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HomeMy WebLinkAbout02 GPA 2013-002, HOUSING ELEMENT UPDATEMEETING DATE TO: FROM: SUBJECT: SUMMARY AGENDA REPORT OCTOBER 1. 2013 JEFFREY C. PARKER, CITY MANAGER COMMUNITY DEVELOMENT DEPARTMENT GENERAL PLAN AMENDMENT (GPA) 2013 -002, HOUSING ELEMENT UPDATE Agenda Item Reviewed: City Manager Jri&2r11rfz�? Finance Director N/A The Housing Element of the Tustin General Plan sets forth the City's strategy to preserve and enhance the community's character, expand housing opportunities for the City's various economic segments, and provide policy guidance for local decision making related to housing. The City is mandated by the State to update its Housing Element to include recent available data and to submit the document to the State Department of Housing and Community Development (HCD). On June 21, 2013, copies of the draft Housing Element and Technical Memorandum were submitted to HCD for a sixty (60) -day review period. Preliminary verbal comments from HCD were provided to City staff on August 7, 2013. On August 13, 2013, the Planning Commission adopted Resolution No. 4227, recommending that the City Council adopt a Negative Declaration for the Housing Element Update (General Plan Amendment 2013 -002), and Resolution No. 4228, recommending that the City Council approve General Plan Amendment 2013 -002, updating the Housing Element. Following the Planning Commission's action, the revised draft Housing Element and Technical Memorandum which incorporated the verbal comments from HCD were transmitted to HCD for review. In a letter dated August 22, 2013, HCD confirmed that the draft Housing Element will comply with State law upon its adoption by the City Council and transmittal to HCD. RECOMMENDATION That the City Council: 1. Adopt Resolution No. 13 -85, adopting a Negative Declaration for General Plan Amendment 2013 -002; and, 2. Adopt Resolution No. 13 -86, approving General Plan Amendment 2013 -002, updating the Housing Element. City Council Report GPA 2013 -002, Housing Element October 1, 2013 Page 2 FISCAL IMPACT General Plan Amendment 2013 -002 is a City- initiated project. There are no direct fiscal impacts anticipated as a result of adopting the Housing Element Update. However, the implementation of the policies within the Housing Element may result in fiscal impacts to the City. CORRELATION TO THE STRATEGIC PLAN The proposal supports the implementation of Goal A within the City's Strategic Plan: Goal A: Economic and Neighborhood Development: Enable business opportunities and job development and to enhance the vibrancy and quality of life in all neighborhoods and areas of the community. APPROVAL AUTHORITY Government Code Sections 65353 through 65355 require: The Planning Commission to hold at least one public hearing before approving a recommendation on the amendment to the General Plan. The Planning Commission to make written recommendation on the amendment to the General Plan. A recommendation for approval shall be made by affirmative vote of not less than a majority of the total membership of the Commission. The Planning Commission shall send its recommendation to the legislative body (the City Council). The legislative body (the City Council) to hold at least one public hearing prior to amending a General Plan. INTRODUCTION This staff report provides the City Council with an overview of the proposed Housing Element Update and is organized as follows: • OVERVIEW OF THE HOUSING ELEMENT — A summary of the General Plan Housing Element including the purpose, content, and Regional Housing Needs Assessment process and allocation numbers. • HOUSING ELEMENT UPDATE - An explanation of Housing Element Update requirements including new requirements that are effective in this housing element cycle and land inventory. • STATE OF CALIFORNIA DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT (HCD) REVIEW — An overview of verbal comments, questions, and approval provided by HCD staff. • PUBLIC INPUT — A summary of the public input received to date. • PLANNING COMMISSION ACTION — The action taken by the Commission. • AIRPORT LAND USE COMMISSION (ALUC) DETERMINATION — An overview of the consistency determination with the Airport Environs Land Use Plans (AELUPs). • ENVIRONMENTAL REVIEW — The environmental review for the proposed General Plan Amendment. City Council Report GPA 2013 -002, Housing Element October 1, 2013 Page 3 OVERVIEW OF THE HOUSING ELEMENT State law requires each city and county to adopt a general plan containing at least seven mandatory elements including housing. Unlike the other general plan elements, the housing element is subject to detailed statutory requirements and mandatory review by a State agency, the California Department of Housing and Community Development (HCD). Housing elements have been mandatory portions of local general plans since 1969. This reflects the statutory recognition that housing is a matter of statewide importance and cooperation between government and the private sector is critical to attainment of the State's housing goals. Purpose of the Housing Element The purpose of the Housing Element is to assure that the City: 1) recognize its responsibility in contributing to the attainment of State housing goals; 2) prepare and implement the housing element toward attainment of State housing goals; 3) determine efforts that are required to contribute to the attainment of State Housing goals; and 4) ensure that the City cooperates with other local governments to address regional housing needs. In general, the Housing Element sets forth the City's strategy to: • Preserve and enhance the community's character; • Expand housing opportunities for the City's various economic segments; and • Provide the policy guidance for local decision making related to housing. Housing Element Content The City's Housing Element addresses the following topical areas: 1. Summary of Issues, Needs, Constraints, and Opportunities 2. Identification of Goals and Policies 3. Implementation Programs 4. Review of Previous Policies, Programs, and Objectives The Summary of Issues, Needs, Constraints, and Opportunities section summarizes Tustin's current and projected housing needs to form the basis for establishing program priorities and quantified objectives in the Housing Element. This section identifies the City's assigned RHNA numbers for the planning period (see discussion under Regional Housing Needs Assessment). The Identification of Goals and Policies section contains the goals and policies the City intends to implement to address a number of housing - related issues. The Implementation Program section provides specific actions the City intends to undertake to achieve the established goals and policies. This section identifies quantified objectives, available financial resources and affordable housing resources, and provides a list of specific programs the City intends to pursue. The Review of Previous Policies, Programs, and Objectives section provides a summary of the City's previous policies, programs, and objectives. This allows the City to assess its past performance and provide evaluation of efforts in meeting the identified goals and objectives. City Council Report GPA 2013 -002, Housing Element October 1, 2013 Page 4 The Housing Element Technical Memorandum is an accompanying document that provides background information and supporting documentation to the Housing Element. Regional Housing Needs Assessment State law requires the City to accommodate its fair share of the State's housing need. The State of California Department of Housing and Community Development (HCD) is mandated to determine the state -wide housing need. In cooperation with HCD, local governments and councils of government (SCAG for Southern California Region) are charged with making a determination of their city's or region's existing and projected housing need as a share of the state -wide housing need. This process is called the Regional Housing Needs Assessment (RHNA). As part of this process, the City must quantify in its General Plan Housing Element the number of homes that are projected to be built and conserved during the Housing Element planning period. For the 2014 -2021 Housing Element Planning Period, the City of Tustin was assigned a Regional Housing Needs Assessment (RHNA) allocation of 1,227 housing units, including units for 283 very low- income, 195 low- income, 224 moderate - income, and 525 above moderate - income households (see Table 1). Considering the housing units approved, the City of Tustin has identified the following remaining numbers of units to achieve the 2012 RHNA's construction objective: 195 very low- income, 122 low- income, 123 moderate - income, and 29 above moderate - income units. TABLE SUMMARY OF QUANTIFIED RHNA OBJECTIVES CITY OF TUSTIN 2014 -2021 Income Group RHNA Units Approved Net RHNA Construction Need Very Low 141 88 53 Extremely-Low 1421 142 Low 195 73 122 Moderate 224 101 123 Above Moderate 525 496 29 Total 1,227 758 469 Pursuant to Government Code Section 65583(a)(1), City's share of extremely -low income units is 142 (50 percent of the total Very Low Income new construction objective). Source: 2012 RHNA, SCAG, 2005 -2009 ACS While the City's Land Use Plan provides adequate sites to fulfill the needs established by RHNA, construction of new units will depend upon the timing of the landowner and developer in the submission of building plans to meet market demands. Housing subsidies will depend upon the availability of government funds — local, county, state, and federal. Development projects are also subject to the interests of private developers. It is important to note that while the quantified objectives of the RHNA are required to be part of the Housing Element and the City will strive to attain these objectives, Tustin cannot guarantee that these needs will be met given its own limited financial resources, the dissolution of City Council Report GPA 2013 -002, Housing Element October 1, 2013 Page 5 redevelopment agencies, and the present affordability gap. Satisfaction of the City's regional housing needs will partially depend upon cooperation of private funding sources and the funding levels of County, State, and Federal programs that are used to support the needs of the very- low, low and moderate - income persons. Additionally, outside economic forces heavily influence the housing market. HOUSING ELEMENT UPDATE Housing elements are required to be updated on a regular basis, as specified by State law. In this cycle (2014- 2021), jurisdictions are eligible for an eight -year Housing Element cycle, provided they comply with State Housing Law. For the 2014 -2021 Housing Element planning period, HCD is encouraging local jurisdictions to use their existing housing element as a base and to update the housing element to reflect new statutory requirements and new demographic data. The City of Tustin adopted its previous Housing Element update on June 16, 2009. The proposed 2013 Housing Element Update includes most of the policies and programs from the 2009 Housing Element Update, but also incorporates new demographic data from the U.S. Census Bureau, new assigned Regional Housing Needs Assessment (RHNA) numbers, other new data sources, elimination of the Redevelopment Agencies policies, and addresses several new housing element requirements. New Housing Element Requirements There are several new housing element requirements and changes that apply to the current Housing Element cycle, including: 1) the analysis of the special housing needs of persons with developmental disabilities; 2) the establishment of polices, ordinances, or procedures to allow the reasonable accommodation of persons with disabilities; and, 3) amended alternative adequate sites provisions. The needs of persons with developmental disabilities are specifically addressed in the draft Housing Element on pages 23 -24 and page 96. In 2011, the City of Tustin amended the Zoning Code to remove governmental constraints to reasonable accommodation for the disabled. The amendment provides for a process in which deviations from the development standards associated with physical improvements to accommodate the disabled would be allowed through an administrative approval and without the need of a public hearing, thereby satisfying the new State requirement for reasonable accommodation. As for the amended alternative site provisions which pertain to the Government Code Section that allows local governments to satisfy up to 25 percent of their adequate sites requirements by making available affordable units through rehabilitation, conversion, and /or preservation, these provisions are not directly applicable to Tustin in this housing element cycle, because all of the adequate site requirements are being met through new construction. Another significant change is that the housing element planning period has been extended to up to eight (8) years in duration, provided the jurisdiction is in compliance with State Housing Element Law. Jurisdictions that do not adopt their elements on time and in accordance with State law are required to update their housing element again in four years. Land Inventory As indicated in the Draft Housing Element, there are a total of 205.3 acres of land (177.1 acres within former MICAS Tustin within Neighborhoods D and G, and 15.35 acres of vacant land and City Council Report GPA 2013 -002, Housing Element October 1, 2013 Page 6 12.85 acres of underutilized land in various other areas of Tustin) with residential development potential. These sites could potentially be developed with approximately 2,882 units. This demonstrates that the City has sufficient amount of land available to accommodate the residential developments to meet the remaining RHNA construction needs through the 2021 period. Pursuant to state law, a default density of 30 units per acre has been established by the Department of Housing and Community Development for jurisdictions in metropolitan counties which shall be deemed appropriate to accommodate housing for lower income households. No analysis is required in the housing element to demonstrate how the number of affordable units is determined for a default density site. In Neighborhood D, the maximum density on any individual parcel may exceed 25 dwelling units per acre as long as the total dwelling units allocated to Neighborhood D is not exceeded. Thus, a default density of 30 units per acre could be achieved in Neighborhood D. The remaining development potential in Neighborhood D is 515 dwelling units (plus potential density bonus units), which satisfies the City's remaining RHNA construction objective. The development of Tustin Legacy is anticipated to occur during the Housing Element planning period. In addition, a total development potential of 587 dwelling units outside of Tustin Legacy has been identified during the Housing Element planning period on vacant and underutilized sites. However, these sites are not required to satisfy the City's RHNA allocation. DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT (HCD) REVIEW Copies of the draft Housing Element and Technical Memorandum were submitted to HCD on June 21, 2013 for a sixty -day review period. Preliminary verbal comments were provided to City staff on August 7, 2013. These relatively minor comments are summarized as follows: • Public Participation — Summarize and address public comments received. • Transitional Supportive Housing — Clarify where transitional housing is allowed by right. • Sites Inventory — Specify the number of units on sites used to satisfy RHNA allocation. • Approved units at Tustin Legacy sites — Provide approval dates and anticipated completion dates. • Housing Rehabilitation Objectives — Include these objectives in the Housing Objectives table. • Program 1.10 — Move up date for adoption of SRO Ordinance. • Program 1.12 — (Deleted) • Program 1.15 — Quantified objective should address new construction. • Program 1.17 — Specify how developers would be encouraged to consolidate lots. • Program 1.20 — Move up date for adoption of any identified zoning amendments. • Program 1.23 — Provide more detail regarding the establishment of assessment districts. • Program 1.24 — Indicate whether fee waivers or deferments will be evaluated annually. • Program 4.5 — Move up date and provide information to public through other venues. The comments from HCD were summarized for the Planning Commission for their consideration at their August 13, 2013, public hearing. The draft Housing Element was then revised to address the comments received from HCD, and a copy of the revised document was sent to HCD. In a letter dated August 22, 2013 (Attachment E), HCD confirmed that the revised draft City Council Report GPA 2013 -002, Housing Element October 1, 2013 Page 7 Housing Element will comply with State law upon its adoption by the City Council and transmittal to HCD. PUBLIC INPUT A public workshop was conducted on April 23, 2013 to provide an opportunity for interested persons to ask questions and offer suggestions on the proposed Housing Element. Approximately 24 members of the public attended the workshop, and nine (9) individuals provided verbal comments. Seven (7) of the speakers expressed concerns and provided comments regarding the affordable housing needs of individuals with developmental disabilities. These needs and related programs are addressed in the draft Housing Element. The other speakers provided general comments regarding senior housing and the need for affordable housing. The City advertised the availability of the Housing Element in English and Spanish in two local newspapers and also made the Housing Element available at City Hall, the City's website, and the Tustin Library. The City also sent direct mailings to over 100 organizations consisting of youth, seniors, veterans, disabled, homeless shelters, cultural organizations, housing advocates, religious organizations, housing builders, fair housing council, and individuals interested in the process. The Draft Housing Element and its relevant documents are posted on the City's website to allow the public and interested organizations easy access and the ability to download documents. Given the significant content of the Housing Element update, and to provide the City Council with additional time for review, copies of the Draft Housing Element and the Draft Technical Memorandum were transmitted to the Council on September 17, 2013. In addition to public input received at the April 23, 2013, public workshop, the City received written public comments from several individuals and organizations (Attachment F). The City received correspondence pertaining to the needs of individuals with development disabilities. The Housing Element addresses the needs of persons with development disabilities by first defining the term "developmentally disabled," by explaining the specific needs of persons with developmental disabilities, by describing some of the services available, by providing an estimate of the number of persons with development disabilities living in Tustin, and by including a program to work with the Regional Center of Orange County to implement an outreach program that would inform the public of the services available to persons with developmental disabilities in Tustin. In addition, the City's Housing Authority is committed to working with entities seeking funding to provide housing for persons with developmental disabilities. In addition, correspondence was received from the Airport Land Use Commission (Attachment F). Although the Housing Element update does not propose any new development within the John Wayne Airport Planning Area, Airport Land Use Commission staff indicated that their review is required for the General Plan Amendment and that it would be possible for their review to occur prior to the City Council hearing. (An overview of the consistency determination by the ALUC is described below.) Correspondence from the Kennedy Commission commended the City for its efforts in encouraging and facilitating the development of affordable housing. The Kennedy Commission included four recommendations in their letter. The first and third recommendations are already addressed in that the City has continued its partnership with the Kennedy Commission and the City already has density bonuses and other incentives available citywide for affordable housing. The second and fourth recommendations relate to potential funding sources and fee waivers for affordable housing. More specifically, the Kennedy Commission recommends that the City City Council Report GPA 2013 -002, Housing Element October 1, 2013 Page 8 prioritize and commit potential funding sources to proposed extremely low- income affordable rental developments that leverage additional funding sources. The other recommendation is that the City waive application processing fees for proposed affordable housing developments with a minimum of 10 percent very low- income homes. The implementation of fee waivers is generally addressed in Housing Element Program 1.24, and the use of any available local resources is generally addressed through programs such as Housing Rehabilitation (Program 4.6). Should the Council desire to include the specific programs recommended by the Kennedy Commission, Table H -20 (Housing Element Programs 2013 -2021) could be modified accordingly. Finally, the Department of Transportation (Caltrans) provided general comments on the Draft Housing Element, encouraging efficient land use patterns and more sustainable communities, and acknowledging that the Housing Element update does not propose any significant land use changes. PLANNING COMMISSION ACTION On August 13, 2013, the Planning Commission adopted Resolution No. 4227 (Attachment C) , recommending that the City Council adopt a Negative Declaration for the Housing Element Update (General Plan Amendment 2013 -002), and Resolution No. 4228 (Attachment C), recommending that the City Council approve General Plan Amendment 2013 -002, updating the Housing Element. The approved Minutes from the August 13, 2013, Planning Commission meeting are provided as Attachment D. AIRPORT LAND USE COMMISSION (ALUC) REVIEW On September 19, 2013, the Airport Land Use Commission found that the Housing Element Update is consistent with the Airport Environs Land Use Plans (AELUPs) for John Wayne Airport and Heliports, provided the following two policies are added to the Housing Element: 1) Buildings and structures shall not penetrate Federal Aviation Regulation (FAR) Part 77 Imaginary Obstruction Surfaces for John Wayne Airport unless found consistent by the Airport Land Use Commission (ALUC). Additionally, in accordance with FAR Part 77, applicants proposing buildings or structures that penetrate the 100:1 Notification Surface shall file a Form 7460 -1 Notice of Proposed Construction or Alteration with FAA. A copy of the FAA application shall be submitted to ALUC and, the applicant shall provide the City with FAA and ALUC responses. 2) Development projects that include structures higher than 200 feet above existing grade shall be submitted to ALUC for review. In addition, projects that exceed a height of 200 feet above existing grade shall file Form 7460 -1 with the Federal Aviation Administration (FAA). These two policies have been incorporated into the revised draft Housing Element attached to this report. ENVIRONMENTAL REVIEW On January 16, 2001, the City of Tustin certified the Program Final Environmental Impact Statement/Environmental Impact Report (FEIS /EIR) for the reuse and disposal of MICAS Tustin. On December 6, 2004, the City Council adopted Resolution No. 04 -76 approving a City Council Report GPA 2013 -002, Housing Element October 1, 2013 Page 9 Supplement to the FEIS /EIR for the extension of Tustin Ranch Road between Walnut Avenue and the future alignment of Valencia North Loop Road. On April 3, 2006, the City Council adopted Resolution No. 06-43 approving an Addendum to the FEIS /EIR. And, on May, 13, 2013, the City Council adopted Resolution No. 13 -32 approving a second Addendum to the FEIS /EIR. The FEIS /EIR along with its Addenda and Supplement is a program EIR under the California Environmental Quality Act (CEQA). The FEIS /EIR, Addenda and Supplement considered the potential environmental impacts associated with development on the former Marine Corps Air Station, Tustin. Pursuant to the California Environmental Quality Act (CEQA) Guidelines Section 15063, the City of Tustin has completed an Initial Study and prepared a Negative Declaration. Since the majority of the development of new housing units would take place at the Tustin Legacy, the Initial Study incorporates the analysis and applicable mitigation measures contained in the Program Final Environmental Impact Statement/Environmental Impact Report (FEIS /EIR) for the reuse and disposal of MCAS Tustin. The Initial Study determines that effects associated with the proposed housing element were adequately evaluated in the FEIS /EIR, that no new effects would occur, that no substantial increase in the severity of previously identified significant effects would occur, that no new mitigation measures would be required, that no applicable mitigation measures previously not found to be feasible would in fact be feasible, and that there are no new mitigation measures or alternatives applicable to the project that would substantially reduce effects of the project that have not been considered and adopted. Moreover, no new information of substantial importance has surfaced since certification of the FEIS /EIR and its Supplement and Addenda. The Initial Study prepared for this project is included as Exhibit 1 of Resolution No. 13 -85 (Attachment A). The draft Negative Declaration was made available for public review from July 11, 2013, through August 12, 2013. No comments on the Negative Declaration were received as of the date of this report. Scott Reekstin Principal Planner Attachments: A. City Council Resolution No. 13 -85 Elizabeth A. Binsack Director of Community Development • Exhibit 1: Initial Study /Negative Declaration B. City Council Resolution No. 13 -86 • Exhibit 1: Draft Revised General Plan Housing Element and Technical Memorandum C. Planning Commission Resolution Nos. 4227 and 4228 D. Minutes from the Planning Commission meeting of August 13, 2013 E. HCD Letter dated August 22, 2013 F. Correspondence ATTACHMENT A CITY COUNCIL RESOLUTION NO. 13-85 RESOLUTION NO. 13 -85 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF TUSTIN, CALIFORNIA, ADOPTING A NEGATIVE DECLARATION PURSUANT TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT FOR GENERAL PLAN AMENDMENT 2013 -002 (HOUSING ELEMENT UPDATE). The City Council of the City of Tustin does hereby resolve as follows: The City Council finds and determines as follows: A. That proposed General Plan Amendment 13 -002 is considered a "project" subject to the terms of the California Environmental Quality Act ( "CEQA ") (Public Resources Code §21000 et. seq.). B. That implementation of the Housing Element Update's goals includes proposed housing development within the MCAS- Tustin Reuse Plan area and infill areas outside the Reuse Plan area throughout the City. Since the majority of future housing units identified in the Housing Element Update would be located within the MCAS- Tustin Reuse Plan area, an Initial Study was prepared to determine if impacts to the environment of such housing were analyzed and addressed in the previously approved Final EIS /EIR for the Disposal and Reuse of the MCAS Tustin (Program EIS /EIR for MCAS- Tustin). C. That on January 16, 2001, the City of Tustin certified the Program Final Environmental Impact Statement/Environmental Impact Report (FEIS /EIR) for the reuse and disposal of MCAS Tustin, On December 6, 2004, the City Council adopted Resolution No. 04 -76 approving a Supplement to the FEIS /EIR for the extension of Tustin Ranch Road between Walnut Avenue and the future alignment of Valencia North Loop Road. On April 3, 2006, the City Council adopted Resolution No. 06 -43 approving an Addendum to the FEIS /EIR. And, on May, 13, 2013, the City Council adopted Resolution No. 13 -32 approving a second Addendum to the FEIS /EIR. D. That the FEIS /EIR and its Supplement and Addenda is a program EIR under the California Environmental Quality Act ( "CEQA "). The FEIS /FEIR and its Supplement and Addenda considered the potential environmental impacts associated with development on the former Marine Corps Air Station, Tustin. Resolution No. 13-85 GPA 2013-002 ND Page 2 E. That a Notice of Intent to Adopt a Negative Declaration was filed with the Clerk of the County of Orange for posting, and provided to members of the public using a method permitted under CEQA Guidelines Section 15072(b). The Initial Study and Draft Negative Declaration were made available for a 30-day public review and comment period from July 11, 2013, through August 12, 2013, in compliance with Sections 15072 and 15105 of the State CEQA Guidelines. F. That pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15063, the City of Tustin completed an Initial Study (Exhibit 1) and determined that all effects associated with the implementation of the Housing Element Update were evaluated in the Program EIS/EIR for MCAS Tustin, that no new effects would occur, that no substantial increase in the severity of previously identified significant effects would occur, that no new mitigation measures would be required, that no applicable mitigation measures previously not found to be feasible would in fact be feasible, and that there are no new mitigation measures or alternatives applicable to the project that would substantially reduce effects of the project that have not been considered and adopted. G. That the Planning Commission conducted a duly-noticed public hearing on August 13 2013, to consider the Initial Study, proposed Negative Declaration, and General Plan Amendment 2013-002, at which hearing, members of the public were afforded an opportunity to comment upon the project. At the conclusion of the public hearing, the Planning Commission adopted Resolution No. 4227 recommending that the City Council adopt a Negative Declaration for General Plan Amendment 13-002. H. That the City Council conducted a duly noticed public hearing on October 1 , 2013, to consider Resolution No. 13-85 for the Negative Declaration prepared for GPA 13-002 at which hearing, members of the public were afforded an opportunity to comment upon the project. I. That the City Council considered the Initial Study and the Negative Declaration (Exhibit, 1) and finds it to be adequate for General Plan Amendment 2013-002. II. The City Council of the City of Tustin does hereby find that the proposed project is within the scope of the Final EIS/EIR for the Disposal and Reuse of MCAS Tustin (Program EIS/EIR for MCAS-Tustin), an EIR approved from an earlier project, and that the Program EIS/EIR for MCAS-Tustin adequately describes the general environmental setting of the Housing Resolution No. 13-85 GPA 2013-002 ND Page 3 Element Update, the significant environmental impacts of the implementation of the Housing Element Update, and alternatives and mitigation measures related to each significant effect. III. The City Council hereby adopts the Negative Declaration attached hereto as Exhibit 1, incorporating herein by reference all of the applicable mitigation measures identified in the Program EIS/EIR for MCAS-Tustin. PASSED AND ADOPTED at a regular meeting of the Tustin City Council held on the 151 day of October, 2013. ELWYN A. MURRAY MAYOR JEFFREY C. PARKER CITY CLERK STATE OF CALIFORNIA ) COUNTY OF ORANGE ) SS CITY OF TUSTIN I, Jeffrey C. Parker, City Clerk and ex-officio Clerk of the City Council of the City of Tustin, California, do hereby certify that the whole number of the members of the City Council of the City of Tustin is five; that the above and foregoing Resolution No. 13-85 was duly passed and adopted at a regular meeting of the Tustin City Council, held on the 1st day of October, 2013, by the following vote: COUNCILMEMBER AYES: COUNCILMEMBER NOES: COUNCILMEMBER ABSTAINED: COUNCILMEMBER ABSENT: JEFFREY C. PARKER CITY CLERK I ::192II T11K INITIAL STUDY /NEGATIVE DECLARATION TUSTIN BUILDING OUR. FUTURE HONORING OUP, PAST City of Tustin Community Development Department 300 Centennial Way Tustin, CA 92780 Table of Contents 1. BACKGROUND ..................................................................................................................................... ..............................3 1.1 PROJECT LOCATION ............................................................................................................................. ..............................3 3.2 1.2 ENVIRONMENTAL SETTING ................................................................................................................. ..............................3 3.3 1.3 PROJECT DESCRIPTION ........................................................................................................................ ..............................8 3.4 1.4 CITY ACTION REQUIRED ...................................................................................................................... ..............................9 3.5 2. ENVIRONMENTAL CHECKLIST .............................................................................................................. .............................10 3.6 2.1 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED ....................................................................... .............................10 3.7 2.2 DETERMINATION (TO BE COMPLETED BY THE LEAD AGENCY) ......................................................... .............................10 3.8 2.3 EVALUATION OF ENVIRONMENTAL IMPACTS .................................................................................... .............................11 3.9 2.4 REFERENCES ....................................................................................................................................... .............................37 3.10 3. ENVIRONMENTAL ANALYSIS ............................................................................................................... .............................38 3.1 AESTHETICS ........................................................................................................................................ .............................38 3.2 AGRICULTURE RESOURCES ................................................................................................................ .............................39 3.3 AIR QUALITY ....................................................................................................................................... .............................40 3.4 BIOLOGICAL RESOURCES .................................................................................................................... .............................42 3.5 CULTURAL RESOURCES ...................................................................................................................... .............................44 3.6 GEOLOGY AND SOILS .......................................................................................................................... .............................46 3.7 GREENHOUSE GAS EMISSIONS .......................................................................................................... .............................49 3.8 HAZARDS AND HAZARDOUS MATERIALS ........................................................................................... .............................50 3.9 HYDROLOGY AND WATER QUALITY ................................................................................................... .............................52 3.10 LAND USE AND PLANNING ................................................................................................................. .............................56 3.11 MINERAL RESOURCES ........................................................................................................................ .............................57 3.12 NOISE ................................................................................................................................................. .............................57 3.13 POPULATION AND HOUSING ............................................................................................................. .............................61 3.14 PUBLICSERVICES ................................................................................................................................ .............................62 3.15 RECREATION ....................................................................................................................................... .............................64 3.16 TRANSPORTATION/ TRAFFIC ............................................................................................................... .............................65 3.17 UTILITIES AND SERVICE SYSTEMS ....................................................................................................... .............................68 3.18 MANDATORY FINDINGS OF SIGNIFICANCE ........................................................................................ .............................70 List of Figures Figure Page FIGURE 1 REGIONAL LOCATION List of Tables 5 Table Page TABLE 1 NOISE LEVELS GENERATED BY TYPICAL CONSTRUCTION EQUIPMENT 60 01 1. Background This Initial Study has been prepared to evaluate the potential environmental effects associated with the adoption of the City of Tustin Housing Element Update. This is a revision to the Housing Element that is required by Government Code Section 65588 (b). This analysis has been conducted in compliance with the California Environmental Quality Act (CEQA) and Guidelines, as amended. 1.1 PROJECT LOCATION The Regional Location Map (Figure 1) shows the location of the City of Tustin within the context of the Orange County region. Tustin is located in central Orange County and is bordered by a developed, unincorporated portion of Orange County (North Tustin) to the north, the City of Orange to the northwest, Santa Ana to the west and southwest, and Irvine to the south, southeast, and east. The 55 Freeway forms the majority of the City's western boundary, the 1 -5 transacts the southwestern area of the City, and the Eastern Transportation corridor parallels the City's eastern border. 1.2 ENV IRONMENTAL SETTING Existing Land Use The City of Tustin is developed with a mix of commercial, industrial, and residential uses. The growth trends in Tustin show significant population increases in the 1980s, followed by a slower rate of growth thereafter. From 1980 to 1990, the City's population increased from 36,119 to 50,689 (40.3 percent) and from 2000 to 2010 population Increased from 67,504 to 75,540 (11.9 percent). Recent projections released by the Center for Demographic Research, CSUF (Orange County Projections 2010 Modified, January 26, 2012) indicate that the City's population will increase by an annual rate of 0.7% during this Housing Element Implementation period. In 2012, the City's estimated population of 76,567 represented 2.51 % of Orange County's total population. The California Department of Finance (DOF) estimated that in 2011, 24,945 households resided in Tustin, and the average household size was 2.97 persons. Overall, median resale home prices for zip codes in the City of Tustin ranged from $360,000 to $476,000 in 2012. According to RealFacts (a database publisher specializing in the housing market), the average rent for the City of Tustin was $1,567 in the first quarter of 2013. Tustin has a high percentage of multi - family units compared to other Orange County communities. Approximately 35.1 percent of the housing stock is comprised of single - family attached /detached units while 61.5 percent of the housing stock consists of multi - family units. Additionally, Tustin has an almost equivalent number of renters and owners. In 2010, 50.8 percent of the housing stock was owner - occupied (48.7 percent of the population) and 49.2 percent was renter - occupied (50.6 percent of the population). According to Table H -12 of the Housing Element Update, 192.45 acres of vacant land with residential development potential exists in the City of Tustin, while another 12.85 acres of land with residential development potential are underutilized. Based on established land use densities, this offers a potential for 30,186 total housing units in the City at build out capacity. Of the 192.45 acres of vacant land, 177.1 acres are located at the former MCAS- Tustin and 15.35 acres are located generally in infill neighborhoods. The 12.85 acres of underutilized land are located generally in the Old Town area and other underutilized land throughout the City. The City of Tustin is required, per California Housing Element law, to meet its "fair share" of existing and future housing needs for all income groups. As determined by the Southern California Association of Governments (SCAG), Tustin's "fair share" is 1,227 additional units for the 2013 -2021 planning period. Based on the analysis of vacant land and underutilized land within the City, the majority of the required housing units would be provided at Tustin Legacy, also known as the former Marine Corps Air Station (MCAS) Tustin. Other housing units would be provided through infill developments within the rest of the City. 1. Background Tustin Legacy (former MCAS - Tustin) Tustin Legacy is the portion of the former Marine Corps Air Station (MCAS) Tustin within the City of Tustin corporate boundaries. Owned and operated by the Navy and Marine Corps for nearly 60 years, approximately 1,585 gross acres of property at MCAS Tustin were determined surplus to federal government needs and the base was officially closed in July 1999. The majority of the Tustin Legacy lies within the southern portion of the City of Tustin. The approximately 73 acres lies within the City of Irvine. On January 16, 2001, the City Council adopted a General Plan Amendment to change the City's land use designation for the former MCAS- Tustin from Military and Public /Institutional to the MCAS Tustin Specific Plan. The Specific Plan area is generally bounded by Edinger Avenue to the north, Harvard Avenue to the east, Barranca Parkway to the south, and Red Hill Avenue to the west (Figure 2). A Final Joint Environmental Impact Statement/Environmental Impact Report (FEIS /EIR) for the Disposal and Reuse of Marine Corps Air Station (MCAS) Tustin and Mitigation Monitoring and Reporting Program for the EIS /EIR was prepared by the City of Tustin and the Department of the Navy (DoN) in accordance with the California Environmental Quality Act (CEQA) and the National Environmental Policy (NEPA). The FEIS /EIR analyzed the environmental consequences of the Navy disposal and local community reuse of the MCAS Tustin site per the Reuse Plan and the MCAS Tustin Speck Plan /Reuse Plan. The CEQA analysis also analyzed the environmental impacts of certain "Implementation Actions" that the City of Tustin and City of Irvine must take to implement the MCAS Tustin Specific Plan /Reuse Plan. The Final EIS /EIR for the Disposal and Reuse of the former MCAS- Tustin was certified by the City Council on January 16, 2001. The DoN published its Record of Decision (ROD) on March 3, 2001. On December 6, 2004, the City Council adopted Resolution No. 04 -76 approving a Supplement to the FEIS /EIR for the extension of Tustin Ranch Road between Walnut Avenue and the future alignment of Valencia North Loop Road. On April 3, 2006, the City Council adopted Resolution No. 06-43 approving an Addendum to the FEIS /EIR (herein after referred to as Program EIS /EIR for MCAS- Tustin). And, on May, 13, 2013, the City Council adopted Resolution No. 13 -32 approving a second Addendum to the FEIS /EIR. Infill Developments The infill developments consist of utilizing vacant and underutilized land in other areas of City. The areas include infill neighborhoods primarily in the Old Town area and scattered infill neighborhoods elsewhere in the City (Figure 3). Circumstances surrounding the implementation of the Housing Element Update at the former MCAS - Tustin and in the infill sites are essentially the same. In general, these similar circumstances can be summarized as follows: • Housing units at the former MCAS- Tustin would be developed in an urban setting involving mixed land uses, similar to infill development in other areas of the City; • Development of housing units at former the MCAS- Tustin and infill sites will be required to comply with the City's and State's existing regulations pertaining to air quality, noise, water quality, construction standards, etc. • The former MCAS- Tustin areas and infill sites will generally be served by the same utility system: the former MCAS- Tustin areas will be served by the Irvine Ranch Water District, and infill sites will be served by the Orange County Sanitation District and Tustin Water; • Both the former MCAS- Tustin areas and infill sites will be served by the same public service agencies such as Orange County Fire Authority, Tustin Police Department, Tustin Parks and Recreation Department, etc. • Children living in Tustin Legacy (former MCAS- Tustin) would attend Tustin Unified and Irvine Unified schools and children living in infill sites of Tustin would attend Tustin Unified schools; • Residents from the former MCAS- Tustin and infill sites would utilize existing and future parks and recreational facilities available to all City residents, etc. 4 1. Background Figure 1 Regional Location. 