05/06/2026
PUBLIC COMMENT:
LAMAS HOUSING PROJECT (LHP)
2227 E. Florida Ave
Hemet, CA 92544
Phone: (951) 357-2027
Email: [email protected]
Date: May 05, 2026
To:
California Department of Housing and Community Development
Re: Technical Public Comment on Draft Guidelines – Affordable Housing and High Road Jobs Act (Gov. Code §§ 65912.100–65912.140)
I. Organizational Standing and Regional Representation
LAMAS HOUSING PROJECT (LHP) is a California nonprofit development organization engaged in acquisition, development, and redevelopment of housing serving low-income and underserved populations.
LHP operates within Riverside County, including the Hemet San Jacinto Valley and broader Inland Empire region, where housing demand, affordability gaps, and entitlement constraints are materially pronounced. This comment is submitted on behalf of communities within this region and for inclusion in the administrative record of material fact.
II. General Support for Implementation
LHP supports the Department’s implementation of the Act, particularly:
The establishment of a streamlined, ministerial review process (Guidelines §102(v); §401)
Activation of commercially zoned land for residential use (Guidelines §200(a)(1); §300(a)(1))
Reliance on objective planning standards (Guidelines §102(aa); §401(b)(1))
Statewide uniformity and preemption of conflicting local requirements (Gov. Code §65912.100 et seq.)
These provisions are critical to advancing housing production in constrained markets such as Riverside County.
III. Technical Comments on Specific Guideline Sections
A. Ministerial Review and Consistency Determinations (Guidelines §401)
LHP supports the framework establishing “use by right” processing and exemption from discretionary review. However, the following clarifications are essential:
§401(b)(1)(A)(i)-(ii): Reinforce that objective standards must be strictly non-discretionary and uniformly verifiable, and that any standard requiring interpretation is not permissible.
§401(b)(1)(A)(viii): Strengthen directive language ensuring that objective standards are interpreted to maximize housing production, not restrict it.
§401(b)(1)(E): The “deemed consistent” provision is appropriate and should remain unambiguous to ensure enforceability where jurisdictions fail to respond within statutory timelines.
B. Site Eligibility Criteria (Guidelines §200; §300)
LHP acknowledges statutory constraints but identifies practical limitations in field application:
§200(a)(3) / §300(a)(3): 75% Urban Adjacency Requirement
Recommend interpretive flexibility or additional clarification recognizing transitional infill conditions, particularly in semi-urban regions such as the San Jacinto Valley where parcel patterns may not meet strict adjacency thresholds despite functional urban characteristics.
§200(a)(5)(D) and §300(a)(7)(D): Fire Hazard Severity Zones
Current exclusion of vacant sites in very high fire hazard zones may disproportionately impact Inland Empire jurisdictions.
Recommend clarification allowing eligibility where projects comply with California Building Code Chapter 7A and applicable fire mitigation standards, consistent with buildable conditions.
C. Density Standards – 100% Affordable Developments (Guidelines §202(b))
LHP supports the absence of a maximum density cap. However:
Clarify that local objective standards (setbacks, height limits, lot coverage) shall not be applied in a manner that functionally reduces achievable density below feasibility thresholds.
Reinforce alignment with Housing Element default densities (Gov. Code §65583.2(c)(3)) as a floor, not a ceiling.
D. Mixed-Income Density Framework (Guidelines §302)
§302(b) and §302(c):
The allowable and minimum density thresholds are appropriate; however, further clarification is recommended to ensure that objective standards cannot indirectly constrain these statutory densities.
§302(e): Height Standards: Support state-imposed minimum height allowances; recommend explicit confirmation that local standards cannot reduce these baseline entitlements.
E. Affordability Requirements (Guidelines §201; §301)
LHP supports long-term affordability requirements:
§201(a): 100% affordability for lower-income households is consistent with mission-driven development.
§301(a):
Mixed-income thresholds are workable; however, clarification is requested to ensure compatibility with:
Low-Income Housing Tax Credit (LIHTC) structures
Project-based subsidy layering
Public-private financing models
Explicit confirmation would reduce uncertainty in capital structuring.
F. Objective Planning Standards (Guidelines §102(aa); §202(c); §302(f))
Reinforce that objective standards must be:
Adopted prior to application submittal.
Externally measurable and not subject to interpretation.
Recommend additional guidance preventing use of design overlays or generalized plan language as a basis for denial.
G. Environmental and Post-Approval Requirements (Guidelines §203; §303; §500–§502)
§203 and §303:
Phase I Environmental Assessment requirements are appropriate and align with standard due diligence practices.
§501: Timely issuance of subsequent permits is critical; support prohibition of unreasonable delay consistent with Gov. Code §65913.3.
§502:
Modification provisions are well-structured; recommend maintaining strict limits on reapplication of new standards post-approval.
IV. Regional Impact Statement
In Riverside County and the San Jacinto Valley, the constraints addressed by this Act—entitlement delays, zoning limitations, and inconsistent application of development standards—are primary barriers to housing production.
The Guidelines, if implemented as written and enforced consistently, will:
Unlock underutilized commercial land for housing.
Enable nonprofit developers to deliver deeply affordable housing at scale.
Reduce timelines that currently inhibit project feasibility.
Support equitable housing access in historically underserved communities.
V. Conclusion
LAMAS HOUSING PROJECT respectfully supports the Draft Guidelines and recommends continued emphasis on:
Strict preservation of ministerial processing.
Clear limitations on subjective interpretation.
Protection of density and development feasibility
Consistent statewide enforcement.
We appreciate the opportunity to submit this technical comment for the administrative record of material fact and remain available for further engagement.
Respectfully submitted,
Sonia Lamas
Founder & Chief Executive Officer
LAMAS HOUSING PROJECT (LHP)
Riverside County – Hemet /San Jacinto Valley / Inland Empire Region
Nuestro Pueblo Building Up Lives Foundation Lighthouse of Hope Foundation Inc LAMAS Housing Project Riverside County Department of Housing & Workforce Solutions
