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City of El Cerrito Draft 2015‐2023 Housing Element Housing Policy Program I November 2014 Page 103 of 187 IV. HOUSING POLICY PROGRAM Previous sections of the Housing Element establish the housing needs, opportunities, and constraints in the City of El Cerrito. The Housing Policy Program contains policies and programs that will be implemented to address a number of important housing‐related issues. This section also contains quantified objectives for housing construction, rehabilitation, and the preservation of affordable housing. City staff regularly reviews Housing Element programs and progress towards accommodating the City’s share of the regional housing need. The City will prepare an annual implementation report and provide it to the California Office of Planning and Research (OPR) and California Department of Housing and Community Development (HCD). A. GOALS, POLICIES, AND PROGRAMS This section describes the City of El Cerrito’s Policy Program for the 2007‐2014 planning period. The Policy Program contains broad policy statements to guide decision making and describes specific actions necessary to address present and future housing needs, meet statutory requirements, and consider the input by residents and stakeholders. In developing this Policy Program, the City assessed its housing needs, evaluated the performance of existing programs, considered available staff and financial resources, and collaborated with residents and stakeholders. GOAL H1 Existing Housing Conserve and improve El Cerrito’s existing housing supply. Policies H1.1 Encourage neighborhood preservation and housing rehabilitation of viable older housing to preserve neighborhood character and, where possible, retain a supply of very low‐, low‐, and moderate‐income units. (Source: 2010 Housing Element, Policy 1) H1.2 Discourage the conversion of residential uses to non‐residential uses, unless there is a finding of clear public benefit and equivalent housing can be provided for those who would be displaced by the proposed conversion. (Source: 2010 Housing Element, Policy 2) H1.3 Maintain housing supply and reduce the loss of life and property caused by earthquakes by encouraging structural strengthening and hazard mitigation in all housing types. (Source: 2010 Housing Element, Policy 3) ---PAGE BREAK--- Draft 2015‐2023 Housing Element City of El Cerrito Page 104 of 187 Housing Policy Program I November 2014 H1.4 Continue to permit new housing units and housing rehabilitation in mixed use and commercial zoning districts subject to Zoning Ordinance requirements so that housing and commercial uses can complement and support one another. (Source: 2010 Housing Element, Program 1.4) H1.5 Continue to regulate condominium conversions in accordance with Chapter 19.45 of the Zoning Ordinance. (Source: 2010 Housing Element, Program 1.5) H1.6 Retain existing residential zoning and discourage non‐residential uses in these zones. The City will strictly enforce the Zoning Code which states that non‐residential uses in residential areas are limited to churches, daycares, and schools. (Source: 2010 Housing Element, Program 2.1) GOAL H2 New Housing Development Encourage the development of housing at all income levels to meet regional housing needs allocation by facilitating housing development and minimizing the impact of potential governmental constraints on the development of housing. Policies H2.1 Provide adequate residential sites for the production of new for‐sale and rental residential units for existing and future residents. (Source: 2010 Housing Element, Policy 4) H2.2 Encourage the construction of transit‐oriented developments (TODs) that seek to maximize opportunities for the use of public transit and transportation corridors through high‐density residential and mixed‐use projects along those corridors in accordance with the San Pablo Avenue Specific Plan and the City’s Incentives Program (Chapter 19.23 of the El Cerrito Zoning Ordinance). (Source: 2010 Housing Element, Policy 5) H2.3 Continue to enforce the sections of the Zoning Ordinance that increase density, reduce parking requirements, and establish design and development standards to create inviting, mixed‐use neighborhoods around transit, and enforce the San Pablo Avenue Specific Plan. (Source: 2010 Housing Element, Program 23.1, modified) H2.4 Encourage and facilitate the construction of second/accessory dwelling units, pursuant to the City’s Second Unit regulations (Section 19.20.190 of the El Cerrito Zoning Ordinance). (Source: 2010 Housing Element, Policy 6) ---PAGE BREAK--- City of El Cerrito Draft 2015‐2023 Housing Element Housing Policy Program I November 2014 Page 105 of 187 H2.5 Continue to permit manufactured and prefab housing in residential districts provided any manufactured unit is certified under the standards set forth in the