1. Background Figure 2 WAS Tustin Specific Plan Area. Neighborhoods tU WA LEGEND - M07rOMgOD A - COYCAMMN1Lw .. KrirebMAO ! - 011.+OC Mtll!!IO - NDOiMOM /pOD t • RtGdM.l PAM �I;:. Kv710OI1M00 0 - CbrYIMfY COW • Ij 4464MM000 C • OAAYAw Mau . KbiOFM000 r - RC0 "Ll-OWO'EM CIIY KRL 01 IKI • KMNOOFOOO G ' IWC"MiuL "t • 4todo +000 !I - MVNII RC•l(Mnt WV*&f tWSANTA NIA SOUMLMY 9rG 6AilMilC tQ1TLSS3t.G:gfI CFAItA N� i1J�lt4f1'ihG f,CDYb[ ri•L4 nSCnv YSU.`fA. [sYw �Yt tf.0 iCKi »tl. 9E � �4p AY,� MFtiRxffl a5 • Imcfc OL M 60 wNY y :i!(iC.Jtin .,r+sn'+.a Nf30en ld'M[ fiiMC#.t WCM.'' W, AM6(Y('xm Ij 1. Background Figure 3 Vacant & Underutilized Land in the City of Tustin. 4 Und.n,vlaed Land - Vacant Land `r, �y.:. rw , ��• r if N 1. Background U. Surrounding Land Use The City is located in a mature area with a mix of land uses. The surrounding cities of Santa Ana, Orange, unincorporated County of Orange, and Irvine contain a mix of residential, commercial, industrial, and open space uses. 1.3 PROJECT DESCR/PT/oN L Proposed Project The Housing Element is one of the seven General Plan Elements mandated by the State of California, as articulated in Sections 65580 to 65589.8 of the Government Code. State Law requires that the Housing Element consist of "an identification and analysis of existing and projected housing needs and a statement of goals, policies, quantified objectives, and scheduled programs for the preservation, improvement and development of housing." The residential character of the City is, to a large extent, determined by the variety of its housing stock, its location and physical condition. The Housing Element is, therefore, an official municipal response to the need to provide housing for all economic segments of the population. The Housing Element Update provides in -depth analysis of the City's population, economic, household, and household stock characteristics as required by State Law. The Element also provides a comprehensive evaluation of programs and regulations related to priority goals, objectives, and program actions that directly address the needs of Tustin residents. The City of Tustin's General Plan Housing Element and this Housing Element Update detail the City's strategy for enhancing and preserving the community's character, sets forth strategies for expanding housing opportunities for the City's various economics segments, and provides the primary policy guidance for local decision - making related to housing. The Housing Element Update provides the implementation strategies for addressing the housing needs of Tustin residents through the 2013 -2021 planning period. As described in Section 1.2.1, the majority of the housing units required by the Housing Element Update would be provided at the former MCAS- Tustin. Other units would be provided through scattered infill developments within the City. As a result, the initial study prepared for the Housing Element Update focuses primarily on the MCAS- Tustin Speck Plan area. This is because the circumstances of the MCAS- Tustin project studied in the Program EIS /EIR and the Housing Element Update project are similar. TThe Final EIS /EIR for the Disposal and Reuse of the former MCAS- Tustin was certified by the City Council on January 16, 2001. The DoN published its Record of Decision (ROD) on March 3, 2001. On December 6, 2004, the City Council adopted Resolution No. 04 -76 approving a Supplement to the FEIS /EIR for the extension of Tustin Ranch Road between Walnut Avenue and the future alignment of Valencia North Loop Road. On April 3, 2006, the City Council adopted Resolution No. 06-43 approving an Addendum to the FEIS /EIR (herein after referred to as Program EIS /EIR for MCAS- Tustin). And, on May, 13, 2013, the City Council adopted Resolution No. 13 -32 approving a second Addendum to the FEIS /EIR. A copy of the Program EIS /EIR for MCAS- Tustin and its supplement and addenda are available for public review at the City of Tustin Community Development Department located at 300 Centennial Way, Tustin, California 92780. The Housing Element Update is only one facet of the City's overall planning program. The California Government Code requires that General Plans contain an integrated, consistent set of goals and policies. The Housing Element is, therefore, affected by development policies contained in other elements of the General Plan. 1. Background 11. Purpose of Initial Study As discussed in Section 1.1 (Project Location) most of the development of new housing units would take place at the former MCAS- Tustin. The purpose of the initial study is to determine whether the Program EIS /EIR for MCAS- Tustin would adequately describe the project's general environmental setting, significant environmental impacts, project alternatives, and mitigation measures related to each significant impact. The initial study is also designed to determine whether there are any additional, reasonable alternatives or mitigation measures that should be considered as ways of avoiding or reducing the project's significant effects. The City of Tustin is close to its build -out capacity. Opportunities to meet its "fair share" to build an additional 1,227 housing units in the City largely depend on the availability of the former MCAS- Tustin land. This land is the only significant area of vacant and underutilized land that is available in the City to accommodate a large number of housing units. Other vacant lands identified are infill sites scattered throughout the City. The Program EIS /EIR for MCAS- Tustin identified several impact categories where significant impacts to the environment could not be mitigated to an insignificant level, and accordingly a Statement of Overriding Considerations was adopted by the City of Tustin for approval of the General Plan Amendment on January 16, 2001. For the purpose of this initial study, an evaluation has been made to ensure that impacts previously identified relating to this project has not been intensified. Program EIS /EIR for MCAS - Tustin also identified several impact categories where impacts could be lessened to a level of insignificance with the imposition of mitigation measures. Each of these impact categories were analyzed to determine if new impacts associated with the project would occur that were not identified in the Program EIS /EIR. Impact categories not identified to have a potential impact in the Program EIS /EIR for MCAS- Tustin have been reviewed and identified in the initial study to determine if the project would create any additional or new significant impacts which were not considered by the Program EIS /EIR for MCAS- Tustin. 1,4 CITYACT /ON REQUIRED The proposed action is the adoption of the Housing Element Update of the City's General Plan (the "Housing Element Update "). 2. Environmental Checklist 2.1 ENVIRONMENTAL FACTORS OTENTIALLYAFFECTED The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a "Potentially Significant Impact," "More Significant Impact," or "New Significant Impact" as indicated by Environmental Checklist 2(a) and 2(b) from page 10 — 37. ❑ Aesthetics ❑ Agriculture and Forestry ❑ Air Quality Resources ❑ Biological Resources ❑ Cultural Resources ❑ Geology /Soils ❑ Greenhouse Gas ❑ Hazards & Hazardous ❑ Hydrology / Water Quality Emissions Materials ❑ Noise ❑ Land Use / Planning ❑ Mineral Resources El Recreation ❑ Population / Housing ❑ Public Services 17 Mandatory Findings of ❑ Transportationrrrafric El Utilities Utilities I Service Systems 2.2 DETERMINATION: (To Be Completed By the Lead Agency) On the basis of this initial evaluation: ® I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared. ❑ I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared. ❑ I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required. ❑ I find that the proposed project MAY have a "potentially significant impact' or "potentially significant unless mitigated" impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed. ❑ I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required. / Signature: e���13.� Date: Printed Name: Elizabeth A. Binsack Title: Community Development Director Signature: Date: 7 11,13 Preparer: Scott Reekstin Title: Principal Planner 2. Environmental Checklist 2.3 EVALUATION OFENVIRONMENTAL IMPACTS A brief explanation is required for all answers except "No Impact" answers. The environmental checklists 2(A) from pages 12 — 24 and 2(B) from pages 25 — 36 are the starting point of the analysis. Checklist 2(A) describes the environmental conditions related to infill development sites throughout the City of Tustin whereas checklist 2(B) refers to the conditions specific to the former MCAS — Tustin Specific Plan area. In Environmental Checklist 2(A), a "No Impact" answer and a "No Substantial Change from Previous Analysis" answer in Environmental Checklist 2(B) is adequately supported if the referenced information sources show that the impact simply does not apply to projects like the one involved (e.g. the project falls outside a fault rupture zone). A "No Impact" answer is explained where it is based on project - specific factors, as well as general standards (e.g. the project would not expose sensitive receptors to pollutants, based on a project - specific screening analysis). All answers take account of the whole action involved, including off -site and on -site, cumulative and project - level, indirect and direct, and construction and operational impacts. Once the lead agency has determined that a particular physical impact may occur, and then the checklist answers must indicate whether the impact is potentially significant, less than significant with mitigation, or less than significant. "Potentially Significant Impact" is appropriate if there is substantial evidence that an effect may be significant. If there are one or more "Potentially Significant Impact" entries when the determination is made, an EIR is required. Earlier analyses may be used for subsequent activities if the effects of the project have been adequately analyzed in a program EIR. The Program EIS /EIR for MCAS- Tustin has been reviewed to determine if it is adequate for this project. In this case, a brief discussion should identify the following: • Earlier Analysis Used. Identify and state where they are available for review. • Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis. • Mitigation Measures. For effects that are "Less than Significant with Mitigation Measures Incorporated," describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site - specific conditions for the project. Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g. general plans, zoning ordinances). Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated. Supporting Information Sources: A source list should be attached, and other sources used or individuals contacted should be cited in the discussion. 11 2(A). Environmental Checklist Less Than Potentially Significant With Less Than Significant Mitigation Significant No Issues Impact Incorporated Impact Impacts 1. AESTHETICS. Would the project: a) Have a substantial adverse effect on a scenic vista? b) Substantially damage scenic resources, including, but not limited to, trees, rocks, outcroppings, and historic buildings within a state scenic highway? c) Substantially degrade the existing visual character or quality of the site and its surroundings? d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? 11. AGRICULTURE AND FOREST RESOURCES. In determining whether impacts to agricultural resoi are significant environmental effects, lead agencies refer to the California Agricultural Land Evaluation < Assessment Model (1997) prepared by the Californ of Conservation as an optional model to use in asst impacts on agriculture and farmland. In determininc whether impacts to forest resources, including timb, are significant environmental effects, lead agencies refer to information compiled by the California Depa of Forestry and Fire Protection regarding the state': inventory of forest land, including the Forest and M Assessment Project and the Forest Legacy Assess project; and forest carbon measurement methodolc provided in Forest Protocols adopted by the Califor Resources Board. Would the project: a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non - agricultural use? 12 ❑ ❑ ❑ ❑ ❑ ❑ D ❑ ❑ ❑ El E El E El 9 El z ■ ► 2(A). Environmental Checklist c) Conflict with existing zoning for, or cause rezonir ❑ El of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined t Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 61104(g)) t d) Result in the loss of forest land or conversion of ❑ forest land to non - forest use? e) Involve other changes in the existing environmer El Z which, due to their location or nature, could resul in conversion of Farmland, to non - agricultural us or conversion of forest land to non - forest use? III. AIR QUALITY. Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project: a) Less Than D Potentially Significant With Less Than Significant Mitigation Significant No Issues Impact Incorporated Impact Impacts b) Conflict with existing zoning for agricultural use, Violate any air quality standard or contribute ❑ a Williamson Act contract? 1:1 c) Conflict with existing zoning for, or cause rezonir ❑ El of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined t Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 61104(g)) t d) Result in the loss of forest land or conversion of ❑ forest land to non - forest use? e) Involve other changes in the existing environmer El Z which, due to their location or nature, could resul in conversion of Farmland, to non - agricultural us or conversion of forest land to non - forest use? III. AIR QUALITY. Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project: a) Conflict with or obstruct implementation of the D ❑ ❑ applicable air quality plan? b) Violate any air quality standard or contribute ❑ ❑ 1:1 substantially to an existing or projected air quality violation? c) Result in a cumulatively considerable net r_1 ❑ ❑ increase of any criteria pollutant for which the project region is non - attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)? d) Expose sensitive receptors to substantial ❑ El pollutant concentrations? e) Create objectionable odors affecting a El El substantial number of people? 13 2(A). Environmental Checklist Less Than Potentially Significant With Less Than Significant Mitigation Significant No Issues Impact Incorporated Impact Impacts 1 ► r� 7 [ � ] �� Z r7 CST ► � �� 3 t I ►J l � 1 � � 1 Would the project. a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (Including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? 14 u ❑■ , u n IIIIIIII 01 FE] ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ►� ►1 Tol 1 y /1 02 2(A). Environmental Checklist Less Than Potentially Significant With Less Than Significant Mitigation Significant No Issues Impact Incorporated Impact Impacts V. CULTURAL RESOURCES. Would the project. a) Cause a substantial adverse change in the ❑ ❑ ❑ ED significance of a historical resource as defined in § 15064.5? b) Cause a substantial adverse change in the ❑ ❑ El significance of an archaeological resource pursuant to § 15064.5? c) Directly or indirectly destroy a unique E] ❑ ❑ paleontological resource or site or unique geologic feature? d) Disturb any human remains, including p p p those interred outside of formal cemeteries? W. GEOLOGYAND SOILS. Would the project. a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury or death involving: I. Rupture of a known earthquake fault, 1:1 El 11 as delineated on the most recent Alquist - Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. H. Strong seismic ground shaking? ❑ ❑ ❑ III. Seismic - related ground failure, ❑ ❑ E] including liquefaction? iv. Landslides? 1:1 E] v. Result in substantial soil erosion or the 13 loss of topsoil? 15 2(A). Environmental Checklist c) Be located on expansive soil, as defined in Table 18 1 B of the Uniform Building Code (1994), creating substantial risks to life or property? d) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? Vll. GREENHOUSE GAS EMISSIONS Would the project. a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? Vlll. HAZARDS AND HAZARDOUS MATERIALS. Would the project. a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one - quarter mile of an existing or proposed school? iry ❑ ❑ Less Than ❑ Potentially Significant With Less Than Significant Mitigation Significant No Issues Impact Incorporated Impact Impacts b) Be located on a geologic unit or soil that is ❑ ❑ ❑ unstable, or that would become unstable as a result of the project, and potentially result in on- or off -site landslide, lateral spreading, subsidence, liquefaction or collapse? c) Be located on expansive soil, as defined in Table 18 1 B of the Uniform Building Code (1994), creating substantial risks to life or property? d) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? Vll. GREENHOUSE GAS EMISSIONS Would the project. a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? Vlll. HAZARDS AND HAZARDOUS MATERIALS. Would the project. a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one - quarter mile of an existing or proposed school? iry ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ El S El 0 El S 11 0 ��Ql 2(A). Environmental Checklist IX. HYDROLOGYAND WATER QUALITY. Would the project. a) Violate any water quality standards or ❑ ❑ ❑ waste discharge requirements? b) Substantially deplete groundwater 11 ❑ supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table (e.g., the production rate of pre- existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted)? 17 Less Than Potentially Significant With Less Than Significant Mitigation Significant No Issues Impact Incorporated Impact Impacts d) Be located on a site which is included on a list ❑ of hazardous materials sites compiled pursuant to Government Code section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? e) For a project located within an airport land ❑ El 1:1 use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? f) For a project within the vicinity of a private El 7 ❑ airstrip, would the project result in a safety hazard for people residing or working in the project area? g) Impair implementation of or physically ❑ ❑ ❑ interfere with an adopted emergency response plan or emergency evacuation plan? h) Expose people or structures to a significant ❑ El risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands? IX. HYDROLOGYAND WATER QUALITY. Would the project. a) Violate any water quality standards or ❑ ❑ ❑ waste discharge requirements? b) Substantially deplete groundwater 11 ❑ supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table (e.g., the production rate of pre- existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted)? 17 2(A). Environmental Checklist d) Substantially alter the existing drainage D ❑ El pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off -site? e) Create or contribute runoff water which Less Than ❑ ❑ Potentially Significant With Less Than Significant Mitigation Significant No Issues Impact Incorporated Impact Impacts c) Substantially alter the existing drainage ❑ ❑ El 0 pattern of the site or area, including through the alteration of the course of a polluted runoff? stream or river, in a manner which would f) Otherwise substantially degrade water result in substantial erosion or siltation ❑ ❑ on- or off -site? quality? d) Substantially alter the existing drainage D ❑ El pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off -site? e) Create or contribute runoff water which ❑ ❑ would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff? f) Otherwise substantially degrade water ❑ ❑ quality? g) Place housing within a 100 -year flood 1:1 ❑ ❑ hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map? h) Place within a 100 -year flood hazard area ❑ ❑ ❑ structures that would impede or redirect flows? i) Expose people or structures to a 11 E] significant risk of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam? j) Inundation by seiche, tsunami, or ❑ mudflow? 18 2(A). Environmental Checklist Less Than Potentially Significant With Less Than Significant Mitigation Significant No X. LAND USE AND PLANNING. Would the project: a) Physically divide an established community? 13 ❑ ❑ b) Conflict with any applicable land use plan, 1:1 ❑ ❑ policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? c) Conflict with any applicable habitat ❑ ❑ conservation plan or natural community conservation plan? XI. MINERAL RESOURCES. Would the project: a) Result in the loss of availability of a known 1:1 ❑ mineral resource that would be of value to the region and the residents of the state? b) Result in the loss of availability of a locally- El ❑ important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? X11. NOISE. Would the project result in: a) Exposure of persons to or generation of noise EJ ❑ 17 levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? b) Exposure of persons to or generation of E] excessive groundborne vibration or groundborne noise levels? c) A substantial permanent increase in ambient ❑ ❑ noise levels in the project vicinity above levels existing without the project? 19 ►.1 /1 ►/ ►5 ►:1 TI ./ TO, 2(A). Environmental Checklist e) For a project located within an airport land ❑ n ❑ use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? f) For a project within the vicinity of a private E] ❑ ❑ airstrip, would the project expose people residing or working in the project area to excessive noise levels? F_�I1�1�1a ►1i���r�7�T t � � . • � Would the project: a) Induce substantial population growth in an El ❑ El area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of road or other infrastructure)? b) Displace substantial numbers of existing El ❑ El housing, necessitating the construction of replacement housing elsewhere? c) Displace substantial numbers of people, ❑ E] ❑ necessitating the construction of replacement housing elsewhere? 20 Less Than Potentially Significant With Less Than Significant Mitigation Significant No Issues Impact Incorporated Impact Impacts d) A substantial temporary or periodic increase ❑ in ambient noise levels in the project vicinity above levels existing without the project? e) For a project located within an airport land ❑ n ❑ use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? f) For a project within the vicinity of a private E] ❑ ❑ airstrip, would the project expose people residing or working in the project area to excessive noise levels? F_�I1�1�1a ►1i���r�7�T t � � . • � Would the project: a) Induce substantial population growth in an El ❑ El area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of road or other infrastructure)? b) Displace substantial numbers of existing El ❑ El housing, necessitating the construction of replacement housing elsewhere? c) Displace substantial numbers of people, ❑ E] ❑ necessitating the construction of replacement housing elsewhere? 20 2(A). Environmental Checklist Less Than Potentially Significant With Less Than Significant Mitigation Significant No Issues Impact Incorporated Impact Impacts XIV. PUBLIC SERVICES. Would the project: a) Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: 1. Fire protection? lf. Police protection? iii. Schools? iv. Parks? v. Other public facilities? XV. RECREATION. Would the project: a) Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which have an adverse physical effect on the environment? 21 ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ► ►1 2(A). Environmental Checklist XW. TRANSPORTATION/ TRAFFIC. Would the project., a) Conflict with an applicable plan, ordinance or ❑ policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non - motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit? b) Conflict with an applicable congestion management program, including, but not limited to level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways? c) Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks? d) Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? e) Result in inadequate emergency access? f) Conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities? FFa ❑O 01 ❑M ❑ Less Than ❑ Potentially Significant With Less Than Significant Mitigation Significant No Issues Impact Incorporated Impact Impacts XW. TRANSPORTATION/ TRAFFIC. Would the project., a) Conflict with an applicable plan, ordinance or ❑ policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non - motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit? b) Conflict with an applicable congestion management program, including, but not limited to level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways? c) Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks? d) Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? e) Result in inadequate emergency access? f) Conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities? FFa ❑O 01 ❑M ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑O ►0 ►/ El E El Z -2(A). Environmental Checklist Less Than Potentially Significant With Less Than Significant Mitigation Significant No Issues Impact Incorporated Impact Impacts XVI I UTILITIES AND SERVICE SYSTEMS. Would the project. a) Exceed wastewater treatment requirements of 11 the applicable Regional Water Quality Control Board? b) Require or result in the construction of new 17 ❑ water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? c) Require or result in the construction of new E] 0 storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? d) Have sufficient water supplies available to E] n ❑ serve the project from existing entitlements and resources, or are new or expanded entitlements needed? e) Result in a determination by the wastewater E] ❑ ❑ treatment provider which serves or may serve the project that it has adequate capacity to serve the project's projected demand in addition to the provider's existing commitments? f) Be served by a landfill with sufficient permitted E] n ❑ capacity to accommodate the project's solid waste disposal needs? g) Comply with federal, state, and local statutes ❑ and regulations related to solid waste? 23 2(A). Environmental Checklist Less Than Potentially Significant With Less Than Significant Mitigation Significant No Issues Impact Incorporated Impact Impacts XW1I MANDATORY FINDINGS OF SIGNIFICANCE a) Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self- sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? b) Does the project have impacts that are D ❑ El 0 individually limited, but cumulatively considerable? ( "Cumulatively considerable" means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current project, and the effects of probable future projects.) c) Does the project have environmental effects F-1 ❑ which will cause substantial adverse effects on human beings, either directly or indirectly? Note: Authority cited: Sections 21083 and 21083.05, Public Resources Code. Reference: Section 65088.4, Gov. Code; Sections 21080(c), 21080.1, 21080.3, 21082.1, 21083, 21083.05, 21083.3, 21093, 21094, 21095, and 21151, Public Resources Code; Sundstrom v. County of Mendocino, (1988) 202 Cal.App.3d 296; Leonoff v. Monterey Board of Supervisors, (1990) 222 Cal.App.3d 1337; Eureka Citizens for Responsible Govt. v. City of Eureka (2007) 147 Ca1.App.4th 357; Protect the Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal.App.4th at 1109; San Franciscans Upholding the Downtown Plan v. City and County of San Francisco (2002) 102 Ca1.App.4th 656. See Section 3 for narrative support for the conclusions identified in this checklist. 24 2(01:3). Environmental Checklist New Significant More Severe No Substantial Impact Impacts Change From Previous Issues Analysis 1. AESTHETICS. Would the project. a) Have a substantial adverse effect on a scenic vista? b) Substantially damage scenic resources, including, but not limited to, trees, rocks, outcroppings, and historic buildings within a state scenic highway? c) Substantially degrade the existing visual character or quality of the site and its surroundings? d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? 11. AGRICULTURE AND FOREST RESOURCES. In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state's inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project. a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non- agricultural use? 25 ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ 2(B). Environmental Checklist New Significant More Severe No Substantial Impact Impacts Change From Previous Issues Analysis b) Conflict with existing zoning for agricultural use, Conflict with or obstruct implementation of the ❑ ❑ or a Williamson Act contract? applicable air quality plan? c) Conflict with existing zoning for, or cause b) Violate any air quality standard or contribute rezoning of, forest land (as defined in Public El Resources Code section 12220(g)), timberland (as defined by Public Resources Code section violation? 4526), or timberland zoned Timberland c) Result in a cumulatively considerable net increase El Production (as defined by Government Code of any criteria pollutant for which the project region section 51104(g))? d) Result in the loss of forest land or conversion of El forest land to non - forest use? state ambient air quality standard (including e) Involve other changes in the existing releasing emissions which exceed quantitative environment which, due to their location or thresholds for ozone precursors)? nature, could result in conversion of Farmland, d) to non - agricultural use or conversion of forest ❑ land to non- forest use? concentrations? Ill. AIR QUALITY. Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project. a) Conflict with or obstruct implementation of the ❑ ❑ applicable air quality plan? b) Violate any air quality standard or contribute ❑ El substantially to an existing or projected air quality violation? c) Result in a cumulatively considerable net increase El ❑ of any criteria pollutant for which the project region is non - attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)? d) Expose sensitive receptors to substantial pollutant ❑ concentrations? e) Create objectionable odors affecting a substantial ❑ ❑ number of people? M 2(B). Environmental Checklist New Significant More Severe No Substantial Impact Impacts Change From Previous Issues Analysis Would the project. a) Have a substantial adverse effect, either directly E or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? b) Have a substantial adverse effect on any El 1:1 riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? c) Have a substantial adverse effect on federally ❑ ❑ IR protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? d) Interfere substantially with the movement of any 0 ❑ native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? e) Conflict with any local policies or ordinances ❑ F1 protecting biological resources, such as a tree preservation policy or ordinance? f) Conflict with the provisions of an adopted ❑ Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? 27 2(B). Environmental Checklist New Significant More Severe No Substantial Impact Impacts Change From Previous Issues Analysis Would the project. a) Cause a substantial adverse change in the significance of a historical resource as defined in § 15064.5? b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5? c) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? d) Disturb any human remains, including those interred outside of formal cemeteries? A GEOLOGYAND SOILS. Would the project. a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury or death involving: I. Rupture of a known earthquake fault, as delineated on the most recent Alquist- Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. H. Strong seismic ground shaking? 111. Seismic - related ground failure, including liquefaction? iv. Landslides? v. Result in substantial soil erosion or the loss of topsoil? b) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off -site landslide, lateral spreading, subsidence, liquefaction or collapse? W., C ■ a A■ [it' ❑■ ■ C Fo ❑ ■ 3 0 a OR �1 ►1 1� ► 1 2(B). Environmental Checklist New Significant More Severe No Substantial Impact Impacts Change From Previous Issues Analysis c) Be located on expansive soil, as defined in Table 18 1 ❑ E B of the Uniform Building Code (1994), creating substantial risks to life or property? d) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? Vll. GREENHOUSE GAS EMISSIONS Would the project: a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? Vlll. HAZARDS AND HAZARDOUS MATERIALS. Would the project: a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions Involving the release of hazardous materials into the environment? c) Emit hazardous emissions or handle hazardous or 1:1 acutely hazardous materials, substances, or waste within one - quarter mile of an existing or proposed school? d) Be located on a site which is included on a list of 11 ❑ hazardous materials sites compiled pursuant to Government Code section 65962.5 and, as a result, would it create a significant hazard to the public or thi environment? M 2(B). Environmental Checklist 30 Issues New Significant More Severe No Substantial Impact Impacts Change From Previous Analysis e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? f) For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area? g) Impair implementation of or physically interfere ❑ with an adopted emergency response plan or emergency evacuation plan? h) Expose people or structures to a significant risk of El ❑ ED loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands? IX. HYDROLOGYAND WATER QUALITY. Would the project. a) Violate any water quality standards or waste discharge requirements? b) Substantially deplete groundwater supplies or E interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table (e.g., the production rate of pre- existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted)? c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or off -site? d) Substantially alter the existing drainage El ❑ pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on -or off -site? 30 2(B). Environmental Checklist New Significant More Severe No Substantial Impact Impacts Change From Previous Issues Analysis e) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? f) Otherwise substantially degrade water quality? M ❑ g) Place housing within a 100 -year flood hazard area ❑ n as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map? h) Place within a 100 -year flood hazard area El 1:1 structures that would impede or redirect flows? i) Expose people or structures to a significant D risk of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam? J) Inundation by seiche, tsunami, or mudflow? X. LAND USE AND PLANNING. Would the project. a) Physically divide an established community? M b) Conflict with any applicable land use plan, policy, ❑ ID or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? c) Conflict with any applicable habitat conservation E plan or natural community conservation plan? X1. MINERAL RESOURCES. Would the project. a) Result in the loss of availability of a known mineral ❑ E resource that would be of value to the region and the residents of the state? b) Result in the loss of availability of a locally- ❑ E-1 important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? 31 2(B). Environmental Checklist New Significant More Severe No Substantial Impact Impacts Change From Previous Issues Analysis E f(1Mw77ORM Would the project result in: a) Exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? b) Exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels? c) A substantial permanent increase in ambient noise 1:1 ❑ levels in the project vicinity above levels existing without the project? d) A substantial temporary or periodic increase in D ambient noise levels in the project vicinity above levels existing without the project? e) For a project located within an airport land use plan El ❑ or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? f) For a project within the vicinity of a private airstrip, ❑ F1 would the project expose people residing or working in the project area to excessive noise levels? Kill. POPULATION AND HOUSING. Would the project: a) Induce substantial population growth in an area, E] ❑ either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of road or other infrastructure)? b) Displace substantial numbers of existing housing, ❑ ❑ necessitating the construction of replacement housing elsewhere? c) Displace substantial numbers of people, El 11 necessitating the construction of replacement housing elsewhere? 32 2(B). Environmental Checklist New Significant More Severe No Substantial Impact Impacts Change From Previous Issues Analysis XIV.. PUBLIC SERVICES. Would the project. a) Result in substantial adverse physical impacts Cl associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptal service ratios, response times or other performance objectives for any of the public services: I. Fire protection? F71 El H. Police protection? ❑ ❑ Ill. Schools? ❑ ❑ iv. Parks? n n v. Other public facilities? ❑ XV. RECREATION. Would the project. a) Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which have an adverse physical effect on the environment? 33 ❑■ IN X ❑■ /1 / -1 2(B). Environmental Checklist New Significant More Severe No Substantial Impact Impacts Change From Previous Issues Analysis XW. TRANSPORTATION/ TRAFFIC. Would the project: a) Conflict with an applicable plan, ordinance or ❑ ❑ policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non - motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit? b) Conflict with an applicable congestion ❑ ❑ management program, including, but not limited to level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways? c) Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks? d) Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? e) Result in inadequate emergency access? ❑ Q Conflict with adopted policies, plans, or ❑ ❑ programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities? 34 2(B). Environmental Checklist New Significant More Severe No Substantial Impact Impacts Change From Previous XVI I UTILITIES AND SERVICE SYSTEMS. Would the project. a) Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board? b) Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? c) Require or result in the construction of new 13 D storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? d) Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed? e) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project's projected demand in addition to the provider's existing commitments? f) Be served by a landfill with sufficient permitted capacity to accommodate the project's solid waste disposal needs? g) Comply with federal, state, and local statutes ❑ ❑ and regulations related to solid waste? 35 2(01-3). Environmental Checklist New Significant More Severe No Substantial Impact Impacts Change From Previous Issues Analvsis XWII MANDATORY FINDINGS OF SIGNIFICANCE a) Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self- sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? b) Does the project have impacts that are individually ❑ limited, but cumulatively considerable? ( "Cumulatively considerable" means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current project, and the effects of probable future projects.) c) Does the project have environmental effects which E3 11 will cause substantial adverse effects on human beings, either directly or indirectly? See Section 3 for narrative support for the conclusions identified in this checklist. G 2. Environmental Checklist 2.4 REFERENCES No. Reference 1. City of Tustin General Plan. 2. City of Tustin Draft Housing Element Update, 2013. 3. Tustin City Code 4. State Department of Finance, Population, and Housing Estimates. 5. Final Environmental Impact Statement/Environmental Impact Report (EIS /EIR) for the Disposal and Reuse of MCAS- Tustin (Program EIS /EIR for MCAS- Tustin), January 16, 2001, Supplement and its addenda. 6. Marine Corps Air Station (MICAS) Tustin Specific Plan /Reuse Plan, October 1996 and September 1998 Errata adopted by the City Council February, 2003 and its amendments. 37 3. Environmental Analysis The previous Section 2.3 provided a checklist of environmental impacts. This section provides an evaluation of the impact categories and questions contained in the checklist, and it identifies mitigation measures where applicable. Mitigation measures identified in the Program EIS /EIR for MCAS- Tustin shall be implemented through implementation of the Specific Plan for the former MCAS- Tustin. 3.1 AESTHET ICS a) Have a substantial adverse effect on a scenic vista? b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? Development anticipated by the Housing Element Update would be located in mostly urbanized areas or areas that are planned to be urbanized that are not part of scenic vistas. No scenic vistas are located in the vicinity of any proposed development locations such as, infill developments identified in Table H -14 and Figure 1 of the Housing Element Update, and potential residential development at the Tustin Legacy. Further, the City of Tustin does not contain any City- or County- designated scenic highways. Therefore, implementation of the proposed project would not create significant impacts on scenic vista, scenic resources, and scenic highway. Mitigation Measures/Monitoring Required. No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -81 to 4 -87) and Addendum (Pages 5 -3 to 5- 7) c) Substantially degrade the existing visual character or quality of the site and its surroundings? The proposed project provides for 1,227 units for development. The majority of these housing units would be constructed within the Tustin Legacy (MCAS Tustin Specific Plan). As each component of the Specific Plan is developed, there would be visual contrast created as previously undeveloped land at the Tustin Legacy converts to urban uses or existing structures are demolished. The visual quality of the project sites would be improved through application of the speck urban design features such as landscaping, as development occurs. Mitigation Measure Vis -1 of the Program EIS /EIR for MCAS- Tustin would provide measures to reduce the potential visual impacts to a level of insignificance. Infill developments outside of the Tustin Legacy would be developed in accordance with the City's Land Use Element and development standards and would not create a demonstrable negative aesthetic effect to the City's visual qualities. With the City's existing Design Review process that requires specific findings for development compatibility with the surroundings, including height and bulk of the building, exterior materials and colors, landscaping, etc., it is not anticipated that future infill developments would create any significant visual impacts. Mitigation Messures/Monitoring Required: No further mitigation measures would be required beyond those identified in the Program EIS /EIR for MCAS- Tustin, which are hereby incorporated by reference. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -81 to 4 -87) and Addendum (Pages 5 -3 to 5- 7) d) Create a new source of substantial light or glare, which would adversely affect day or nighttime views in the area? New development in accordance with the City's Housing Element Update would create new sources of light and glare such as exterior lighting, lighting of streets and walkways, and interior lighting which 38 3. Environmental Analysis could be visible from the outside. However, the development would not result in any impacts beyond those identified in the Program EIS /EIR for MCAS- Tustin. To minimize potential light and glare impacts for infill developments, future development would be required to comply with Tustin's Security Ordinance. , In addition, the lights and glare 'shall be controlled through design controls and building materials restrictions as part of the City's existing Design Review process. The Design Review process requires specific findings to be made for development compatibility with its surroundings including exterior illumination. Mitigation Measures/Monitoring Required: No further mitigation measures would be required beyond those identified in the Program EIS /EIR for MCAS- Tustin, which are hereby incorporated by reference. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -81 to 4 -87) and Addendum (Pages 5 -3 to 5- 7) 3.2 AGRICULTURE RESOURCES a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non - agricultural use? According to the Farmland Mapping and Monitoring Program, the City of Tustin had Prime Farmland located at the Tustin Legacy. The implementation of the MCAS Tustin Specific Plan would result in a significant adverse effect of converting prime agricultural land to a variety of urban uses. Approximately 289 acres of Prime Farmland would ultimately be developed with housing units. The Program EIS /EIR for MCAS- Tustin has provided detailed analysis of the alternatives and potential mitigation measures and concluded that the impact is unavoidable. Other available vacant or underutilized land within the City identified as potential land for residential developments are not zoned or used for agricultural uses. Therefore, no significant impacts to farmland resources would result from the development of these infill lands. The implementation of the Housing Element Update would potentially result in a significant impact of converting agricultural land to urban uses at the Tustin Legacy area. However, the implementation of the Housing Element Update would not result in any impacts beyond those identified in the Program EIS /EIR for MCAS- Tustin. No further mitigation measures would be required. Mitigation Measures/Monitoring Required., No mitigation measures were determined to be feasible for MCAS- Tustin. A Statement of Overriding Considerations was adopted. