HomeMy WebLinkAboutLetter of Intent with SB330 Preliminary Application
Allen Matkins Leck Gamble Mallory & Natsis LLP
Attorneys at Law
One America Plaza
600 West Broadway, 27th Floor | San Diego, CA 92101-0903
Timothy M. Hutter
Los Angeles | Orange County | San Diego | Century City | San Francisco | New York
Allen Matkins
Via Submission by Applicant
June 25, 2024
Ms. Damaris Abraham
Community Development
Department, Director
City of Lake Elsinore
130 S. Main Street
Lake Elsinore, CA 92530
Email: dabraham@lake-elsinore.org
Re: The SB 330 Preliminary Application for 3rd Street and Dexter
Avenue
Dear Ms. Abraham:
Our firm represents Fairbrook Communities, LLC (“Fairbrook”), the applicant for the
project located at 3rd Street and Dexter Avenue (“Project”). The Applicant submits a Preliminary
Application for the Project pursuant to the Housing Crisis Act of 2019, Senate Bill 330,
concurrently with this cover letter.
The Project is located north of Dexter Avenue between 3rd Street and 2nd Street on
approximately 23.44 acres (“Property”). The Project proposes 447 residential units, including 137
single-family homes, 90 townhouses, and 220 apartment units. The Project is consistent with the
General Plan land use designation and zoning for the Property, with any non-standard components
achieved and authorized through the use of the State Density Bonus Law. The Project will seek
approval of a Tentative Tract Map and subsequent Final Map.
As you know, a Preliminary Application must include all of the information specified in
Government Code section 65941.1. Local agencies may not request information in a Preliminary
Application beyond the items specified in Section 65941.1. (Gov. Code § 65941.1(b)(3).) A
Preliminary Application is deemed complete by operation of law upon the submittal of the
information enumerated in the statute. An affirmative completeness determination by a local
agency is not required. (Gov. Code § 65941.1(c)(3).)
Relatedly, the Project qualifies as a housing development project under the Housing
Accountability Act because it consists entirely of residential units. (Gov. Code § 65589.5(h)(2).)
Allen Matkins Leck Gamble Mallory & Natsis LLP
Attorneys at Law
Ms. Damaris Abraham
June 25, 2024
Page 2
The Housing Accountability Act only permits local governments to subject housing development
projects to “objective, quantifiable, written development standards, conditions, and policies
appropriate to, and consistent with, meeting the jurisdiction’s share of the regional housing need
….” (Gov. Code § 65589.5(f)(1).) A local government only may subject a housing development
project to the “ordinances, policies, and standards adopted and in effect” at the time that a
Preliminary Application is submitted. (Gov. Code § 65589.5(o)(1).) In other words, the
ordinances, policies, and standards applicable to a housing development project are frozen in time
upon submittal of a Preliminary Application. Fairbrook is currently preparing its full development
application for the Project, and will submit it in the next few months.
The Project will be a new, high-quality development that will provide much needed housing
that will address the state’s housing crisis. Fairbrook looks forward to working with the City and to
enhancing the community through the Project’s development. If there are any issues that require
assistance or clarification on the legal side, please consider our team as a resource, as we hope to
work with you and your staff, as well as the City Attorney, to address those issues in a collaborative
manner.
Sincerely,
Timothy M. Hutter
TMH