National Manufactured Housing Construction and Safety Standards Act of 1976 (42 USC 5401 et seq.) and follows the standards set in Chapter 19.20 of the Zoning Ordinance. (Source: 2010 Housing Element, Policy 7 and Program 7.1, combined) H2.6 Identify and evaluate the reuse of underutilized or deteriorated sites in commercial areas with potential under the City’s zoning requirements for conversion or redevelopment to mixed use housing, retail, and commercial uses that can support and complement one another. (Source: 2010 Housing Element, Policy 8) H2.7 Encourage innovative housing approaches in the design and ownership of units to increase the availability of affordable housing. (Source: 2010 Housing Element, Policy 9) H2.8 Encourage diversity of unit size and number of bedrooms within multifamily housing developments and strive to provide family housing of 3 to 4 bedroom units within projects. (Source: 2010 Housing Element, Policy 10) H2.9 Provide regulatory and/or financial incentives where appropriate to offset or reduce the costs of affordable housing development, including density bonuses and flexibility in site development standards. (Source: 2010 Housing Element, Policy 11) H2.10 Periodically review the City’s regulations, ordinances and development fees to ensure they do not unduly constrain the production, maintenance and improvement of housing. (Source: 2010 Housing Element, Policy 12) H2.11 Provide for streamlined processing of residential projects to minimize the time and costs in order to encourage housing production. (Source: 2010 Housing Element, Policy 13) H2.12 Based on the land‐use strategy developed in the General Plan and Zoning Ordinance, direct growth into compact patterns of development to promote infill and intensify land uses. (Source: 2010 Housing Element, Policy 14) ---PAGE BREAK--- Draft 2015‐2023 Housing Element City of El Cerrito Page 106 of 187 Housing Policy Program I November 2014 H2.13 Assist and cooperate with non‐profit, private, and public entities to maximize opportunities to develop affordable housing, including extremely low‐income housing. (Source: 2010 Housing Element, Policy 18) GOAL H3 Special Needs Housing Encourage and Expand housing opportunities for the elderly, the disabled, the homeless, large households, and for other persons with special housing needs. Policies H3.1 Encourage the provision of housing for special needs groups. (Source: 2010 Housing Element, Policy 15) H3.2 Support efforts to provide temporary and permanent shelter and transitional housing for the homeless. (Source: 2010 Housing Element, Policy 17) H3.3 Continue to allow emergency shelters as a permitted use within the CC, TOHIMU, and TOMIMU zones. (Source: 2010 Housing Element, Program 17.1) H3.4 Continue to enforce Federal and State Handicapped Accessibility and Adaptability Standards. (Source: 2010 Housing Element, Program 15.2) H3.5 Encourage the development of housing accessible to people with disabilities, including developmental disabilities. (Source: New Policy) GOAL H4 Equal Housing Opportunity Prohibit discrimination in the provision of housing based on race, color, religion, gender identity, age, marital status, national origin, ancestry, familial status, disability, or sexual orientation and to promote equal housing opportunities. Policies H4.1 Promote fair housing opportunities for all people. (Source: 2010 Housing Element, Policy 19) ---PAGE BREAK--- City of El Cerrito Draft 2015‐2023 Housing Element Housing Policy Program I November 2014 Page 107 of 187 GOAL H5 Energy Conservation and Sustainable Development Promote energy conserving practices in the location, construction, renovation and maintenance of El Cerrito’s housing units. Policies H5.1 Promote residential energy conservation programs that provide assistance for energy conservation improvements. (Source: 2010 Housing Element, Policy 20) H5.2 Encourage the incorporation of energy conservation design features in existing and future residential development. (Source: 2010 Housing Element, Policy 21) H5.3 Encourage the use of sustainable and green building design in new and existing housing in compliance with the legislation in AB 32 and SB 375. (Source: 2010 Housing Element, Policy 22) H5.4 Encourage the location of multifamily housing near transit centers where living and/or working environments are within walkable distances in order to reduce auto trips to work, roadway expansion and air pollution. (Source: 2010 Housing Element, Policy 23) H5.5 Continue to enforce the State Energy Conservation Standards for new residential construction and additions to existing structures. (Source: 2010 Housing Element, Program 21.1, modified) ---PAGE BREAK--- Draft 2015‐2023 Housing Element City of El Cerrito Page 108 of 187 Housing Policy Program I November 2014 Implementation Program Policies Implemented Potential Funding Responsibility Time