5037 DATE: August 2 , 1985 TO: The Honorable Mayor and City Council John Goss, City Manager Paul Desrochers, Community Development Director 6jrFROM: Charles R. Gill , Assistant City Attorney SUBJECT: Density Bonuses and Other Incentives On July 16, 1985, the City Council considered a request from Starboard Investment Company for a 53 unit family apartment project involving a density bonus based upon the developer ' s promise to construct affordable apartment units . The City Council requested that staff respond to several questions raised by the Council relating to the application of density bonuses for affordable housing. Specifically, you requested that the City Attorney' s office provide an analysis of Chapter 4 .3 ( commencing with Section 65915*) of Division 1 of Title 7 of the Government Code. Said Chapter establishes a statewide requirement that local agencies must follow. Section 65915 provides in relevant part: " ( a) When a developer of housing agrees to construct at least ( 1) twenty five percent of the total units of a housing development for persons and families of low or moderate income, . . .or ( 2 ) ten percent of the total units of a housing development for lower-income households, . . . (3 ) fifty percent of the total dwelling units of a housing development for qualifying residents. . .a city. . . shall either ( 1) grant a density bonus or (2 ) provide other incentives of equivalent financial value. * hereinafter all section references are to the Government Code unless otherwise specified. 276 Fourth Avenue Chub Vista,California 92010 The Honorable Mayor and City Council August 2 , 1985 / 2 (b) . . .The city, county, or city and county shall establish procedures for carrying out this section which shall include legislative body approval of the means of compliance with this section. ( c) For the purposes of this chapter , "density bonus" means a density increase of at least twenty five percent of the otherwise maximum allowable residential density under the applicable zoning ordinance and land use element of the general plan. The density bonus shall not be included when determining the number of housing units which is equal to ten or twenty five percent of the total. The density bonus shall apply to housing developments consisting of five or more dwelling units. (d) If a developer agrees to construct both the twenty five percent of the total units for persons and families of low or moderate income and ten percent of the total units for lower income households, the developer is entitled to only one density bonus under this section although the city . . .at its discretion may grant more than one density bonus. " (Emphasis added) The above quoted provisions establish a mandatory requirement upon the City to provide a density bonus when requested by the developer. In addition, this section provides that the City shall establish procedures for carrying out the section' s provisions. Therefore, the state legislature has recognized the authority of the City to establish reasonable requirements for the implementation of the density bonus provisions. Section 65916 provides that where there is a direct financial contribution to a housing development pursuant to Section 65915 , the City must assure that the affordable housing units shall be available for thirty years . In addition, Section 65916 provides that , "when appropriate, the agreement provided for in Section 65915 shall specify the mechanisms and procedures necessary to carry out this section" . The inclusion of the word "agreement" provides a recognition that Section 65915 should be implemented through some type of contractual relationship. Accordingly, the adoption of a policy by the City pursuant to Section 65915 may specify the terms by which the City will agree to the applicability of a density bonus for affordable housing. The Honorable Mayor and City Council August 2 , 1985 Page 3 Section 65917 is a statement of the legislature' s intent in adopting Chapter 4 . 3. The legislature intends that "this chapter shall contribute significantly to the economic feasibility of low and moderate income housing in proposed housing developments" . Finally, Section 65918 makes the provisions of Chapter 4 .3 applicable to charter cities, such as the City of Chula Vista. The provisions of Chapter 4 .3 have not been interpreted by a court of law. The only available published opinions relating to these statutory provisions are by the Attorney General . In 63 Ops. Cal . Atty. Gen. 478 ( 1980) , the Attorney General considered a provision of Section 65915 relating to other incentives that has been repealed. Due to the amendment of Section 65915, this Attorney General opinion does not provide any direction as to the interpretation of the currently existing chapter , except to note that the city is free to choose any "equivalent" incentives it may deem to be appropriate. In 64 Ops. Cal . Atty. Gen. 370 ( 1981) , the Attorney General addressed a question relating to direct financial contribution as provided in Section 65916 . Specifically, the Attorney General considered whether or not the granting of