HomeMy WebLinkAboutCC 2025-09-23_10a AGMC Amendment Re Supportive HousingItem 10.a.
MEMORANDUM
TO: City Council
FROM: Brian Pedrotti, Director of Community Development
BY: Andrew Perez, Planning Manager
SUBJECT: Amendments to Title 16 of the Arroyo Grande Municipal Code
Regarding Supportive Housing, Transitional Housing, and Low Barrier
Navigation Centers
DATE: September 23, 2025
RECOMMENDATION:
1) Introduce an Ordinance adding Section 16.52.280 to Title 16 of the Arroyo Grande
Municipal Code (AGMC) relating to supportive housing, transitional housing, and low
barrier navigation centers; and
2) Find that the Ordinance is exempt from review under the California Environmental
Quality Act (CEQA) because it will not result in a direct or reasonably foreseeable indirect
physical change in the environment (State Guidelines Section 15060(c)(2) and
15061(b)(3)).
IMPACT ON FINANCIAL AND PERSONNEL RESOURCES:
There is no direct fiscal impact associated with this proposed ordinance related to
supportive housing, transitional housing, and low barrier navigation centers .
BACKGROUND:
On January 26, 2021, the City Council adopted the 2020-2028 Housing Element. The
Housing Element was certified by the State Department of Housing and Community
Development (HCD) on May 5, 2021. The Housing Element includes numerous programs
that the City must initiate to implement the policies and achieve the quantified objectives
listed in the Housing Element. Planning staff reports the status of each of the programs
to HCD in the annual progress reports submitted to the State. The proposed Code
amendments would implement Housing Element Programs J.2-2 and J.2-3 to address
requirements affecting the regulation of supportive housing, transitional housing, and low-
barrier navigation centers, as defined in State law, through the creation of a new section
in Chapter 16.52 of the AGMC.
Page 117 of 169
Item 10.a.
City Council
Amendments to Title 16 of the Arroyo Grande Municipal Code Regarding
Supportive Housing, Transitional Housing, and Low Barrier Navigation Centers
September 23, 2025
Page 2
Planning Commission Review
The proposed Code amendments were presented to the Planning Commission for review
on September 2, 20251. The Planning Commission was supportive of the amendments
as proposed and adopted a Resolution recommending that the City Council adopt the
proposed Ordinance.
ANALYSIS OF ISSUES:
Supportive & Transitional Housing
Supportive housing provides long-term affordable housing with onsite services to a “target
population,” as defined by State law. Generally, this target population may include
members of the community with low incomes who face ongoing challenges, such as
chronic homelessness, mental health conditions, disabilities, or substance use disorders.
Supportive housing provides occupancy to the target population, with no limit on length
of stay, and is linked to an on-site or off-site service that assists the supportive housing
resident in retaining the housing, improving their health status, and maximizing their ability
to live and, when possible, work in the community.
By contrast, transitional housing, which is a subset of supportive housing, is meant to be
a temporary housing solution where on-site support services are provided to help
individuals and families stabilize and move toward self -sufficiency. Under State law,
transitional housing means buildings configured as rental housing developments, but
operated under program requirements that require the termination of assistance and
recirculation of the assisted unit to another eligible program recipient at least six months
from the beginning of the assistance. The p roposed Code amendments will codify the
State law definitions of “target population,” “supportive housing,” and “transitional
housing” in Section 16.52.280(A)(2) of the AGMC.
Assembly Bill (AB) 2162 of 2018 (codified in Government Code Section 65583(c)(3), and
referencing Government Code Sections 65650 et seq.), requires that supportive and
transitional housing be treated as a residential use and be subject to the same standards
that govern the development of residential dwellings of the same type in the same zone.
Additionally, State law requires that supportive housing be a use “by right,” not subject to
any discretionary permit or public hearing, in all the zoning districts where multifamily and
mixed uses are permitted, if the proposed development meets certain State -specified
criteria.
The proposed addition to the AGMC would update the standards and procedures for
establishing and operating supportive and transitional housing, consistent with State law.
Additionally, the proposed Code amendments will implement Program J.2-2 of the City’s
Housing Element. Program J.2-2 provides that the City will update its Development Code
to ensure compliance with AB 2162 to allow supportive housing in accordance with State
1 https://pub-arroyogrande.escribemeetings.com/filestream.ashx?DocumentId=15749
Page 118 of 169
Item 10.a.
