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Page 3 of 4 <br />jurisdiction would be limited by low-density zoning (1–4 units per acre) and reliance on <br />wells and septic systems. <br />• Included in City Housing Element: The City identified the site (Area 22 – Merritt <br />Property) in its 6th Cycle Housing Element based on longstanding annexation efforts <br />and the anticipated, and ultimately approved, development application described herein. <br />• Basis for RHNA Transfer: The proposed RHNA transfer is based on the property’s <br />existing County zoning capacity. Under current zoning, the four parcels allow up to 20 <br />units by right; with two existing units, the net potential is 18 additional units. <br />• Proposed Adjustment: The County and City propose reducing the County’s RHNA <br />obligation by 18 units, reflecting the site’s remaining by-right capacity, with the City <br />receiving RHNA credit for units constructed following annexation. <br />• Income Category: Due to the very low-density potential (approximately 0.44 units per <br />acre at maximum buildout), the transferred units are categorized as Above-Moderate- <br />Income, consistent with rural, low-intensity development patterns. <br /> <br />CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) <br />As part of its project approvals, in July 2024, the City Council determined that the Project was <br />exempt under California Environmental Quality Act (CEQA) Guideline Section 15183, as <br />documented in the adopted Section 15183 Checklist for the Project. The transfer of RHNA <br />units between the County and City is a ministerial action associated with the previously <br />approved annexation component of the Project. Therefore, no additional environmental review <br />is required. <br /> <br />CONCLUSION <br />In summary, City staff believes the proposed agreement, which would transfer 18 above- <br />moderate-income units based on the factors outlined above, reflects a reasonable and <br />equitable proposal for both the City and the County. The City would be able to receive credit in <br />future reporting of housing production, for most of the market-rate and all of the deed-restricted <br />units ultimately constructed. <br /> <br />If authorized by the City Council, the Mayor would sign the RHNA unit transfer agreement <br />letter. County staff expects to take a similar request for approval to the Board of Supervisors <br />in March, after which staff would submit the joint letter to ABAG/Metropolitan Transportation <br />Commission (MTC) for review and approval, in accordance with the procedures outlined in the <br />Government Code. Pursuant to Government Code Section 65584.07(d), if both the City and <br />the County mutually agree on the apportionment, ABAG/MTC shall accept the proposal as <br />submitted and adjust the RHNA allocations for both jurisdictions accordingly. <br /> <br />EQUITY AND SUSTAINABILITY <br />The action directly implements the Housing Element, a key goal of which is to increase <br />housing opportunities, including affordable housing for lower- and middle-income residents – <br />both through inclusionary requirements and by creating more opportunities for partnerships <br />with housing developers. The construction of the Merritt project would allow for the <br />construction of 18 senior-age-qualified BMR units, consistent with the requirements of the <br />City’s inclusionary ordinance. <br />Page 49 of 242