Frame GOAL H1: EXISTING HOUSING Program H1.1. Residential Rental Inspection Program Continue to implement the Residential Rental Inspection Program (Section 16.30.040 of the El Cerrito Municipal Code) to ensure that rental housing units are maintained in a safe and habitable condition and comply with all codes and standards applicable to rental housing. If the property is in compliance with applicable codes and standards, a certificate of compliance shall be issued to the property owner. Over time, as it is implemented, the Program will provide a current housing condition survey of all rental housing units within the city. This survey should include the number of units in need of rehabilitation or replacement. (Source: 2010 Housing Element, Program 1.1) H1.1 General Fund, Program Fees Building Division Ongoing Program H1.2. Code Enforcement Continue to investigate complaints and take action about code violations in single‐ and multifamily rental housing, and provide information on the City’s Residential Rental Inspection Program, the County Rental Rehabilitation Program, and the County Neighborhood Preservation Program. (Source: 2010 Housing Element, Program 1.2) H1.1 General Fund Building Division Ongoing ---PAGE BREAK--- City of El Cerrito Draft 2015‐2023 Housing Element Housing Policy Program I November 2014 Page 109 of 187 Implementation Program Policies Implemented Potential Funding Responsibility Time Frame Program H1.3. Housing Rehabilitation Programs Continue to encourage the rehabilitation of existing housing units by providing information on programs available to assist in housing rehabilitation, such as the Contra Costa County Housing Authority Rental Rehabilitation Loan Program and the Contra Costa County Neighborhood Preservation Program. Informational material on these programs will be available through the City’s website, at City Hall and in conjunction with the City’s code enforcement program. (Source: 2010 Housing Element, Program 1.3) H1.1 Staff time, County Housing Authority and County CDBG funding Community Development Department Ongoing Program H1.4. Monitor Assisted Units Continue to regularly monitor assisted housing units to help preserve the existing stock of affordable housing. The City shall continue to maintain a database of assisted housing units and annually review existing agreements to ensure that they are in compliance with affordability requirements. The City shall continue to enforce notification requirements on Below Market Rate [BMR] and Section 8 Project Based Subsidy units, prior to resale of units or and/or conversion of such units to market‐rate in accordance with Chapter 19.22 of the Zoning Ordinance. (Source: 2010 Housing Element, Program 1.6 and Program 1.7, combined) H1.1 Staff time Affordable Housing Program Annually ---PAGE BREAK--- Draft 2015‐2023 Housing Element City of El Cerrito Page 110 of 187 Housing Policy Program I November 2014 Implementation Program Policies Implemented Potential Funding Responsibility Time Frame Program H1.5. Eviction for Good Cause Ordinance The City shall consider adopting a Good Cause for Eviction Ordinance that would prohibit landlords from terminating tenancy without good or just cause. (Source: New Program) H1.1 Staff time Affordable Housing Program 2016 Program H1.6. Capital Improvements Program The Planning Commission and City Council shall, on an annual basis, review the City Capital Improvement Program (CIP) to determine what special priorities are needed for capital improvement projects required to maintain the community’s older residential neighborhoods. Annual review of the CIP shall also include verification that needed improvements are scheduled for funding. (Source: 2010 Housing Element, Program 1.8) H1.1 Staff time Planning Division, Public Works Department Annually ---PAGE BREAK--- City of El Cerrito Draft 2015‐2023 Housing Element Housing Policy Program I November 2014 Page 111 of 187 Implementation Program Policies Implemented Potential Funding Responsibility Time Frame Program H1.7. Seismic Retrofit Program Consider enacting additional incentive programs and requirements to encourage retrofitting of seismically unsafe buildings, such as soft‐story buildings. Explore possible funding sources or programs to minimize the financial impact of retrofits on low‐ and moderate‐income residents. Review upcoming grant opportunities on a quarterly basis and explore programs bi‐annually. (Source: 2010 Housing Element, Program 3.1 and 3.2, combined) H1.3 Staff time, grant funding Community Development Department 2017, Review funding opportunities quarterly, plan for programs bi‐ annually GOAL H2: NEW DEVELOPMENT Program H2.1. Maintain Sites Inventory Conduct an annual evaluation of the City’s inventory of available sites, and take appropriate action to ensure that the inventory list is available to potential housing developers. Continue