City Council
Amendments to Title 16 of the Arroyo Grande Municipal Code Regarding
Supportive Housing, Transitional Housing, and Low Barrier Navigation Centers
September 23, 2025
Page 3
law. Specifically, that program calls for amendments to the code to allow supportive
housing without discretionary review in all zoning districts that allow multifamily housing
or mixed-use development, as provided by State law (Government Code Section 65650
et seq.). These updates will be codified in Section 16.52.280(B) of the AGMC.
Low Barrier Navigation Centers
Low Barrier Navigation Centers (LBNC) are a new use type established by AB 101 of
2019 (codified in Government Code Sections 65660 et seq.), and limit the local laws that
may regulate these kinds of facilities. An LBNC is defined by State law as a Housing First,
low-barrier, service-enriched shelter focused on moving people into permanent housing
that provides temporary living facilities while case managers connect individuals
experiencing homelessness to income, public benefits, health services, shelter, and
housing. A Low Barrier Navigation Center may be non -congregate and relocatable. “Low
Barrier” means best practices to reduce barriers to entry, and may include, but is not
limited to, the following:
The presence of partners if it is not a population-specific site, such as for survivors
of domestic violence or sexual assault, women, or youth.
Pets.
The storage of possessions; and
Privacy, such as partitions around beds in a dormitory setting or in larger rooms
containing more than two beds, or private rooms.
An LBNC is designed to have minimal entry requirements , making it easier for occupants
to access services that connect people to permanent housing solutions. This definition
will be added to Section 16.52.280(A)(2) of the AGMC.
If certain listed requirements are met, State law requires the City to allow LBNC as a use
by right (no discretionary review) in areas zoned for mixed use and other nonresidential
zones that allow multifamily residential uses. The key component of an LBNC is the
coordinated entry system, which is designed to coordinate program participant intake,
assessment, and referrals. Facility staff will be able to compile information about client
stays, demographics, income, and exit destination.
The proposed Code amendments would codify this requirement of State law and
implement Program J.2-3 of the City’s Housing Element. Program J.2-3 calls for revisions
to the Development Code to allow low-barrier navigation centers for the homeless
pursuant to Government Code Sections 65660-65668. The proposed ordinance
implements Program J.2-3 by allowing these uses consistent with State law, and will be
added to the AGMC as Section 16.52.280(C).
Conforming Edits
In addition to the new Section 16.52.280 proposed with this Code amendment, several
other sections will need to be amended to maintain consistency throughout the AGMC.
Page 119 of 169
Item 10.a.
City Council
Amendments to Title 16 of the Arroyo Grande Municipal Code Regarding
Supportive Housing, Transitional Housing, and Low Barrier Navigation Centers
September 23, 2025
Page 4
For example, land use tables in Sections 16.32.040 and 16.36.030 will be amended to
reference applicable Code sections regarding supportive and transitional housing and
LBNCs. Section 16.04.070 regarding definitions will be amended to delete definitions
related to the supportive housing and transitional housing, which are included in the new
section 16.52.280, for easier reference. These changes are included in the proposed
Ordinance as Sections 4-6, as shown in Attachment 1.
ALTERNATIVES:
The following alternatives are provided for the Council’s consideration:
1. Introduce the Ordinance establishing regulations for supportive housing,
transitional housing, and low-barrier navigation centers;
2. Modify as appropriate and introduce the modified Ordinance;
3. Do not introduce the Ordinance and provide direction to staff on specific revisions;
or
4. Provide other direction to staff.
ADVANTAGES:
The Code amendment would implement two housing programs from the City’s Housing
Element related to special needs housing. The ordinance amendments would establish a
process to develop supportive housing, transitional housing, and low-barrier navigation
centers that would serve a vulnerable segment of the population.
DISADVANTAGES:
None identified.
ENVIRONMENTAL REVIEW:
The proposed development code amendment has been determined to be exempt from
CEQA review pursuant to State CEQA Guidelines Sections 15060(c)(2) and 15061(b)(3).