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -109 to 4 -113) and Addendum (Pages 5 -8 to 5 -9) 39 3. Environmental Analysis b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? The City of Tustin General Plan does not include any land designated for agricultural use. Furthermore, there is no land zoned solely for agricultural purposes or covered by a Williamson Act contract in the City. The Williamson Act was adopted in 1965 and established a voluntary farmland conservation program which restricts contracted land to agricultural and /or open space uses for at least ten years. Landowners who enroll their lands would receive preferential tax treatment based on the actual use of the land for agricultural purposes, as opposed to the unrestricted market value. The previous interim agricultural uses at the former MCAS - Tustin have been discontinued since preparation of the Program EIS /EIR for MCAS- Tustin, nor are infill developments areas within the City under a Williamson Act contract. Mitigation Measures/Monitoring Required., No mitigation measures are necessary. Sources: Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -109 to 4 -113) and Addendum (Pages 5 -8 to 5 -9) c) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non - agricultural use? The City of Tustin General Plan does not contain any land designated for agricultural use. Furthermore, there is no land zoned solely for agricultural purposes. Except for those impacts identified under Section 3.2 (a) above, there is no evidence or changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non - agricultural use. Mitigation Measures/Monitoring Required: No mitigation measures are required. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -109 to 4 -113) and Addendum (Pages 5 -8 to 5 -9) 3.3 A/R QUAL/ry a) Conflict with or obstruct implementation of the applicable air quality plan? b) Violate any air quality standard or contribute substantially to an existing or projected air quality violation? c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non - attainment under an applicable federal or state ambient air quality standard (including releasing emissions that exceed quantitative thresholds for ozone precursors)? d) Expose sensitive receptors to substantial pollutant concentrations? The Housing Element Update identifies an assigned fair share growth in the City for 1,227 new housing units from 2013 - 2021. According to the South Coast Air Quality Management District CEQA Air Quality Handbook, the air quality impacts of the development of 1,227 dwelling units would exceed the District's threshold of significance. New development would generate pollutant emissions due to new vehicle trips, use of construction equipment, and off -site power and natural gas generation. During the construction phases of individual development projects, construction vehicles and activities would also generate emissions. Air pollutant emissions associated with the project could occur over the short-term for demolition, site preparation and construction activities to support the proposed land use. in addition, emissions could result from the long -term operation of the completed development. 40 3. Environmental Analysis Short-Term Construction - Related Im Short-term emissions are those occurring during the construction phases of individual developments in the City. Air quality impacts may occur during the site preparation and construction activities required to prepare the proposed on -site land use. Major sources of emissions during this phase include exhaust emissions generated during demolition of an existing structure, site preparation and subsequent structure erection and fugitive dust generated as a result of soil disturbances during excavation activities. The Program EIS /EIR for MCAS- Tustin identifies impacts that would result from the construction of the housing units at the Reuse Plan area. To minimize these impacts, future development projects would be required to comply with specific construction control measures identified in mitigation measure AQ -1 and AQ -2, if not already required by the SCAQMD Rule 403 related to wind entrainment of fugitive dust. These mitigation measures are incorporated herein. For infill developments, the City will require compliance with AQMD Rule 403 related to air quality construction control measures and the City's standard construction control measures (i.e. controlling construction parking to minimize traffic interference, providing temporary traffic control during construction activities to improve traffic flow, etc.). This would reduce air quality construction - related impacts to a less than significant level. Long -Term Air Quality Impacts Long -term air quality impacts are those associated with the emissions produced from project - generated vehicle trips as well as from stationary sources related to the use of natural gas for heating and use of electricity for lighting and ventilation. The net increase in new development anticipated by the Housing Element Update is related to a change in the number of housing units and additional vehicle trips. Long -term emissions from mobile (vehicular) and stationary sources within the Reuse Plan area are identified in the Program EIS /EIR for MCAS- Tustin as significant and unavoidable. Mitigation measure AQ-4 related to individual development's Transportation Demand Management (TDM) plan would reduce the impact, but there are no feasible mitigation measures that will reduce the impact to a less- than - significant level. A statement of overriding consideration was adopted. Long -term emissions resulting from infill developments are insignificant if developed individually but could be significant cumulatively. These impacts shall be reduced through urban design planning as suggested in the CEQA Air Quality Handbook prepared by the South Coast Air Quality Management District (i.e. incorporation of bus turnouts, pedestrian friendly site design, provision for bike lanes, etc.). Through the City's Design Review process, these design measures shall be determined on a case -by -case basis as developments are proposed. Compliance with these measures would reduce impacts related to long -term emission to a less than significant level. Consistency with South Coast Air Basin (SCAB) Air Quality Management Plan (AQMP) The City's measures related to air quality for infill development and development of the Tustin Legacy have been identified in the 2007 AQMP prepared by the SCAQMD. In summary, development anticipated by the Housing Element Update is in compliance with the growth projections in the City's Land Use and Circulation Elements. The implementation of the Housing Element Update would result in both short-term and long -term impacts. These impacts include construction - related impacts associated with clearing and grading of the site and construction of building and infrastructure and operational impacts attributable to air emissions from vehicular travel and generation of air contaminants by the development. These impacts would not result beyond those identified in the Program EIS /EIR for MCAS- Tustin. No further mitigation measures would be required beyond those identified in the Program EIS /EIR for MCAS- Tustin. Infill developments would be evaluated on an individual basis when the specific development is proposed. Such development must comply with the City's Design Review process and would be required to reduce potential impacts to a less than significant level. In addition, under CEQA, the degree of specificity required in an environmental review corresponds to the degree of specificity 41 3. Environmental Analysis involved in the project (14 C.G.R. § 15146). Thus, an environmental analysis of the adoption of a general plan element will necessarily be much more general than an environmental review on a construction project. Mitigation Measures/Monitoring Required: A Statement of Overriding Considerations was adopted by the City of Tustin. No further mitigation measures would be required beyond those identified in the Program EISIEIR for MCAS- Tustin, which are hereby incorporated by reference. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -207 to 4 -224) and Addendum (Pages 5 -10 to 5 -27) e) Create objectionable odors affecting a substantial number of people? Odors are one of the most obvious forms of air pollution to the general public. Odors can present significant problems for both the source and the surrounding community. Although offensive odors seldom cause physical harm, they can cause agitation, anger, and concern to the general public. Most people determine an odor to be offensive (objectionable) if it is sensed longer than the duration of a human breath, typically 2 to 5 seconds. The potential odors associated with the project are from the application of asphalt and paint during construction periods. These odors, if perceptible, are common in the environment and would be of very limited duration. In addition, due to their nature as residential housing units, no obnoxious odor would result from development of housing units identified in the Housing Element Update. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin 3.4 BIOLOGICAL a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? c) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? d) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? e) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional or state habitat conservation plan? Biological resources include plant and animal species and the habitats or communities within which they occur. The implementation of the Housing Element Update consists of development within the former MCAS- Tustin and infill areas outside the former MCAS- Tustin area. Impacts associated with Biological Resources within the former MCAS- Tustin area would occur at the construction phase for implementing the Reuse Plan development. in general, impacts can be summarized as follows: 42 3. Environmental Analysis Vegetation Vegetation in the Reuse Plan can generally be categorized as low quality cultivated fields or non- native grassland. The agricultural fields on the former Air Station were regularly cultivated with row crops. Because of the agricultural and historic military uses, the cultivated fields and landscaped areas do not provide suitable habitat for rare plant species known from the region. In addition, the Program FEIS /EIR determined that replacement of the agricultural fields, non - native grassland, and ornamental landscaping with the development of housing units was not considered to be significant because of the low quality vegetation and past disturbances on the site. As such no mitigation measure related to vegetation is necessary. Wildlife. Sensitive, Threatened. and Endangered Wildlife Species Industrial, commercial, and residential land uses surrounding the Tustin Legacy and other vacant land area typically would limit a site's value as wildlife habitat. The Program EIS /EIR for MCAS- Tustin identified Southwestern Pond Turtle, "species of special concern," within the MCAS boundary; however, based upon the analysis in the Program EIS /EIR, the sighting was found within areas identified for development of commercial and commercial businesses. Therefore, no impact to southwestern pond turtle habitat would result from the implementation of the Housing Element Update at the former MCAS- Tustin. Nevertheless, Mitigation measures were included in the Program FEIS /EIR to require the relocation of the turtles and establishment of an alternative off -site habitat, and to require the applicant to obtain Section 404, Section 1601, and other permits as necessary for areas on the project site affecting jurisdictional waters of the U.S. or vegetated wetlands. Infill developments identified in Table H -14 and H -15 of the Housing Element Update would occur in the urbanized area of the City. The properties are not located on any riparian habitat or other sensitive natural community. Therefore, it is not anticipated that the sites would contain endangered wildlife, protected riparian habitats, or any other biological resources. Mitigation Measures/Monitoring Required: No further mitigation measures would be required beyond those identified in the Program EIS /EIR for MCAS- Tustin, which are hereby incorporated by reference. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -103 to 4 -107) and Addendum (Pages 5 -28 to 5 -39) f) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? The development of housing units within the MCAS- Tustin Reuse Plan would have impacts to wetlands. The Reuse Plan is situated in the Tustin Plain, which is underlain by the Irvine groundwater basin. The site is situated in historic marshland which was filled over 60 years ago for cultivation. The Peters Canyon Channel, an unlined drainage channel, traverses the former MCAS - Tustin area. The Program EIS /EIR identified impacts to jurisdictional waters total approximately 16.64 acres, including 13.88 acres of temporary impacts and 2.76 acres of permanent impacts. The Program EIS /EIR has identified mitigation measures to reduce impacts associated with jurisdictional waters and wetlands to a level of insignificance. These mitigation measures are incorporated herein. Infill development sites identified in Table H -14 and H -15 of the Housing Element Update are not located on federally protected wetlands. As such, no impact would result from the development of the sites. In summary, the implementation of the Housing Element Update, particularly the development at the Tustin Legacy, would potentially create impacts to vegetated and seasonal wetlands. The Program 43 3. Environmental Analysis EIS /EIR for MCAS- Tustin identifies wetland impact mitigation. There would not be any additional impacts beyond those identified in the Program EIS /EIR for MCAS- Tustin. Mitigation Measures/Monitoring Required: No further mitigation measures would be required beyond those identified in the Program EIS /EIR for MCAS- Tustin. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -103 to 4 -107) and Addendum (Pages 5 -26 to 5 -39) 3.5 CULTUR4L RESOURCES a) Cause a substantial adverse change in the significance of a historical resource as defined in §15064.5? Section 10564.5 defines historic resources as resources listed or determined to be eligible for listing by the State Historical Resources Commission, a local register of historical resources, or the lead agency. Generally a resource is considered to be "historically significant," if it meets one of the following criteria: i. Is associated with events that have made a significant contribution to the broad patterns of California's history and cultural heritage; it. Is associated with the lives of persons important in our past; ill. Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or Iv. Has yielded, or maybe likely to yield, information important in prehistory or history ( §15064.5) The majority of the construction of residential units described in the Housing Element Update would occur at Tustin Legacy. The Program FEIS /EIR identified two discontiguous eligible historic districts in which two hangars are located in Tustin Legacy as historic resources. Pursuant to Section 106, the State Historic Preservation, the Advisory Council on Historic Preservation, the Navy, the City of Tustin, and the County of orange executed a Memorandum of Agreement (MOA) that identifies measures to mitigate the effects of the destruction of portions of the eligible historic district, including the hangars. If financially feasible for adaptive reuse, both blimp hangars would be preserved. However, if it is determined that it is not financially feasible to retain either of the hangars, removal of the hangars was determined to be a significant unavoidable impact pursuant to CEQA. There is no new technology or methods available to reduce the identified significant unavoidable project - specific and cumulative impacts to historical resources to a level considered less than significant. Therefore, these unavoidable project - specific and cumulative impacts also occur with development of housing units at Tustin Legacy. A Statement of Overriding Consideration for the FEIS /EIR was adopted by the Tustin City Council on January 16, 2001, to address potential significant unavoidable impacts to historical resources resulting from the removal of the historic resources. No substantial change for MCAS Tustin is expected from the analysis previously completed in the FEIS /EIR, its Supplement and Addenda. Infill developments may occur within the City's designated Cultural Resources Overlay District. Development within this district is required to comply with development standards in the Zoning Code, including a Design Review process in the District. The Design Review process requires specific findings to be made to ensure the proposed design is compatible and consistent with the City's Cultural Resources District design criteria and development standards. Compliance with the City's Design Review and Certificate of Appropriateness procedures would reduce potential impacts to a level of insignificance. 44 3. Environmental Analysis Mitigation Measures/Monitoring Required: A Statement of Overriding Considerations was adopted by the City Council. Applicable mitigation measures have been adopted by the Tustin City Council in the Program FEIS /EIR; these measures are incorporated herein. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -93 to 4 -99) and Addendum (Pages 5 -40 to 5-45) b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5? Impacts to archeological sites are considered significant only if the sites themselves are deemed significant. The majority of the housing development identified in the Housing Element Update would be located in the Tustin Legacy. To determine if there are any archeological sites located in the Tustin Legacy, various surveys were conducted. In summary, one archeological site was recorded but it is believed to have been destroyed. The State Historic Preservation Office (SHPO) has concurred with the assessment that the site has been adequately surveyed and the site has been considered to be insignificant due to its lack of integrity. Therefore, there would not be an adverse effect on the one known archeological resource in the Tustin Legacy. Grading activities at the Tustin Legacy, however, may uncover buried archeological resources. In this case, appropriate mitigation measures were identified in the Program EIS /EIR for MCAS- Tustin and are incorporated herein. Infill developments outside of the Tustin Legacy are located in the urbanized areas of the City. The City's General Plan does not identify the infill sites as sensitive areas and there are no known archeological resources exist in the infill sites. However, through City's standard procedures and policies, if buried archeological resources are found, certified archeologists would need to be retained to assess the site significance and perform appropriate mitigation. The implementation of Housing Element Update would not result in any impacts beyond those identified in the Program EIS /EIR for MCAS- Tustin. Mitigation Measures/Monitoring Required: No further mitigation measures would be required beyond those identified in the Program EIS /EIR for MCAS- Tustin. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -93 to 4 -99) and Addendum (Pages 5 -40 to 5 -45) c) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? Development anticipated by the housing element would be located mostly in the Tustin Legacy. Grading in the Tustin Legacy may destroy geological deposits within which unique paleontological resources are buried. In anticipation of possible impacts to resources, a Paleontological Resources Management Plan (PRMP) has been prepared which would apply to any type of grading /development activity at the Reuse Plan. The Program EIS /EIR for MCAS- Tustin has incorporated mitigation measures to reduce potential impacts to less than significant levels by requiring certified paleontologists to be retained to assess the site significance of archeological resources and conduct salvage excavation of unique paleontological resources, if they are found. Infill developments would be located in the urbanized areas. The City's General Plan does not identify the infill sites as sensitive areas and there are no known paleontological resources exist in the infill sites. However, through City's standard procedures and policies, if buried paleontological resources are found, a certified paleontologist would need to be retained to assess the site significance and perform appropriate mitigation. 45 3. Environmental Analysis The implementation of Housing Element Update would not result in any impacts beyond those identified in the Program EIS /EIR for MCAS- Tustin. Mitigation Measures/Monitoring Required., No further mitigation measures would be required beyond those identified in the Program EIS /EIR for MCAS- Tustin. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -93 to 4 -99) and Addendum (Pages 5 -40 to 5 -45) d) Disturb any human remains, including those interred outside of formal cemeteries? Due to past agricultural uses at the Tustin Legacy and current urbanized character of the City, it is considered highly unlikely that any human remains would be uncovered due to the proposed project. For development in the Tustin Legacy, the Program EIS /EIR for MCAS- Tustin has incorporated mitigation measures to reduce potential impacts to less than significant levels by requiring a certified archeologist to be retained to assess the site significance of archeological resources and conduct salvage excavation if any human remains are found. Infill developments would be located in the urbanized areas. Although unlikely, grading of these sites may uncover human remains. if any human remains are found during grading, a qualified archaeologist would be required to assess the site significance and perform the appropriate mitigation. The implementation of the Housing Element Update would not result in any impacts beyond those identified in the Program EIS /EIR for MCAS- Tustin. Mitigation Measures/Monitoring Required., No further mitigation measures would be required beyond those identified in the Program EIS /EIR for MCAS- Tustin. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -93 to 4 -99) and Addendum (Pages 5 -40 to 5 -45) 3.6 GEOLOGYAND SO /LS a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: I. Rupture of a known earthquake fault, as delineated on the most recent Alquist - Priolo Earthquake Fault Zoning map, issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. ii. Strong seismic ground shaking? iii. Seismic - related ground failure, including liquefaction? iv. Landslides? Geotechnical hazards that may affect the development of housing units within the Reuse Plan area and Infill areas are either related to seismic events or non - seismic events. Geotechnical hazards not related to earthquake activity include local settlement, regional subsidence, expansive soils, construction - related slope instability, erosion, landslides, and mudflows. Seismic hazards include surface default displacement, high - intensity ground shaking, and ground failure, ground lurching, tsunami and seiches, and flooding attributable to dam failure after an earthquake. According to the City's General Plan, there are several unnamed faults within 10 to 45 miles of the City, mapped by the Division of Mines and Geology. The fault with the most potential for activity is the El Modena Fault; however, it and all other faults are considered inactive. The City does not lie FRI 3. Environmental Analysis within the bounds of an "Earthquake Fault Zone," as defined by the State of California in the Alquist- Priolo Earthquake Fault Zoning Act. There are a number of faults in the southern California area which are considered active and which could have an effect on the site in the form of moderate to strong ground shaking, should they be the source of an earthquake. These include, but are not limited to: the San Andreas Fault, the San Jacinto fault, the Whittier - Elsinore fault, the Chino fault and the Newport- Inglewood fault zone. The possibility of ground acceleration or shaking at the site may be considered as approximately similar to the southern California region as a whole. The Newport- Inglewood Fault (about 10 miles southwest of the City) would likely generate the most severe site ground motions. The Newport- Inglewood Fault would be capable of a maximum credible magnitude of 7.1. Estimated peak horizontal ground accelerations resulting from the above - stated maximum credible earthquakes on the Newport- Inglewood Fault are on the order of 0.43g. The duration of strong motion on the Newport- Inglewood Fault would be about 26 seconds for a 7.1 magnitude earthquake and about 11 seconds for a maximum probable earthquake of 5.9 magnitude. Since any areas in the City would be subject to strong ground shaking during major earthquakes, similar to other areas in California, any development that occurs would be required by City Ordinance to comply with seismic design parameters contained in the most current version of the Uniform Building Code for seismic zone 4, Title 24 of the California Building Code, and the standards of the Structural Engineers Association of California. Compliance with these existing building standards is considered the best possible means of reducing seismic hazards. Therefore, no significant impacts are anticipated as a result of implementation of the Housing Element Update. Mitigation Measures /Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -115 to 4 -121) and Addendum (Pages 546 to 5-49) b) Result Insubstantial soil erosion or the loss of topsoil? Developments anticipated by the housing element are mostly located in the Tustin Legacy. The Program EIS /EIR for MCAS- Tustin identified the soils in the Tustin Legacy area as expansive, unstable, and subject to erosion. Grading within the Tustin Legacy could result in increased erosion rates, especially if grading is conducted in dry, but windy, summer weather. Such activities are required to comply with existing City regulations related to erosion and runoff control. Once an individual site is graded and landscaping vegetation is established, the erosion potential of the soils would be diminished to a level of insignificance. Therefore, the impact is considered less than significant. Infill areas outside the Tustin Legacy are relatively flat and surface runoff would be similarly controlled by existing City regulations. Future developments would also be required to comply with Best Management Practices and other City regulations to minimize potential erosion and sedimentation impacts into City storm drains. In addition, development sites are required by City Code to be improved with landscaping which would reduce the potential for on -site erosion, after construction. No significant impacts are anticipated. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -115 to 4 -121) and Addendum (Pages 5-46 to 5-49) 47 3. Environmental Analysis c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off -site landslide, lateral spreading, subsidence, liquefaction or collapse? Liquefaction describes a phenomenon in which cyclic stresses, produced by earthquake induced ground motion, create excess pore pressures in relatively cohesionless soils. This occurs in areas where the ground water table is within 50 feet of the ground surface. According to the City's General Plan, soils in Tustin are more susceptible to liquefaction in the southern portion of the City. The area north of the Santa Ana freeway is identified as being moderately susceptible. Soils in the foothill areas are generally not susceptible to liquefaction, due to the more solid underlying geologic structure and lower water table. The Tustin Legacy located south of the Santa Ana freeway, has a high probability of liquefaction in the event of a major earthquake. The Program EIS /EIR for MCAS- Tustin addresses potential impacts that may result from liquefaction, and mitigation measures were incorporated to reduce the potential impacts to a level of less than significant. Areas within the Tustin Legacy have also been determined by the State geologist to be within a liquefaction hazard zone. Compliance with existing State and local regulations and standards and established engineering procedures and techniques would provide adequate protection from geotechnical hazards. As a result, the potential impact would be less than significant. Similar to the Tustin Legacy, infill developments outside the Tustin Legacy would also be required to comply with existing State and local regulations and standards, and the State Department of Conservation, Mines and Geology Division's established engineering procedures and techniques, to identify necessary improvements to ensure long -term geotechnical stability. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -115 to 4 -121) and Addendum (Pages 5 -46 to 5-49) d) Be located on expansive soil, as defined in Table 18 -1 -B of the Uniform Building Code (1994), creating substantial risks to life or property? Developments anticipated by the Housing Element Update consist of development in the Tustin Legacy and Infill areas outside the Tustin Legacy. The Program EIS /EIR for MCAS- Tustin noted that the Tustin Legacy lies within an area of high to very high expansivity of soils. Infill areas outside the Tustin Legacy have not been identified as areas with expansive soils. As part of the City's development review, each development would be required to provide a determination of the expansion potential of on -site soils and implement appropriate remedial measures in accordance with the City's requirements. The measures might include the removal of clay -rich soils and replacement with specific thickness of non - expansive granular soil beneath the structures, concrete slabs, and footings. Mixing during grading of localized expansive soils with granular non - expansive soils could also be used to reduce this hazard. Post - construction drainage control to keep water from collecting under or adjacent to structures might also be used to reduce the hazard. Compliance with State and local regulations and standards, and established engineering procedures would not result in an unacceptable potential risk of loss, injury, or death. Impacts related to expansive soils would be less than significant. Mitigation Measures/Monitoring Required. No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -115 to 4 -121) and Addendum (Pages 5 -46 to 5-49) 48 3. Environmental Analysis e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?,., Developments anticipated by the Housing Element Update consist of development in the Tustin Legacy and infill areas outside the Tustin Legacy. The implementation of the Tustin Legacy would require improvement to the existing sewer system located at the Tustin Legacy area. The Program EIS /EIR for MCAS- Tustin discusses the needed improvements to accommodate the anticipated development. In general, the existing facilities located in the Tustin Legacy area would ultimately be replaced with installation of new sewer systems. Infill developments are located within urbanized areas of the City. Developments that occur in the infill areas are required by existing City regulation to utilize the local sewer system. Compliance with existing State and local regulations and standards related to soil condition and compliance with the State Department of Conservation, Mines and Geology Division's established engineering procedures would reduce any potential impact to a level of insignificance. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -32 to 446) and Addendum (Pages 546 to 5 -49) 3.7 GREENHOUSE GAS EMISSIONS a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant Impact on the environment? b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? New development in accordance with the City's Housing Element Update would create new sources of greenhouse gas (GHG) emission which could result in significant impact. The Program EIS /EIR for MCAS- Tustin does not specifically provide an analysis of GHG emissions. However, potential impacts are indirectly addressed, and the development would not result in any impacts beyond those identified in the Program EIS /EIR for MCAS- Tustin. New development would generate greenhouse gas emissions due to new vehicle trips, use of construction equipment, and off -site power and natural gas generation. During the construction phases of individual development projects, construction vehicles and activities would also generate emissions. Greenhouse gas emissions associated with the Tustin Legacy project, in addition to infill development, could occur over the short-term for demolition, site preparation, and construction activities to support the proposed land use. In addition, emissions could result from the long -term operation of the completed development. GHG emissions associated with the Housing Element Update and the development of residential uses within Tustin Legacy would occur over the short term from construction activities, consisting primarily of emissions from equipment exhaust. There would also be long -term regional emissions associated with project - related new vehicular trips and indirect source emissions, such as electricity usage for lighting. Future development projects involving temporary increases in greenhouse gas emissions are likely to occur during construction which would be greater than those typically experienced in the existing neighborhood. New construction will be required to comply with the latest edition of applicable codes which include energy codes related to efficiency. However, impacts associated with any future project would be identified during the project review process and evaluated in conjunction with the applicable discretionary or building permit process that may be subject to separate CEQA review. The Housing Element Update would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases and does not differ from the existing 49 3. Environmental Analysis standards within the City Code or General Plan. No further mitigation measures would be required beyond those identified in the Program EIS /EIR for MCAS- Tustin, which are hereby incorporated by reference. Mitigation Measures/Monitoring Required., No further mitigation measures would be required beyond those identified in the Program EIS /EIR for MCAS- Tustin, which are hereby incorporated by reference. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -207 to 4 -224) and Addendum (Pages 5 -10 to 5 -27) 3.8 HAZARDS AND HAZARDOUS MATERIALS a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? b) Create a significant hazard to the public or the environment through reasonable foreseeable upset and accident conditions involving the release of hazardous materials into the environment? c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one - quarter mile of an existing or proposed school? d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? The Program EIS /EIR for MCAS- Tustin has identified areas with potential environmental contamination and debris on the site as a result of military activities. The Department of the Navy (DON) is in the process of implementing various remedial actions that will remove, manage, or isolate potentially hazardous substances. This is required by the Federal Law. Although the development of residential units within the Tustin Legacy would not result or create significant hazardous substance, recreational uses (commercial, linear parks, etc.) to support the residential uses may utilize pesticides. However, through compliance with existing applicable Federal, State, and local regulations, any potential impacts would be reduced to below a level of significance. Infill developments would be unlikely to use, transport, or dispose significant hazardous materials due to their nature as residential properties. Other than those chemicals typically found in residential properties (i.e. cleaning solutions, fertilizers, etc. regulated by the Orange County Health Department if disposed improperly), no hazard or hazardous materials would likely be transported, used, disposed, released, or emitted. Therefore, no significant impact would result from the infili developments. Mitigation Messures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -130 to 4 -135) and Addendum (Pages 5 -49 to 5 -55) 50 3. Environmental Analysis e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? John Wayne Airport is located approximately two miles southwest of the City of Tustin. This facility is the primary airport serving Orange County. Land use restrictions exist for areas adjacent to and under flight patterns for John Wayne Airport. These regulations restrict sensitive uses in order to minimize the potential loss of life and property in the event of an aircraft accident, reduce noise impacts, and reduce the risk of aircraft colliding with tall buildings or other structures. The developments anticipated by the Housing Element Update consist of developments in the Tustin Legacy and infill areas outside the Tustin Legacy. The aircraft pattern for John Wayne Airport crosses north of the westerly portion of Tustin and in the vicinity of Red Hill Avenue, adjacent to the Tustin Legacy area. According to Airport Land Use Commission (AELUP), no restrictions are in place in conjunction with possible crash zones. However, the Tustin Legacy falls within a 20,000 foot area of concern for buildings with heights ranging from 110 feet to 200 feet. Any structures within the Tustin Legacy that exceed the height thresholds would be subject to review by the Federal Aviation Administration (FAA) and the Airport Land Use Commission. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 3 -13 to 3 -17) and Addendum (Pages 5 -49 to 5 -55) f) For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area? There are no private airstrips located within the City of Tustin; therefore, the proposed project would not result in any significant safety hazards from private airstrip /airport related activity. Mitigation Measures/Monitoring Required., No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 3 -13 to 3 -17) and Addendum (Pages 5 -49 to 5 -55) g) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? The proposed project would not conflict with the City of Tustin's emergency response or evacuation plans. As housing units at the Tustin Legacy area develop overtime, a new roadway network system would be added in accordance with the phasing plan described in the Program EIS /EIR for MCAS - Tustin. The new roadway system includes an emergency response plan and emergency evacuation plan. Therefore, no adverse impact would be anticipated. With respect to the infill areas, no conflict with the City of Tustin's emergency response or evacuation plans would be anticipated. Compliance with the City's Land Use Element, Circulation Element, and Public Safety Element would ensure that proposed developments would not interfere or impair the implementation of an adopted emergency response plan or emergency evacuation plan. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin and Addendum (Pages 5-49 to 5 -55) 51 3. Environmental Analysis h) Expose people or structures to a significant risk of loss, injury, or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands? The Orange County Fire Authority (OCFA) identified two major sections of the City — residential and commercial districts south of the Santa Ana Freeway and north of Edinger Avenue —as having inherent fire danger problems, which could result in extensive fires under worst -case conditions. This whole area includes high - density residential development composed of wood frame buildings with shake shingle roofs. The second area of concern is the Peters Canyon area. This is adjacent to a wildland interface area from which natural fires could spread to residential neighborhoods. Urban and wildland fire hazards could result from a number of causes, including arson, carelessness, home or industrial accidents, or from ignorance of proper procedures for home or business repairs. Low water pressures could also contribute to fire hazards in Tustin. The current practice and code requirements for use of fire retardant roofing materials, the enforcement of building code that assure adequate fire protection, the upgrading of emergency water line capacities in conjunction with development as required by the Orange County Fire Authority, and the City's and Orange County Fire Authorities maintenance of its mutual aid agreement with surrounding jurisdictions will reduce the risk of loss, injury, or death from fires. New development as a result of the Housing Element would be required to comply with the City's and OCFA rules and regulations. Thus, any impacts would be reduced to a level of insignificance. Mitigation Measures/Monitoring Required. No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin and Addendum (Pages 5-49 to 5 -55) 3.9 f/YDROLOGYAND WATER QUALITY a. Violate any water quality standards or waste discharge requirements? The Housing Element Update provides for the development of 1,227 housing units. As these units are developed, wastewater would be discharged into the local sewer system and on -site drainage would flow into the City's existing storm drain system. As part of Section 402 of the Clean Water Act, the U.S. Environmental Protection Agency (EPA) has established regulations under the National Pollution Discharge Elimination System (NPDES) program to control direct storm water discharges. In California, the State Water Quality Control Board (WCQB) administers the NPDES permitting program and is responsible for developing NPDES permitting requirements. The NPDES program regulates industrial pollutant discharges, including construction activities. The City of Tustin is a co- permittee with the County in the National Pollution Discharge Elimination System (NPDES) permit. Future development would be required to comply with the NPDES program. Additionally, through the City's existing regulations, compliance with water quality standards and waste discharge requirements in construction operations is required, thereby reducing potential water quality impacts to a level that is less than significant. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -32 to 446) and Addendum (Pages 5 -56 to 5.91) Tustin Water Department and Irvine Ranch Water District b. Substantially deplete groundwater supplies or interfere substantially with groundwater recharge, such that there would be a net deficit in aquifer volume or a lowering of the local 52 3. Environmental Analysis groundwater table level (e.g. the production rate of pre - existing` nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted)? Groundwater resources in the area consist of a complex system of aquifers and aquicludes, separated by bedrock or layers of soil. The City of Tustin is located within the East Coastal Plain /Orange County groundwater basin. The City straddles the Irvine, Forebay, and Pressure sub- areas of the Orange County Basin. Within these systems the aquifers are separated by low - permeability strata known as aquitards, which generally limit the vertical hydraulic exchange between the aquifers. The Basin is replenished with flows from the Santa Ana River and imported water supplies purchased from Metropolitan Water District. The Orange County Water District actively and beneficially manages the Basin. The development of 1,227 additional housing units by 2021 would increase water consumption in the City as well as increase dependence on local and imported supplies of groundwater. The Program EIS /EIR for MCAS- Tustin discusses impacts related to groundwater supplies and recharge, and according to the IRWD, there is adequate water capacity to supply civilian reuse development at the former MCAS- Tustin. As in the infill areas, the City's Water Department has also determined that there would be adequate water supply to support infill developments. Therefore, no significant impact to groundwater supplies or groundwater recharge would result from the implementation of the Housing Element Update. Mitigation Messures/Monitoring Required., No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -32 to 4 -46) and Addendum (Pages 5 -56 to 5 -91) Tustin Water Department and Irvine Ranch Water District c. Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in flooding on- or off -site? d. Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner, which would result in flooding on- or off -site? Erosion is not anticipated to be substantial during construction or operation of developments anticipated by the City of Tustin Housing Element. Development of the Tustin Legacy area would replace undeveloped areas with urban -type development. While the proposed linear parks would provide some pervious surfaces to absorb rainwater, the overall amount of impervious surface would increase, thereby increasing the amount of surface water runoff. Utilizing the existing storm drain system at the former MCAS- Tustin would not be a practical alternative because most of those pipes and channels are undersized. To accommodate the development at the Tustin Legacy, a conceptual storm drain plan has been developed in coordination with the Orange County Flood Control District ( OCFCD). This conceptual system includes five major drainage areas with mainline facilities and improvements to the OCFCD Barranca Channel. This system shall be provided by the cities of Irvine, Tustin and OCFCD as a condition or pre- condition of development approvals; therefore, impacts would be less than significant. Infill areas within the City are connected to the City's storm drain system and are not anticipated to create substantial erosion or siltation on- or off -site. In addition, adherence to existing City codes and required City's standards in the Grading Manual designed to prevent erosion and siltation during the construction phase would reduce potential impacts to a level of insignificance. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. 53 3. Environmental Analysis Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -32 to 4 -46) and Addendum (Pages 5 -56 to 5 -91) e. Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? Development anticipated by the Housing Element Update involves developing primarily vacant land and some infill land. Since the sites anticipated for development are currently vacant, the construction of proposed housing would increase the amount of impervious surface coverage; therefore, the total volume of surface water runoff would be increased by the proposed project, although sediment transport will decrease significantly. Under the NPDES Stormwater Permit issued to the County and City of Tustin (as a co- permittee), all development and significant redevelopment must be implemented with pollution control measures more commonly referred to as Best Management Practices (BMPs). Under existing City's regulations, compliance with BMP and other NPDES requirements will reduce potential impacts to a level of insignificance. Mitigation Measures /Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -32 to 446) and Addendum (Pages 5 -56 to 5 -91) f. Otherwise substantially degrade water quality? Development at Tustin Legacy and some of the infill areas would increase the amount of impervious surfaces, particularly by developing areas currently used for agriculture. Contaminants commonly associated with urban development include leaking motor oils, fuels, and other vehicular fluids, and trash can be washed by rain and carried with runoff into local and regional waterways. Under the existing NPDES permit, all development and significant redevelopment must be implemented with non -point source pollution control measures. These existing measures would reduce potential impacts to a level of insignificance. Mitigation Measures /Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -32 to 4 -46) and Addendum (Pages 5 -56 to 5 -91) g. Place housing within a 100 -year flood hazard area as mapped on a federal Flood hazard Boundary of Flood Insurance Rate Map or other flood hazard delineation map? The development of housing units at Tustin Legacy and infill development sites are outside of the 100 year flood plain. In accordance with the City's Floodplain Management Ordinance, the City shall require all new development to comply with provisions to reduce the flood hazards by either anchoring, increasing building elevation, or utilizing materials and equipment resistant to flood damage. Compliance with this existing Ordinance would reduce potential impacts to a level of insignificance. Mitigation Measures /Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin Fioodplain Management Ordinance (Tustin City Code Section 9801 to 9806) Tustin General Plan Housing Element Update 54 3. Environmental Analysis Program EIS /EIR for MCAS- Tustin (Pages 4 -32 to 4 -46) and Addendum (Pages 5 -56 to 5 -91) It. Place within a 100 -year flood hazard area structure, which would impede or redirect flood flows? The development at the Tustin Legacy and infill areas are not located within a 100 -year flood hazard area structure. Development in areas with flood hazards would be subject to the existing Floodplain Management Ordinance to limit the personal and property damage that may occur due to flooding and inundation. Compliance with the existing Uniform Building Codes and the Floodplain Management Ordinance would reduce potential impacts to a level of insignificance. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin Floodplain Management Ordinance (Tustin City Code Sections 9801 to 9806) Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -32 to 4-46) and Addendum (Pages 5 -56 to 5 -91) I. Expose people or structures to a significant risk of loss, injury, or death involving flooding, including flooding as a result of the failure of a levee or dam? According to the City's Water Department, catastrophic dam failure or flooding resulting from the failure of any one of the main reservoirs in the Tustin area could generate flooding impacts in the City of Tustin. The risk of flooding resulting from dam breaches or failures would be reduced by working directly with the State Office of Emergency Services to make physical improvements (if necessary) and monitor the safety of the reservoirs. With respect to the Tustin Legacy area, if either of the Santiago and Villa Park reservoirs failed during or after a major earthquake, this would cause a flooding impact to the Tustin Legacy area and potentially to infill areas. However, both reservoirs have been designed and constructed according to applicable earthquake standards to reduce the chance of reservoir failure. The City has also implemented emergency response plans in the case of an earthquake to respond to this hazard. These plans would ensure the removal of people from the site to avoid loss of human life, but property could be exposed. Property loss would be experienced with reservoir failure, but by working directly with the State Office of Emergency Services to make physical improvements (if necessary) and through proper monitoring of the safety of the reservoirs, unacceptable potential risk of loss, injury, or death would be avoided. Mitigation Measures /Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -32 to 4 -46) and Addendum (Pages 5 -56 to 5 -91) Tustin Water Department and Irvine Ranch Water District J. Inundation by seiche, tsunami, or mudfiow? A seiche is a surface wave created when a body of water such as a lake or reservoir is shaken, usually by earthquake activity. Seiches are of concern relative to water storage facilities because inundation from a seiche can occur if the wave overflows a containment wall, such as the wall of a reservoir, water storage tank, dam, or other artificial body of water. Neither the Tustin Legacy area nor the infill areas are located near any confined bodies of water that might be subject to seiche in the event of an earthquake. 55 3. Environmental Analysis A tsunami is ocean waves induced by large earthquake. Low -lying coastal areas may be subject to flooding and other related property damage. Given the distance to the coast, neither the Tustin Legacy area, nor the infill areas lie within an area of tsunami run -up risk. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin and Addendum (Pages 5 -56 to 5 -91) 3.90 LAND USEAND PLANNING a) Physically divide an established community? Development anticipated by the Housing Element Update would involve development of vacant land at Tustin Legacy and infill developments. The implementation of the Housing Element Update would involve a change in land use from vacant to residential urban uses and /or intensification of uses at certain sites. The change in land use and /or intensification of uses at certain sites however would not significantly divide any community or reduce access to community amenities. Compliance with the Land Use Element of the General Plan and the City's zoning regulations would ensure that the development of new housing units would not divide an established community. Mitigation Measures /Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS - Tustin (Pages 4 -6 to 4 -7) and Addendum (Pages 5 -92 to 5- 94) b) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to, the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? Development anticipated by the Housing Element Update would take place primarily on lands designated for residential use by the General Plan and zoned residential per the City's Zoning Ordinance. With respect to the Tustin Legacy area, development would result in substantial change in existing land use by replacing military and agricultural uses with civilian urban uses. Individual, site - specific compatibility impacts are addressed by appropriate site design such as buffering, screening, setbacks, landscaping, etc. with proposed Specific Plan. Infill areas would be developed in accordance with the City's Code that requires compliance with Zoning designations and the General Plan. Therefore, no conflict with any applicable land use plan, policy, or regulations is anticipated nor additional mitigation will be required. Mitigation Measures/Monitoring Required: No mitigation measures are necessary Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -6 to 4 -7) and Addendum (Pages 5 -92 to 5- 94) c) Conflict with any applicable habitat conservation plan or natural community conservation plan? Development anticipated by the Housing Element Update is located primarily on land designated for residential uses in developed urban neighborhoods and on vacant land at the Tustin Legacy. The proposed project would not conflict with any habitat conservation plans or natural community conservation plans. No significant impacts would result from project development. 56 3. Environmental Analysis Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin and Addendum (Pages 5 -92 to 5 -94) 3.11 MINERAL a) Result in the loss of availability of a known mineral resource that would be a value to the region and the residents of the state? Currently there are no mineral extraction activities in the City of Tustin. Regionally significant resources are found north of the City in the Cities of Orange and Anaheim, but future developments within Tustin would not impact those resources. No significant impacts are anticipated to result from project development. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin and Addendum (Page 5 -95) b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? The City does not contain any mineral resource recovery sites or mineral resource recovery areas. No significant impacts would result from the development of the proposed project. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin and Addendum (Page 5 -95) 3.12 NO /SE a) Exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Noise impacts can be broken down into three categories. The first is "audible" impacts, which refers to increases in noise level that are perceptible to humans. Audible increases in noise levels generally refer to a change of three dBA or more since this level has been found to be barely perceptible in exterior environments. The second category, "potentially audible," refers to a change in noise level between one and three dBA. This range of noise levels was found to be noticeable to sensitive people in laboratory environments. The last category is changes in noise level of less than one dBA that are typically "inaudible" to the human ear except under quiet conditions in controlled environments. Only "audible" changes in noise level are considered as potentially significant. Mobile- source noise (i.e. vehicles) is preempted from local regulation. For mobile sources, an impact would be considered significant if the project were to increase noise by 3 dBA (a barely discernible increase) and the resultant noise exceeded the City's noise standards, or 5 dBA (notable to most people) if the resultant noise remained below City standards. The proposed project site is located within the City of Tustin and thus is subject to the General Plan and existing City's noise ordinances. The General Plan discusses the effects of noise exposure on the population and sets land use compatibility goals aimed at protecting residents from undue noise. The Plan follows the recommendations set forth in Title 25 of the California Administrative Code and discourages residential development in areas where exterior noise levels exceed 65 dBA CNEL, unless measures are implemented to reduce noise levels to below this value. 57 3. Environmental Analysis The Tustin Noise Element contains the following residential noise level standards: Noise Land Use InterioP I Exterior Residential — Single- family multifamily, duplex, mobile I CNEL 45 dB I CNEL65 Residential —Transient lodging, hotels, motels, nursing I CNEL 45 d6 ( CNEL 65 1. CNEL: Community Noise Equivalent Level. Leq (12): The A- weighted equivalent sound level averaged over a 12 -hour period (usually the hours of operation). 2. Noise Standards with windows closed. Mechanical ventilation shall be provided per UBC requirements to provide a habitable environment. 3. Indoor environment excluding bathrooms, toilets, closets, and corridors. 4. Outdoor environment limited to rear yard of single - family homes, multi - family patios, balconies (with a depth of W or more), and common recreation areas. Noise Ordinance The Tustin Noise Ordinance establishes standards for maximum noise levels within residential areas in the City. The exterior noise level standard is 65 dBA, and the interior noise level standard is 45 dBA. The City realizes that the control of construction noise is difficult at best. It does however implement its Land Use Compatibility Standards, which provide development standards for exterior noise levels across the various land use categories. State of California Standards The California Office of Noise Control has set acceptable noise limits for sensitive uses. Sensitive -type land uses, such as schools and homes, are "normally acceptable" in exterior noise environments up to 65 dBA CNEL and "conditionally acceptable" in areas up to 70 dBA CNEL. A "conditionally acceptable" designation implies that new construction or development should be undertaken only after a detailed analysis of the noise reduction requirements for each land use type is made and needed noise insulation features are incorporated in the design. By comparison, a "normally acceptable" designation indicates that standard construction can occur with no special noise reduction requirements. Future development would be required to comply with the City's Building Code and State's existing regulations on vehicle noise, roadway construction, and insulation standards. This would ensure that noise levels in Tustin residential areas are maintained within acceptable standards that prevent extensive disturbance, annoyance, or disruption. The implementation of the Tustin Legacy would result in additional vehicular noise from traffic generated by new development. Projected noise levels along major roadways are included in the Program EIS /EIR for MCAS- Tustin. The proposed extension of Tustin Ranch Road could expose existing residences to noise levels greater than 65dB(A) CNEL. Some existing residential units within the Tustin Legacy area may experience noise levels greater than 65dB(A) CNEL. With reuse and future development, noise levels at residential and park locations adjacent to Warner Avenue may exceed 65dB(A) CNEL. The Program EIS /EIR for MCAS- Tustin addresses potential impacts that may result in noise impacts and mitigation measures were incorporated to reduce the potential impacts to a level of less than significant. Infill developments would generate additional noise typically associated with residential uses to the area. However, compliance with the City's existing noise regulations would reduce impacts to a less than significant level. Development of any infill sites adjacent to arterial noise exceeding the maximum noise levels would be required to comply with State and Building Code standards for insulation and interior noise levels. In summary, the implementation of the Housing Element Update would not result in any impacts beyond those identified in the Program EIS /EIR for MCAS- Tustin. 58 3. Environmental Analysis Mitigation Measures /Monitoring Required: No further mitigation measures would be required beyond those identified in the Program EIS /EIR for MCAS- Tustin, which are hereby incorporated by reference. Mitigation Measures /Monitoring Required: No mitigation measures are necessary for infill developments. Sources: Tustin City Code (Section 4611 to 4624) Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -231 to 4 -237) and Addendum (Pages 5 -96 to 5 -101) b) Exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels? The development of residential housing units would not result in exposure of people with excessive groundborne vibration or groundborne noise levels. However, during the construction of potential new units, there could be temporary groundborne vibration during the grading of the sites which will be reduced with implementation in the Feld of City's standard procedures and policies related to construction (i.e. complaints regarding vibration would require construction hours to be altered, replacement of construction equipment to minimize vibration, etc.) Mitigation Measures/Monitoring Required. No mitigation measures are necessary. Sources: Tustin City Code (Section 4611 to 4624) Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -231 to 4 -237) and Addendum (Pages 5 -96 to 5 -101) c) A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project? Traffic related to the increased development contemplated by the Housing Element Update would result in permanent increases in ambient noise levels. The Program EIS /EIR for MCAS- Tustin addresses potential noise impacts that may result from the implementation of the Tustin Legacy and mitigation measures were identified to reduce the potential impacts to a level of less than significant. Infiil developments proposed by the Housing Element Update would be required to comply with the City's existing ordinances that would ensure that noise levels in infill areas are maintained within acceptable standards. The implementation of the Housing Element Update, particularly the development at the Tustin Legacy, would potentially create noise impacts. However, the implementation of the Housing Element Update would not result in any impacts beyond those identified in the Program EIS /EIR for MCAS- Tustin. Mitigation Measures/Monitoring Required: No further mitigation measures would be required beyond those identified in the Program EIS /EIR for MCAS- Tustin. No mitigation measures are necessary for infill developments. Sources: Tustin City Code (Section 4611 to 4624) Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -231 to 4 -237) and Addendum (Pages 5 -96 to 5 -101) 59 3. Environmental Analysis d) A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project? Noise levels associated with construction activities would be higher than the ambient noise levels in the City, but would subside once construction of the residential units proposed in the Housing Element Update are completed. Two types of noise impacts could occur during the construction phase. First, the transport of workers and equipment to the construction site would incrementally increase noise levels along site access roadways. Even though there would be a relatively high single event noise exposure potential with passing trucks (a maximum noise level of 86 dBA at 50 feet), the increase in noise would be less than one dBA when averaged over a 24 -hour period and should therefore have a less than significant impact at noise receptors along City truck routes. The second type of impact is related to noise generated by on -site construction operations. Local residents would be subject to elevated noise levels due to the operation of on -site construction equipment. Construction activities are carried out in discrete steps, each of with its own mix of equipment, and consequently its own noise characteristics. Table 1 lists typical construction equipment noise levels recommended for noise impact assessment at a distance of 50 feet. Noise ranges have been found to be similar during all phases of construction, although the erection phase tends to be less noisy. Noise levels range up to 89 dBA at 50 feet during the erection phase of construction, which is approximately 2 dBA lower than other construction phases. The grading and site preparation phase tends to create the highest noise levels, because the noisiest construction equipment is found in the earthmoving equipment category. This category includes excavating machinery (backfiilers, bulldozers, draglines, front loaders, etc.) and earthmoving and compacting equipment (compactors, scrapers, graders, etc). Typical operating cycles may involve one or two minutes of full power operation followed by three to four minutes at lower power settings. Noise levels at 50 feet from earthmoving equipment range from 73 to 96 dBA. TABLE 1 NOISE LEVELS GENERATED BY TYPICAL CONSTRUCTION EQUIPMENT Type of Equipment Range of Sound Levels Measured (dBA at 50 feet) Suggested Sound Levels for Analysis (dBA at 50 feet) Pile Drivers 12,000-18,000 ft-lb /blow 81 -96 93 Rock Drills 83 -99 96 Jack Hammers 75 -85 82 Pneumatic Tools 78 -88 85 Pumps 68 -80 77 Dozers 85 -90 88 Tractor 77 -82 80 Front -End Loaders 86 -90 88 Hydraulic Backhoe 81 -90 86 Hydraulic Excavators 81 -90 86 Graders 79 -89 86 Air Compressors 76 -86 86 Trucks 81 -87 86 Source: Noise Control for Buildings and Manufacturing Plants, BBN 1987. All construction - related noise shall be subject to existing City's noise regulations. The City's Noise Ordinance limits construction noise to 7:00 a.m. to 6:00 p.m. Monday through Friday and from 9:00 a.m. to 5:00 p.m. on Saturdays. All construction activities are prohibited on Sundays and City- observed Federal holidays. Compliance with the construction noise limitations and dBA noise standards would ensure that temporary or periodic noise levels are maintained within acceptable standards. 3. Environmental Analysis Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code (Sections 4611 to 4624) Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -231 to 4 -237) and Addendum (Pages 5 -96 to 5 -101) e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? John Wayne Airport is located a little over two miles southwest of the City of Tustin. According to the John Wayne Quarterly Noise Abatement Reports, the noise level resulting from aircraft noise is below the acceptable 65 dB Community Noise Equivalent Level (CNEL). Mitigation Measures/Monitoring Required. No mitigation measures are necessary. Sources: Tustin City Code (Sections 4611 to 4624) Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 3 -13 to 3 -17) and Addendum (Pages 5 -96 to 5 -101) John Wayne Airport Quarterly Noise Abatement Reports f) For a project within the vicinity of a private airstrip, would the project expose people residing or working in the project area to excessive noise levels? There are no private airstrips located within the City of Tustin; therefore, the proposed project would not result in any significant safety hazards from private airstrip related activity. Mitigation Measures/Monitoring Required. No mitigation measures are necessary. Sources: Tustin City Code (Section 4611 to 4624) Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 3 -13 to 3 -17) and Addendum (Pages 5 -96 to 5 -101) 3.13 POPULATION AND HOUSING a) Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other Infrastructure)? The City of Tustin had an estimated population of 76,567 in 2012. The City has experienced rapid population growth over the last 30 years. This population growth has occurred with increases in the number of housing units. The Housing Element Update anticipates an additional 1,227 housing units, including single - family residential and multi - family residential, for development through 2021. The anticipated units are within the constraints set forth in the City's current General Plan. The development of an additional 1,227 housing units, of which the majority would be located at the Tustin Legacy, would result in an increase in the City's population and housing over an eight -year period, not a significant impact on the City's population. The development of the Tustin Legacy would also result in the development of affordable housing in selected areas which would address the needs of the homeless, as well as those of low and moderate income. Therefore, the implementation of the Tustin Legacy would provide a beneficial impact. Infill developments that would occur outside the Tustin Legacy area would also generate population and housing growth in the City. However, this growth is insignificant given the City's total population and if is within the constraints set forth in the City's General Plan. This will help the City to achieve its 61 3. Environmental Analysis Regional Housing goals. Again, this impact would have a beneficial impact for the City's housing stock. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -14 to 4 -21) and Addendum (Pages 5 -101 to 5 -111) b) Displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere? c) Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere? Future developments anticipated by the Housing Element Update would be constructed primarily on vacant land in the City. There may be new infill construction activities that could result in the displacement of existing housing units, however there is no requirement in place that requires the construction of replacement housing elsewhere. Consistent with State Law, the City would not be required to prepare relocation and /or displacement plans, replace units displaced or destroyed, or provide relocation services and benefits to displaced households. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -14 to 4 -21) and Addendum (Pages 5 -101 to 5 -111) 3,14 PUBLIC SERVICES Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: a) Fire protection? The City of Tustin contracts with the Orange County Fire Authority (OCFA) for fire protection services. The Fire Authority maintains three stations in the City. New housing developments would increase demand for fire protection, as well as emergency medical services. Individual development projects would be required to meet existing OCFA regulations regarding construction materials and methods, emergency access, water mains, fire flow, fire hydrants, sprinkler systems, building setbacks, and other relevant regulations. Adherence to the OCFA regulations would reduce the risk of uncontrollable fire and increase the ability to efficiently provide fire protection services to the City. The number of fire stations in the areas surrounding the site will meet the demands created by the proposed project. b) Police protection? The City of Tustin operates its own Police Department. New housing developments at the Tustin Legacy would increase the need for police emergency and protection services. The need for police protection services is assessed on the basis of resident population estimates, square footage of industrial uses, and square footage of retail uses. The Program EIS /EIR for MCAS- Tustin identifies that the need for additional police services could be accommodated at the existing City police station and no new facilities would be required. 1E, 3. Environmental Analysis c) Schools? Development of additional housing would induce population growth, therefore increasing the number of school age children. Of the 1,227 housing units proposed in the Housing Element Update, most housing developments anticipated would be located in the Tustin Legacy. The Tustin Legacy is located within the Tustin Unified School District (TUSD), Irvine Unified School District (IUSD), and Santa Ana Unified School District (SAUSD). The implementation of the Tustin Legacy would provide for two 10 -acre elementary school sites and one 40 -acre high school site within the TUSD. The TUSD has agreed that these sites would be considered adequate to accommodate new students generated by the Tustin Legacy development, as well as some of the future growth anticipated for the Tustin community as a whole. With respect to the IUSD, the implementation of the Tustin Legacy would provide for a 20 -acre school site to IUSD to serve the growing student population within its district. With respect to the SAUSD, although no housing exists in this area to be reused and no new housing would be constructed in its boundaries, indirectly new students could be generated through the provision of new employment. The commercial uses would generate employment and if new employees were to seek housing in locations served by the SAUSD, they would indirectly generate students. However, where these students would locate within SAUSD is not known at this time, and accordingly, construction or housing impacts cannot be identified. There is no impact on community college facilities because students in Tustin can attend any community college In the County. Therefore, except for construction level impacts which will be mitigated to a level of insignificance due to required compliance with existing City regulations, no other school impacts are anticipated. With respect to the infill areas, all potential sites are located within the TUSD boundaries. Future anticipated growth for the anticipated infill sites will be assessed school impact fees to accommodate any impacts to existing schools. d) Parks? The City of Tustin currently has 14 parks and 4 community /recreation facilities. The implementation of the Tustin Legacy would provide new park sites. These park sites include a regional park, a community park, and several smaller neighborhood parks. A linear park would be constructed as well. These facilities would provide park and recreation opportunities to the population of the Tustin Legacy areas as well as the City and the region and their development will not result in a significant impact on the environment. Once constructed, these parks would meet residential population demand. Existing parks in the City of Tustin will serve new infill development as well. e) Other public facilities? Most of the development of these new housing units would be provided within the Tustin Legacy. The Program EIS /EIR for MCAS- Tustin discusses impacts related to other public facilities that may result from the implementation of the Tustin Legacy. These facilities include libraries and recreational bikeway /trails. Library Using the County's criteria, the implementation of the Tustin Legacy would result in a demand of up to approximately 2,500 square feet of library space. This relatively small amount of space is well below the library system's general minimum size of 10,000 square feet for a branch library, and would not trigger the need for a new facility. Therefore, there would be no significant effects on the environment. Nevertheless, a new library twice the capacity of the previous library was completed in 2009 to accommodate existing and future Tustin residents. Recreational Bikeway /Trails Implementation of the Tustin Legacy would include bikeway /riding and hiking trails, although such is not required by the Housing Element Update. This system would connect vital links necessary for a comprehensive regional and improved local bikeway /riding and hiking trail system and would be a beneficial impact. 63 3. Environmental Analysis With respect to the infill areas, consistent with the policies of the City's Circulation Element, the City would support and coordinate the development and maintenance of bikeway /riding and hiking trails with the County of Orange. As development of bikeways /trails occurs, City regulations would reduce construction related impacts to a level of insignificance. Mitigation/Monitoring Required. No mitigation is required. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -56 to 4 -70) and Addendum (Pages 5 -112 to 5 -122) 3.15 RECREAT ION a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities, such that substantial physical deterioration of the facility would occur or be accelerated? The City of Tustin has 16 parks and recreation facilities on approximately 100 acres and, through the school district, operates school playgrounds. In addition, the City maintains one senior citizen center and three family and youth community centers. The implementation of the Tustin Legacy would provide new park sites to serve residents generated under the Housing Element Update. There is no evidence that the infill development or Housing Element Update will cause or accelerate the physical deterioration of parks. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -56 to 4 -70) b) Does the project Include recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment? New development anticipated by the Housing Element Update would increase the demand for parks and recreation facilities in the City. The implementation of the Tustin Legacy would provide new park sites. These park sites include approximately 296 acres of public and private parkland which comprises of 202 acres of public parks and recreational areas (including the 84.5 acres of Urban Regional Park). Since sufficient parkland is provided within Tustin Legacy, development of new housing units would not generate an increase in the use of existing off -site parks and recreational facilities. However, the development of these facilities will result in construction level impacts that can be mitigated to a level of insignificance under existing City regulations. Infili developments would likely utilize the City's existing recreational facilities. Therefore, no significant impact would result from the development of infill areas. Mitigation Measures/Monitoring Required. No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -56 to 4 -70) and Addendum (Pages 5 -122 to 5 -127) 64 3. Environmental Analysis 3.96 TRANSPORTATION/TRAFF IC a) Cause an increase in traffic, which is substantial in relation to the existing traffic load and capacity of the street system (i.e. result in a substantial increase in either the number of vehicle trips, the volume to capacity ratio on roads, or congestion at intersections)? The Housing Element Update provides for the development of 1,227 housing units required by the Regional Housing Needs Assessment (RHNA). This development would be located in the Tustin Legacy and at infill sites. The additional development and associated traffic volumes of developing the Tustin Legacy are included in the traffic analysis portion of the Program EIS /EIR for MCAS- Tustin. As the impacts of traffic due to housing alone were not separated out and analyzed, the following discussion includes impacts due to commercial, industrial, and institutional uses, as well as housing. In general, a number of intersections would be significantly impacted at the build out of the Tustin Legacy. Most of these impacted can be mitigated to a level of less than significant. However, significant traffic impacts would remain at the intersections of Tustin Ranch Road and Walnut Avenue, and Jamboree Road and Barranca Parkway until full build -out (year 2020). Infill areas are located within the established street system. Although traffic in the City of Tustin is within the acceptable level of service standard, there are intersections that are at an unacceptable level of service. Through the City's existing Design Review process, developments that contribute 1 percent or more of traffic will be assessed with mitigation fees, in areas with an unacceptable level of service, as part of the City's Capital Improvement Program. In addition, where applicable, the City would require dedication of right -of -ways and /or require developers to construct the needed improvements to improve the level of service. Therefore, compliance with the existing City's regulations would reduce potential traffic impacts to a level that is less than significant. In summary, the implementation of the Housing Element Update, particularly the development at the Tustin Legacy and Infill locations, would potentially result in immitigable impacts at two intersections described above. However, the implementation of the Housing Element Update would not result in any impacts beyond those identified in the Program EIS /EIR for MCAS- Tustin. Mitigation Measures/Monitoring Required: A Statement of Overriding Considerations was adopted by the City Council. No further mitigation measures would be required beyond those identified in the Program EIS /EIR for MCAS- Tustin. No mitigation measures are necessary for infill developments. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS - Tustin (Pages 4 -139 to 4 -163 and 7 -32 to7 -41) and Addendum (Pages 5 -127 to 5 -146) b) Exceed, either individually or cumulatively, a level of service standard established by the county congestion management agency for designated roads or highways? The City's Circulation Element establishes a standard for a Level of Service (LOS) "C" or better for major intersections in the City; the City considers LOS "A" through "C" as acceptable, and LOS "D" or greater as unacceptable. The County's Congestion Management Plan (CMP) indicates the LOS should be LOS "E" or better for CMP roadways (freeways and major highways). Development anticipated by the Housing Element Update would be provided in Tustin Legacy and at Infill land. The Program EIS /EIR for MCAS- Tustin provides traffic impact analysis and mitigation measures to address the requirements of the Growth Management Plan and the Congestion Management Plan to reduce the impacts to a level of insignificance. In general, a number of intersections would be significantly impacted at the build out of the Tustin Legacy. Most of these impacted can be mitigated to a level of less than significant. However, significant traffic impacts would remain at the intersections of Tustin Ranch Road and Walnut Avenue, and Jamboree Road and Barranca Parkway under full build out (year 2020). Infill developments would be subject to review to ensure that individual development would not exceed the level of service standards, individually or cumulatively. Compliance with the City's 65 3. Environmental Analysis Circulation Element and City Ordinances related to streets and highways would reduce potential traffic impacts to a level that is less than significant. In summary, the implementation of the Housing Element Update, particularly the development at the Tustin Legacy, would potentially result in immitigable impacts at the two intersections described above. However, the implementation of the Housing Element Update would not result in any impacts beyond those identified in the Program EIS /EIR for MCAS- Tustin. Mitigation Measures/Monitoring Required., No further mitigation measures would be required beyond those identified in the Program EIS /EIR for MCAS- Tustin. A Statement of Overriding Consideration was adopted by the City Council on January 16, 2001 for the identified unavoidable impact. No mitigation measures are necessary for infill developments. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -139 to 4 -163 and 7 -32 to7 -41) and Addendum (Pages 5 -127 to 5 -146) c) Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks? Development anticipated by the Housing Element Update involves the development of 1,227 housing units on parcels of land throughout the City. The anticipated amount of development would not result in any changes to air traffic patterns, nor would the anticipated amount of development result in any substantial safety risks related to aircraft traffic. Compliance with the Airport Environs Land Use Plan standards under existing City ordinances would reduce potential impacts to a level of insignificance. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 3 -13 to 3 -17) and Addendum (Pages 5 -127 to 5 -146) d) Substantially increase hazards due to a design feature (e.g. sharp curves or dangerous intersections) or Incompatible uses (e.g. farm equipment)? Any needed traffic improvements associated with the anticipated development would be constructed to the City's existing roadway safety standards. With respect to the development at the Tustin Legacy area, the Program EIS /EIR for MCAS- Tustin includes mitigation measures related to traffic control plans and needed traffic improvements to accommodate the implementation of the Tustin Legacy. With respect to infill developments, compliance with the City's existing public works standards, zoning codes, and fire codes would reduce potential impacts to a level of insignificance. In summary, the implementation of the Housing Element Update would not result in any impacts beyond those identified in the Program EIS /EIR for MCAS- Tustin. Mitigation Measures/Monitoring Required: No further mitigation measures would be required beyond those identified in the Program EIS /EIR for MCAS- Tustin. No mitigation measures are necessary for infill developments. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -139 to 4 -163 and 7 -32 to7 -41) and Addendum (Pages 5 -127 to 5 -146) e) Result in inadequate emergency access? W 3. Environmental Analysis Housing development projects would be required to conform to existing City regulations that specify adequate emergency access measures. Compliance with the City's public works standards and the Uniform Fire Codes related to emergency access would reduce potential impact to a level of insignificance. Mitigation Measures/Monitoring Required., No mitigation measures are necessary Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin and Addendum (Pages 5 -127 to 5 -146) f) Result in inadequate parking capacity? Development anticipated by the Housing Element Update involves the development of residential dwelling units. Each development would be required to satisfy City parking standards under existing City regulations. Compliance with the City's parking standards would ensure adequate parking capacity be provided as developments occur. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4-4 to 4 -7) and Addendum (Pages 5 -127 to 5- 146) g) Conflict with adopted policies, plans, or programs supporting alternative transportation (e.g. bus turnouts, bicycle racks)? City of Tustin residents have access to several forms of alternative transportation such as the Metrolink, buses, and bicycle paths. The development of 1,227 housing units may create additional demand for bus service. At the same time, the new arterial roadways proposed through the Tustin Legacy area would provide opportunities for future bus routing, serving persons residing and working in the Tustin Legacy area. The new routes would provide improved service with more direct routes for riders not associated with the Tustin Legacy. The Orange County Transportation Agency (OCTA) prepares regular updates of the countywide transit system. Bus stops would be included in the updates and would be accommodated as development occurs. In addition, a commuter rail station located at the corner of Jamboree Road and Edinger Avenue provides transit opportunities to residents and workers. The Tustin Legacy also identifies additions to the bikeway system, providing additional segments and greater connectivity. The added bike trails would provide an overall benefit to the County bike trail system. Infill developments would be located in the established area, and it would be unlikely to conflict with adopted policies, plans, or programs supporting alternative transportation. Mitigation Measures /Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -139 to 4 -163 and 7 -32 to7 -41) and Addendum (Pages 5 -127 to 5 -146) 67 3. Environmental Analysis 3.17 UT /L IT /ES AND SERVICE SYSTEMS a) Exceed wastewater treatment requirements of the applicable Regional Water Quality Control G Board? b) Result in a determination by the wastewater treatment provider, which serves or may serve the project that it has adequate capacity to serve the project's projected demand in addition to the provider's existing commitments? Wastewater originating from the proposed new housing units would be treated by facilities owned by the Irvine Ranch Water District (IRWD) and /or the Orange County Sanitation District (OCSD). IRWD and OCSD provide sewage treatment service to the City of Tustin. Sewage from the City is diverted to Reclamation Plant Number 1 located in the City of Fountain Valley. For the Tustin Legacy, the Program EIS /EIR for MCAS- Tustin indicates that implementation of the Tustin Legacy will cause additional demand on the existing sewer system from increased sewage flows. The OCSD and IRWD have confirmed that sewer treatment facilities will be adequate to accommodate the Tustin Legacy development. As in the infill areas, the development would create an insignificant impact on wastewater treatment facilities. Mitigation Measures/Monitoring Required., No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -32 to 4 -46) and Addendum (Pages 5 -147 to 5 -164) c) Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? Increased water consumption would result in a higher demand for water resources. Most housing developments under the Housing Element Update would occur within the Tustin Legacy. The Tustin Legacy is located within the water service jurisdiction of the Irvine Water Ranch Districts (IRWD). The IRWD imports approximately 27 percent of its water via Metropolitan Water District (MWD) and 48 percent of the overall supply is pumped from local wells. Of the remaining 25 percent, 21 percent comes from capturing, treating and reusing water that would otherwise go out to sea for irrigation and other non - potable uses and 4% comes from other sources. IRWD has indicated that they would be able to provide water services to the project area and thus the impact would be less than significant. Infill projects would be served by existing systems owned and operated by the City of Tustin and IRWD. Reclaimed water for non - domestic uses such as for agriculture and landscape irrigation is treated at the district's Michelson Reclamation Plant and used as reclaimed water. Potable Water supply is purchased by the IRWD and the City of Tustin from the MWD distribution system or pumped from local wells. Sewer lines in Tustin are owned and maintained by the Orange County Sanitation District (OCSD) and IRWD. With the implementation of development in the former MCAS- Tustin, Tustin Legacy, a new water and sanitary sewer system would be necessary. The only impacts would be construction level; these impacts would be mitigated to a level of insignificance by existing City regulations to reduce construction impacts. With respect to the infill areas, replacement of existing facilities with new residential units would not create the need for a new water or wastewater facility. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update 3. Environmental Analysis Program EIS /EIR for MCAS- Tustin (Pages 4 -32 to 4 -46) and Addendum (Pages 5 -147 to 5 -164) Tustin Water Department and Irvine Ranch Water District d) Require or result in the construction of new storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? Storm drainage is provided through reinforced concrete pipes and open channels throughout the City. Storm water flows are directed towards Orange County Flood Control open channels or indirectly to the Santa Ana River. Storm water in the City generally flows in a general southwesterly direction towards the Pacific Ocean. The City maintains an NPDES co- permit with Orange County for storm drain facilities serving Tustin. New development in the Tustin Legacy would require improvement to the existing storm drain system. A conceptual storm drain plan has been developed in coordination with the Orange County Flood Control District ( OCFCD). The improvement would include five major drainage areas with mainline facilities and improvements to the OCFCD Barranca Channel. New retention basins would also be incorporated to handle storm flows from the Linear Park of the Tustin Legacy. Other on -site facilities would discharge into the County's existing regional facilities. Construction level impacts would be mitigated to a level of insignificance by existing City regulations to reduce construction impacts. With respect to the infill areas, replacement of existing facilities with new residential units would not create the need for a new water or wastewater facility. New development in the infill areas would utilize existing storm drain lines. Compliance with NPDES requirements through the development review process would reduce potential impacts to a less than significant level. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS - Tustin (Pages 4 -32 to 4 -46) and Addendum (Pages 5 -147 to 5 -164) e) Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed? Most of the new housing development would occur within the Tustin Legacy. The area is located within the water service jurisdiction of the Irvine Water Ranch Districts (IRWD). The IRWD imports approximately 27 percent of its water via Metropolitan Water District (MWD) and 48 percent of the overall supply is pumped from local wells. Of the remaining 25 percent, 21 percent comes from capturing, treating and reusing water that would otherwise go out to sea for irrigation and other non- potable uses and 4% comes from other sources. The increase in water consumption that may occur with new development anticipated by the Housing Element Update would not result in significant impacts to local and imported water supplies requiring new or expanded entitlements. According to the IRWD, there is adequate water capacity to supply civilian reuse development. In the infill areas, no impact to the existing water supply owned by the City of Tustin is anticipated. Mitigation Measures /Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -32 to 4 -46) and Addendum (Pages 5 -147 to 5 -164) Tustin Water Department and Irvine Ranch Water District f) Be served by a landfill with sufficient permitted capacity to accommodate the project's solid waste disposal needs? .• 3. Environmental Analysis The Frank R. Bowerman Landfill is the primary facility that receives solid waste from Tustin. This landfill is scheduled to be closed in approximately the year 2053. Based upon the 1998 County of Orange determination, only about 18 percent of the maximum capacity has been used. Accordingly, the landfill has ample capacity to accommodate solid waste generated by the Housing Element Update. Further, the City has adopted .a Source Reduction and Recycling Element (SRRE) that provides implementation programs for achieving a 50 percent reduction in the City's solid waste stream. All new development is required by existing City regulation to comply with the SRRE programs. Therefore, impacts related to solid waste would be less than significant. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -32 to 4 -46) and Addendum (Pages 5 -147 to 5 -164) g) Comply with federal, state, and local statutes and regulations related to solid waste? The developments anticipated by the Housing Element Update include 1,227 additional units. Although there would be increased generation of solid waste due to the proposed project, solid waste disposal facilities in Orange County would have ample capacity to accommodate solid waste generation. All new development would be subject to the existing SRRE requirements and thus would reduce solid waste generation. The impacts are not significant. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. Sources: Tustin City Code Tustin General Plan Housing Element Update Program EIS /EIR for MCAS- Tustin (Pages 4 -32 to 4-46) and Addendum (Pages 5 -147 to 5 -164) 3.18 MANDATORY FINDINGS OF SIGNIFICANCE a) Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self- sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? b) Does the project have impacts that are individually limited, but cumulatively considerable? ( "Cumulatively considerable" means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.) c) Does the project have environmental effects, which will cause substantial adverse effects on human beings, either directly or indirectly? The adoption of the Housing Element Update would not cause negative impacts. However the implementation of the Tustin Legacy could cause significant impacts to the environment. These impacts are identified in the Program EIS /EIR for MCAS- Tustin, Supplement, and its Addenda, and there are no additional impacts that would be created. On January 16, 2001, the City Council considered the benefits of the General Plan Amendment incorporating the Tustin Legacy and balanced those benefits against the unavoidable effects related to aesthetics, cultural, and paleontological resources, agricultural resources, traffic /circulation, and air quality. A Statement of Overriding Consideration was adopted along with the General Plan Amendment. Mitigation Measures/Monitoring Required: No mitigation measures are necessary. 70 3. Environmental Analysis Sources: Tustin City Code Tustin General Plan Housing Element Update Program EVER for MCAS- Tustin (Pages 5 -1 to 5 -11) 71 COMMUNITY DEVELOPMENT DEPARTMENT 300 Centennial Way, Totin, CA 92780 (714) 573 -3100 NEGATIVE DECLARATION Project Title: General Plan Amendment 2013 -002 Project Location: Citywide Project Description: An update to the City of Tustin General Plan Housing Element. The Housing Element sets forth the City's strategy to preserve and enhance the community's character, expand housing opportunities for the City's various economic segments, and provide the policy guidance for local decision making related to housing. Project Proponent: City of Tustin Lead Agency Contact Person: Scott Reekstin Telephone: 714/573 -3016 The Community Development Department has conducted an Initial Study for the above project in accordance with the City of Tustin's procedures regarding implementation of the California Environmental Quality Act, and on the basis of that study hereby finds: That there is no substantial evidence that the project may have a significant effect on the environment. ❑ That potential significant effects were identified, but revisions have been included in the project plans and agreed to by the applicant that would avoid or mitigate the effects to a point where clearly no significant effects would occur. Said Mitigation Measures are included in Attachment A of the Initial Study which is attached hereto and incorporated herein. Therefore, the preparation of an Environmental Impact Report is not required. The Initial Study which provides the basis for this determination is attached and is on file at the Community Development Department, City of Tustin. The public is invited to comment on the appropriateness of this Negative Declaration during the review period, which begins with the public notice of Negative Declaration and extends for twenty (30) calendar days. Upon review by the Community Development Director, this review period may be extended if deemed necessary. REVIEW / PERI OD ENDS 5:00 P.M. ON AUGUST 12,/20113/ Date_�l / 3 � td� L;.,Z — Elizabeth A. Binsack Community Development Director ll_► CITY COUNCIL RESOLUTION NO. 13 -86 RESOLUTION NO. 13 -86 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF TUSTIN, CALIFORNIA, APPROVING GENERAL PLAN AMENDMENT (GPA) 2013 -002, UPDATING THE TUSTIN HOUSING ELEMENT PURSUANT TO GOVERNMENT CODE SECTION 65588. The City Council of the City of Tustin does hereby resolve as follows: The City Council finds and determines as follows: A. That California State Law Section 65588 requires each City to review as frequently as appropriate and to revise its Housing Element as appropriate. B. That the City of Tustin adopted an amendment of its Housing Element on June 16, 2009. C. That the Housing Element is required to be updated to reflect new statutory requirements. D. That a public workshop was held on April 23, 2013, to familiarize the general public and the Planning Commission with the purpose and intent of the Housing Element Update. E. That the City advertised the availability of the Housing Element in English and Spanish in two local newspapers and also made the Housing Element available at City Hall, the City's website, and the Tustin Library. The City also sent a direct mailing to over 100 organizations consisting of youth, senior, veterans, disabled, homeless shelters, cultural organizations, housing advocates, religious organizations, housing builders, fair housing council, and individuals interested in the process. F. That the California Department of Housing and Community Development reviewed the Draft Housing Element and provided minor verbal comments to the City on August 7, 2013. G. That a public hearing was duly called, noticed, and held on General Plan Amendment 2013 -002 on August 13, 2013, by the Planning Commission to consider and provide further opportunity for the general public to comment on and respond to the proposed Housing Element Update, and the Planning Commission adopted Resolution No. 4228 recommending that the City Council approve GPA 2013 -002. H. That on August 22, 2013, the California Department of Housing and Community Development (HCD) confirmed that the revised draft Housing Resolution No. 13 -86 GPA 2013 -002 Page 2 Element will comply with State law upon its adoption by the City Council and transmittal to HCD. That a public hearing was duly called, noticed, and held on said application on October 1, 2013, by the City Council. J. That pursuant to the California Environmental Quality Act (CEQA) Guidelines Section 15063, the City of Tustin has completed an Initial Study to evaluate the potential environmental impacts associated with General Plan Amendment 2013 -002, and a Negative Declaration was prepared for the project. II. The City Council hereby approves General Plan Amendment 2013 -002, updating the Housing Element as identified in "Exhibit 1" attached hereto. PASSED AND ADOPTED by the City Council of the City of Tustin, at a regular meeting on the 15t day of October, 2013. ELWYN A. MURRAY MAYOR ATTEST: JEFFREY C. PARKER CITY CLERK Resolution No. 13 -86 GPA 2013 -002 Page 3 STATE OF CALIFORNIA ) COUNTY OF ORANGE ) CITY OF TUSTIN ) I, Jeffrey C. Parker, City Clerk and ex- officio Clerk of the City Council of the City of Tustin, California, do hereby certify that the whole number of the members of the City Council of the City of Tustin is five; that the above and foregoing Resolution No. 13 -86 was duly passed and adopted at a regular meeting of the Tustin City Council, held on the 1St day of October, 2013, by the following vote: COUNCILMEMBER AYES: COUNCILMEMBER NOES: COUNCILMEMBER ABSTAINED: COUNCILMEMBER ABSENT: JEFFREY C. PARKER CITY CLERK EXHIBIT 1 DRAFT REVISED GENERAL PLAN HOUSING ELEMENT AND TECHNICAL MEMORANDUM Housing Element TUSTIN GENERAL PLAN October, 2013 Adopted by Resolution No. 13-86 This page intentionally left blank. TABLE OF CONTENTS Section Page INTRODUCTION TO THE HOUSING ELEMENT 7 Purpose Of The Housing Element 7 Scope And Content Of Element 8 Consistency With State Planning Law 8 General Plan Consistency 10 Citizen Participation 11 SUMMARY OF ISSUES, NEEDS, CONSTRAINTS AND OPPORTUNITIES 14 Summary Of Housing Needs 14 Preservation Of Units At Risk Of Conversion 28 Summary Of Housing Issues 34 Housing Constraints 37 Housing Opportunities 51 HOUSING ELEMENT GOALS AND POLICIES 61 Housing Supply/ Housing Opportunities 61 Maintenance And Conservation 64 Environmental Sensitivity 65 Related Goals And Policies 66 HOUSING ELEMENT IMPLEMENTATION PROGRAM 68 RHNA Quantified Objectives 2014 -2021 68 Identification Of Affordable Housing Resources 73 Housing Programs 93 APPENDICES A - Review of Past Performance B - Affordability Gap Analysis C - Public Participation Mailing List D - References CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 4 LIST OF TABLES Tables Page TABLE H -1: State Housing Element Requirements 8 TABLE H- 2: Population Growth 15 TABLE H -2A: Population Projections 16 TABLE H- 3:Employment Projections 16 TABLE H- 4: List Of Major Employers 17 TABLE H- 5: Jobs/ Housing Balance 18 TABLE H- 6: Apartment Inventory Characteristics 21 TABLE H- 7: Tenure Of Households With Head Of Household Aged 65 Years Or Older 22 TALBE H -7A: Estimated Household Income Distribution - Households With Head Of Household Aged 65 Years Or Older 27 TABLE H- 8: Emergency Shelter/ Transitional Housing Facilities 30 TABLE H- 9: Assisted Housing Inventory 34 TABLE H -10: Summary Of Existing Housing Needs 33 TABLE H -11: Anticipated Development At Mcas - Tustin 41 TABLE H -11A: Summary Of Homeless Accommodation Zoning Regulations 48 TABLE H -12: Land Inventory And Residential Development Potential 53 TABLE H- 13A: Summary of Quantified RHNA Objectives 2014 -2021 55 TABLE H- 13B: Vacant And Underutilized Land With Residential Development Potential 56 TABLE H -14: Vacant Land Suitable For Residential Developments 59 TABLE H -15: Underutilized Land Suitable For Residential Developments 60 TABLE H -16: Housing Related Goals And Policies By Element 66 TABLE H -17: Quantified Objectives Summary 70 TABLE H -18: Summary Of Quantified Objectives 72 TALBE H -19: Affordable Housing Resources 75 TABLE H- 20: Housing Element Programs 93 CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 5 LIST OF FIGURES Page FIGURE 1: Vacant & Underutilized Land in the City of Tustin 58 CITY OF TUSTIN GENERAL PLAN HOUSING ELEMENT INTRODUCTION TO THE HOUSING ELEMENT The availability of decent housing and a suitable living environment for every family has been an ongoing concern to all levels of government. In California, this concern is addressed by the California Government Code requirement that each City adopt a Housing Element as a mandatory part of its General Plan. State Planning Law mandates that jurisdictions within the Southern California Association of Governments (SCAG) region adopt revisions to their Housing Elements by October 15, 2013. As a consequence of this due date, a series of time frames for various aspects of the Housing Element preparation are established. There are two relevant time periods: 2006 -2014: The previous planning period began in 2006, and ends on June 30, 2014. ° October 2013 - October 2021: the current Housing Element planning period for assessing short -term housing construction needs and implementing housing programs. The planning period for the Regional Housing Needs Assessment (RHNA) as prepared by SCAG, is from January 1, 2014 to October 1, 2021, a seven and three - quarter year period. The source of most of the demographic data in this Housing Element and the related Housing Element Technical Memorandum is the U.S. Census Bureau, American Community Survey, 2007 -2011 Five -Year Estimates. This was the most comprehensive and recent source of data available at time this Housing Element was prepared. PURPOSE OF THE HOUSING ELEMENT The Land Use Element is concerned with housing in a spatial context while the Housing Element identifies housing programs aimed at meeting the identified housing needs of the City's population. The Tustin Housing Element includes the identification of strategies and programs that focus on: 1) housing affordability, 2) rehabilitating substandard housing, 3) meeting the existing demand for new housing, and 4) conserving the existing affordable housing stock. The Tustin Housing Technical Memorandum provides background information and supporting documentation. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 7 SCOPE AND CONTENT OF ELEMENT The State Legislature recognizes the role of the local general plan, and particularly the Housing Element, in implementing statewide housing goals. Furthermore, the Legislature stresses continuing efforts toward providing affordable housing for all income groups. The Legislature's major concerns with regard to the preparation of Housing Elements are: • Recognition by local governments of their responsibility in contributing to the attainment of State housing goals; • Preparation and implementation of housing elements which coordinate with State and Federal efforts in achieving State housing goals; • Participation by local jurisdictions in determining efforts required to attain State housing goals; and ° Cooperation between local governments to address regional housing needs. The State Department of Housing and Community Development (HCD) set forth specific requirements regarding the scope and content of housing elements. CONSISTENCY WITH STATE PLANNING LAW The preparation of the City's Housing Element is guided by and must conform to Section 65580 et seq. of the California Government Code. In the introduction of these Government Code sections, the Legislature establishes a policy that the availability of housing in a suitable environment is of vital statewide importance, and a priority of the highest order. It further states that local governments are to address the housing needs of all economic segments, while considering the economic, environmental and fiscal factors and community goals set forth in the General Plan. The following table cites the required components for the Housing Element and cites the document and page references for the required components. TABLE H -1 STATE HOUSING ELEMENT REQUIREMENTS Required Housing Element Component Page A. Housing Needs Assessment 1. Analysis of population trends in Tustin in relation to regional trends HTM 9 & HE 10 2. Analysis of employment trends in Tustin in relation to regional trends HTM 12 & HE 11 CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN A TABLE H -1 STATE HOUSING ELEMENT REQUIREMENTS CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 9 Required Housing Element Component Page 3. Projection and quantification of Tustin's existing and projected housing needs HE 30 & HTM 40 for all income groups 4. Analysis and documentation of Tustin's housing characteristics including the following: a level of housing cost compared to ability to pay, HTM 22 b overcrowdfn • HTM 17 c) Housing stock condition. HIM 31 5. An inventory of land suitable for residential development including vacant HE 69 sites and sites having redevelopment potential and an analysis of the relationship of zoning, public facilities and services to these sites 6. Identification of a zone or zones where emergency shelters are allowed as a HE 58-60 permitted use 7. Analysis of existing and potential governmental constraints upon the HTM 49 & HE 36 maintenance, improvement, or development of housing for all income levels 8. Analysis of existing and potential non - governmental and market constraints HTM 71 & HE 33 upon maintenance, improvement, or development of housing for all income levels 9. Analysis of special housing need: persons with disabilities (including HE 18 & HTM 23 developmental disabilities), the elderly, large families, female- headed family households, farmworkers, and families and persons in need of emergency shelter 10. Analysis concerning the needs of homeless individuals and families in Tustin HE 21 & HTM 26 11. Analysis of opportunities for energy conservation with respect to residential HTM 76 development 12. Analysis of existing assisted housing developments that are eligible to change HE 32 -34 & HTM from low- income housing uses during the next 10 years B. Goals and Policies 1. Identification of Tustin's goals, quantified objectives and policies relative to HE 71 maintenance, preservation, improvement, and development of housing CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 9 TABLE H -1 STATE HOUSING ELEMENT REQUIREMENTS a,uca:e: Cattrurnia Government Code, gtww, et aL GENERAL PLAN CONSISTENCY While a city must consider housing needs for all economic segments, it must also maintain internal consistency among other elements of the General Plan as required by state law. Neither the Housing Element nor any other element may supersede any other required Tustin General Plan elements. The Housing Element relates to other elements in a variety of ways. The Land Use Element directly relates to the Housing Element by designating areas of the City in which a variety of residential types and densities exist. The Housing Element's relationship to the Conservation, Open Space, and Recreation Element is conditioned by the need to serve a growing population's recreational needs in the areas of the City with the highest density. Also, housing needs for low cost land must be balanced by the need to conserve natural resources. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 10 Required Housing Element Component Page C. Implementation Program An im lementation ro am should do the following: 1. Identify adequate sites which will be made available through appropriate HE 121 -147 action with required public services and facilities for a variety of housing types for all income levels 2. Assist in the development of adequate housing to meet the needs of extremely HE 121 -147 low, very -low, low -and moderate - income households 3. Identify and, when appropriate and possible, remove governmental HE 121 -147 constraints to the maintenance, improvement, and development of housing 4. Conserve and improve the condition of the existing and affordable housing HE 121 -147 stock 5. Promote housing opportunities for all persons HE 121.147 6. Identify programs to address the potential conversion of assisted housing HE 121 -147 developments to market rate units 7. Identify agencies and officials responsible for implementation HE 135 8. Include a description of the public participation effort HE 6-8 a,uca:e: Cattrurnia Government Code, gtww, et aL GENERAL PLAN CONSISTENCY While a city must consider housing needs for all economic segments, it must also maintain internal consistency among other elements of the General Plan as required by state law. Neither the Housing Element nor any other element may supersede any other required Tustin General Plan elements. The Housing Element relates to other elements in a variety of ways. The Land Use Element directly relates to the Housing Element by designating areas of the City in which a variety of residential types and densities exist. The Housing Element's relationship to the Conservation, Open Space, and Recreation Element is conditioned by the need to serve a growing population's recreational needs in the areas of the City with the highest density. Also, housing needs for low cost land must be balanced by the need to conserve natural resources. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 10 The Circulation Element attempts to provide an efficient and well- balanced circulation system. This system must be designed to accommodate allowed land uses, including residential uses, and the intensity of allowable uses should not exceed the ultimate capacity to accommodate them The Safety Element relates to the Housing Element by designating areas that are unsafe for development such as Alquist -Priolo Zones, floodplains, etcetera. Similar to the Safety Element, the Noise Element relates to the Housing Element by addressing a health related issue area. Techniques for reducing noise often involve buffers between land uses. The Growth Management Element overlaps the issues raised in the Housing Element in its efforts to ensure that the planning, management, and implementation of traffic improvements and public facilities are adequate to meet the current and projected needs of Orange County. The Housing Element has been reviewed for consistency with the City's other General Plan elements and policy directions. As parts of the General Plan are amended in the future, this housing element will be reviewed to ensure that consistency is maintained. CITIZEN PARTICIPATION The California Government Code requires that local governments make diligent efforts to solicit public participation from all segments of the community in the development of the Housing Element. Public participation in the Housing Element Update process occurred through the following methods: • A public workshop was conducted on April 23, 2013 to provide an opportunity for interested persons to ask questions and offer suggestions on the proposed Housing Element. Approximately 24 members of the public attended the workshop, and nine (9) individuals provided verbal comments. Seven (7) of the speakers expressed concerns and provided comments regarding the affordable housing needs of individuals with developmental disabilities. These needs and related programs are addressed in the draft Housing Element. The other speakers provided general comments regarding senior housing and the need for affordable housing. Notice of this workshop was published in the Tustin News, on the City's website, and was also mailed to the City's list of local housing interest groups. A copy of the mailing list is included as Appendix C. • Specific implementation programs included in the Housing Element Update were also discussed at various public hearings in anticipation of the Housing Element Update. These hearings include the Federal Community CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 11 Development Block Grant Program public hearings held on March 5, 2013, and May 7, 2013. • Public hearings were held on August 13, 2013, by the Planning Commission and on October 1, 2013, by the City Council to provide additional opportunities for public review and comment on the Housing Element Update and supporting documents. All public meetings were advertised in the Tustin News and the City's website. Special notifications were also sent to those on the City's list of interested parties. • Draft Housing Element, Technical Memorandum, and relevant documents were made available at the City Hall, Library, on City's website for easy access and download, and mailed to requesting parties. Public comments received were evaluated and incorporated into the staff report to the Planning Commission and the City Council. As appropriate, the Housing Element has been revised to address these comments. • On June 21, 2013, the City sent the draft Housing Element to the Department of Housing and Community Development (HCD). On October 1, 2013, the City Council adopted the Housing Element Update as required by the State Law. Following adoption, on October 2, 2013, the City sent the adopted Housing Element to HCD for final review. On, 2013, the City received final approval from HCD. The City advertised the availability of the Housing Element in English and Spanish in two local newspapers and also made the Housing Element available at City Hall, the City's website, and the Tustin Library. The City also sent direct mailings to over 100 organizations consisting of youth, seniors, veterans, disabled, homeless shelters, cultural organizations, housing advocates, religious organizations, housing builders, fair housing council, and individuals interested in the process. Revised Housing Element and its relevant documents are posted on the City website to allow the public and interested organization easy access and download. In addition to public input received at the April 23, 2013, public workshop, the City received written public comments from several individuals and organizations. The City received correspondence pertaining to the needs of individuals with development disabilities. The Housing Element addresses the needs of persons with development disabilities by first defining the term "developmentally disabled," by explaining the specific needs of persons with developmental disabilities, by describing some of the services available, by providing an estimate of the number of persons with development disabilities living in Tustin, and by including a program to work with the Regional Center of Orange County to implement an outreach program that would inform the public of the services available to persons with developmental disabilities in Tustin. In addition, the CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 12 City's Housing Authority is committed to working with entities seeking funding to provide housing for persons with developmental disabilities. In addition, a letter was received from the Airport Land Commission. Although the Housing Element update does not propose any new development within the John Wayne Airport Planning Area, Airport Land Commission staff indicated that their review is required for the General Plan Amendment and that it would be possible for their review to occur prior to the City Council hearing. This review is more procedural in nature, and no issues are anticipated. Correspondence from the Kennedy Commission commended the City for its efforts in encouraging and facilitating the development of affordable housing. The Kennedy Commission included four recommendations in their letter. The first and third recommendations are already addressed in that the City has continued its partnership with the Kennedy Commission and the City already has density bonuses and other incentives available citywide for affordable housing. The second and fourth recommendations relate to potential funding sources and fee waivers for affordable housing and therefore, will be considered by the City Council. Finally, the Department of Transportation (Caltrans) provided general comments on the Draft Housing Element, encouraging efficient land use patterns and more sustainable communities, and acknowledging that the Housing Element update does not propose any significant land use changes. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 13 SUMMARY OF ISSUES, NEEDS, CONSTRAINTS AND OPPORTUNITIES This section of the Housing Element summarizes Tustin's current and projected housing needs to form the basis for establishing program priorities and quantified objectives in the Housing Element. This section also: • Estimates the number of households that meet Federal or State criteria for special consideration when discussing specialized needs; • Evaluates assisted units at risk of conversion; • Describes constraints that may discourage the construction of new housing, and • Examines housing opportunity sites. SUMMARY OF HOUSING NEEDS A number of factors will influence the degree of demand or "need" for housing in Tustin. The major "needs" categories considered in this Element include: • Housing needs resulting from increased population and employment growth in the City and the surrounding region, • Housing needs resulting from household overcrowding; • Housing needs resulting from the deterioration or demolition of existing units; • Housing needs that result when households are paying more than they can afford for housing, • Housing needs resulting from the presence of "special needs groups" such as the elderly, large families, female- headed households, households with a disabled person, and the homeless; and • Housing needs resulting from conversion of the assisted housing stock to market rate. Population Growth As shown in Table H -2, between 2000 and 2010 the City's population grew from 67,504 to 75,540, an increase of 11.9 percent. Between 2010 and 2012 population growth slowed significantly, falling 41.2 percent from the yearly average of 1.2 percent between 2000 and 2010 to .7 percent over the past 2 years. The City of Tustin's growth rate between 2010 and 2012 was slightly slower than the CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 14 countywide growth rate but faster than the nearby cities of Garden Grove, Orange, and Santa Ana. Recent projections released by the Center for Demographic Research, CSUF (Orange County Projections 2010 Modified, January 26, 2012) indicate that Tustin's population will increase by an annual rate of approximately 0.7 percent during this implementation period, bringing the total population to 83,534 by the year 2025. Table H -2 compares the City's growth rate between 2000 and 2012 with other Orange County cities and the County as a whole. A large percentage of Tustin's population growth can be attributed to annexations that have occurred since 1980. The remainder can be attributed to a variety of other factors, including shifts in family structures from smaller to larger families, redevelopment of existing developed areas, infill development, and residential construction in East Tustin and Tustin Legacy (former Marine Corps Air Station [MCAS] Tustin). Substantial population and housing growth will continue during this planning period with the continued development at Tustin Legacy. TABLE H- 2 Population Growth 2000 -2012 Citv of Tustin. Nearhv Turkdir►inne and Jurisdiction 20001 20102 20123 Percent Growth 2000 -2010 2010 -2012 Tustin 67,504 75,540 76,567 11.9% 1.4% Anaheim 328,014 336,265 343,793 2,5% 2.2% Garden Grove 165,196 170,883 172,648 3.4% 1.0% Irvine 143,072 212,375 223,729 48.4% 5.3% Orange 128,821 136,416 138,010 5.9% 1.2% Ana 337,977 324,528 327,731 -4,0% 1.0% !nta ge un 3,010232 3,055,792 5.8% 1.5% 31010 U.S. census s Department of Finance estimates 2012 Population projections are shown in Table H -2A. According to Orange County Projections (OCP) 2010 Modified data, the population in the City of Tustin is expected to increase by approximately 6.3 percent from 77,965 persons in 2015 to 82,878 persons by the year 2035, after a peak population of 83,944 in 2030. The decrease in the last five years of the projections is attributed to general countywide CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 15 demographic characteristics, such as the age structure of the population, declining fertility rates, low housing growth, and declining immigration. TABLE H- 2A Population Projection source: center for Demographic Research at Cal State Fullerton - OCP 2010 Modified, January 26, 2012 Employment According to 2007 -2011 American Community Survey data, the City of Tustin had 41,761 residents in the labor force, of which 38,308 (91.7 percent) were in the labor market. Of these, 83.7 percent were private wages and salary workers. Table HTM-4 in the Technical Memorandum shows the breakdown of employment by occupation. In 2011, the largest occupational category was management, business, science and arts occupations, in which a total of 15,698 were employed. The second largest category was the sales and office occupations, employing 10,214. Table H -3 provides employment projections between the years 2015 and 2035. According to OCP -2012 Modified data, employment in the City of Tustin is expected to increase by approximately 47 percent between 2015 and 2035. TABLE H- 3 Employment Projection 2015 2020 2025 2030 2035 Percent Change 2015 2035 Tustin 77,965 81,310 83,534 53,944 82,878 6.30% source: center for Demographic Research at Cal State Fullerton - OCP 2010 Modified, January 26, 2012 Employment According to 2007 -2011 American Community Survey data, the City of Tustin had 41,761 residents in the labor force, of which 38,308 (91.7 percent) were in the labor market. Of these, 83.7 percent were private wages and salary workers. Table HTM-4 in the Technical Memorandum shows the breakdown of employment by occupation. In 2011, the largest occupational category was management, business, science and arts occupations, in which a total of 15,698 were employed. The second largest category was the sales and office occupations, employing 10,214. Table H -3 provides employment projections between the years 2015 and 2035. According to OCP -2012 Modified data, employment in the City of Tustin is expected to increase by approximately 47 percent between 2015 and 2035. TABLE H- 3 Employment Projection Source: OCP 2010 Modified, Prepared by Center for Demographic Research at Cal State Fullerton In terms of industry, the Educational services, and health care and social assistance and Professional, scientific, and management, and administrative and waste management services sectors employed the largest number of persons with 6,947 (18.1 %) and 5,606 (14.6 %) employees, respectively. Table H-4 is a summary of the number of employees by industry. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 16 Percent 2015 2020 2025 2030 2035 Change 2015 -2035 Tustin 45,428 51,890 60,370 65,425 66,771 46.98% Source: OCP 2010 Modified, Prepared by Center for Demographic Research at Cal State Fullerton In terms of industry, the Educational services, and health care and social assistance and Professional, scientific, and management, and administrative and waste management services sectors employed the largest number of persons with 6,947 (18.1 %) and 5,606 (14.6 %) employees, respectively. Table H-4 is a summary of the number of employees by industry. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 16 Due to its favorable location, demographics, and business environment, Tustin is home to several large employers. The City's top ten employers include: Young's Market Co. LLC, Tustin Unified School District, Lamppost Pizza Corp., Ricoh Electronics Inc., Toshiba America Medical Systems, Rockwell Collins Inc., Costco, Cherokee International Inc., City of Tustin, and Raj Manufacturing Inc. Table H-4 provides a list of the largest employers in Tustin in 2011. The list includes a variety of industries, including manufacturing, health care, retail, and technology sectors. TABLE H- 4 LIST OF MAJOR EMPLOYERS IN TUSTIN. CA 2011 Company /Address No. Emp. Product/Service Young's Market Co LLC 2,100 Distributor 14402 Franklin Ave Tustin, CA 92780 Tustin Unified School District 1,728 Education 300 South C St. - Tustin 92780 Lamppost Pizza Corp 1,4001 Corporation 3002 Dow Ave, Tustin, CA Ricoh Electronics, Inc. 1,384 Manufacturer 1100 Valencia Ave. - Tustin, 92780 Toshiba America Medical Systems 900 Distributor, Medical 2441 Michelle Dr. - Tustin, 92780 Equipment Rockwell Collins - (714) 317 -8102 600 Manufacturer 14192 Franklin Ave.- Tustin, 92780 Costco Wholesale 450 Wholesale Trade 2700 Park Ave. - Tustin 92780, 2655 El Camino Real, Tustin, CA Cherokee International 350 Power Supplies 2841 Dow Ave. - Tustin, 92780 City of Tustin 300 Government 300 Centennial Way - Tustin 92780 Raj Manufacturing Inc. 260 Manufacturing 2692 Dow Ave, Tustin, CA Cash Plus Inc. 250 Financial Services 3002 Dow Ave, Tustin, CA Kleen Impressions 250 Cleaning Services 1730017th St # j Pmb 388, Tustin, CA Ricoh Business Solutions 250 Business Services 1123 Warner Ave Tustin, CA 92780 Southern California Pipeline 235 Construction 15991 Red Hill Ave, Tustin, CA Home Depot 203 Retail 2782 El Camino Real - Tustin, 92780 Health South Tustin Rehab Hospital 200 Medical 14851 Yorba St, Tustin, CA CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 17 Logomark, Inc. 200 Wholesale Trade 1201 Bell Ave. - Tustin 92780 Total Jobs 36,869 Red Robin Gourmet Burgers2 2001 Retail 3015 El Camino Real, Tustin, CA 1,046,323 6,311,587 SMC Corporation of America 200 Manufacturer 14191 M ford Rd. - Tustin 92780 Straub Distributing Company3 200 Wholesale Trade 2701 Dow Ave. - Tustin, 92780 Tustin Toyota 200 Automotive Dealer 36 Auto Center Dr., Tustin, CA 1 111u.: ury or r usnn �omprenenstve Annual Financial Report For the Year Ended June 30, 2011 r The employee count appears to include those employed at locations outside of Tustin. 3 Red Robin Gourmet Burgers was located at 3015 EI Camino Real in 2011 and has relocated to 2667 Park Avenue. ' Straub Distributing Company was located in Tustin in 2011 but is no longer doing business in Tustin Jobs- Housing Balance The "jobs- housing balance" test is a general measure of a community's employment opportunities with respect to its residents' needs. A balanced community would reach equilibrium between employment and housing opportunities so the majority of the residents could also work within the community. Table H -5 shows the 2011 jobs - housing balance for the City of Tustin as well as Orange County and the Southern California region. Tustin had a jobs /housing ratio of 1.40 in 2011, while Orange County and the region had jobs /housing ratios of 1.38 and 1.23, respectively. This demonstrates that Tustin is a job -rich community when compared to county and regional averages. TABLE H- 5 JOBS/HOUSING BALANCE CITY /COUNTY /REGION 2011 urc� -: —u: 4007 -4011 American uommunity Survey Center for Economic Studies 2011 Overcrowding From 2007 to 2011 there has been a decrease in unit overcrowding, as fewer households "double up" to save on housing costs. Overcrowding is often reflective CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 18 Tustin Oran a Coun SCAG Re 'on Total Jobs 36,869 1,447,768 7,174,832 Housing Units 26,418 1,046,323 6,311,587 Jobs/ Housing Ratio SO........... 1.40 1.38 1.14 urc� -: —u: 4007 -4011 American uommunity Survey Center for Economic Studies 2011 Overcrowding From 2007 to 2011 there has been a decrease in unit overcrowding, as fewer households "double up" to save on housing costs. Overcrowding is often reflective CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 18 of one of three conditions: 1) a family or household is living in a dwelling that is too small; 2) a family chooses to house extended family members (Le., grandparents or grown children and their families living with parents, termed doubling); or 3) a family is renting living space to non - family members. State and Federal Housing Law defines overcrowded housing units as those in which the ratio of persons -to -rooms exceeds 1.0. The rooms considered in this equation exclude bathrooms, kitchens, and hallways, but includes other rooms such as living and dining rooms. The 2007 -2011 American Community Survey showed 2,508 (10 percent) of households living in overcrowded conditions in Tustin. Of the households living in such conditions, 78 percent were renters. Renter households had a significantly higher incidence of overcrowding than owner households: 7.8 percent of renter and 2.2 percent of owner households were overcrowded. Table HTM -8 of the Housing Element Technical Memorandum illustrates the numbers of all Tustin households living in overcrowded conditions. Substandard Units By 2020, approximately 62 percent of the City's housing stock will be over 30 years old, the age at which housing tends to require significant repairs. This indicates a potential need for rehabilitation and continued maintenance of over 17,324 dwelling unitsl. Affordability State and Federal standards for rental housing overpayment are based on an income -to- housing cost ratio of 30 percent and above. Households paying greater than this percentage will have less income left over for other necessities, such as food, clothing and health care. Upper income households are generally capable of paying a larger proportion of their income for housing, and therefore estimates of housing overpayment generally focus on lower income groups. As identified in the 2012 RHNA, 2,458 Tustin households are at or below 30% of the County Median Household Income (MHI) and considered "Extremely Low Income." The 2012 RHNA also shows 11,266 of Tustin households were paying more than 30 percent (overpaying) of their income on housing needs. Table HTM -12 of the Housing Element Technical Memorandum reflects American Community Survey estimates for households overpaying for shelter. While most extremely low income households are currently housed, they are in a precarious position, particularly those overpaying for housing in light of the current housing market, and could face the threat of homelessness. 12007-2011 American Community Survey; City of Tustin. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 19 The distinction between renter and owner housing overpayment is important because, while homeowners may over - extend themselves financially to afford the option of home purchase, the owner always maintains the option of selling the home, thereby generally lowering housing costs. In addition, home ownership affords tax benefits to reduce monthly costs. Renters are limited to the rental market, and are generally required to pay the rent established in that market. According to the American Community Survey data, of the total 4,585 lower income households identified as over - payers, 3,368 were renter households and 1,217 were owner households. This discrepancy is largely reflective of the disproportionate number of rental housing units in the City and the tendency of renter households to have lower incomes than owner households (see Table HTM -11 in the Technical Memorandum). Table H -6 summarizes the characteristics of the current apartment inventory in the City of Tustin as of the first quarter 2013 based on data from REALFACTS. The data include a total of 28 apartment properties and 5,810 units, with an average of 208 units per property. All properties in the inventory have at least 100 units and were built between 1957 and 1997. Therefore, the data do not include small multifamily properties. The overall rental vacancy rate for Tustin in 2011 was 5.6 percent, up considerably from 4.3 percent in the first quarter of 2007. Generally, a vacancy rate of 5 percent is considered to reflect a "tight" housing market. Department of Finance data for Tustin as of January 2013 show a vacancy rate of 4.8 percent for all housing types in Tustin (single- and multi- family, owner and rental). The data show that approximately 40 percent of apartment units in the City have one bedroom, 52 percent have two bedrooms, and 5 percent have three bedrooms. Average monthly rents are $1,340 for a one - bedroom, one -bath unit. For two - bedroom units, average monthly rents are $1,448 for units with one bath, $1,412 for units with one and a half baths, $1,828 for units with two baths, and $1,695 for two- bedroom townhouse units. The average monthly rent for a three- bedroom unit with one and a half baths is $1,777 and for a three - bedroom unit with two baths the average rent is $2,391. The average rent for a three- bedroom townhouse unit is $1,845. The weighted average rental rate for the inventory increased 1.9percent over the past year2. Rents for studios increased the most at 5.1 percent, followed by two- bedroom one -bath units at 3.5 percent, and one - bedroom one -bath units at 3.1 percent. 2 These weighted average rents weight the average rent by bedroom count by the number of units in that bedroom count category. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 20 TABLE H- 6 Apartment Inventory Characteristics m....t, )m a U7Size Units P ercent Average SF Average Rent Average Ren SF Studio 200 3.4 °/ 521 $1,267 $2.43 r 1 BR 32 0.6 °k 470 $1,070 $2.28 1 BR 1 BA 2,303 39.6% 732 $1,340 $1.83 2 BR 1 BA 625 10.8 °k 976 $1,448 $1.48 2 BR 1.5 BA 266 4.6% 945 $1,412 $1.49 2 BR 2 BA 1,924 33.1% 1,021 $1,828 $1.79 2 BR TH 194 3.3% 1,079 $1,695 1 $1.57 3 BR 1.5 BA 36 0.6% 1,371 $1,777 $1.30 3 BR 2 BA 210 3.6 °k 1,172 $2,391 $2.04 3 BR TH 20 0.3 °k 1,516 $1,845 $1.22 _.....6.­ -.,,...,,,,,,,x...,. Note: Averages for the Total row are weighted averages. Source: Realfacts Affordability Gap Analysis In addition to information related to Housing Constraints provided in the City's Housing Element Technical Memorandum, a Comprehensive Housing Affordability Strategy was prepared in 2008. The report contains a detailed affordability gap analysis to illustrate the "gap" between the cost of developing housing for rent and ownership and what households at a variety of income levels can afford to pay toward their housing expenses. A Summary of Renter and Owner Affordability Gaps for certain prototypical unit types and incomes are provided as Appendix '13.3" Special Needs Groups Certain segments of the population may have a more difficult time finding decent, affordable housing due to special circumstances and may require specific accommodation or assistance to meet their housing needs. Included as special needs groups are the elderly, disabled, including persons with developmental disabilities, female- headed households, large families, and homeless persons. As there are no known "farmworkers" residing in Tustin this group is not discussed in the Housing Element. Elderly: The special needs of many elderly households result from their lower, fixed incomes, physical disabilities, and need for assistance. As shown in Table HTM -2, 3 Summary based on data contained in Comprehensive Housing Affordability Strategy, 2008. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 21 persons aged 65 years or older in Tustin comprised 8.8 percent of the population in 2011. Table H -7 shows the tenure of households with the head of household aged 65 years or older in the City of Tustin in 2011. The City had 1,071 renter households and 2,839 owner households with a head of household aged 65 years or older. Households with a senior householder represented 15.7 percent of all households in the City. TABLE H- 7 Tenure of Households with Head of Household Aged 65 Years or Older 2011 Head of Household 65 Years or Older Tenure # Households % Households Renters 1,071 9.1%1 As a percentage of 11,833 renter households. As a percentage of 13,112 owner households. As a percentage of 24,945 total households. Source: U.S. Census, 2007 -2011 American Community Survey Table H -7A shows the estimated household income distribution for householders aged 65 years or older in 2011. Approximately 14 percent of elderly households in Tustin earned less than $25,000 annually or about 37 percent of ANH for a household of two persons in 2011.4 TABLE H -7A Estimated Household Income Distribution Households with Head of Household Aged 65 Years or Older 2011 Income Range Number Percent Cumulative a/o Less Than $10,000 153 19% 3.9% $10,000- $24,999 394 10.1% 14.0% $25,000- $34,999 300 7.7% 20.7% $35,000 - $49,999 479 12.2% 33.9% $50,000 - $74,999 676 17.3% 50.2% $75,000 - $99,999 566 14.5% 64.7% $100,000 or More 1,342 34.3% 100.0% Bureau: 4 HUD median household income for a family of two in Orange County in 2011 was $67,350. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 22 Disabled: Physical and developmental disabilities can hinder access to housing units of traditional design and potentially limit the ability to earn adequate income. According to the 2009 -2011 ACS, a total of 2,192 persons in Tustin between 18 and 65 years of age reported a disability. In addition, 1,745 persons over age 65 reported a disability in 2011. Special housing needs of disabled individuals include wheelchair accessibility, railings, and special construction for interior living spaces. The Housing Element sets forth policies to encourage the development of disabled- accessible housing (see policies 1.11, 1.13,1.15). Persons with Developmental Disabilities: As defined by federal law, developmental disability" means a severe, chronic disability of an individual that: • Is attributable to a mental or physical impairment or combination of mental and physical impairments; • Is manifested before the individual attains age 22; • Is likely to continue indefinitely; • Results in substantial functional limitations in three or more of the following areas of major life activity: a) self -care; b) receptive and expressive language; c) learning; d) mobility, e) self - direction; f) capacity for independent living; or g) economic self - sufficiency; • Reflects the individual's need for a combination and sequence of special, interdisciplinary, or generic services, individualized supports, or other forms of assistance that are of lifelong or extended duration and are individually planned and coordinated. The U.S. Census Bureau does not record developmental disabilities. According to the U.S. Administration on Developmental Disabilities, an accepted estimate of the percentage of the population that can be defined as developmentally disabled is 1.5 percent. Many developmentally disabled persons can live and work independently within a conventional housing environment. More severely disabled individuals require a group living environment where supervision is provided. The most severely affected individuals may require an institutional environment where medical attention and physical therapy are provided. Because developmental disabilities exist before adulthood, the first issue in supportive housing for the developmentally disabled is the transition from the persons living situation as a child to an appropriate level of independence as an adult. The State Department of Developmental Services (DDS) currently provides community-based services to approximately 243,000 persons with developmental CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 23 disabilities and their families through a statewide system of 21 regional centers, four developmental centers, and two community -based facilities. The Regional Center of Orange County (RCOC) is one of 21 regional centers in California that provides point of entry to services for people with developmental disabilities. The RCOC is a private, non - profit community agency that contracts with local businesses to offer a wide range of services to individuals with developmental disabilities and their families. Any resident of Orange County who has a developmental disability that originated before age 18 is eligible for services. Services are offered to people with developmental disabilities based on Individual Program Plans and may include: Adult day programs; advocacy; assessment /consultation; behavior management programs; diagnosis and evaluation; independent living services; infant development programs; information and referrals; mobility training; prenatal diagnosis; residential care; respite care; physical and occupational therapy; transportation; consumer, family vendor training, and vocational training. RCOC also coordinates the state - mandated Early Start program, which provides services for children under age three who have or are at substantial risk of having a developmental disability. According to the RCOC February 2010 Facts and Statistics data, the RCOC currently serves approximately 16,728 individuals. According to the RCOC, there are at least 428 children and adults with developmental disabilities living within the City of Tustin. There may be others who have chosen not to receive services from the Regional Center or who are not aware of or understand the services provided by the Regional Center. Large Families: A family household containing five or more persons is considered a large family, as defined by the Census Bureau. Large families are identified as groups with special housing needs because of the limited availability of adequately sized, affordable housing units. Large families are often of lower income, frequently resulting in the overcrowding of smaller dwelling units and accelerating unit deterioration. According to the 2007 -2011 ACS, 3,852 family households, or 15.4 percent of all households, had five or more persons (see Housing Element Technical Memorandum Table HTM -14). Of those, approximately 47.6 percent were owner- households and 52.4 percent were renter households. Female- Headed Parent Households: The housing needs of female- headed households with children are generally related to affordability since such households typically have lower than average incomes. According to the 2007 -2011 ACS, the City of Tustin had 1,652 female- headed households with children less than 18 years of age. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 24 Single Room Occupancy (SRO): A single room occupancy unit typically is a 250 to 500 square feet residential unit, with a sink and closet, which may require the occupant to share a communal bathroom, shower, and /or kitchen. SRO units are allowed within the City's Multiple Family Residential districts and Planning Area 3 of the MCAS Tustin Specific Plan. Single room occupancy units such as rest homes also are allowed within Commercial Districts in the city through approval of a Conditional Use Permit. Although no specific ordinance is in place to address SRO units, the City may consider the adoption of single -room occupancy (SRO) ordinance during the planning period. The Homeless: Measuring the extent of the homeless population specifically in Tustin remains a challenge for community leaders. To complicate the challenge of meeting homeless persons' needs, the issue of homelessness is considered regional in nature. Nomadic tendencies of homeless persons make it difficult to assess the population accurately on a citywide basis; therefore, homelessness should be addressed on a countywide basis, in conjunction with cities and local non - profit organizations. The Orange County Housing and Community Development Department defines homelessness as not having a permanent address, sleeping in places not meant for habitation, not having ample food and medical attention or a place to change clothes or bathe. Per this definition, the County of Orange estimates in 2011 there were 18,325 homeless in the County. For those 18,325 homeless, there are only about 3,357 available beds, including 1,156 emergency shelter beds and 2,201 beds in transitional housing facilities, according to the Orange County Ten -Year Plan to End Homelessness 2012. The homeless population is comprised of subgroups, which include: a) The economic homeless who lack financial resources to pay rent, b) The situational homeless who have suffered economic or personal trauma and find themselves in personal disorganization; and, c) The chronic homeless who are unable to care for themselves due to chronic illness, disability or debilitating substance abuse. The City of Tustin's 2010 -2015 Consolidated Plan states that, according to police reports and windshield surveys performed within the City of Tustin, most homeless persons migrate through Tustin to other parts of the County rather than stay for extended periods of time within the City. The City's Police Department estimates that there are 10 -12 homeless persons residing in the City at any given time. There are numerous factors that contribute to homelessness in Tustin and Orange County. The known causes of homelessness include unemployment, limited skills, CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 25 and a breakdown in the family as a social and economic unit. Additionally, cutbacks in social service programs and the de- institutionalization of the mentally ill during the 1980s have contributed to the homeless population. A new trend, however, is emerging as a significant contributing element to homelessness: a fast - growing lack of affordable housing, which could exacerbate any of the above conditions, but may increasingly become a standalone cause of homelessness. Although there are no established areas where unsheltered homeless persons congregate in the City, there are several homeless services facilities in the City. One of the shelters in Tustin, the 45 -bed Sheepfold shelter provides shelter, food, clothing, job training, and job - referral services primarily to battered women and children. Guests are admitted on a first -come, first- served basis. Usually all beds are fully occupied. The shelter services a large area including many portions of Orange and San Bernardino Counties. Within the City of Tustin, there are a variety of Non -Profit Organizations (NPOs) that provide direct housing and related services to homeless persons. These include Village of Hope, an emergency/ transitional home; Sheepfold, a feeding program affiliated with the United Way; Families Forward, a homeless provider; Olive Crest, transitional homes and services for abused and neglected children, and Laurel House, an emergency shelter and transitional housing provider for homeless youth in the City. Additional programs have been provided at the Tustin Legacy site. A Homeless Assistance Plan has been established for MCAS, Tustin that is consistent with the continuum of care model embodied in the Consolidated Plans for the Cities of Tustin and neighboring Irvine. The fundamental components of the continuum of care system implemented with the MCAS Tustin Specific Plan: Provide emergency shelter beds and intake assessment Offer transitional housing and services Provide opportunities for permanent affordable housing by the private sector. In Tustin Legacy, four homeless service providers including the Salvation Army, Orange Coast Interfaith Shelter, Families Forward, and Human Options currently are operating 48 family units. The Orange County Rescue Mission operates a 192 - unit transitional /emergency shelter (Village of Hope) and the Orange County Social Services Agency operates a 90bed facility for abused and neglected children and their families. Numerous other agencies provide shelter and other services to the homeless in the nearby cities of Santa Ana, Irvine, and Orange. Table H -8 is a list of organizations in Tustin that provide homeless services. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 26 TABLE H- 8 EMERGENCY SHELTER/TRANSITIONAL HOUSING FACILITIES Facility Services Provided Sheepfold Provides shelter, food, clothing, job training, and job - referral services to women with children. Temporary housing for teenagers in crisis. The facility also Laurel House provides food, informal counseling, and access to medical care and clothing. St. Cecilia's Distributes food supplies to needy populations. Redhill Lutheran Operates emergency food program where a person can receive food supplies. Tustin Presbyterian Collects food supplies and distributes the food to various or anizations involved in rovidin homeless services. Aldergate Refers interested persons to Ecumenical Services Alliance in Santa Ana. Operates a food service program and 192 units transitional Village of Hope home at the Village of Hope operated by the Orange County Rescue Mission 90 -bed intermediate care shelter for abused children and their Tustin Family Campus parents operated by the Orange County Social Services Agency. Salvation Army Six (6) transitional units at Tustin Field I operated by Salvation Army. Acquisition of 16 transitional units in Buena Park operated by Salvation Army Salvation Army. The City assisted in acquisition and contributed grant funds to acquire the units Fourteen (14) transitional units at Columbus Grove operated Families Forward' by Families Forward, formerly Irvine Temporary Housing in Irvine. Human Options Six (6) transitional units at Columbus Grove operated by Human Options Orange Coast Interfaith Shelter Six (6) transitional units at Columbus Grove operated by Orange Coast Interfaith Shelter. Tustin Family and Youth Center Distributes food supplies to needy populations. ­­-w, u-w units are located in me City or trvme, these units were negotiated as part of the base realignment /conveyance process which Tustin is the Local Redevelopment Authority designated by the Department of Navy. Source: City of Tustin, 2013 CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 27 Additional discussion regarding land use regulations that apply to facilities serving the homeless is found in the Housing Constraints section of this document and in the Technical Memorandum. PRESERVATION OF UNITS AT RISK OF CONVERSION According to the 2012 RHNA, Tustin has one project that contains units at risk of converting to unrestricted market rate during the 2013 -2021 planning period. Tustin Gardens is a 101 -unit Section 223(a) (7)/221(D) (4) project with a Section 8 contract for 100 units Tustin Gardens is extended on an annual basis. Their current contract is due to expire on July 13, 2014. Although Tustin Gardens is at risk, there has been no indication from HUD of terminating the contract or from the project owners of opting out. Table H -9 is an inventory of all units assisted under federal, state, and /or local programs, including HUD programs, state and local bond programs, City programs, and local in -lieu fee, inclusionary, density bonus, or direct assistance programs. The inventory includes all units that are eligible to convert to non -lower income housing uses due to termination of subsidy contract, mortgage prepayment, or expiring use restrictions. Various restrictions and incentives affect the likelihood that at risk units will convert to other uses. Congress passed the Low Income Housing Preservation and Resident Homeownership Act (LIHPRHA) in 1991. This measure assured residents that their homes would be preserved for their remaining useful lives while owners were assured of fair - market compensation. However, modifications to the Act in 1996 restored the owners' right to prepayment, under the provisions that the owner would be encouraged to sell the property to resident endorsed or other non - profit organizations. Tustin Gardens is the only project based Section 8 subsidized project at -risk of losing affordability restrictions during the Housing Element planning period. However, it appears unlikely that the affordability of these units will be threatened based on the determination that project based Section 8 contracts can be renewed on an annual basis. Given the relative weakness of economic conditions and the current housing market, the city will proceed to negotiate the extension of affordability restrictions on these units. The amount of assistance provided will be negotiated based on the specific economics of each development and the potential availability of leverage financing, such as tax - exempt bonds and 4% tax credits. Funds were previously allocated to this program in prior planning periods. However, as a result of the dissolution of Redevelopment, the Low and Moderate Income Housing Funds, allocated to this program were recaptured by the State and transferred to the CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 28 Orange County Auditor- Controller for distribution to the appropriate taxing entities. Programs for Preservation of At -Risk Units: The City will make efforts to preserve units "at risk" at Tustin Gardens. The cost of acquiring and preserving the at -risk units is less than replacing the units with new construction. The actual amount required to preserve these units is currently unknown. The City will also be looking at possible work with nonprofits in the community to explore acquisition of existing buildings with at risk units by nonprofit organizations. The specific actions that the City will take to protect (or replace) at- risk units are identified in the Housing Element Implementation Program. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 29 F z o � � Q W o o w u� u u u z m a O �•ywg x Aaa"�r o F a 7 G Ya...a: p •p y.T � H F, .., w w" •v � � � w w w w W N r F4 C Cl) W b ,� p •C7 p '4 rra Eiai W„ U Y O .e/yR� C L� CO � G b ti %.i F H i.l F iai iar v EMII C ( C h x cod UO Q v 6 < ti a G 6° 1a c U p ti U an d � b q w .Q' y •au .k N 'D N} z z �� .0 rn o F ", rn w +� C rn •p C � Z _ Q u U n U gu u E' t a N w W r W:. 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H G G y �H• o G 0 o aka �RQ b N cod b y aC G G Ci R Um °U a° G �t�u., ti � :C S v v a x b U H H [tea wU >� Grn mrn Rcm Z pp Ar m CL W U C7 u v U {2i H H W O �i e-+ N o v o� � FU Qi V R oq > U y o c RU3 ao �N � N R U ~ G U U�"SHn I� V N �i 0 W z xz f-0 � N 0 x H o p V U V U V w 8 N N 1:R AA A m A AAA AA W N � � �•�+ f� N H rr vi NN Nn O •� y ?•�v O O W O O O O 274 tn o b o 3 y a a w a ad ccQ xQ rAd zC v 'a O Z 0 a 0 a 0 0 a a u¢v U�°J^,U ryU VoU GU QH FF HF QE+ VH UH F z w W W z m 0 x M M Ha a 014 Hz w U 0 ( § �§ ao z k( w= 2 § \ )ƒ 7) J& } \k a § ) &! #$ * t \ bo " § c) ii )B ) MC /7 \ #tea \k/ \;{ §\ a §§ / � u 3 � } } § K $ \/ \� /{ ;a !2§ \d }() § \ ; \ \\ \ !/ u= SUMMARY OF HOUSING ISSUES Housing is a fundamental component of land use within a community necessary to support the resident population. Obtaining affordable housing has been an ongoing issue for persons of all income groups in California. The following Table H -10 presents an overview of households in the City with special housing needs or issues with their existing housing, such as overpayment or overcrowded conditions. The following text highlights the issues relevant to the City of Tustin, which are addressed by the goals, policies and implementation plans. TABLE H -10 SUMMARY OF EXISTING HOUSING NEEDS CITY OF TUSTIN 2014-2021 Growth Needs l Special Needs Grou ..Very Low Units 283 Elderly Personsz 6,492 Low Units 195 Disabled Persons 4,440 Moderate Units 224 Large Households 3,852 Above - Moderate (Units) 525 Female- Headed Households with Children under 18 years 1,652 TOTAL 1,227 -Overcrowding Overpaying Households Renter Percent renter Owner Percent owner 1,955 16.5% 553 4.2% Renter -Total Owner -Total 6,617 5,845 TOTAL 2,508 Total 12,462 Regional Housing Needs Assessment, SCAG, 2012 =Persons age 65 and over. Households containing 5 or more people. Sources: U.S. Census 5 Year and 3 Year ACS; Comprehensive Affordable Housing Strategy 2008 -2018. • Overpayment. 49 percent of the City's lower income households (households which earn less than $75,000 annually) are currently overpaying for housing (see Table HTM -12). • Overcrowding. Household overcrowding has decreased over the past decade as fewer individuals and families "double up" to save on housing costs. Housing Growth Needs. For the 2014 -2021 planning period, SCAG identifies a housing growth need of 1,227 dwelling units in Tustin. These units are allocated among the following income categories: 525 above - moderate income units; 224 moderate - income units; 195 low- income units; and 283 very -low income units (see Table H -10). CITY OF TUSTIN GENERAL PLAN 34 HOUSING ELEMENT • Large Families. 15.4 percent of City's households contain 5 more persons in the households. The average household size in the City was 2.97 in 2011, up slightly from 2.82 in 2000, largely due to changes in the ethnic composition and the economic downturn which had not yet recovered by 2011. This indicates a potential need for larger housing units to accommodate these families (see Table HTM -14). • Extremely -Low Income households. In 2009, 2,458 households are at or below 30% of the Area Median Income (AM) and considered "Extremely Low Income." While the extremely low income households are currently housed, they are in a precarious position, particularly those overpaying for housing in light of the current housing market, and could face the threat of homelessness. • Affordability Gap. Based upon available information on rental rates in the City, it is difficult to find rental housing that is large enough and affordable for large, low- income families (see Table HTM -24 and Table HTM -25). • Elderly. As the City's population ages, the number of elderly persons will continue to increase. This underscores an increasing need to address the special housing needs of the elderly (see Table HTM -2). • Disabled, including Developmentally Disabled. Some disabled individuals have particular housing needs relating to access and adaptability. • Female- Headed Parent Households. Female- headed parent households made up 9.4 percent of all families with children under 18 in Tustin in 2011. Many of these households have incomes below the poverty level and have special housing needs such as access to childcare services. • Homeless. Growing numbers of homeless persons in Southern California have created particular housing and social service needs. The redevelopment of MCAS Tustin for civilian uses has provided an opportunity for additional housing supply in the City including accommodation of the needs of the homeless and the need for affordable housing (see Table HTM -15). In addition, a group housing arrangement (with less than six (6) residents) in a single family home is not subject to a Conditional Use Permit (consistent with State Law). A group housing arrangement of over six (6) residents is classified as a boarding house. The R -3 and R-4 zoning districts would allow for boarding houses with a Conditional Use Permit (CUP). • First Time Homebuyers. High housing costs have put home ownership beyond the reach of many potential first -time homebuyers. CITY OF TUSTIN GENERAL PLAN 35 HOUSING ELEMENT • Governmental Constraints. Govemmental regulations, such as land use controls, fees, and processing procedures, can act as constraints to the maintenance and production of housing. • Units at Risk of Conversion to Market Rate. By State law, the City must identify and develop programs and policies to address affordable housing units that are at risk of converting to market rate housing. During the 2013- 2021 planning period, the City of Tustin faces the potential conversion of 100 low- income units (see Table HTM -27). • Tenure. The City has a high proportion of renter - occupied housing as compared to other jurisdictions in Orange County. In 2011, 47.4 percent of the City's units were renter - occupied, compared to 39.7 percent renter occupied units countywide. Promotion of home ownership opportunities in the City may be necessary to maintain a balanced community (see Table HTM -20). • Housing Stock Condition. According to 2011 ACS data, over 56percent of the City's housing stock is 30 years old or older - the age at which housing typically begins to require major repairs. In addition, the lack of adequately sized affordable housing can lead to overcrowding and in turn, deteriorated housing conditions. Maintenance and improvement of existing housing conditions over the long term will require ongoing maintenance of existing units, rehabilitation or replacement of substandard housing and programs to maintain neighborhood quality (see Table HTM -21). • Historic Resources. Older neighborhoods in Tustin contain historic residences that should be preserved as part of the community's heritage. These historic homes were identified through inventories of historic buildings in 1990 and 2002. • Target Neighborhoods. A large portion of the City's lower income housing is concentrated in the southwest neighborhoods. Targeted programs such as graffiti removal, proactive code - enforcement, loan and grant housing rehabilitation program, removal of abandoned vehicles, increased police presence, removal/ trimming overgrown trees in public right -of -way, various physical improvements for street widening, and street lighting and alley improvements have been and will continue to be implemented. • Energy Conservation. Due to its mild climate, the City can take advantage of solar energy to reduce reliance on non - renewable energy supplies. CITY OF TUSTIN GENERAL PLAN 36 HOUSING ELEMENT HOUSING CONSTRAINTS Actual or potential constraints on the provision and cost of housing affect the development of new housing and the maintenance of existing units for all income levels. Market, governmental, infrastructure, and environmental constraints to housing development in Tustin are summarized below and discussed in greater detail in the Housing Element Technical Memorandum. Market Constraints The high cost of renting or buying adequate housing is a primary ongoing constraint. High construction costs, land costs and market financing constraints are contributing to increases in the cost of affordable housing. Construction Costs: The 2005 -2010 Tustin Consolidated Plan reports that the single largest cost associated with building a new house is the cost of building materials, usually comprising between 30 to 50 percent of the sales price of a home. These costs are influenced by many factors such as the cost of labor, building materials, and site preparation. Marshall & Swift is widely considered the authority on estimating these costs and has been providing the real estate industry with cost data for more than 75 years. According to Marshall & Swift estimates, the cost of residential wood frame construction averages $96.30per square foots. This estimate includes labor and materials, excluding the cost of land, off -site improvements, and indirect costs such as financing costs, escrow fees, property tax, etc. The costs attributed to construction alone for a typical 2,200 square foot, wood frame home would be at minimum $211,860. A reduction in amenities and quality of building materials (above a minimum acceptability for health, safety, and adequate performance) could result in lower sales prices. Additionally, pre- fabricated, factory built housing may provide for lower priced housing by reducing construction and labor costs. An additional factor related to construction costs is the number of units built at the same time. As the number of units developed increases, construction costs over the entire development are generally reduced, based on economies of scale. This reduction in costs is of particular benefit when density bonuses are utilized for the provision of affordable housing. Although it should be noted that the reduced costs are most attributed to a reduction in land costs; when that cost is spread on a per unit basis. Land: Although the Consolidated Plan 2010 -15 reported that the single largest cost was related to construction costs, other factors such as the cost of land, depending upon the type of residential product and market condition is often a more significant cost than that of labor and materials. With the exception of the former MCAS Tustin site that is now referred to as Tustin Legacy, the City of Tustin is 5 Wood frame average quality for Orange County area in 2013 CITY OF TUSTIN GENERAL PLAN 37 HOUSING ELEMENT generally built out. This scarcity of land within the developed areas of the City and the price of land on the fringes are constraints adding to the cost of housing and pricing housing out of the reach of low- to moderate - income families. Financing: Interest rates can have an impact on housing costs. Some mortgage financing is variable rate, which offers an initial lower interest rate than fixed financing. The ability of lending institutions to raise rates to adjust for inflation will cause existing households to overextend themselves financially, and create situations where high financing costs constrain the housing market. An additional obstacle for the first -time homebuyer is the minimum down - payment required by lending institutions. Even if Tustin homebuyers are able to provide a 3 percent down - payment and obtain a 3.6 percent 30 -year loan (average loan rate for FHA or VA guaranteed loans for May 2013), monthly mortgage payments on median priced single - family detached homes in the City place such homes out of the reach of moderate and lower - income households in the City. At a 3.6percent interest rate, monthly mortgage payments on median priced condominiums and townhouses can place such units out of reach of Tustin's low and very low income households (see Tables HTM -23 and HTM -25). The greatest impediment to homeownership, however, is credit worthiness. According to the Federal Housing Authority, lenders consider a persons debt -to- income ratio, cash available for down payment, and credit history, when determining a maximum loan amount. Many financial institutions are willing to significantly decrease down payment requirements and increase loan amounts to persons with good credit rating. Persons with poor credit ratings may be forced to accept a higher interest rate or a loan amount insufficient to purchase a house. Poor credit rating can be especially damaging to lower- income residents, who have fewer financial resources with which to qualify for a loan. The FHA is generally more flexible than conventional lenders in its qualifying guidelines and allows many residents to re- establish a good credit history. Profit, Marketing and Overhead: According to the Comprehensive Affordable Housing Strategy6, minimum developer profit is estimated at 12 percent of development costs, based on input from developers and the Building Industry Association. This level is considered a baseline profit or "hurdle rate," representing the minimum necessary for the deal to proceed. In the past, due to high market demand in communities like Tustin, developers were able to command for higher prices and realized greater margins for profit. As demand increased and prices rose, this profit margin was impacted by the escalating costs of land resulting from a shrinking supply of land. Marketing and overhead costs also add to the price of 6 City of Tustin Comprehensive Affordable Housing Strategy, 2008 - 2018. CITY OF TUSTIN GENERAL PLAN 38 HOUSING ELEMENT homes. The Comprehensive Affordable Strategy 2008 - 2018 estimated developer overhead is at 4 percent of total development costs. Governmental Constraints Housing affordability is affected by factors in the private and public sectors. Actions by the City can have an impact on the price and availability of housing. Land use controls, site improvement requirements, building codes, fees and other local programs intended to improve the overall quality of housing may serve as a constraint to housing development. Land Use Controls: In efforts to protect the public's health, safety, and welfare, government agencies may place administrative constraints on growth through the adoption and implementation of land use plans and ordinances. The General Plan may restrict growth if only limited areas are set aside for residential land uses, and if higher residential densities are not accommodated. The zoning ordinance may impose further restrictions if development standards are too rigid, or if zoning designations do not conform to existing land uses. On the contrary, the zoning ordinance may also be utilized as a tool in encouraging and directing affordable housing, i.e. relaxed development standards, higher density, provision of incentives (waiver of fees, expedited review process, etc.) in exchange of the production of affordable housing, etc. Tustin's existing zoning ordinance allows for a range of residential densities from an effective density of 4.35 units per net acre in the E4 Residential Estate District to 24.9 units per net acre in the R -3 Multiple Family Residential District. Tustin's General Plan allows a maximum of seven (7) units per acre with effective density of 5.61 dwelling units per acre within the Low Density Residential land use to a maximum of 25 units per acre with effective density of 21.53 dwelling units per acre within High Density Residential land use. Ten (10) units per net acre are also permitted in the MHP Mobile home Park District (see Table HTM -32). The Planned Community District has authorized residential subdivisions with single - family lots of 3,500 -5,000 net square feet, which significantly increases density potential. The Planned Community Development also provides incentives such as no height limits when certain criterion are met and for innovative designs that incorporate small lots, residential clustering, mixed density, and mixed income types which also provides flexibility in overall density. Within the Multi- Family Residential District (R -3), a 35 foot height limitation and 65 percent coverage precludes the development of housing projects with building height above the 35 foot limitation. In the interest of protecting adjoining single - family lot owners, multifamily structures above 20 feet in height require a conditional use permit when the structures are within 150 feet of single - family residentially zoned lots. There are approximately 20 properties with an R -3 zoning designation that abut Single Family Residential (R -1) zoning comprised of a variety of CITY OF TUSTIN GENERAL PLAN 39 HOUSING ELEMENT older apartment units and several parcels within Old Town Tustin that are adjacent to the First Street commercial zoning areas. While these height limits may place some restrictions on housing development, these limits are designed to maintain compat- ibility of land use intensity and to ensure proper and effective transportation within the community and are commonly used by local governments as a development tool to further this ideal. When designed properly with features such as limited windows and door openings along the walls facing single family zoned properties or using stepped building heights and design to minimize intrusion to the privacy of existing residents, Conditional Use Permits to allow such development projects have been granted. Conversely, within Neighborhood D of the MCAS Tustin Specific Plan, a 150 foot height limitation up to 180 foot if approved by the Community Development Director would be allowed which provides for layering products (i.e. stacked flats, podium style, etc.) with mixed use developments, thereby providing opportunities for the development of higher density residential products. The Land Use Element indicates that residential development that supports commercial uses may also be permitted in the City's Old Town Commercial area. A market analysis of the Old Town area prepared in conjunction with comprehensive 1994 General Plan Amendments indicated that new multi- family residential development would be an important supporting use for the areas mixed -used commercial /retail development. As a result, the General Plan was amended in 1997 to permit up to 291 additional residential units in the Old Town commercial area. To ensure compatibility of residential uses with the commercial area, the location, density, and building intensity standards for these residential units will be governed by planned community regulations, the adoption of a specific plan, or the approval of a Conditional Use Permit. The East Tustin Specific Plan provides for single - family detached products to be developed at a variety of densities. The Low Density designation requires a minimum lot area of 5,000 net square feet while the Medium -Low designation requires a minimum lot area of 3,000 net square feet and densities not to exceed 5 and 10 units per net acre respectively. The MCAS Tustin Specific Plan designation provides opportunities for development of a variety of residential products at varied density ranging up to 25 dwelling units per acre. In addition, the Specific Plan allows for density bonuses and density averaging. For example, in Neighborhood D, the maximum density on an individual parcel may exceed 25 units per acre as long as the total dwelling units allocated to Neighborhood D is not exceeded. Consistent with the City's policy to increase homeownership to maintain a balanced community, the majority of residential units authorized within the Specific Plan are owner - occupied units. However, in response to market demand, the City processed an amendment to the CITY OF TUSTIN GENERAL PLAN 40 HOUSING ELEMENT MCAS Tustin Specific Plan that allowed for additional renter - occupied units, including affordable rental units. The Final joint EIS /EIR for the Disposal and Reuse of the MCAS- Tustin (hereafter referred to as Program EIS /EIR for MCAS- Tustin) for the reuse of the base identifies specific improvements needed to support residential development. The build out of the WAS Tustin Specific Plan is expected to occur incrementally over a 20+ year timeframe. The actual level of development within any given phase will be tied to the availability of infrastructure necessary to support such development. Implementation triggers of specific infrastructure improvements are included in the EIS /EIR for the project. The anticipated timing of residential development of the MCAS - Tustin Specific Plan is as follows: TABLE H -11 Anticipated Development at MCAS -Tustin Land Uses Through 2016 -2025 2015 Low Density (1 -7 DU /acre) Planning Area 15 533 Medium Density (8 -15 DU /acre) Planning Area 15 375 114 Medium to High Density (16-25 DU /acre) Planning Area 15 225t Community Core (16-25 DU /acrez) Planning Area 8,13, and 14 533t 5152 Total 1,133 1,162 Includes combined total of 190 density bonus units. 