to support property owners and developers to identify underutilized and deteriorated properties where redevelopment as higher‐density, transit‐oriented developments could be feasible. (Source: 2010 Housing Element, Program 4.1and Program 8.1) H2.1, H2.2, H2.6 Staff time Community Development Department Ongoing ---PAGE BREAK--- Draft 2015‐2023 Housing Element City of El Cerrito Page 112 of 187 Housing Policy Program I November 2014 Implementation Program Policies Implemented Potential Funding Responsibility Time Frame Program H2.2. Promote High Density and Mixed-use Development in City Nodes Promote development of mixed‐use and high‐density residential housing in development nodes of the city through the use of the following zoning tools that are incorporated in the City’s Zoning Ordinance: San Pablo Avenue Specific Plan; Density Bonus; Planned Development and Development Agreement process; Economic Development efforts to market vacant and underutilized sites (Source: 2010 Housing Element, Program 5.1) H2.1, H2.2, H2.3, H2.9, H2.10, H2.12 Staff time Community Development Department Ongoing Program H2.3. Fast Track Permitting for Second Units Continue to fast‐track processing for second units meeting established City standards and provide additional information on second units and the application process for public distribution. (Source: 2010 Housing Element, Program 6.1) H2.4, H2.7, H.211 Staff time Community Development Department Ongoing ---PAGE BREAK--- City of El Cerrito Draft 2015‐2023 Housing Element Housing Policy Program I November 2014 Page 113 of 187 Implementation Program Policies Implemented Potential Funding Responsibility Time Frame Program H2.4. Master Fee Schedule Update During the annual revision of the Master Fee Schedule evaluate planning and development fees as they relate to housing development. (Source: 2010 Housing Element, Program 12.1) H2.10 Staff time Community Development and Public Works Departments Annually Program H2.5. Streamlined Application Process The City will help streamline the application process by continuing to offer interdepartmental team meetings with applicants, conceptual review and study sessions with approval bodies, and assistance with pursuing outside funding opportunities. (Source: 2010 Housing Element, Program 13.1) H2.11 Staff time Community Development and Public Works Departments Ongoing Program H2.6. Assist in Affordable Housing Development To the extent financially feasible, the City shall assist and support in the development of extremely low‐, very low‐, low‐, and moderate income housing units. The City shall encourage developers to leverage limited local funds and resources with other sources of assistance, such as Low Income Housing Tax Credits, mortgage revenue bonds, and other sources that fund affordable housing. (Source: 2010 Housing Element, Program 16.1 and Program 16.3, combined) H2.13 Staff time, future repayments to the Low/Mod Housing Asset Fund and any deposits to the City Housing Trust Fund Affordable Housing Program Subject to Funding Availability ---PAGE BREAK--- Draft 2015‐2023 Housing Element City of El Cerrito Page 114 of 187 Housing Policy Program I November 2014 Implementation Program Policies Implemented Potential Funding Responsibility Time Frame Program H2.7. Explore Partnerships for Affordable Housing The City will look for opportunities with non‐profits and other agencies for cooperative efforts to expand the City’s supply of affordable housing. (Source: 2010 Housing Element, Program 18.1) H2.13 Staff time Affordable Housing Program Ongoing Program H2.8. Inclusionary Housing Ordinance Conduct a study of the feasibility of an inclusionary housing ordinance that would include the terms and conditions under which new developments would be required to provide a specified percentage of housing affordable to very low‐, low‐, and/or moderate‐income households, or pay an affordable housing in‐lieu fee (i.e. based on a percent of project cost) to offset building affordable units. As part of a potential inclusionary program, the City will consider requirements and incentives to developers for a mix of dwelling sizes, including units with three or more bedrooms to meet the need of large families. (Source: 2010 Housing Element, Program 16.2) H2.8, H2.13 Staff time, grant funding Affordable Housing Program 2016 ---PAGE BREAK--- City of El Cerrito Draft 2015‐2023 Housing Element Housing Policy Program I November 2014 Page 115 of 187 Implementation Program Policies Implemented Potential Funding Responsibility Time Frame Program H2.9. Local Affordable Housing Financing Source The City shall investigate potential local financing sources that could be used to develop affordable housing, such as a housing mitigation impact fee or community facilities district. Prepare any required financial analyses, such as a nexus study, to legally establish a fee structure, assessment districts or other revenue generating instruments. Evaluate the impact of the proposed fees on the financial feasibility of new residential development. Develop a financing plan to phase in any proposed fees or districts. Consider adoption of financing program as developed under the preceding analyses.