Just as Portola Valley was set to submit its latest draft of a housing plan ahead of this month's deadline, the state has brought up additional questions to the surprise and consternation of town leaders.

The state's request for Portola Valley to make further edits to the oft-revised document called the housing element is "super disappointing and frustrating," Mayor Sarah Wernikoff said during the Town Council meeting on Wednesday, Jan. 10.

"Given the size of our small town, the process has had an outsized impact on our overall operations, our staff and our budget," she said. "And having worked on the housing element for literally almost three years, I know we're a community that is working in good faith toward adoption and certification."

The council that night had expected to approve formally sending the town's revamped plan to the state Department of Housing and Community Development (HCD) by the Jan. 31 cutoff. Last month, the town Planning Commission reviewed the updated housing element and recommended its submission to the state for final certification.

But on Monday, Jan. 8, HCD emailed Portola Valley that more changes are needed, putting the town's ability to make the state deadline in possible jeopardy.

"Do they (HCD) acknowledge at all that they put us in this pickle?" Wernikoff asked.

Vice Mayor Judith Hasko noted that the timing, in some ways, is "incredibly disappointing."

"But I guess if we had approved it tonight and then gotten that feedback, we'd be no better," she said.

Among the new feedback, HCD wants Portola Valley to strengthen land-use strategies for housing mobility, target additional community partnerships during the planning period and look to rezone areas throughout town to increase multifamily development opportunities.

Town staffers expected to meet with an HCD representative on Thursday, Jan. 11, to address all the issues that just came up.

"It's a brand new set of changes that they're requesting that we sort of felt like we had the rug pulled up from under us," Jon Biggs, the town's interim planning and building director, told the council.

But the changes could be manageable enough to do in time to make the deadline.

"We're cautiously optimistic that these are not substantive changes," Biggs said. "Hopefully, we can get that wrapped up."

The town would then release the draft with the newest revisions for community members to go over and comment on, he said. It could still go back to the Planning Commission for another review if changes turn out to be more substantial than hoped before returning to the council.

The council is now scheduled to take up the matter again on Jan. 24, exactly a week before the deadline.

The state Regional Housing Needs Allocation (RHNA) program requires Portola Valley to plan for 253 new units during the current 2023-31 cycle compared to just 64 in the last eight-year period.

On Dec. 1, the town released its fourth attempt to get its plan certified after HCD kept sending back previous drafts for further work.

That fourth draft sought to resolve concerns HCD raised in July, including providing a zoning-density range of 20-23 units per acre for multifamily housing and boosting efforts to encourage the production of accessory dwelling units, or ADUs, should numbers start dropping below projections.

If the plan continues to fall short in the eyes of HCD, Portola Valley would remain subject to adverse consequences such as financial penalties and a state provision dubbed "builder's remedy" that allows developers to bypass local land-use rules to pursue their projects.

"Despite this week's setback, it's personally still my goal to try and get to adoption on January 31, so we can turn the page and focus our efforts and limited resources on actual implementation," Wernikoff said. "We're one year into our eight-year cycle at this point, and the clock is ticking."