The development code amendment would establish transitional housing and supportive
housing as permitted uses in all zones where other residential uses are currently allowed,
subject to the same development standards that apply to other dwellings of the same type
in the same zone. Similarly, the development code amendment would allow low barrier
navigation centers as an allowed use in mixed use zones and nonresidential zones that
allow multifamily residential uses. The Ordinance would not change the amount of
physical development that is currently allowed pursuant to the existing development code.
Allowing the proposed uses in zones where residential development is already permitted
by-right or conditionally would not alter the residential nature of the affected zone. Further,
the Ordinance would assure that the City’s development code is consistent with the City’s
Housing Element and applicable State Housing laws. As a result, there is no possibility
that the project may have a significant effect on the environment.
Page 120 of 169
Item 10.a.
City Council
Amendments to Title 16 of the Arroyo Grande Municipal Code Regarding
Supportive Housing, Transitional Housing, and Low Barrier Navigation Centers
September 23, 2025
Page 5
PUBLIC NOTIFICATION AND COMMENTS:
The Agenda was posted at City Hall and on the City’s website in accordance with
Government Code Section 54954.2. A public hearing notice was published in the New
Times and on the City’s website on September 11, 2025.
ATTACHMENTS:
1. Ordinance
Page 121 of 169
ATTACHMENT 1
ORDINANCE NO.
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF
ARROYO GRANDE ADDING SECTION 16.52.280 TO TITLE 16
OF THE ARROYO GRANDE MUNICIPAL CODE RELATING
TO SUPPORTIVE HOUSING, TRANSITIONAL HOUSING, AND
LOW BARRIER NAVIGATION CENTERS
WHEREAS, on May 5, 2021, the California Department of Housing and Community
Development certified the City’s sixth cycle (2020-2028) Housing Element; and
WHEREAS, the Housing Element profiles the City’s compliance with various state housing
laws; and
WHEREAS, Housing Element program J.2-2 directs the City to amend the Municipal Code
to comply with Assembly Bill 2162 to allow supportive housing without discretionary review
in all zoning districts that allow multifamily housing or mixed-use development; and
WHEREAS, Housing Element program J.2-3 directs the City to amend the Municipal Code
to comply with Assembly Bill 101 to allow low-barrier navigation centers for the homeless
pursuant to Government Code Sections 65660–65668; and
WHEREAS, this ordinance creates section 16.52.280 to establish development standards
for supportive housing, transitional housing, and low barrier navigations centers; and
WHEREAS, on September 2, 2025, the Planning Commission conducted a duly noticed
public hearing to consider the staff report, recommendations by staff, and public testimony
concerning the ordinance. Following the public hearing, the Planning Commission voted to
forward the ordinance to the City Council with a recommendation in favor of its adoption; and
WHEREAS, on September 23, 2025, the City Council conducted a duly noticed public
hearing to consider the ordinance, including: (1) the public testimony and agenda reports
prepared in connection with the ordinance; (2) the policy considerations discussed therein;
and (3) the consideration and recommendation of the Planning Commission; and
WHEREAS, the City Council of the City of Arroyo Grande, at its regularly scheduled public
meeting on __________, 2025 introduced this Ordinance to add Section 16.52.280 to Title
16 of the Arroyo Grande Municipal Code; and
WHEREAS, all legal prerequisites to the adoption of the ordinance have occurred.
Page 122 of 169
NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF ARROYO GRANDE DOES
ORDAIN AS FOLLOWS:
SECTION 1. Incorporation. The above recitals are true and correct and are incorporated
herein by this reference.
SECTION 2. Environmental. The City Council finds that this ordinance is exempt from the
California Environmental Quality Act (“CEQA”) pursuant to State CEQA Guidelines section
15060(c)(2) and 15061(b)(3) because it will not result in a direct or reasonably foreseeable
physical change in the environment; and the activity is covered by the gene ral rule that CEQA
applies only to projects which have the potential for causing a significant effect on the
environment. The development code amendment would establish transitional housing and
supportive housing as permitted uses in all zones where other residential uses are currently
allowed, subject to the same development standards that apply to other dwellings of the
same type in the same zone. Similarly, the development code amendment would allow low
barrier navigation centers as an allowed use in mixed use zones and nonresidential zones
that allow multifamily residential uses. The Ordinance would not change the amount of
physical development that is currently allowed pursuant to the existing development code.