(Source: New Program) H2.8, H2.13 Staff time, grant funding Community Development Community Department 2016 Program H2.10. Use Planning Development Process to Encourage Affordable Housing Encourage the use of the planning development process included in the Zoning Ordinance to allow innovative approaches aimed at increasing affordable rental and for‐sale housing opportunities. (Source: 2010 Housing Element, Program 9.1) H2.7 Staff time Planning Division Ongoing ---PAGE BREAK--- Draft 2015‐2023 Housing Element City of El Cerrito Page 116 of 187 Housing Policy Program I November 2014 Implementation Program Policies Implemented Potential Funding Responsibility Time Frame GOAL H3: SPECIAL NEEDS HOUSING Program H3.1. Pursue Funding for Special Needs Housing Assist developers in obtaining State, Federal, and other appropriate sources of funding available to develop affordable and supportive housing for seniors, persons with special needs, including developmental disabilities, and large families and households with children. (Source: 2010 Housing Element, Program 15.1) H3.1, H3.6 Staff time, grant funding Affordable Housing Program Ongoing Program H3.2. Fast Track Permitting for Special Needs Housing The City will continue to fast track the planning and building inspection processes for housing units with three or more bedrooms for large families, housing for seniors, and other special needs housing for extremely low‐, very low‐, low‐, and moderate‐income households. (Source: 2010 Housing Element, Program 15.3) H2.8, H2.11, H3.1 Staff time Planning and Building Division Ongoing ---PAGE BREAK--- City of El Cerrito Draft 2015‐2023 Housing Element Housing Policy Program I November 2014 Page 117 of 187 Implementation Program Policies Implemented Potential Funding Responsibility Time Frame Program H3.3. Senior Housing Development The City shall continue to encourage and support development of senior housing and senior residential care facilities that offer a wide range of housing choices and community services including healthcare, nutrition, transportation, and other amenities, and supports “aging in place” for the City’s senior population. (Source: 2010 Housing Element, Program 15.4 and Program 15.5, combined) H3.1 Staff time Community Development Department Ongoing Program H3.4. Participate in Homeless Census Count Participate in the biannual homeless survey conducted by the County’s Task Force on Homelessness to maintain estimates of the demand for emergency housing. (Source: 2010 Housing Element, Program 17.2) H3.2 Staff time Affordable Housing Program Biannually, starting in 2015 Program H3.5. Consolidated Plan Continue to coordinate with the County and cities to develop the Five‐Year Consolidated Plan for 2015‐2020 and 2020‐2025 to address housing and social service needs of the homeless and other special needs groups in Contra Costa County. (Source: 2010 Housing Element, Program 17.3) H3.1, H3.5 Staff time Affordable Housing Program 2015, 2020 ---PAGE BREAK--- Draft 2015‐2023 Housing Element City of El Cerrito Page 118 of 187 Housing Policy Program I November 2014 Implementation Program Policies Implemented Potential Funding Responsibility Time Frame Program H3.6. Reasonable Accommodation Procedures To accommodate the needs of persons with disabilities and provide a streamlined permit review process, the City will continue to implement reasonable accommodation procedures. The City will continue to provide information on accommodation procedures. (Source: 2010 Housing Element, Program 19.2) H3.5 Staff time Planning and Building Divisions Ongoing Program H3.7. Encourage Development of Housing for Persons with Disabilities The City shall reach out to developers of supportive housing to encourage development of projects targeted for persons with disabilities, including developmental disabilities. The City shall support applications for funding in support of housing construction and rehabilitation for persons with disabilities, including developmental disabilities. (Source: New Program) H3.1, H3.5 Staff time Affordable Housing Program Annually Program H3.8. Coordinate with the Regional Center of the East Bay The City shall work with the Regional Center of the East Bay to implement an outreach program informing residents of the housing and services available for persons with developmental disabilities. The City shall make information available on the City website. (Source: New Program) H3.5 Staff time Affordable Housing Program Annually ---PAGE BREAK--- City of El Cerrito Draft 2015‐2023 Housing Element