a density bonus or an exception from a local ordinance provision constituted a direct financial contribution. The Attorney General concluded that a direct financial contribution is one involving the spending of money and that the legislature has mandated that the monetary outlay be "direct" as opposed to indirect. (at page 373 ) . To further analyze the provisions of Chapter 4 .3 , we must turn to the well-established principles of statutory construction. In interpreting statutes, the cardinal rule is to "ascertain the intent of the legislature so as to effectuate the purpose of the law" (Select Base Materials v. Board of Equalization [ 1959 ] 51 Ca1 .2d 640 , 645 . ) In ascertaining legislative intent , we look first to the words of the statute, giving the language its usual and ordinary meaning. (Moyer v. Workmen' s Compensation Appeals Board [ 1973 ] 10 Ca1 .3d 222, 230 ) . The construction of a statute that renders some words surplusage is to be avoided. (California Manufacturers Association v. Public Utilities Commission [ 1979] 24 Ca1 .3d 836, 844) . Also, the various provisions of a statute should be harmonized and construed together . (People v. Corey [ 1978 ] 21 Ca1 .3d 738, 743) . The Honorable Mayor and City Council August 2 , 1985 Page 4 Applying these rules, we note that the statutory scheme of Chapter 4 .3 prescribes several ways in which the City may comply with the developer ' s desire to construction affordable housing . Chapter 4 .3 does not prohibit the imposition of reasonable requirements by the City upon such a developer . Said requirements could be imposed pursuant to an adopted City policy or ordinance which implements the provisions of Section 65915 . The adoption of a City policy would provide a rational basis for the approval or disapproval of density bonus projects thus making the City ' s action defensible in court. Therefore, this office recommends that the City Council adopt a policy relating to the provisions of Chapter 4 .3 in order to implement reasonable standards as required by state law. CRG: lgk 0649a Date: July 23, 1985 To: David Gustafson, Housing Coordinator Via: Paul Desrochers, Community Development Director From: George Krempl , Planning Director GV Oept Subject: Approving Density Bonus for Housing Project by Starboard Investment Company and Approving Agreement At the City Council meeting on July 16, 1985, the Density Bonus request by Starboard Investment Company was continued by the City Council . Among issues discussed by the Council was the one pertaining to the density permitted within the R-3 zoning category and whether or not a density bonus of 25 percent as mandated by the state should automatically be added thereto. Staff has considered this item and would offer the following comments: 1 . The state-mandated density bonus is theoretically possible to affix to the existing maximum allowed density within the zoning category. 2. That proviso, however, is qualified with respect to several con- siderations: a. The proposal must meet all of the normal R-3 requirements as to setback, building height, lot coverage, parking, open space, and so on. b. In the multiple family category the project is subject to the review and approval of the City' s Design Review Committee. If the Design Review Committee were to determine that the project was not compatible with the neighborhood surrounding it, due for example to scale or the bulk of the project, the project could be denied. c. The statute allows for incentives in lieu of the density bonus to be negotiated with the applicant. The emphasis on such negotiation could be from a rather conservative position by the City with burden of proof to the contrary to be placed on the applicant, in light of the general language of the statute. 3. A down-zoning of the R-3 zoning category by means of changing the maximum density permitted is not recommended. If such were contemplated, it would need to be predicated on findings that the maximum density permitted within the zoning district conflicts with and is too high to sustain the present environment lifestyle David Gustafson July 23, 1985 / ` I Page 2 and qualitative aspects of the City of Chula Vista. Staff would have concern with the implications of attempting such a program Citywide for both vacant as well as under-utilized zoned parcels. Through past experience, it does not appear that due to density that development quality has been compromised with resultant negative impacts on the City as a whole. Staff's preference would be continue working with applicants with respect to tailoring their design, their density, and so forth to the unique circumstances of each individual sites. This still permits the prerogative of recommending denial of projects deemed incompatible based on failure to meet planning criteria. We would be happy to furnish you with any additional information which you might feel would assist you in preparing your report back to Council on this matter. GK:vt -, ii'S ), r- '. r a " (-- feET-411_ i..101,=T 4 oFFices ... q o e'� IIIti c T GE.LI�c�&L f2acA I: I t Project -- - - - y •R NDR Y 4reo -- - • MF _ gF MI` fil J'!FI MF I I.F �W 1 I x �„ --, MF f I I I M F L.