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Draft Housing Element December 14, 2022 5 of 21 projects, including infill projects within and adjacent to existing residential neighborhoods. This is outlined in Program 6.1. Second, staff recommends adjusting the PUD process to create two paths. One path would be as it exists today, and would be applicable to projects seeking rezoning, and/or wishing (or needing to) deviate from established objective design standards. Another path, PUD conformance review, would be established for rezone sites identified for housing in the 6th Cycle Housing Element. Staff suggests the PUD process for these sites should be limited to a conformance analysis of proposed projects with the Objective Design Standards. This adjusted process would involve approv al by the Planning Commission and the City will base its review, and related approval or denial of a project, on the applicable objective standards that have been adopted. All Planning Commission approvals are reported to the City Council who has authority to call decisions up for review if needed. The draft program language that was added is as follows: Program 4.8 The City will develop a modified Planned Unit Development (PUD) process that serves strictly as a conformance review. This PUD conformance review will evaluate housing sites against objective standards and will not require City Council approval. Modifications to Residential Multi-Family (RM) Zoning Standards In both HCD’s formal letter to staff, as well as in the two calls with staff, HCD provided feedback and questions related to land use controls (e.g., height, parking standards, setbacks). Specifically, HCD questioned if existing land use controls impact projects’ ability to achieve maximum densities without receiving any exceptions (e.g., Variances, Conditional Use Permits, or PUDs). Typically, single-family and commercial projects are able to build without requiring exceptions and submit Design Review applications complying with existing zoning districts. However, historically, typically multi-family residential projects, particularly on smaller, infill sites, pursue PUDs (though some have developed within existing zoning, without a PUD or any exceptions). Some of the potential constraints to accommodating the allowed densities within RM zones include the required setbacks, as well as required on-site parking, although it is noted and acknowledged that the City has emphasized residential projects being fully parked on site in order to avoid “overflow” impacts on to neighboring streets, especially within the downtown. It is further noted that the PMC allows for some flexibility in parking standards within downtown sites, specifically to reduce constraints to development on these sites. Given HCD’s line of questioning surrounding the land use controls, and based on experience with similar comments in other jurisdictions, to satisfy HCD’s concern and achieve a certified Housing Element, the City’s Professional Services Team (Lisa Wise Consulting) recommends including a program to review and update the Residential Multi-Family zoning standards, to create more standards that allow for assigned densities to be feasibly achieved, without the need to pursue a PUD, Variance, or other