Analysis of Consistency with General Plan
The housing element affects a locality’s policies for growth and residential land uses. Among other things, the housing element establishes the locality’s housing goals, policies, and objectives; identifies sites for new construction; and addresses governmental constraints. The goals, policies, and objectives of an updated housing element should be reviewed in the context of the land-use, circulation, open-space elements, zoning, and/or redevelopment and capital improvement plans, especially if these plans or elements have not recently been updated.
The general plan is required to be “internally consistent” meaning any and all conflicts between general plan elements should be acknowledged and resolved. Jurisdictions must ensure programs and policies in other elements do not conflict with those of the housing element; in particular the land-use, circulation, or conservation elements. For example, the circulation element levels of service (LOS) standards may need to be updated to reflect potential build out capacities proposed in the housing element. Also, realistic development capacity could be impacted by the conservation element policies that require new residential projects to provide large, open-space corridors or buffer areas.
When conflicts exist, the housing element must describe how consistency will be achieved and how the goals of the housing element will be addressed.
Many communities attempt to address and resolve conflicts by amending the zoning ordinance and all relevant elements of the general plan concurrent with amendment of the housing element. For example, if densities of particular sites must be increased to identify adequate sites, the attendant amendments to the general plan and zoning ordinance could be proposed and adopted at the same public hearing as the housing element.
In addition to resolving inconsistencies among various elements and/or ordinances at the time of updating the housing element, any subsequent amendment to the housing element or other general plan elements, should trigger a review of the entire general plan, especially land-use provisions, to ensure internal consistency is maintained.