December 11, 2023

Dear Ms. Navarrete:

LandWatch submitted comments on the draft Soledad Housing Element (below and attached) objecting that it relies on development of the Miramonte Specific Plan (MSP) area for 70% of the units identified in the Site Inventory, including 43% of the lower income units. (HE, Table 6-2.) Despite this, the draft Housing Element fails to clarify which of the City’s existing or proposed policies, programs, and ordinances apply to the MSP.

LandWatch’s comments pointed out in detail that the Miramonte Specific Plan areas is not subject to the same policies, programs, and ordinances as other areas in the City because it has a vesting tentative map that requires the developer to honor the policies, programs, and ordinances in effect when its map application was completed.  Critically, the Miramonte area will not be subject to the revised policies, programs, and ordinances set out in the proposed Housing Element. Accordingly, the Housing Element simply fails to provide required information about the policies, programs, and ordinances that will actually apply to the majority of the site inventory area. Soledad should be required to amend the Housing Element to specify the applicable policies, programs, and ordinances.

The revised version of the housing element submitted to HCD on December 8, 2023 acknowledges but entirely fails to address LandWatch’s comments.  (December HE, p. 20.)  LandWatch asks that HCD require Soledad to provide an accurate and detailed account of the policies, programs, and ordinances that apply to the Miramonte area.

Best regards,

Michael D. DeLapa
Executive Director