Allowing the proposed uses in zones where residential development is already permitted by-
right or conditionally would not alter the residential nature of the affected zone. Further, the
Ordinance would assure that the City’s development code is consistent with the City’s
Housing Element and applicable State Housing laws. As a result, there is no possibility that
the project may have a significant effect on the environment.
SECTION 3. Required Findings. In accordance with section 16.16.040(E) of the Arroyo
Grande Municipal Code, the City Council hereby makes the following findings:
1. General Plan. The ordinance’s amendments to the AGMC are consistent with
the General Plan and necessary and desirable to implement the provisions thereof.
Specifically, Housing Element program J.2-2 compels the City to comply with AB 2162 by
allowing supportive housing and transitional housing projects by right in specified zones,
consistent with State law. This ordinance effectuates and implements program J.2-2 by
establishing development standards for these uses. Additionally, program J.2-3 directs the
City to update the Municipal Code to allow low barrier navigation centers as required by State
law. This ordinance effectuates and implements program J.2-3 by specifying areas in which
they are allowed and the development standards for establishing the use. For these reasons,
the ordinance’s amendments to the AGMC are consistent with the General Plan and
necessary and desirable to implement the provisions thereof.
2. Health, Safety, and Welfare; Illogical Land Use Pattern. Adoption of the
ordinance will not adversely affect the public health, safety, and welfare as it updates the
AGMC to allow ministerial review of housing projects for those with special needs as required
by State law. Finally, this ordinance will not result in an illogical land use pattern as it is not
amending the City’s zoning map.
Page 123 of 169
3. Consistency with Title 16. This ordinance is consistent with the purpose and
intent of AGMC Title 16 because it does not alter or revise the type or intensity of allowed
uses and ensures that the provisions thereof are consistent with the City’s Housing Element.
4. Environmental. See Section 2 above.
SECTION 4. Code Amendment. The definitions for “Supportive Housing” and "Transitional
Housing” of Section 16.04.070 “Definitions” of Chapter 16.04 “Introductory Provisions and
Definitions” of Title 16 “Development Code” are hereby deleted in their entirety and Section
16.04.070 shall be automatically adjusted alphabetically.
SECTION 5. Code Amendment. Table 16.32.040-A of Section 16.32.040 “Use regulations
for residential districts” of Chapter 16.32 “Residential Districts” of Title 16 “Development
Code” is hereby amended to reference Section 16.52.280 for “Supportive housing,”
“Transitional housing” and “Low Barrier Navigation Centers” as shown in the attached Exhibit
“A-1,” and incorporated by reference.
SECTION 6. Code Amendment. Table 16.36.030(A) of Section 16.36.030 “Uses Permitted
Within Mixed Uses and Commercial Districts” of Chapter 16.36 “Commercial and Mixed Use
Districts” of Title 16 “Development Code” is hereby amended to reference Section 16.52.280
for “Supportive housing,” “Transitional housing” and “Low Barrier Navigation Centers” as
shown in the attached Exhibit “A-2,” and incorporated by reference.
SECTION 7. Code Amendment. Section 16.52.280 is hereby added in its entirety to Title
16, Chapter 52 of the Arroyo Grande Municipal Code as shown in the attached Exhibit “A-3,”
and incorporated by reference.
SECTION 8. Publication. A summary of this ordinance shall be published in a newspaper
published and circulated in the City of Arroyo Grande at least five days prior to the City
Council meeting at which the proposed ordinance is to be adopted. A certified copy of the full
text of the proposed ordinance shall be posted in the office of the City Clerk. Within 15 days
after adoption of the ordinance, the summary with the names of those City Council members
voting for and against the ordinance shall be published again, and the City Clerk shall post a
certified copy of the full text of such adopted ordinance.
SECTION 9. Effective Date. This ordinance shall become effective 30 days after adoption.
SECTION 10. Severability. Should any provision of this ordinance, or its application
to any person or circumstance, be determined by a court of competent jurisdiction to be
unlawful, unenforceable or otherwise void, that determination shall have no effect on any
other provision of this ordinance or the application of this ordinance to any other person or
circumstance, and, to that end, the provisions hereof are severable. The City Council
declares that it would have adopted all the provisions of this ordinance that remain valid if
any provisions of this ordinance are declared invalid.