Housing Policy Program I November 2014 Page 119 of 187 Implementation Program Policies Implemented Potential Funding Responsibility Time Frame GOAL H4: EQUAL HOUSING OPPORTUNITY Program H4.1. Non-Discrimination Clauses Continue to provide non‐discrimination clauses in rental agreements and deed restrictions for housing constructed with either City funds or when City participation occurs. (Source: 2010 Housing Element, Program 19.1) H4.1 Staff time Community Development Department Ongoing Program H4.2. Participate in CDBG Consortium Continue the City’s participation in the Contra Costa Urban County CDBG Consortium and distribute information about the free services offered by the Housing Services Collaborative including tenant‐landlord counseling, fair housing services, and legal advice and representation to Urban County residents, including El Cerrito. The City will distribute brochures and information about the services offered by the Housing Services Collaborative through the City’s website, at City Hall, the City’s Senior and Community Centers, and the El Cerrito Library. (Source: 2010 Housing Element, Program 19.3) H4.1 Staff time, County CDBG funding Affordable Housing Program Ongoing ---PAGE BREAK--- Draft 2015‐2023 Housing Element City of El Cerrito Page 120 of 187 Housing Policy Program I November 2014 Implementation Program Policies Implemented Potential Funding Responsibility Time Frame GOAL H5: ENERGY CONSERVATION AND SUSTAINABLE DEVELOPMENT Program H5.1. Structure Fees to Incentivize Energy and Water Efficiency and Solar Energy Installation The City shall review its building permit fees, process, and requirements and consider ways to structure them to incentivize energy efficiency, clean energy, and water conservation improvements. (Source: Climate Action Plan, Objective EW‐1.1) H5.1, H5.2, H5.3 Staff time Community Development Department 2016‐17 Program H5.2. Partnerships for Energy and Water Efficiency The City shall continue to develop partnerships with PG&E, EBMUD, ABAG, Contra Costa County Weatherization and Green Business Programs, CESC, East Bay Energy Watch and others to bring residential energy and water efficiency technical assistance and incentives to El Cerrito. (Source: Climate Action Plan, Objective EW‐1.1) H5.1 Staff time Community Development Department Ongoing Program H5.3. Marketing Strategy The City shall continue to implement a low‐cost marketing strategy to encourage resident participation in energy and water efficiency programs. (Source: Climate Action Plan, Objective EW‐ 1.1) H5.1 Staff time Community Development Department Ongoing ---PAGE BREAK--- City of El Cerrito Draft 2015‐2023 Housing Element Housing Policy Program I November 2014 Page 121 of 187 Implementation Program Policies Implemented Potential Funding Responsibility Time Frame Program H5.4. Apply for Energy Efficiency Grants The City shall apply for appropriate grants for marketing, outreach, and incentive programs dedicated to energy and water efficiency in El Cerrito. H5.1, H5.2 Staff time Community Development Department Ongoing Program H5.5. Residential PACE Financing The City will adopt residential PACE financing if it becomes available in California. (Source: Climate Action Plan, Objective EW‐ 1.2). H5.1 Staff time Community Development Department 2016 Program H5.6. Home Energy Performance Reports The City will encourage home energy performance reports at time of sale in order to promote better understanding of home comfort, indoor air quality, and utility costs. (Source: Climate Action Plan, Objective EW‐1.3). H5.1 Staff time Community Development Department Ongoing ---PAGE BREAK--- Draft 2015‐2023 Housing Element City of El Cerrito Page 122 of 176 Housing Policy Program I November 2014 B. QUANTIFIED OBJECTIVES State law requires that the City plan to accommodate its fair share of the Regional Housing Needs Allocation (RHNA). In addition, this Housing Element includes quantified objectives, shown in Table IV‐1, for the number of units that can reasonably be expected to be rehabilitated, conserved, or constructed during the next eight years. The quantified objectives expected to be met through Housing Element programs are estimated based on past program performance, construction trends, land availability, and anticipated future program funding. These quantified objectives reflect current economic conditions and the dramatic decrease in funding with the elimination of the Redevelopment Agency. Table IV-1 Quantified Objectives (January 31,2015 – January 31, 2023) Income Category New Construction Rehabilitation1 Preservation2 Extremely-Low Income 50 0 0 Very-Low Income 50 16 0 Low Income 100 24 58 Moderate Income 75 0 0 Above-Moderate Income 300 0 0 Total 575 32 58 Notes: 1The quantified objective for rehabilitated units is based on the County program. 2 The City will continue to monitor the 58 at-risk assisted units.