-ZZ-'' r �� r- -- - , ° , sF SF tt� m LMAN ST. b� -------- a) SF F1 f- --L i i�Fj �TF I MF ---- R_ y_ S I--�--1 11_ i 1 1 I --- it ,„ g-lali REIM _bird. I , rf j I I MF s'1 I� FIMF' CU '+I" Lej i I 1 1—`" D" STREET 7 NI _ f , s Ili SF , &P : 1 : mi . m Ill 5F SF rn _ 1 Z _ -_-,r----r sF C 1 o MARETTA ST. �*1 MF 1 v SF 1 TF 1. , 41mi- _ __ 1 • - - - l — — . )(Park Vista '20C4 TOR iiiii RCS-84-5 iii) 1 i t c0 2co ---- Subdivision NORTH i ,......_ , .../...2_,3 _ _ August 9, 1985 z ITEM NO. 14 To: The Honorable Mayor and City Counci Via: John Goss, City Manager Via: Paul Desrochers, Community Development Director From: Dave Gustafson, Assistant Community Development Director Subject: Starboard Investment Company Density Bonus Request and Density Bonus Policy The above issues were continued from the Council meeting of August 6 in order to correct discrepancies in the associated documents. The corrections have been made and the amended documents are attached to the original resolutions from the August 6 meeting. Regarding the first issue, the Starboard Investment Company request, it was necessary to amend language and add language to the Housing Cooperation Agreement as it pertained to occupancy of the affordable units. The language of the Housing Cooperation Agreement provided to the Council at the last meeting limited the occupancy of affordable apartments as follows: 1 . One-bedroom apartments to be occupied by two-person households. 2. Two-bedroom apartments to be occupied by four-person households. That language did not reflect the understanding between staff and the developer and was forwarded to the City Council as a result of inadvertently using an original draft of the first Housing Cooperation Agreement ever considered by the City Council . To make the Starboard Housing Cooperation Agreement consistent with other Housing Cooperation Agreements approved by the Council , and to make the requirements consistent with market practices, the language has been changed to reflect the following: Units shall be occupied by households having annual gross incomes not exceeding the lower income limit for that household size. Therefore, one-bedroom units could be occupied by one-person households, and two-bedroom units could be occupied by three-person households. Additionally, definitions of the low-income limits for various household sizes were added to the DEFINITIONS section. Regarding the issue of a policy for density bonuses, an amended draft makes corrections recommended by the City Attorney' s office as a result of further clarification of the issue. The changes are as follows: by the City Council of Chula Vista, ...,lifornia Dated �... u_ .___,:_ The Honorable Mayor and City Council -2- August 9, 1985 1. Condition No. 1 : The original draft called for 25% of the predensity bonus units as being for low-income households. The intent was to maximize the low-income units, since the moderate-income units would have rent restrictions way above market rents. However, the Attorney's office advises that some moderate-income units must be included to respond to the State law language. Therefore, Condition 1 of the attached report calls for 20% of the pre-density bonus units to be for low-income households and 5% of the pre-density units to be for moderate-income households. A definition of moderate income has been added to Condition 1 . 2. Procedure 2: Language is added to indicate that necessary and appropriate City development approvals will be based on the standards for the number of post-density bonus units. Such a policy point will obviate substandard developments under the State law mandate. 3. Procedure 3c: The phrase ".. .for articulable reasons" is added after "invalid" to make it clear that a denial will be based on specific noncompliance with the policy. Further regarding the policy, a review of City Council minutes on discussions of Eucalyptus Grove Apartments and a search of Council referral records shows no Council request for a workshop on density bonuses. Although it is not perceived as absolutely essential to adopt the density bonus policy at this meeting, it would be comfortable to have a policy in place as soon as possible in order to be able to respond to any additional density bonus request. If the Council wishes to schedule a workshop on this matter, perhaps the policy could be adopted at this point and a workshop could be scheduled for further consideration and refinement of the policy prior to converting the policy to a zoning text amendment. In summary, the actions before the Council tonight are as follows: 1 . Consider adoption of resolution approving Starboard Investment Company's density bonus request and approving amended Housing Cooperation Agreement. 2. Consider adoption of resolution approving housing density bonus policy. 3. Consider requesting a Council Conference on the issue of density bonuses. As the Council will recall , the resolution regarding the State Densiit a Bonus Law for League of California Cities' consideration was approved August 6 meeting. DG:nr WPC 1226X