Page 124 of 169
SECTION 11. Records. The documents and materials associated with this ordinance that
constitute the record of proceedings on which the City Council’s findings and determinations
are based are located at 300 E. Branch Street, Arroyo Grande, CA 93420. The City Clerk is
the custodian of the record of proceedings.
On motion by Council Member ______, seconded by Council Member _______, and by the
following roll call vote to wit:
AYES:
NOES:
ABSENT:
the foregoing Ordinance was adopted this ____ day of _______, 2025.
Page 125 of 169
___________________________________
CAREN RAY RUSSOM, MAYOR
ATTEST:
___________________________________
JESSICA MATSON, CITY CLERK
APPROVED AS TO CONTENT:
________________________________
MATTHEW DOWNING, CITY MANAGER
APPROVED AS TO FORM:
___________________________________
ISAAC ROSEN, CITY ATTORNEY
Page 126 of 169
EXHIBIT A-1
USE RE RH RR RS SF VR
D-
2.4a
MF MFA MFVH MHP
18. Supportive Housing Pursuant to Section 16.52.280
19.Transitional
Housing
Pursuant to Section 16.52.280
20. Low Barrier
Navigation Centers
Pursuant to Section 16.52.280
Page 127 of 169
EXHIBIT A-2
Allowed Land
Uses and Permit
Requirements—
LAND USE
IMU TMU
D-
2.11
VCD HCO
D-2.4
VMU D-
2.11
HCO D-
2.4
GMU FOMU HMU OMU 1
D-2.20
RC
F. RESIDENTIAL
USES
Supportive
Housing
NP Pursuant to Section 16.52.280 NP
Transitional
Housing
NP Pursuant to Section 16.52.280 NP
Low Barrier
Navigation
Centers
NP Pursuant to Section 16.52.280 NP
Page 128 of 169
EXHIBIT A-3
16.52.280 – Transitional Housing, Supportive Housing, and Low Barrier Navigation
Centers
A. Purpose and Definitions.
1. Purpose. These provisions are intended to allow transitional housing and
supportive housing, as defined in Government Code Section 65582, and low
barrier navigation centers, as defined in Government Code Section 65660,
consistent with State law to ensure equality of treatment for all residential uses
regardless of the occupant. Supportive housing helps provide housing linked to a
range of support services designed to enable residents to maintain stable housing
and lead fuller lives. Transitional housing is a subset of supportive housing used
to facilitate the movement of people experiencing homelessness into permanent
housing and independent living. A low barrier navigation center acts as a housing
first, low-barrier, service-enriched shelter focused on moving people into
permanent housing that provides temporary living facilitie s while case managers
connect individuals experiencing homelessness to income, public benefits, health
services, shelter, and housing. This section implements Housing Element
programs J.2-2, J.2-3, and state law requirements applicable to transitional
housing, supportive housing, and low barrier navigation centers. If this section
conflicts with state law, state law shall govern.
2. Definitions.
“Low Barrier Navigation Center” has the same definition as Government Code
Section 65660(a), as amended from time to time.
“Supportive housing” has the same definition as in Government Code Section
65582(n), as amended from time to time.
“Target population” has the same definition as in Government Code Section
65582(p), as amended from time to time.
“Transitional housing” has the same definition as in Government Code Section
65582(q), as amended from time to time.
B. Transitional Housing and Supportive Housing
1. General Application. Transitional housing and supportive housing shall be
considered a residential use of property and shall be subject only to those
provisions and development standards that apply to other residential dwellings of
the same type in the same zone. Additionally, supportive housing shall be a use
Page 129 of 169
by right in all zones where multifamily and mixed uses are permitted, as provided
in Government Code Section 65650 et seq.
2. Supportive Housing, Use by Right. To qualify for approval as a use by righ t,
supportive housing must satisfy all of the requirements of Government Code
Section 65650 et seq., including:
a. Units within the development are subject to a recorded affordability restriction
for 55 years;
b. One hundred percent of the units, excluding managers’ units, within the
development are dedicated to lower income households and are receiving
public funding to ensure affordability of the housing to lower income
Californians. For purposes of this paragraph, “lower income households” has
the same meaning as defined in Section 50079.5 of the Health and Safety
Code. The rents in the development shall be set at an amount consistent with
the rent limits stipulated by the public program providing financing for the
development.
