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Planning Commission pushes on Kelly Avenue farmworker housing permits to third meeting

By August Howell

May 2, 2024 Updated May 4, 2024

Project Street View Rendering

Courtesy City of Half Moon Bay


After several hours of discussion and public comment between two meetings, the Half Moon Bay Planning Commission has twice postponed making a decision on approving permits and the design for the proposed 40 units of farmworker housing on Kelly Avenue.


At a special meeting on Tuesday, a continuation of its April 23 meeting, commissioners once again examined the proposal from Mercy Housing and Ayudando Latinos A Soñar. After another two hours of public comment followed by more deliberation, planners decided to continue the topic to May 14.


From a planning perspective, this is a complex and nuanced project, layered in state law and city policy. The five commissioners outlined various concerns about the development, namely that the scope and design of the five-story building appear to be at odds with consistency with major policies in the city’s Local Coastal Lane Plan designed to protect coastal resources.


While the Planning Commission can’t require Mercy Housing to come back with alternatives, the commission asked Mercy staff to incorporate the feedback from meetings, including a reduced scope, and present design changes. If the commission approves the project, it will go before the Half Moon Bay City Council.


Ramie Dare, Mercy’s Housing regional director of real estate development for the Bay Area, said Mercy needs permits soon to be eligible for funding, and delaying a decision could delay the construction by a year.


Because the plan calls for 40 low-income units, and many of the city’s development standards would have to be waived, the project is a major test for the city’s Local Coastal Land Use Plan, which was approved by the California Coastal Commission in 2020.


“Our objective is to get this project right so it’s a good quality project for the people who live, it meets the standards we’ve put in our policies, and it also sets a super critical precedent for every project that comes before us,” commissioner Rick Hernandez said.


Mercy is eyeing a $43 million price tag for this project. The city will still own the land, but Mercy will lease the land to run the housing. ALAS will pay Mercy a sub-market rent to operate a Farmworker Resource Center in the building.


Because the project proposes 100% affordable units for extremely low- and very low-income households, the development qualifies as a “super density bonus” project under the State Density Bonus Law. As a result, “the city must allow the project to include unlimited density and up to three stories of additional height. The city may not impose any parking requirements and must grant the applicant up to four ‘concessions,’ which are waivers from other development standards that provide identifiable project development cost reductions,” reads the staff report. “(Mercy) has requested two (of four allowable) concessions that waive the city’s open space and building setback requirements.”


As noted by city staff, the State Density Bonus Law does not “supersede” the Coastal Act. As a result, Half Moon Bay is still required to evaluate the project to determine if it was consistent with its LCLUP and make related findings. While the state density bonus prohibits the commission from requiring a height limit, they argue that it’s the height of the building (59 feet) that is not consistent with the aesthetic of downtown Half Moon Bay.


“I’m concerned that this will be the first of many projects where we have no control,” Hernandez said. “So I want to make sure we have objective criteria we can use from a design perspective. The applicant believes they’ve produced something that demonstrates the characters of Half Moon Bay, which conveys to me we don’t have enough objective design criteria.”


A key question the commission is grappling with is whether this building, which would be the tallest in the city, would meaningfully detract or promote Half Moon Bay’s small-town character and heritage. Because of the regulations and planning that go into a coastal city, Half Moon Bay’s small-town character is a coastal resource and is protected by the Coastal Act. So, the commission has to weigh if the project protects other coastal resources such as safe access from downtown to the beach and enhances wayfinding at a gateway into town. Hernandez also posed a question on whether the development would set a precedent in which the city would have little local control over future downtown projects.


The commission also has to determine whether the project is exempt from review requirements from the California Environmental Quality Act. Under CEQA, the city can only address traffic impacts through projected vehicle miles traveled, which refers to the amount and distance of automobile travel attributable to a project. That means the city can’t consider traffic delays or parking a significant environmental effect. Half Moon Bay does not have an adopted VMT threshold of significance, but staff believe there are several reasons to conclude that the VMT generated by the project would not be large, largely because the building is within walking distance to transit and services downtown.


Under the density bonus law, the city cannot require the project to provide parking. However, Mercy Housing has agreed to have 18 spaces in a parking garage (which could be up to $3 million) and modify the parking lot at the Ted Adcock Community Center to increase the number of spaces. A Mercy Housing staff member estimated the cost to reconfigure the parking lot could be $50,000 to $100,000.


Commissioners questioned the applicant if the offices were necessary for the building and could be put elsewhere. Per the regulatory agency, which will likely be the state’s low-income tax credit program, Mercy is required to provide free property management and resident services offices in the building. Mercy services include fitness classes, health and wellness programs, and housing and budgeting workshops. ALAS will provide mental health services, English classes, computer skills, cultural arts and health care referrals, and more. All of those will be on the first floor.


As part of a condition of approval, Mercy also agreed to seek a parking agreement with the adjacent Our Lady of Pillar Catholic Church. Half Moon Bay is also starting to collaborate with CUSD and the Boys and Girls Club of the Coastside to discuss coordinated use of on-site and on-street parking for drop-off and pick-up related to the CUSD Events Center, according to the staff report.


The units will be restricted to senior farmworkers and their households. A senior farmworker is identified as someone aged 55 and over who is working or retired and gets a substantial part of their income from agriculture employment. There are income restrictions per unit. Mercy Housing will be in charge of vetting housing. Staff estimate around 95 occupants to live in the building, with a maximum of 130 people allowed. The occupants will be checked annually to make sure they are still eligible to live on Kelly Avenue.

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