c. At least 25 percent of the units in the development or 12 units, whichever is
greater, are restricted to residents in supportive housing who meet criteria of
the target population. If the development consists of fewer than 12 units, then
100 percent of the units, excluding manage rs’ units, in the development shall
be restricted to residents in supportive housing.
d. The developer shall provide the City with the information required by
Government Code Section 65652 pertaining to the developer’s plan for
providing supportive services for residents, with documentation demonstrating
that supportive services will be provided onsite to residents in the project, as
required by Government Code Section 65651, and describing those services,
which shall include:
i. The name of the proposed entity or entities that will provide supportive
services.
ii. The proposed funding source or sources for the provided onsite supportive
services.
iii. Proposed staffing levels.
e. Nonresidential floor area shall be dedicated for onsite supportive services and
administrative office space in the following amounts:
i. For a development with 20 or fewer total units, at least 90 square feet shall
be provided for onsite supportive services.
ii. For a development with more than 20 units, at least 3 percen t of the total
nonresidential floor area shall be provided for onsite supportive services that
are limited to tenant use, including, but not limited to, community rooms, case
management offices, computer rooms, and community kitchens.
iii.The total floor area dedicated to administrative office space shall not exceed
25 percent of the total floor area.
Page 130 of 169
f. The developer replaces any dwelling units on the site of the supportive housing
development in the manner provided in paragraph (3) of subdivision (c) of
Government Code Section 65915.
g. Units within the development, excluding managers’ units, include at least one
bathroom and a kitchen or other cooking facilities, including, at minimum, a
stovetop, a sink, and a refrigerator.
3. Parking Exception. If the supportive housing development is located within one -
half mile of a public transit stop, no parking spaces are required for the units
occupied by supportive housing residents per Government Code Section 65654.
4. Reduction in Residents. Notwithstanding any other provision of this section, the
City shall, at the request of the project owner, reduce the number of residents
required to live in supportive housing if the project-based rental assistance or
operating subsidy for the supportive housing project is terminated through no fault
of the project owner, but only if all of the following conditions have been met:
a. The owner demonstrates that it has made good faith efforts to find other
sources of financial support.
b. Any change in the number of supportive service units is restricted to the
minimum necessary to maintain project’s financial feasibility.
c. Any change to the occupancy of the supportive housing units is made in a
manner that minimizes tenant disruption and only upon t he vacancy of any
supportive housing units.
5. Processing Timelines. The City shall notify the applicant whether their supporting
housing use application is complete within 30 days of receipt of an application to
develop supportive housing in accordance with this section. The City shall
complete its review of the application within 60 days after the application is
complete for a project with 50 or fewer units, or within 120 days after the
application is complete for a project with more than 50 units.
C. Low Barrier Navigation Centers
1. Low barrier navigation centers are allowed as a use by right, as defined in
subdivision (i) of Government Code Section 65583.2, in any zone that allows
mixed use and nonresidential zones that allow multifamily uses. Low barrier
navigation centers shall not be subject to a planned development permit or a
conditional use permit if the application is in compliance with the following
development and management standards:
a. The low barrier navigation center offers services to connect people to
permanent housing through a services plan that identifies services staffing;
b. b. The low barrier navigation center is linked to a coordinated entry system, so
that staff in the interim facility or staff who co-locate in the facility may conduct
assessments and provide services to connect individuals to permanent
housing. "Coordinated entry system" is generally described as a centralized or
coordinated assessment system developed pursuant to Section 576.400(d) or
Section 578.7(a)(8), as applicable, of Title 24 of the Code of Federal
Page 131 of 169
Regulations, as those sections read on January 1, 2020, and any related
requirements, designed to coordinate program participant intake, assessment,
and referrals;
c. The low barrier navigation center complies with Chapter 6.5 (commencing with
Section 8255) of Division 8 of the Welfare and Institutions Code;
d. The low barrier navigation center has a system for entering information
regarding client stays, client demographics, client income, and exit destination
through the local Homeless Management Information Systems, as defined by
Section 578.3 of Title 24 of the Code of Federal Regulations; and
2. Within 30 days of receipt of an application for a low barrier navigation center, the
City shall notify the applicant whether the application is complete pursu ant to
Government Code Section 65943. Within 60 days of receipt of a completed
application for a low barrier navigation center, the City shall act upon its review of
the application.
Page 132 of 169