2Pursuant to the WAS Tustin Specific Plan, the maximum density on an individual parcel in Planning Areas 8,13, and 14 may exceed 25 dwelling units per acre as long as the total dwelling units allocated to Neighborhood D is not exceeded. Notes: All figures are estimates as schedule will be impacted by market conditions. Figures in text are rounded for discussion purposes. Figures are based on estimated anticipated development indicated in the environmental document for MCAS Tustin Specific Plan. Actual construction figures may be different. Source: Final Joint EIS /EIR for the Disposal and Reuse of MCAS - Tustin, MCAS Tustin Specific Plan /Reuse Plan and its Supplement and Addendum, City of Tustin. Future market demand and the complexity and timing of environmental cleanup efforts are additional factors influencing the schedule of development. CITY OF TUSTIN GENERAL PLAN 41 HOUSING ELEMENT The remaining opportunity sites consist of a large proportion of small vacant and underutilized land that is located within the City or Old Town residential areas where infrastructure is available and no major improvements would be anticipated. Limited residential uses are also permitted in areas designated Public/ Institutional provided the intended occupants are associated with the primary institutional uses. Additionally, homeless facilities are permitted by right in the MCAS Tustin Specific Plan and are allowed throughout the remainder of the City either as an outright permitted or conditionally permitted use depending on the number of residents in the project. The City's Zoning Ordinance calculates parking requirements by unit type (See HTM -32 for summary of parking requirements). Parking requirements in Tustin are generally two spaces per unit, with an additional requirement of one guest space per every four units in multi- family development. Carports for multi- family units are permitted which would reduce development costs in contrasts to the provision of garages. Furthermore, affordable and senior housing development meeting the State Density Bonus Law would be eligible to use the reduced parking standards under the State Law. In response to State mandated requirements and local needs, the City has adopted ordinances allowing for the development of accessory rental units and density bonuses. Beyond local requirements, state law created a sliding scale which allows developers to increase the density of a residential development by at least 20 percent up to 35 percent provided that certain numbers of units are allocated for lower and moderate - income housing. In addition, in response to state - mandated requirements and local needs, the City allows for second dwelling units. Second units serve to augment resources for senior housing and the needs of other segments of the population. Second dwelling units are outright permitted in residentially zoned properties that are at least 12,000 square feet in lot size. A two -car garage is required. The City's land use regulatory mechanisms accommodate the development of housing at a range of densities and products and do not constrain the potential for new construction at densities suitable to meet the needs of all income ranges, although assistance may be required for units offered at prices affordable to lower income households. Housing for Persons with Disabilities/Reasonable Accommodation The City of Tustin recognizes the importance of addressing the housing needs for persons with disabilities. The City's Zoning Code defines "family" as "an CITY OF TUSTIN GENERAL PLAN 42 HOUSING ELEMENT individual or two (2) or more persons living together as a single housekeeping unit in a dwelling unit." This definition accommodates unrelated persons living together in a dwelling unit; thus, the City's definition for a family would not constrain the development and rehabilitation for persons with disabilities. The City requires each development to comply with Title 24 of the California Code. All multi- family complexes are required to provide accessible parking spaces based upon the prescribed State code requirements. For development of special needs housing such as housing for the disabled, senior housing, etc., parking requirements would be determined based upon parking demand analysis which by nature would allow for lower parking ratio in comparison to those required for multiple family residential units. In addition, an off - street parking ordinance adopted by the City allows for the reduction in parking due to an American with Disabilities Act (ADA) upgrade. The Community Development Director is authorized to allow the reduction in the number of required parking spaces when the site is brought up to ADA standards. This provision provides incentives to property owners to provide reasonable accommodation to the disabled. The City also requires new multi- family housing units and apartment conversions to condominiums to comply with State specifications pursuant to SB 520 for accommodation of the disabled. A Residential Care facility serving six (6) or fewer persons is a permitted use in all residential districts. The City's Zoning Ordinance does not contain maximum concentration requirements for a residential care facility serving six (6) or fewer persons. The City recognizes the need of disabled persons to retrofit their residences to allow for mobility such as wheelchair ramps, widened doorways, grab bars, and access ramps. When these improvements meet development standards, only a building permit is required. , In 2011, the City amended the Zoning Code to remove governmental constraints to reasonable accommodation for the disabled. The amendment provides a process in which deviations from the development standards associated with physical improvements to accommodate the disabled would be accommodated with administrative approval and without the need of a public hearing. Homeless Accommodation Homelessness is a statewide concern that affects many cities and counties. Throughout the country, homelessness has become an ongoing problem. Factors contributing to homelessness include the general lack of housing affordable to low and moderate income persons, increases in the number of persons whose incomes fall CITY OF TUSTIN GENERAL PLAN 43 HOUSING ELEMENT below the poverty level, reductions in public subsidy to the poor, and the deinstitutionalization of the mentally ill. The issue of homelessness is considered regional in nature. Nomadic tendencies of homeless persons make it difficult to assess the population accurately. Within the City of Tustin, Police reports and windshield surveys indicate limited numbers of persons on the street and have shown that there are no established areas where homeless persons congregate in the City and that most persons migrate through Tustin to other areas within Orange County, rather than stay for extended periods of time. Information regarding the nature and extent of homelessness by racial and ethnic groups is not available at this time. The Orange County Partnership, a non- profit organization whose purpose is to strengthen public and private agencies serving the homeless and those at risk of homelessness, reported that in 2009 there were 10 homeless persons who identified Tustin as the city of last known permanent address. The McKinney -Vento Homeless Education Assistance Act reported 55 homeless children and youth enrolled in the Tustin Unified School District during 2006 -07. hi addition to identifying homeless needs in Tustin, pursuant to Senate Bill (SB) 2, statute of 2007, the City is required to engage in a more detailed analysis of emergency shelters, transitional, and supportive housing (See Technical Memorandum for further details) by identifying the needs for homeless shelters in its Housing Element and designating adequate zoning districts to accommodate the needs. In those districts, emergency shelters must be allowed without a conditional use permit or other discretionary permit. With the closure of the Marine Corps Air Station (MCAS) Tustin, the City was provided with opportunity to address homeless accommodation. As part of the conveyance process and under the Base Closure Community Redevelopment and Homeless Assistance Act of 1994 (The "Redevelopment Act'), the City of Tustin as, the Local Redevelopment Authority (LRA) was required to consider the interest of the homeless in buildings and property on the base in preparing the Reuse Plan (MCAS Tustin Specific Plan/Reuse Plan). In developing the Reuse Plan, one criteria the Secretary of Housing and Urban Development (HUD) utilized to determine the adequacy of the Reuse Plan was whether the Plan considered the size and nature of the homeless population in the communities, in the vicinity of the installation, and availability of existing services in such communities to meet the needs of the homeless in such communities. At the time of the preparation of the Reuse Plan, it was estimated that there was a total net homeless need of 411 persons in the City of Tustin and City of Irvine (A portion of the MCAS Tustin is located within the City of Irvine jurisdiction). A large portion of this homeless need was identified as necessary to support CITY OF TUSTIN GENERAL PLAN 44 HOUSING ELEMENT emergency transitional housing for youth and individuals. The local homeless need as described in both Tustin and Irvine's Consolidated Plans also indicated a gap in the continuum of care in the areas of vocational and job training/ educational opportunities, some emergency and transitional housing units for individuals and families, support services, and affordable ownership units. Accordingly, the Homeless Assistance Plan for MCAS Tustin was adapted to addresses the problem of homelessness by utilizing the continuum of care model promulgated by HUD for accommodating the needs of the homeless in a manner which is consistent with the Consolidated Plans approved for the cities of Tustin and Irvine. The fundamental components of the continuum of care system implemented with the MCAS Tustin Reuse Plan: • Provides emergency shelter beds; • Offers transitional housing and services which enable homeless persons to progress to self - sufficiency; and • Provides opportunities for permanent affordable housing by the private sector. As a result, the adopted MCAS Tustin Specific Plan provided sites and designated land uses to accommodate the identified homeless needs. The following sites were set aside in implementing the homeless accommodation at Tustin Legacy (formerly MCAS Tustin): • An approximate five (5) acre transitional/ emergency shelter site was set - aside for accommodation of the homeless at MCAS Tustin. The City acquired a site from the Department of Navy; initially ground leased the site, and ultimately conveyed the site to the Orange County Rescue Mission at no cost and facilitated the construction of Village of Hope, a 192 unit transitional housing facility, without the need for a Conditional Use Permit. The project has been completed. A four (4) acre site was recommended by the City of Tustin and deeded directly by the Department of Navy at no cost to the Orange County Social Services Agency for the development of an abused and neglected child and emancipated youth facility with 90 beds capacity. The project is complete. A total of 50 transitional housing units were originally included in the Base Reuse Plan. Based on further negotiations with non - profit homeless providers, a total of 32 new transitional housing units were constructed and conveyed at no cost to non - profit homeless providers at Tustin Legacy. CITY OF TUSTIN GENERAL PLAN 45 HOUSING ELEMENT These units are dispersed throughout the Tustin Legacy community to allow integration into the community. The sites are designated as residential sites and the units were constructed in conjunction with market rate units subject to only those restrictions that apply to other residential uses. The units are transparent since the units are developed identical to those of market rate units in terms of size, materials, locations, etc. No special or other entitlement applications were required for the creation of these units other than those typically required for development of residential units at Tustin Legacy. In addition to the homeless accommodation on -site at Tustin Legacy, the City also facilitated the purchase of a 16 unit transitional housing facility off -site for one of the homeless providers. The City subsidized the creation of these units through the use of housing set aside funds and Federal HUD Homeless Assistance funds. In addition to the homeless accommodation, the City also encourages support services to support the community of continuum of care model to end the cycle of homelessness and to provide participants with tools to once again become contributing members of the community as follows: • Private sector opportunities are provided to create a balanced mix of housing types on the base. Through inclusionary Zoning standards in the MCAS Tustin Specific Plan, a total of 8797 affordable units or 20.8 percent of total authorized units at Tustin Legacy are required to allow participants with opportunity to achieve self- sufficiency. Specific affordable housing requirements would be established at the time of development project approval to ensure conformity with the Housing Element of the City's General Plan. • The Navy will be transferring a child care facility at the former MCAS Tustin to the City of Tustin, which will provide opportunities for access for all to mainstream child care facilities, including early child care and education programs, Head Start, etc. • Adult education and training opportunities will be provided by the South Orange County Community College District within the educational village. Emergency Shelters, Transitional Housing, and Supportive Housing. SB 2 defines "Emergency Shelters" as housing for homeless purposes intended for occupancy of less than six (6) months, where no person is denied occupancy because of inability to pay. In the City of Tustin, emergency shelters are designated as permitted uses 7 Includes 32 transitional housing units set aside for non - profit homeless providers. CITY OF TUSTIN GENERAL PLAN 46 HOUSING ELEMENT within Planning Area 3 of the MCAS Tustin Specific Plan. Planning Area 3 is a five (5) acre site that had been a no cost conveyance to the Orange County Rescue Mission for the development of an emergency/ transitional shelter that is known as Village of Hope. The City facilitated the development of the Orange County Rescue Mission Village of Hope and waived permits fees as this was a public /private partnership. The project consists of 192 units available for emergency and transitional needs. As of April 30„ 2013, the Orange County Rescue Mission Village of Hope was at 90% capacity, with a total of 173 homeless individuals consisting of homeless single men, single women, single women with children, single men with children, and two parent families. The largest homeless sub - population on the Village of Hope campus is single women with children. The Orange County Rescue Mission Village of Hope priority is to serve Tustin homeless population prior to taking any other referrals from other cities or the County. The Tustin Police Department actively refers individuals to the Village of Hope upon encounter. The Orange County Rescue Mission Village of Hope also provides a food service program of approximately 550 meals daily to the Armory. Based upon the available data obtained from the Orange County Partnership and McKinney Vento Homeless Education Assistance Act, approximately 3455 individuals reported either Tustin as their last known permanent address or enrolled within the Tustin Unified School District. This means that the City of Tustin is accommodating 137 -158 homeless persons beyond its jurisdictional boundaries thereby accommodating a regional need. The City interviewed the Orange County Rescue Mission Village of Hope representative and the City was told that there are generally 5 vacant units and a minimum of five (5) percent vacancy is available at any given time. The Orange County Rescue Mission Village of Hope also indicated that the shelter has met above and beyond the City's conservative estimate of 55 homeless persons and that the shelter could accommodate the year -round needs and seasonal fluctuation in the amount of available beds. Transitional housing is defined as rental housing for stays of at least six (6) months where the units are re- circulated to another person after a set period. This housing can take several forms, including group housing or multi- family units, and often includes supportive services component to allow individuals to gain necessary life skills in support of independent living. Tustin's Zoning Code accommodates transitional housing within several zoning districts depending on the project's physical structure: 1) transitional housing operated as a residential care facility is permitted /conditionally permitted depending on the number of occupants in residential districts; and 2) transitional housing operated as rental apartments, it is CITY OF TUSTIN GENERAL PLAN 47 HOUSING ELEMENT permitted by right as a multi- family residential use where multifamily housing is permitted. Supportive housing is defined as permanent (no limit on the length of stay), provides supportive services and is occupied by low- income persons with disabilities and certain other disabled persons. Services may include assistance designed to meet the needs of the target population in retaining housing, career counseling, mental health treatment, and life skills. Tustin's Zoning Code permits supportive housing as a residential use, provided supportive services are ancillary to the primary use. Emergency shelters are permitted within Planning Area 1 of the MCAS Tustin Specific Plan. Transitional homes and supportive housing are also designated as permitted uses within Planning Areas 1 and 3 of the MCAS Tustin Specific Plan. Community care facilities such as group homes, foster homes, elderly care facilities, etc. with six (6) or fewer people are outright permitted within any residentially zoned property. Table H 11 -A summarizes zoning regulations for homeless accommodation. TABLE H -11A SUMMARY OF HOMELESS ACCOMMODATION ZONING REGULATIONS Housing Type Conditionally Zoning Emergency Shelters Permitted Planning Area 3 of MCAS Tustin Specific Plan Planning Area 3 of MCAS Transitional Home Permitted Tustin Specific Plan; All residentially zoned I Includes congregate care facility, single room occupancy hotel, and children s intermediate care shelter Source: City of Tustin The following are transitional homes that have been provided at Tustin Legacy. CITY OF TUSTIN GENERAL PLAN 48 HOUSING ELEMENT Planning Areas 1 and 3 of Supportive housing Permitted MCAS Tustin Specific Plan; All residentially zoned properties Community Care Facility for six (6) or fewer Permitted All residentially zoned properties Family care home, foster home, or group home for Permitted All residentially zoned six 6 or fewer' oroperties I Includes congregate care facility, single room occupancy hotel, and children s intermediate care shelter Source: City of Tustin The following are transitional homes that have been provided at Tustin Legacy. CITY OF TUSTIN GENERAL PLAN 48 HOUSING ELEMENT • A 192 -units emergency / transitional home at the Village of Hope operated by the Orange County Rescue Mission. • A 90 -bed intermediate care shelter for abused children and their parents operated by the Orange County Social Services Agency. • Six (6) units at Tustin Field I operated by Salvation Army. • Acquisition of 16 units in Buena Park operated by the Salvation Army. The City assisted in acquisition and contributed grant funds to acquire the units. • Fourteen (14) units at Columbus Grove operated by Families Forward, formerly Irvine Temporary Housing.9 • Six (6) units at Columbus Grove operated by Human Options. • Six (6) units at Columbus Grove operated by Orange Coast Interfaith Shelter. With the exception of the emergency shelter, these units are transparent and dispersed throughout the community consistent with the City's goals and policies to provide adequate supply of housing to meet the need for a variety of housing types and the diverse socio-economic and to promote the dispersion and integration of housing for all socio-economic throughout the community. The City's policies for homeless accommodation do not create constraints in the location of adequate emergency shelters, transitional homes, shelters, and supportive housing. In addition, current provision of homeless accommodation supports not only the need of the city but the county as well. Fees and Improvements: Various fees and assessments are charged by the City and other outside agencies (e.g., school districts) to cover costs of processing permits and providing services and facilities, such as utilities, schools and infrastructure. These fees are assessed based on the concept of cost recovery for services provided. Tustin is urbanized with most of the necessary infrastructure, such as streets, sewer and water facilities in place. Nonetheless, site improvements can significantly add to the cost of producing housing. Cost - effective site planning can minimize site improvement costs. The Housing Element Technical Memorandum describes in detail required site improvements and provides a list of fees associated with development (Table HTM -34) Development fees are not considered a constraint to housing. However, fees do contribute to the total cost of development and impact the final purchase or rental 8 As defined pursuant to the U.S. Census Bureau definition. 9 Although these units are located in the City of Irvine, these units were negotiated as part of the base realignment /conveyance process with Tustin as the Local Redevelopment Authority. CITY OF TUSTIN GENERAL PLAN 49 HOUSING ELEMENT price. The City, in conjunction with the preparation of the 2009 Housing Element also prepared the Affordable Gap and Leveraged Financing Analysis (Appendix A of the Housing Element Technical Memorandum). The analysis evaluated development costs to arrive to per unit affordability gap in producing affordable units. Table 12 and Table 13 of the analysis summarize average per unit development processing and impact fee of $29,277 to $37,530 per unit for owner housing prototype and $25,586 per unit for rental housing prototype (See Appendix A for specific development processing fees and analysis). In response to the recent economic downturn, the City Council also adopted an economic stimulus program which allowed the payment of specific development fees for construction of new residential units to be deferred until either prior to final inspection or issuance of certificate of occupancy. This program provided direct and indirect assistance to developer of residential units in that reduced on -hand cash flow were required at time of permit issuance. Building Codes and Enforcement: The City of Tustin adopts the Uniform Construction Codes, as required by State law, which establish minimum construction standards as applied to residential buildings. The City's building codes are the minimum standards necessary to protect the public health, safety and welfare and ensure safe housing. Only local modifications to the codes are made which respond to local climatic or geographic conditions and clarify administrative procedures. Although not mandated to do so, the City has adopted the State Historical Code that relaxes building code requirements citywide for historic structures /buildings. Adoption of codes reduces rehabilitation costs. Local Processing and Permit Procedures: The evaluation and review process required by City procedures contributes to the cost of housing. State law establishes maximum time limits for project approvals and City policies provide for the minimum processing time necessary to comply with legal requirements and review procedures. The Community Development Department serves as the coordinating agency to process development applications for the approval of other in -house departments such as Police, Public Works/ Engineering, and Parks and Recreation. All projects are processed through plan review in the order of submission. The City has eliminated the potential increase in financing costs caused by a delay in permit processing by assigning priority to the plan review and permit issuance for low - income housing projects. If a complete application is submitted, all Design Review Committee members and plan checking departments simultaneously review the plans. The Design Review application does not require a public hearing or Planning Commission approval. The Tustin City Code authorizes the Community Development Director to approve development plans when findings can be made CITY OF TUSTIN GENERAL PLAN 50 HOUSING ELEMENT that the location, size, architectural features and general appearance of the proposed development will not impair the orderly and harmonious development of the area. In making such findings, the Zoning Code provides items to be considered such as height, bulk, setbacks, site planning, exterior materials and colors, relationship of the proposed structures with existing structures in the neighborhood, etc. This code provision affords the developers with tools to design their projects and thus increase certainty of project's design review and approval. Project application which complies with all the development standards prescribed by the district in which the project is located would not be required to go through any other discretionary approval. For Tustin Legacy, developments under the former Master Developer footprint (approximately 800 acres) are subject to the Legacy Park Design Guidelines to ensure compatibility of products proposed by vertical builders. The design guidelines present minimum design criteria for the achievement of functional, quality, and attractive development expected at the Tustin Legacy. The guidelines are intended to complement the MCAS Tustin Specific Plan district regulations and to provide staff, builders, design professionals, and other users with a concise document when dealing with Design Review process to avoid ambiguity. Together the Zoning Code, Design Review provisions, the Legacy Park Design Guidelines, and the "one- stop" processing system provide certainty to developers seeking approval for the development of residential projects. For projects of significant benefit to the low - income community, costs can be waived by the City Council. Workload: Another governmental constraint is the number of staff and amount of staff time available for processing development projects. Since the workload is determined by outside and uncontrolled forces (economy and market for housing and availability of general fund revenue), a shortage of staff time may occur which could lead to increased processing time for development projects. HOUSING OPPORTUNITIES Table H -12 shows the existing and potential dwelling units permitted under each General Plan land use category, as well as the potential net increase within each category. Based on the City's Land Use Plan, Tustin has a residential holding capacity of approximately 29,821 dwelling units. The Land Use Plan provides for a mix of unit types and densities, including low- density single - family homes, medium density homes, higher density homes, and mixed -use projects that allow for a combination of commercial and residential uses. A large portion of future residential development in the City of Tustin will take place in the MCAS Tustin Reuse Specific Plan area. The other large Specific Plan CITY OF TUSTIN GENERAL PLAN 51 HOUSING ELEMENT community in Tustin, Tustin Ranch (the East Tustin Specific Plan) has been built out. CITY OF TUSTIN GENERAL PLAN 52 HOUSING ELEMENT r w w a w c� z m a 0 x M LO F� Ow �z _w U C7 Housing Units Approved/Entitled and Under Construction A total of 88 Very Low Income units, 73 Low Income units, 101 Moderate Income units, and 871 Above Moderate Income units were approved/ entitled at the time of the preparation of this housing element as follows: St. Anton Partners: This residential affordable multiple- family project was approved on November 6, 2012, and will consist of 225 affordable units, of which 88 units are set aside as Very Low Income units, 73 units for Low Income, and 64 units for Moderate Income households. Completion of the project is anticipated in spring of 2014. The Irvine Company Legacy Villas: This residential multiple family project was approved on November 6, 2012, and will consist of 533 residences, including 37 units for Moderate Income households. Completion of the project is anticipated in spring of 2014. Table H -14 illustrates the residential development potential of the vacant and underutilized land inventory in the City of Tustin. The Tustin Legacy site (formerly MCAS Tustin) presents the City with 180.67 acres suited for residential development that could accommodate an additional 2,105units. During the planning period, the majority of the anticipated units will be accommodated at Tustin Legacy and is being implemented through both the adoption of a Specific Plan by the City and the adoption of a Redevelopment Project Area (dissolved in 2011). Based on State Redevelopment Law at that time and Specific Plan requirements, at least 15 percent of the units (607 units) constructed at the MCAS Tustin site will be affordable to Very-Low, Low, and Moderate - income households, of which at least 6 percent or 243 units must be affordable to Very Low - income households. The remaining 364 units would be distributed among the Low and Moderate income households by utilizing RHNA Low and Moderate income percentages. In addition to these inclusionary obligations, the acreage and densities permitted by the MCAS - Tustin Reuse Plan created 282 additional units for Very Low - income households (192 transitional housing units and 90 social services housing units). Aside from MCAS Tustin, additional sites are located within the City. As a means to ensure affordability, the City may require developers to provide at least 15 percent of all units constructed or rehabilitated at prices affordable to Very Low, Low, and Moderate Income households. The City aggressively negotiates affordable housing units within individual potential projects. An example of an approved infill site is the development of a fifty-four (54) unit affordable senior housing project on a 1.76 acre site. The project was granted a twenty-five (25) percent density bonus above the City s maximum allowable density. In addition, the City entered into a Disposition and Developer Agreement with the developer to issue loans not to exceed $600,000. The loans are secured by loan agreements, promissory notes and deeds of trust, along with Regulatory Agreement and Declaration of Restrictive Covenants to be recorded against the property for a period of not less than 55 years. The project is 100 percent affordable to very low and low income seniors. The remaining capacity in Old Town Tustin will be achieved through recycling of underutilized and vacant infill sites (see Figure 1). According to the City's Land Use Element, the sites in Old Town Tustin area are able to accommodate an overall population range for residential use of 2 -54 persons CITY OF TUSTIN GENERAL PLAN 54 per acre10. The Land Use Element further identifies the potential development of dwelling units in the Old Town Commercial area, which will be facilitated by the proposed adoption of zoning regulations and development standards which will allow mixed -use development (see Program 1.21 of Table H -20 Housing Element Programs). This development potential is supported by the market analysis of the Old Town area. To further create housing opportunities, the City provides the issuance of tax- exempt bonds for the development of affordable housing through a Joint Powers Authority with the California Statewide Communities Development Authority. Other means would include the City's participation in the State and Federal programs such as the Low - Income Housing Revenue Bond Financing program, Low Income Tax Credits, CHFA financing programs, and others. Additionally, a Density Bonus Ordinance is available and can be applied to infill sites to increase allowable density and the Tustin City Code also provides for a Planned Community District which allows flexibility in site development standards such as the creation of smaller lots to allow for higher density. As demonstrated in Table H -13B, there are a total of 205.3 acres of land (177.1 acres from MCAS Tustin, 15.35 acres vacant land, and 12.85 acres underutilized land) with residential development potential. These sites could potentially be developed with approximately 2,882 units. This demonstrates that the City has sufficient amount of land available to accommodate the residential developments to meet the remaining RHNA construction needs through the 2021 period. TABLE H- 13A SUMMARY OF QUANTIFIED RHNA OBJECTIVES CITY OF TUSTIN 2014 -2021 Income Group RHNA Units Approved Net RHNA Construction Need Very Low 141 88 53 Extremely -Low 1421 142 Low 195 73 122 Moderate 224 1 101 1 123 Above Moderate 525 496 29 Total 1,227 758 469 Pursuant to Government Code Section 65583(a)(1), City's share of extremely -low income units is 142 ( 50 percent of the total Very Low Income new construction objective). Source: 2012 RHNA, SLAG, 2005 -2009 ACS 10 See Table LU -3 - "Future Land Use Density /Intensity and Population Capacity of the Land Use Plan' in the City of Tustin General Plan Land Use Element, January 16, 2001. CITY OF TUSTIN GENERAL PLAN 55 M r4 x a F 8 d a 0 0 d � � q e r d q � � A o d r q IL C � z w w a w z O x 9 Z ja O� w z U C7 Figure 1 and Tables H -14 and 15 detail the zoning designations of vacant and underutilized land in Tustin. The vacant and underutilized land inventory includes land that is currently zoned medium- and high- density residential and land that could potentially be designated as high- density residential. Realistic capacity of sites that are identified in Tables H -14 and 15 are derived from past development proposals, historical character of the area, inquiries received by the Community Development Department, Disposition and Development Agreements between the City and developers, exclusive negotiations with potential developer(s) authorized by the City Council, maximum zoning and general plan densities, and eligible incentives to developers for provisions of affordable housing. Realistic capacity for sites identified to meet the City's share of regional housing needs either are determined based upon current zoning and general plan, executed Disposition and Development Agreement, and the City Council authorized exclusive negotiations with potential developers. The closure of MCAS Tustin provides the City with opportunity sites to meet the City s share of regional housing needs. The majority of the City's share of housing needs will be provided at the former MCAS Tustin (Tustin Legacy) project site which was part of the base closure realignment process. The Federal government provided the land to the City at no cost. The City has been conveying the land to developers for the development of the Tustin Legacy. Although the availability of vacant and underutilized land for the provision of housing is not considered a constraint for the 2013 -2021 planning period, future planning periods may be marked by a lack of available land. While the City's Land Use Plan provides an adequate land capacity to fulfill housing needs, current development costs in Tustin may preclude the private housing market from providing affordability for low and very low- income households without subsidies. Necessary infrastructure improvements and litigation constraints may cause some delays in the build -out development of the MCAS Tustin project. Satisfaction of the City's quantified objectives through new construction will be heavily dependent upon real estate market trends, cooperation of private funding sources, and available funding and programs at the local, county, state and federal levels. CITY OF TUSTIN GENERAL PLAN 57 HOUSING ELEMENT Figure 1 -Vacant & Underutilized Land in the City of Tustin* Land Suitable for Residential Development . f VIWendWized Land Ve l Lard CITY OF TUSTIN GENERAL PLAN ,.,__ �t IN In y,. 58 N 4 I r HOUSING ELEMENT N G M F F C y s= G 9 O � C� �y n1 0 c N� 0 �6 c W &Z e 6 b 6 c s w F O 0. �i v �ryF k Y Y v m 0 Uq #O H O V g 8 N N 0 v C ryC V w M I D v b a oq m H O x r3 U P C N G ?E a (i r� L Q dR 'a ag? U G m C 0 N 0 a y� x 8 o y K o A N 0] w b NH U F� V h H 4 g G W ti m v c 0. B m Z n T 3 a �X N H a c � F V a F K n 5 C. tJ 8 r� z 9 0 d 0 U 0 H a E a O V i 4 6 3 z ti m V d G V Y a v Q 9 K C a C. y G F U1 Q U v 0 C �r R r. 'C C yA �g va L G �• L w .e �O y m r �q na A a d •qCq ^a ''' d a"� c. O s Z 0 rQi F z w w a W C) z m x 0 x 0) LO we m� a F .•7 O Fz U CW7 ) ) S / k ( ) � \d �eE /§ ) ) j \ § ) _ ) ; ) ;) }| a f) !/ ■ ! } \ ) ) ) ) ; { \ ( If l§ : / BI&12 B I » \ j , | \ } ( ; ) ; & \ \)\ \j\\ § § §§ f) E ;] \9]/ \) /) { /$(\ 4§i& ;k !`4 ) ®)/ >)\\ !) /) /\ ,c §[ /) }) /\ /} ■; \ \ [ / �} \ ) \ / \ k } } ; { { } k } k } \ { { ) \ . � � ! &I!| ! § 2 / \ ■ (\ \� (\ HOUSING ELEMENT GOALS AND POLICIES This section of the Housing Element contains the goals and policies the City intends to implement to address a number of housing - related issues. To implement the Housing Element, the following six major issue areas are identified with related goals and policies: 1) ensure that a broad range of housing types are provided to meet the needs of existing and future residents; 2) provide equal housing opportunities for all City residents; 3) ensure a reasonable balance between rental and owner occupied housing; 4) preserve existing affordable housing, 5) promote conservation and rehabilitation of housing and neighborhood identity; and 6) ensure housing is sensitive to the existing natural and built environment. HOUSING SUPPLY/HOUSING OPPORTUNITIES Tustin is home to persons requiring a variety of housing options. At different stages in their lives, people require different housing arrangements. Additionally, the City must respond to the housing needs of all economic segments of the community and ensure that housing discrimination does not serve as a barrier. It is also important that the City maintain a balance of housing types and that the City's housing stock is not overly skewed towards the provision of one type of housing. Finally, the continuing need for affordable housing in the region requires the City to attempt to preserve Low - income housing units that are at risk of converting to other uses. The City establishes the following goals and policies to achieve the above objectives. GOAL 1: Provide an adequate supply of housing to meet the need for a variety of housing types and the diverse socio - economic needs of all community residents. Policy 1.1: Promote the construction of additional dwelling units to accommodate Tustin's share of regional housing needs identified by the Southern California Association of Governments (SCAG), in accordance with adopted land use policies. Policy 1.2: Pursue smart growth principles by supporting the construction of higher density housing, affordable housing, and mixed use development (the vertical and horizontal integration of commercial and residential uses) in proximity to transit, services, shopping, schools, senior centers and recreational facilities, where possible. Policy 1.3: Consider site scoring, income targeting, and other selection criteria for competitive funding sources for affordable housing, such as Low Income Housing Tax Credits, when allocating Agency resources for affordable housing to maximize leverage of local funds. Policy 1.3: Continue to implement best practices for developer selection, project underwriting and due diligence for affordable housing developments that receive CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 61 financial and other assistance to ensure long -term viability of affordable housing and to ensure the maximized leverage of local resources. Policy 1.4: Preserve affordable housing units, where possible, through actions such as the maintenance of a mobile home park zone, restrictions on R -3 zone uses to preserve the multiple family residential characters, facilitate resident access to funding sources for preservation of low income and assisted housing. Policy 1.5: Promote the dispersion and integration of housing for low- and very -low income families throughout the community as opposed to within any particular geographic area, neighborhood, or project. Policy 1.6: Encourage the County of Orange to exercise its responsibilities for housing accommodations for low- and very -low income families within Tustin's sphere of influence. Policy 1.7: Utilize various resources, where feasible, to assist in creating opportunities which will expand opportunities for development of affordable housing in the community. Policy 1.8: Allow second (attached/ detached) units in single- and multi- family districts consistent with the Tustin City Code. Policy 1.9: Utilize Planned Community Districts and Specific Plans to authorize and promote a variety of lot sizes and housing types. Policy 1.10: Promote cluster housing consistent with General Plan land use density standards to reduce the cost of housing construction. Policy 1.11: Encourage the availability of affordable housing for special needs households, including large, low - income families. Special needs households include the elderly, large families, female - headed households with children, households with a disabled person, and the homeless (see discussion under Summary of Housing Needs for Special Needs Groups). Policy 1.12: Encourage incentives to assist in the preservation and development of affordable housing such as 1) reducing permit processing time and waiving or reducing applicable permit fees; 2) on -site density bonuses when appropriate; 3) tax- exempt financing including continuing to make use of the City's membership in the California Statewide Communities Development Authority to provide opportunities for developer assistance in pre- development and development financing of affordable housing programs; 4) flexibility in zoning or development standards; and 5) other financial incentives using a variety of special State and Federal grant and housing programs. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 62 Policy 1.13: Encourage the design and occupancy of housing for senior citizens and the disabled. Promote the construction or rehabilitation and adoption of dwelling units accessible to seniors and/or the disabled. Policy 1.14: Provide continued support for the County Homeless Assistance Program and other homeless assistance programs within Tustin and in adjacent cities, including the continued use of the City's membership in California Statewide Communities Development Authority to issue private activity mortgage bonds in support of these programs Policy 1.15: Encourage the provision of grants and technical assistance to various organizations and agencies that provide assistance to persons with special needs such as the homeless, disabled, low - income, and elderly persons. Policy 1.16: Participate in federal and state housing assistance and rehabilitation programs aimed at assisting households in need. Policy 1.17. Utilize design criteria in evaluating projects to ensure compatibility with surrounding developments, while taking into consideration ways to minim;ze housing costs. Policy 1.18: Promote and encourage non - profit and for - profit private sector interests to use available federal and state programs for new or rehabilitated affordable housing. Policy 1.19: Support state - enabling legislation for employers to contribute to the cost of housing for their employees. GOAL 2: Ensure equal housing opportunities for all existing and future City residents regardless of race, religion, ethnicity, sex, age, marital status or household composition. Policy 2.1: Promote equal opportunity housing programs within the community. Policy 2.2: Provide active support to provide fair housing opportunities. Policy 2.3: Support programs to match elderly and low and moderate - income individuals who want to share housing costs in a joint living arrangement. Policy 2.4: Support public and private efforts to eliminate all forms of discrimination in housing. Policy 2.5: Minimize displacement of lower income and special needs households, whenever possible, to ensure that displacement is carried out in an equitable manner. GOAL 3: Increase the percentage of ownership housing to ensure a reasonable balance of rental and owner- occupied housing within the City. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 63 Policy 3.1: Encourage new housing construction for home - ownership in a mixture of price ranges. Policy 3.2: Examine any existing City home purchasing assistance programs for low- and moderate - income households, including down- payment assistance, - and mortgage revenue bond financing, and recommend program modifications to make them more effective in the current housing market. Policy 3.3: Encourage rental unit conversion and alternative forms of homeownership, such as shared equity ownership and limited equity cooperatives where feasible. Policy 3.4: Examine existing condominium conversion standards to promote renovation of existing units through rental conversion. GOAL 4: Preserve the existing supply of affordable housing in the City. Policy 4.1: Continue to use Federal and State housing initiatives available for low - income households. Policy 4.2: Monitor all federal, state and local funds available to preserve and /or replace lower income units at risk of converting to market rate housing, including tax credit bond financing. Policy 4.3: Assist non - profit organizations in securing the resources necessary to preserve/ replace lower to moderate income units at risk of converting to market rate housing. Policy 4.4: Consider incentives to non - profit housing and for - profit private sector interests to purchase and /or maintain lower income units at risk of converting to non -lower income housing. Policy 4.5: Take advantage of favorable market conditions, as appropriate, to pursue early negotiation and preservation of at -risk affordable housing through extension of existing affordability restrictions. MAINTENANCE AND CONSERVATION Maintenance and preservation of a City's housing stock prevents unhealthy living conditions; eliminates the need for future, more costly housing rehabilitation; prevents neighborhood deterioration; and encourages community pride. The City enforces codes and provides incentives to promote maintenance and conservation. GOAL 5: Conserve, maintain, rehabilitate, and/or replace existing housing in neighborhoods which are safe, healthful and attractive, in accordance with adopted Land Use Policy. Improve the residential character of the City with an emphasis on revitalizing neighborhoods showing signs of deterioration. Promote conservation of the City's sound housing stock, rehabilitation of deteriorated CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 64 units where they may exist Citywide, and elimination of dilapidated units that endanger the health, safety and wellbeing of occupants. Policy 5.1: Through available financial incentives, encourage owners of rental housing units that are determined to be substandard, in need of repair and a hazard to the health and safety of the occupants to remove and replace or rehabilitate the structures. Policy 5.2: Promote the availability of funds for the rehabilitation of single - family dwellings and apartments. Policy 5.3: Periodically evaluate housing conditions and, when appropriate, address any increase in deteriorated housing conditions. Policy 5.4: Continue to enforce health, safety, and zoning codes to eliminate conditions which are detrimental to the health, safety and welfare of residents. Policy 5.5: Promote preservation of historic and architecturally significant residential properties. Policy 5.6: Study and revise existing zoning codes, if warranted, to provide flexibility to facilitate additions and improvements to existing historic and architecturally significant residential properties. Policy 5.7: Review existing guidelines for single- and multi- family rehabilitation programs, including income targeting and neighborhood location, to achieve maximum neighborhood revitalization. ENVIRONMENTAL SENSITIVITY Housing design and land use patterns can have substantial impacts on the natural as well as the built environment. City policies and programs seek to minimize negative environmental impacts. GOAL 6: Ensure that new housing is sensitive to the existing natural and built environment. Policy 6.1: Attempt to locate new housing facilities in proximity to services and employment centers thereby enabling walking or bicycling to places of employment. Policy 6.2: Promote energy conservation measures in the design of new housing units and the redevelopment of older housing units. Policy 6.3: Require design review of lot placement in subdivisions to maximize passive solar energy and solar access. Policy 6.4: Promote water efficient landscapes, efficient irrigation, and use of permeable paving materials. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 65 Policy 63: Streamline processing for approved green building. Policy 6.6: Consider, support, or partner with utility companies to promote energy rebate programs. RELATED GOALS AND POLICIES The goals and policies described in the Housing Element are related to and support the goals and policies included within other General Plan elements. Many goals and policies from the other elements directly or indirectly support the goals and policies of the Housing Element. These supporting goals and policies are identified in Table H -16. TABLE H -16 HOUSING RELATED GOALS AND POLICIES BY ELEMENT CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 66 RELATED GOALS AND POLICIES BY ELEMENT Housing Land Conservation/ Public Growth Issue Area Use Housing Circulation Open Space Safety Noise Management 1.8, 10.2 13.3, Housing 13.4, Opportunities 13.10 1.111.10 25, 3.1, 4.1 Maintenance 1.1, 4.6, and 5.8, 6.4, 3.4, 3.5, Preservation 6.6 5.4 1.7, 22 Affordable Housing Support Service/ Fair Housing 5.3 4.1 CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 66 CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 67 3.6, 9.6, Environmental 9.7, 9.8, 1.14,1.17, 3.3, 4.8, 1.11, Sensitivity 13.1 3.5 2.12, 3.1, 4.1 4.12 1.12 CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 67 HOUSING ELEMENT IMPLEMENTATION PROGRAM The Housing Element Implementation Program provides specific actions the City intends to undertake to achieve the goals and policies of the Element. This section identifies quantified objectives, available financial resources and affordable housing resources, and provides a list of specific programs the City intends to pursue. Housing programs include those currently in operation and new programs added to address housing needs. A description of each program is provided, along with the program funding source, responsible agency, and time frame for implementation. A review of City's past performance on housing element implementation programs is contained in Appendix A of the Housing Element. RHNA QUANTIFIED OBJECTIVES 2014 -2021 State law requires the City to accommodate its fair share of the State's housing need. In doing so, the City must quantify the number of homes that are projected to be built and conserved. The following quantified objectives are adopted as guidelines toward meeting Tustin's housing needs through 2021. It is important to note that while the quantified objectives of the RHNA are required to be part of the Housing Element and the City will strive to attain these objectives, Tustin cannot guarantee that these needs will be met given its own limited financial resources and the present affordability gap. Satisfaction of the City's regional housing needs will partially depend upon cooperation of private funding sources and the funding levels of County, State, and Federal programs that are used to support the needs of the very-low, low and moderate - income persons. Additionally, outside economic forces heavily influence the housing market. New Construction Objectives The City of Tustin promotes and encourages the development of a variety of housing opportunities to accommodate current and projected housing needs which include 283 very low -, 195 low -, 224 moderate -, and 525 above moderate - income households per the 2012 Regional Housing Needs Assessment (RHNA) allocation. While the Land Use Plan provides adequate sites to fulfill needs established by RHNA, construction of new units will depend upon the timing of the landowner and developer in the submission of building plans to meet market demands. Housing subsidies will depend upon the availability of government funds - local, County, State, and Federal. Development projects are subject to the interests of private developers. The construction of secondary units depends upon the desires of the property owners as related to family needs for housing and economic resources. The achievements of the housing objectives are thus dependent upon the private sector and other governmental agencies. The responsibility of the City is to encourage the construction of affordable housing by providing programs and assistance to CITY OF TUSTIN HOUSING ELEMENT developers and to assist in its creation by facilitating the review and approval of development permits. Table H -17 provides new construction housing objectives for the period 2014 -2021. With the exception of Tustin Legacy, all sites identified in Table H -17 are privately owned. Units identified are broken down into various income limits in light of RHNA percentages. Table H -13A discusses the City's progress toward achieving the RHNA quantified objective. Based on units approved or under construction, the City of Tustin has the following remaining units to achieve RHNA's construction objective: 195 Very Low Income, 122 Low Income, 123 Moderate Income and 29 Above Moderate Income units. The City will make its best efforts to accommodate this objective by carrying out the following projects and /or programs: Preservation Pursuant to Government Code Section 65583.1(c), up to 25 percent of the lower income RHNA may be fulfilled with existing units when affordability is achieved through: • Affordability covenants placed on previously non - affordable units; • Extension of affordability covenants on affordable housing projects identified as at risk of converting to market -rate housing; and • Acquisition/ rehabilitation and deed restriction of housing units. With RHNA allocated 478 lower income units, the City may fulfill 120 lower income units (71 Very Low and 49 Low) through preservation of existing housing units. As identified in the Preservation of Units At -risk for Conversion section of the Housing Element, there are a total of 100 units at risk for conversion during the planning period at Tustin Gardens. . The City, in anticipation of this opportunity, had programmed $2,181,672 of RDA housing set aside funds in the Agency's Comprehensive Affordable Housing Strategy's Six- Year Capital Plan to negotiate the preservation of these units. The City Council in their capacity as the Redevelopment Agency (eliminated 2011) adopted the Comprehensive Affordable Housing Strategy (CARS) in June 2008 committing up to $2,181,672 of Agency Housing Set -Aside funds for the preservation efforts of these at -risk units. However, the dissolution of Redevelopment in 2011 effectively eliminated the primary source of funding that could be used to preserve these units at risk of conversion. As presented in Table HTM -34 of the Housing Element Technical Memorandum, the City has fulfilled a portion of its regional share for very low and low income households (362 and 127 units respectively) during the prior planning period, rendering the City eligible to utilize the alternative site program, if desired. The City is in contact with Tustin Gardens regularly and has expressed interest in ensuring the continuation of these affordable units. The City is also in contact with residents CITY OF TUSTIN GENERAL PLAN 69 HOUSING ELEMENT to allow for active public participation with current residents to ensure continued affordability. Tustin Gardens maintains a Section 8 contract for rental assistance. They are currently approved through July 13, 2014 with a HUD - requirement that they provide a one -year notice to terminate their current Section 8 contract. The earliest date affordability restrictions can expire is July 2015. The city will make every effort to assist the owner obtain an extension of the HUD Section 8 contract. Considering the earliest possible scenario of affordability restrictions expiring July 2015, the total cost of subsidizing Tustin Gardens for the term of the Housing Element, July 2014 to October 2021, would be about $4,205,400. The City believes Tustin Gardens is a viable project to receive 4% Tax Credit, Tax - Exempt Bond funding. Tustin Gardens is a 100% affordable, very -low income Senior Project. The City would work with the current owner to establish a non- profit affordable housing entity to apply for 4% Tax Credit, Tax - Exempt Bond funding for the acquisition and rehabilitation of Tustin Gardens. New Construction: Tustin Legacy Former Master Developer Footprint (Neighborhoods D and G) As mentioned throughout the Housing Element, the closure of the MCAS Tustin provides the City with opportunity to create affordable units to accommodate the needs of the residents. The City in 2001 adopted the MCAS Tustin Specific Plan and in 2003 designated the MCAS Tustin as a Redevelopment Project area and adopted the MCAS Tustin Redevelopment Plan (eliminated 2011). As part of the adopted Specific Plan, a total of 4,210 housing units were authorized and to date 2,105 units have been constructed. The 2,105 units yet to be built are under the Former Master Developer footprint. 758 units within Neighborhoods D and G have been approved. 190 of these 758 units are approved density bonus units. Therefore the remaining development potential is 1,537 units (2,105 +190 -758), plus any future density bonus units. In Neighborhood D, the maximum density on any individual parcel may exceed 25 dwelling units per acre as long as the total dwelling units allocated to Neighborhood D is not exceeded. Thus, a default density of 30 units per acre could be achieved in Neighborhood D. The remaining development potential in Neighborhood D is 515 dwelling units plus potential density bonus units. The development of Tustin Legacy is anticipated to occur during the Housing Element planning period. Nezo Ozonership and Rental Housing, outside of Tustin Legacy A total development potential of 587 dwelling units outside of Tustin Legacy has been identified during the Housing Element planning period on vacant and underutilized sites. However, these sites are not required to satisfy the City's RHNA. CITY OF TUSTIN GENERAL PLAN 70 HOUSING ELEMENT Other Neto Constnictlon Units It is likely that other development will occur through Second Units, and the recycling of single family uses on multi- family zoned lots. Based upon recent development proposals, the City has observed increased interest in the development of, second units and the addition of units within multiple family dwelling properties occupied by single family dwellings. The cost to construct these units would be borne by the property owner. However, the City would facilitate the development process. In addition, based upon past development trends (Tustin Grove and Ambrose Lane) that utilized Planned Community Districts to allow for higher densities, the actual number of units created could be higher than identified. The City will strive to ensure that newly constructed units are developed at sufficient densities to assist in fulfillment of low and very low income needs by employing inclusionary zoning for those sites located within former Redevelopment project areas, mixed use zoning in Old Town Tustin, density bonuses particularly in infill sites to allow for increase densities to accommodate affordable housing developments, and Planned Community Districts to allow for flexibility in development standards. TABLE H -17 QUANTIFIED OBJECTIVES SUMMARY CITY OF TUSTIN 2014 -2021 Tustin Legacy Housing Units' Extremely Pro am Total # Low and Low Moderate Upper Neighborhood G of Units Very Low 4 ( <801% (80.120 %) (120 ° /n +) <50% Tustin Legacy Housing Units' Neighborhood D 1,048 195 122 160 571 Neighborhood G 1,247 88 73 64 1,022 Preservation 100 100 New Ownership and Rental Housing 587 131 90 124 242 Second Unit 10 10 Recycling of SF uses to MFD in R -3 district 8 8 Total Quantified Objectives 3,000 514 303 348 1,835 RHNA 1,227 283 195 224 525 Difference 1,773 231 108 124 1,310 CITY OF TUSTIN GENERAL PLAN 71 HOUSING ELEMENT TABLE H -17 QUANTIFIED OBJECTIVES SUMMARY CITY OF TUSTIN 2014 -2021 r MCAS Tustin Specific Plan authorizes a total 4,210 potential units (plus density bonus units) at Tustin Legacy. Based upon the Specific Plan requirement, at least 15 percent of the total units (632 units) would be affordable to Very-Low, Low, and Moderate income households, of which at least 6 percent or 253 units would be affordable to Very Low income households. A total of 296 affordable inclusionary units were included in the authorized total number of units to be developed at Tustin Legacy. Of the 4,210 units, 2,105 units have been completed. A total of 2,105 units (plus density bonus units) are planned within Neighborhoods D and G. Within Neighborhoods D and G, 758 units have been approved and /or are under construction, including 88 Very Low, 73 Low, 101 Moderate, and 496 Above Moderate units, including 190 density bonus units. 2 3 4 Pursuant to Government Code Section 65583(a) (1), City's share of extremely -low income units is 142 (50 percent of the RHNA Very Low income households new construction objective). Total number of units for extremely4ow, income and low income units equals to City's share of very-low income units of 283 units Source: 2012 RHNA; City of Tustin; MCAS Tustin Specific Plan. Preservation, Rehabilitation, and Other Affordable Housing Program Objectives The primary beneficiaries of Preservation and Rehabilitation and Assistance programs are renters and low- income homeowners. It is assumed that above - moderate- income households will rehabilitate units as needed through private efforts. Tustin's affordable housing strategy is based on the City's housing needs, affordability gap analysis, and available financial resources. Several broad policies establish the framework for the City's Housing strategy as applied to preservation, rehabilitation, and other housing program objectives. These include: 1. Conserve, maintain, and rehabilitate existing housing and revitalize existing neighborhoods; 2. Maximize the supply of affordable housing; 3. Increase homeownership; 4. Preserve the existing supply of affordable housing, and, Consistent with the above policies the City has devised a number of programs of housing assistance to address the preservation, rehabilitation, and other housing program objectives. Specific details on these programs can be found in the City of Tustin Comprehensive Housing Affordability Strategy for Fiscal Years 2008/09 to 2017 /18. In addition, Table H -20 - Housing Element Programs 2013 -2021 outlines the City's specific housing programs during the planning period. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 72 Extremely Program Total # Low and Low Moderate Upper of Units Very Low 4 (<801% (80 -120 %) (120 % +) r MCAS Tustin Specific Plan authorizes a total 4,210 potential units (plus density bonus units) at Tustin Legacy. Based upon the Specific Plan requirement, at least 15 percent of the total units (632 units) would be affordable to Very-Low, Low, and Moderate income households, of which at least 6 percent or 253 units would be affordable to Very Low income households. A total of 296 affordable inclusionary units were included in the authorized total number of units to be developed at Tustin Legacy. Of the 4,210 units, 2,105 units have been completed. A total of 2,105 units (plus density bonus units) are planned within Neighborhoods D and G. Within Neighborhoods D and G, 758 units have been approved and /or are under construction, including 88 Very Low, 73 Low, 101 Moderate, and 496 Above Moderate units, including 190 density bonus units. 2 3 4 Pursuant to Government Code Section 65583(a) (1), City's share of extremely -low income units is 142 (50 percent of the RHNA Very Low income households new construction objective). Total number of units for extremely4ow, income and low income units equals to City's share of very-low income units of 283 units Source: 2012 RHNA; City of Tustin; MCAS Tustin Specific Plan. Preservation, Rehabilitation, and Other Affordable Housing Program Objectives The primary beneficiaries of Preservation and Rehabilitation and Assistance programs are renters and low- income homeowners. It is assumed that above - moderate- income households will rehabilitate units as needed through private efforts. Tustin's affordable housing strategy is based on the City's housing needs, affordability gap analysis, and available financial resources. Several broad policies establish the framework for the City's Housing strategy as applied to preservation, rehabilitation, and other housing program objectives. These include: 1. Conserve, maintain, and rehabilitate existing housing and revitalize existing neighborhoods; 2. Maximize the supply of affordable housing; 3. Increase homeownership; 4. Preserve the existing supply of affordable housing, and, Consistent with the above policies the City has devised a number of programs of housing assistance to address the preservation, rehabilitation, and other housing program objectives. Specific details on these programs can be found in the City of Tustin Comprehensive Housing Affordability Strategy for Fiscal Years 2008/09 to 2017 /18. In addition, Table H -20 - Housing Element Programs 2013 -2021 outlines the City's specific housing programs during the planning period. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 72 Summary of Quantified Objectives Table H -18 summarizes the City's Quantified Objectives for the 2013 -2021 period. Based on the requirements of AB 2634, statute of 2006 (Government Code Section 65583(a)(1)), each jurisdiction must address the projected need of Extremely Low - Income households, defined as households earning less than 30 percent of the Area Median Income (AMI). The projected Extremely -Low Income need is assumed to be 50 percent of the Low Income need, or 142 units based upon the percentage of extremely -low income households contained in the regional housing needs assessment determined by SCAG using American Community Survey data as the baseline. TABLE H -18 SUMMARY OF QUANTIFIED OBJECTIVES CITY OF TUSTIN 2014 -2021 Income Group RHNA New Construction Preservation Very Low 141 272 100 Extremely-Low 1421 142 Low 195 303 Moderate 224 348 Above Moderate 525 1,835 Total 1 1,227 1 2,900 100 Pursuant to Government Code Section 65583(a) (1), City's share of extremely -low income units is 142 (50 percent of the total Very Low Income new construction objective). Source: 2012 RHNA, SCAG, 2005 -2009 ACS IDENTIFICATION OF AFFORDABLE HOUSING RESOURCES The City has prepared a Consolidated Plan and Comprehensive Housing Affordability Strategy identifying and describing all funding programs available to the City and Tustin Redevelopment Agency (eliminated 2011) to assist in meeting the City's housing needs. Included in the plan are descriptions of a wide variety of major housing assistance programs available from federal and state agencies and private lending institutions. More specific information including details regarding eligible projects and activities and funding availability can be found in the document. The following is a summary of this information along with updates to reflect new state and federal programs. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 73 The key source of local funding for affordable housing development and preservation in Tustin was the Tustin Community Redevelopment Agency's (eliminated 2011) Low and Moderate Income Housing Fund, also known as the 20 Percent Set -Aside Fund. The estimated fund balance in the Agency's Low and Moderate Income Housing Fund as of June 30, 2007 was $17.86 million. With the dissolution of redevelopment in 2011, these funds are no longer available. • Preservation of At -Risk Affordable Housing Rental Units The City of Tustin has identified the preservation of existing affordable housing units as one of the most cost - effective methods of maintaining the stock of affordable housing therefore a high - priority program for the City. The City has identified 100 units of at -risk housing with expiring use restrictions within the eight -year planning period. The amount of assistance provided will be negotiated based on the specific economics of each development and the potential availability of leverage financing, such as tax - exempt bonds and 4% tax credits. . • Single- and Multi- Family Home Rehabilitation Program The City has identified single- and multifamily home rehabilitation loans and grants as another cost - effective method of extending the life of affordable housing in the community. Based on available funding, the City will target single - family neighborhoods in the vicinity of the Town Center opportunity area as part of the Town Center revitalization effort, as well as multifamily units citywide. • First -Time Homebuyer and/or Foreclosure Negotiated Purchase The City's First -Time Homebuyer Program provided down payment and second mortgage assistance to low and moderate income buyers to assist them to purchase an existing home in the City. The recent mortgage credit crises have resulted in increasing foreclosure rates throughout many parts of California and the nation. The City will seek funding to assist new first -time homebuyers in purchasing a home. This may include negotiated purchase of homes in foreclosure, which may represent a lower cost buying opportunity for first -time homebuyers. Homeless Assistance and Supportive Services The City has allocated $88,090 in 2013/14 CDBG funds to continue its financial support of homeless assistance and supportive services in the City. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 74 The City's goal for this program is to assist 200 homeless individuals per year over the projection period. • Tustin Legacy New Construction The City's inclusionary housing requirements for Tustin Legacy require a minimum of 453 new affordable units in Planning Areas D and G combined, including 126 units affordable to very low income households, 95 units affordable to low income households, and 232 units affordable to moderate income households. • Administrative Support The City and the Tustin Housing Authority will provide administrative support to implement its affordable housing activities. The City has initiated the development of additional very low, low and moderate income housing in the MCAS Tustin Project Area through density bonus incentives. The City is not an entitlement jurisdiction for HOME funds, but may apply to the State for HOME funds as described in a separate report prepared by DRA entitled Affordable Honsing Assistance Programs, presented as Appendix C of the Comprehensive Affordable Housing Strategy. The City is an entitlement jurisdiction for Community Development Block Grant (CDBG) funds. For FY 2012/13, the City of Tustin was allocated $587,277 in CDBG funds. These funds may be used for a number of community development purposes besides housing. Given the many competing needs for these funds and the restrictions on these funds for housing purposes, the City does not typically allocate CDBG funds for affordable housing development. As needed and as shown on Table H -21, the City will utilize State and Federal resources to leverage local resources as these funding sources match the City's programmatic objectives. Table H- 21 is a summary of affordable housing resources. 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O 0 S � a G o L09 p > G G M w b am3•�im•o5�� m G 3 W ^ O � � bA }�.� F u� +3 b .� by ai G � v .� � � O � •^ � N d� `O h. R N � •"3 •S .�p o a F a b w y G CJ " s ' O G E O y W R 0 3E 6•n'2ca °a..Oz FU Q. w c v w en m v 3 OW•a aG &.qq .S [ .6 Q O 1�yo Lo i0., H z w w W O z m 0 O x M zz En Ea F .7 OW z U Cw7 Appendix to Housing Element APPENDIX A REVIEW OF PAST PERFORMANCE CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 115 Appendix to Housing Element This page intentionally left blank. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 116 Appendix to Housing Element REVIEW OF PAST PERFORMANCE State law establishes an eight -year cycle regulating housing element updates. In compliance with the SCAG cycle, the Tustin Housing Element was updated in 1989 at which time it was found to be in compliance with State law, and was updated again in 1994. In 1997, the City of Tustin initiated a comprehensive General Plan update, and the Housing Element was again updated to accommodate the MCAS Reuse Plan and to ensure consistency with other General Plan Elements, as well as to address recent changes in State law. These amendments were adopted on January 16, 2001. In 2002 and 2009, the City updated its Housing Element and was certified by The State's Housing and Community Development Department in compliance with State's Law. Review of Past Housing Element Objectives (2006 -2014) The 2007 SCAG Regional Housing Needs Assessment indicated a new construction need in Tustin by 2014 of 2,381 units, of which 512 units were for very low income households, 410 for low income, 468 for moderate income and 991 for above moderate income. The following discussion highlights the progress, effectiveness and appropriateness of 2006 -2014 Housing Element Objectives and the progress achieved during the 2006 -2014 time period. Table HTM -35 in the Technical Memorandum provides a more detailed summary of the City's overall accomplishments for the years 2006- 2014. As indicated in Table HTM -35, the City was successful in accomplishing the majority of the objectives established for the past planning period. According to City Staff, the following objectives were completely or partially met, or exceeded: New construction 2,102 units were constructed during the 2006- 2014period, partially meeting the City's objective of 4,368units for the planning period. Available Sites The program objective was to primarily utilize Planned Community Districts and Specific Plans to authorize and encourage mixed -use developments to assist in the development of new affordable owner and rental housing. The program has seen development of 2,012 units over the 8 year period. Mobile homes The objective to maintain existing units was accomplished. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 117 Appendix to Housing Element Deed restricted affordable units The objective of requiring deed restrictions to ensure continued affordability for low- or moderate - income housing constructed or rehabilitated with the assistance of any public funds as may be legally required was successfully met. Between the years 2006 -2014, 243 restricted units were established. Pre - application conferences The objective to continue to utilize pre - application conferences and processing procedures to expedite processing was carried out during the review period. Transitional Housing The program objectives were to promote, assist, and facilitate the development of emergency and transient shelters through continued support of the County Homeless Assistance Program, and to support local agencies that provide homeless services with financial assistance. Also, the adoption of a Single Room Occupancy Ordinance was to be considered. The program has been effective in maintaining 3 homes with a total of 16 beds through the period, as well as 90 beds at the Orange County Social Services Tustin Family Campus facility as a shelter for abused and neglected children and their parents and for emancipated youth. Temporary housing for the homeless The program to support countywide efforts to assist approved homeless providers as part of the MCAS Tustin reuse effort was outlined in a series of specific objectives, all of which were achieved. A large variety of temporary and transitional facilities to be operated by various homeless providers have been developed at Tustin Legacy, as follows: Construction of the 192 -bed Village of Hope facility to be operated by the Orange County Rescue Mission is complete. Twenty-three units of transitional housing operated by the Salvation Army have been completed at Tustin Field I, as well as acquired in the city of Buena Park with the City of Tustin's assistance. Six new transitional units for women and children have been completed in the Columbus Grove development at Tustin Legacy, operated by Human Options. An additional 6 units have been completed at Columbus Grove for families with children, operated by Orange Coast Interfaith Shelter. Finally, 14 units at Columbus Grove provide transitional housing for families with children by Families Forward (formerly Irvine Temporary Housing). Housing opportunities for all economic segments The program to monitor the implementation of the affordable housing program adopted as a part of the East Tustin Specific Plan has successfully met the objective of monitoring 174 units in East Tustin over the 10 year period. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 118 Appendix to Housing Element Bonding Programs Prior to its dissolution, the Redevelopment Agency successfully administered a bond financing program that processed a total of 252 restricted units for very -low and low income households to accomplish Five -Year Quantified Objectives and help meet the City's affordable housing needs. Senior Citizen Housing The objective in protecting and providing senior citizen housing was identified as the preservation of 100 at -risk units. The 100 at -risk units were preserved throughout the review period. Senior Services Program The City's objective to develop a senior services program consisting of a comprehensive transportation program, case management, information and referral, and a shard housing program to assist 850 elderly annually was exceeded with approximately 400 elderly receiving served meals annually between 2006 and 2014 and others receiving other services. Ongoing Review of Housing Element Programs The objective to conduct an on -going review of Housing Element programs by preparing an annual report to the Planning Commission assessing the previous years' accomplishments toward meeting Housing Element objectives and then submitting the annual report to the State HCD was achieved. Zoning Studies The City was to undertake zoning studies to consider new programs to encourage and promote affordable housing and recommend appropriate amendments for action by the Planning Commission and City Council. The program was effective in that the City completed the Market Analysis and conducted community meetings to gather input for the Town Center A New Beginning Study, and the City adopted a Reasonable Accommodation Ordinance in 2011. Private Streets In order to reduce construction costs, the City adopted standards for private streets and continued to permit developers to install private rather than public streets when feasible. In the 2006 -2014 period, private streets were created at Tustin Legacy. Site Improvements New developments require the construction of site improvements which are often costs that are passed on from the developer to the housing consumer, creating an CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 119 Appendix to Housing Element even greater barrier to qualifying for the purchase of home. In order to reduce these added housing costs, the objective was to evaluate the use of special assessment district funding at MCAS Tustin (Tustin Legacy) as well as in other developing areas. During the 2006 -2014 period, one of the community facilities district (CID) bonds was refunded to take advantage of lower interest rates, thus reducing costs to property owners. Additionally, a new CID was created at Tustin Legacy, and several special assessment district bonds from the mid -90s were defeased. Environmental Constraints The on -going goal was to require program Environmental Impact Reports (EIR) on all major development projects to decrease the delays in processing and incorporating mitigation requirements into the development plans. During the Housing Element Planning Period, the Final Program EIS /EIR for MCAS Tustin served as the program EIR for the implementation of Tustin Legacy. Density Bonus Program The objective was to process all requests for density bonuses in order to facilitate the construction of affordable housing. During the Housing Element Planning Period, the Density Bonus Ordinance was updated. Between 2001 -2008, Lennar /Lyon were granted 182 density bonus units for the creation of affordable units at Columbus Square and Grove. MCAS Tustin Redevelopment Project Area The goal to create a new redevelopment project area for the MCAS-Tustin site by adopting the MCAS - Tustin Specific Plan and Redevelopment Project area was attained. However, all redevelopment agencies in California were eliminated in 2011. Fair Housing The City's objective to provide housing counseling services to assure equal housing opportunities by assisting approximately 400 residents annually and 3,000 residents by 2014 was partially met. Between 2006 and 2014, over 1,000 Tustin residents were provided with housing counseling services. Shared Housing The City continued to provide coordination and support to an Orange County housing sharing program. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 120 Appendix to Housing Element Housing Referral Program The City continued to provide housing referral services to families in need of housing assistance and information through the Police, Parks and Recreation Services, and Community Development Departments. The objective was to make 7,500 referrals to social agencies and 50 referrals for shared housing by 2014. Between 1998 -2000, 4,375 social service referrals and 25 shared housing referrals were made. Replacement Housing The program objective was to ensure rehabilitation or construction of an equal number of replacement units when low and moderate income residential units are destroyed or removed from the market. The City has exceeded its replacement housing obligations. Housing Rehabilitation The goal to rehabilitate 162 units by allocating CDBG and Redevelopment Agency (eliminated 2011) funds to finance public improvements and rehabilitation of residential units in target areas was partially achieved. A total of 20 units were assisted with RDA funds over the review period. Housing Authority The program to contract with the Orange County Housing Authority (OCHA) for the development and operation of federally assisted low and moderate income housing programs was continued Rental Assistance The program to provide rental assistance through Section 8 certificates and voucher certificate program assistance funds through the OCHA was successful over the review period. The objective to issue 200 certificates/ vouchers annually and 1,200 by 2014 was exceeded. Between 2008 and 2012, 1,704certificates /vouchers were issued. Affordable Senior Housing Project and Senior Board and Care Facility The program objective to maintain 74 units of affordable senior housing (20 units at 17432 -17442 Mitchell Avenue and 54 units at 1311 Sycamore Avenue) was achieved. Over the review period, 74housing units were maintained. Preservation of Assisted Housing Tustin has a total of 100 low income units that have been at risk of conversion during the review period. The objective to monitor and preserve all of these units at risk was completed successfully. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 121 Appendix to Housing Element Enforcement of Building and Housing Codes The City's Code enforcement conducted over 2,240 property maintenance and housing code related inspections between 2008 and 2012. The City has been successful in getting property owners to abate code violations. Cultural Resources District The purpose of the City's Cultural Resources Overlay District is to safeguard the heritage of the City by preserving neighborhoods and structures that reflect the City's heritage and past. The objective in the planning period was to rate historic structures where applicable and process certificates of appropriateness as received. Between 2008 and 2012, the Community Development Department issued 89 Certificates of Appropriateness certifying building changes were consistent with design guidelines and appropriate within the District context. Energy Conservation All new construction is required to be subject to state energy conservation (Title 24) requirements as a condition for the issuance of a building permit. Between 2008 and 2012,1,231 new units were required by the City to meet these standards. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 122 APPENDIX B AFFORDABILITY GAP ANALYSIS CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN 0 City of Tustin Affordability Gap and leveraged Financing Analysis 1.0 Executive Summary The City of Tustin retained David Paul Rosen & Associates (DRA) to prepare an affordability gap analysis and evaluation of leveraged financing options for new residential development in Tustin. The "affordability gap" methodology determines the difference between the supportable mortgage on the unit at affordable rents and sales prices and the actual development cost of the unit. The gap analysis provides planning -level estimates of the typical per unit subsidized required to make different types of housing affordable to households at alternative income levels. The per unit affordability gaps calculated in this report are based on housing prototypes that are i00% affordable to households at each of the income levels modeled (or in the case of the leveraged,fnancing analysis, at the mix of income levels necessary to meet. the requirements andd//or competitive standards of the leveraged financing programs). However, the results can be used in estimating subsidy requirements for mixed income housing developments as well. Under the assumption that the market rate units are financially feasible without subsidy, the subsidy requirement for a mixed income development can be estimated by multipiyin? the number of affordable units bthe appropriate per unit affordability gap. The resu is of the gap analysis Provide a useful tool to the City of Tustin and Tustin Redevelopment Agency for capital planning purposes. DRA recommends -that the subsidy Provided to any Individual housing development be determined based on analysis of the specific economic conditions pertaining to that project The first step in the gap analysis establishes the amount a tenant or homebuyer can afford to contribute to the cost of renting or owning a dwelling unit based on established State and Federal standards. Income levels, housing costs and rents used in the analysis are defined below using 2007 published data for Tustin. The second step estimates the costs of new housing construction in Tustin. For this purpose, DRA, in collaboration with City staff, formulated five prototypical housing developments (one rental development and four owner developments) suitable for the Tustin market today. DRA estimated the cost to develop these housing prototypes In Tustin under current housing conditions using information on actual recent housing developments provided by Tustin and Orange County area developers. The third step in the gap analysis establishes the housing expenses borne by the tenants and owners. These costs can be categorized into operating costs, and financing or mortgage obligations. Operating costs are the maintenance expenses of the unit, including utilities, property maintenance and/or Homeownership Association (HOA) fees, 141 property taxes, management fees, property insurance, replacement reserves, and insurance. For the rental prototype examined in this analysis, DRA assumes that the City of Tustin Affordability Gap and Leveraged Financing Anahsis Page 1 14. i landlord pays ail but certain tenant -paid utilities as an annual operating cost of the unit paid from rental income. For owner prototypes,' DRA assumes the homebuyer pays all operating and maintenance costs for the home. Financing or mortgage obligations are the costs associated with the purchase or development of the housing unit itself. These costs occur when all or a portion of the development cost is financed. This cost is always an obligation of the Iandi9rd or owner. Supportable financing is deducted from the total development cost, less any owner equity or downpayment, to determine the gap between the supportable mortgage on the affordable units and the cost of developing those units. For the rental housing prototype, the gap analysis calculates the difference between total development costs and the conventional mortgage supportable by net operating income from restricted rents. For owners, the gap is the difference between development costs and the supportable mortgage plus the buyer's down payment. Affordable housing costs for renters and owners are calculated based on California Redevelopment Law definitions and occupancy standards. Household income is adjusted based on an occupancy standard of one person per bedroom plus one. The gaps for the owner prototypes *are summarized in Table 1. The gaps have been calculated for the following three income levels:. Affordable Income Limit Housing Cost 1. Very Low Income 50% of Area Median Income (AMI), adjusted 309'0 of 509'9 AMI for household size 2. Low Income 800/9 of AMI, adjusted for household size 30% of 70% AMI 3. Moderate Income 120% of AMI, adjusted for household size 35% of 110% AMI Depending upon the source of subsidy for ownership housing, the gaps may vary. For example, eral HOME funds do not require deduction of a utility allowance in the calculation of affordable mortgage payment However, under California Redevelopment Law, owner affordable housing expense is defined to include monthly utility costs. This increases the ownership gaps. The affordability gaps shown in Table 1 include utility allowance deductions. The gaps for the rental prototype, without non -local leveraged financing, are summarized in Table 2. The gaps have been calculated for the following three income levels: 0 City of Tustin Affordability Cap and Leveraged Financing Analysis page 2 IS i Affordable Housing Income Limit Cost 1. Very Low Income 50% of Area Median Income (AMI), 30% of 50% AMI adjusted for household size 2. Low Income 80% of AMI, adjusted for household size 30% of 60% AMI 3. Moderate Income 120% of AMI, adjusted for household size 30% of 1100/6 AMI DRA produced, under separate cover, a comprehensive review of Federal, State, and private sources of funding that might be used to subsidize affordable rental and ownership housing in Tustin. For ownership housing, per unit mortgage assistance, as available, generally reduces the gap on a dollar for dollar basis. For rental developments, the use of the Low Income Housing Tax Credit -Program and/or tax- exempt bonds is more complicated, because of the formulas for calculating tax credits and the specific income targeting required. Therefore, for the rental prototype,, we have examined the following leverage scenarios: 1. 9% Low Income Housing Tax Credits (Federal only)'; 2. 4% tax credits with tax - exempt bonds, and 3. 4% tax credits, tax - exempt bonds, and the Multifamily Housing Program (MHP) of the California Department of Housing and Community Development (HCD). The assumptions and findings are described in the following section. The sources and uses for each leveraged rental scenario are summarized in Table 3. t Since Orange County was dnignated as a Difficult to Develop Area (DDA) by HUD in 2007, projects in the County are eligible for a 130% basis boost for the calculation of Federal tax credits but are not eligible far State tax credits. City of Tustin Affordability Gap and Leveraged Financing Analysis Page 3 A Source: David Paul Rosen dr Associates City cMstln Affordability Gap and Leveraged Financing Analysis Page 4 Table 1 Homeowner Per Unit Subsidy Requirements' City of Tustin 2008 Very Low Low Moderate PrototvQelUnit Bedroom Count Income income' Income Owner Prototype #1s Attached TOWnhome Two Bedroom $366,000 $322,400 $195,500 Three Bedroom $387,800 $339,400 $198,400 Four Bedroom $426,800 $374,600 $222,300 Average $393,500 $345,500 $205,400 Owner Prototype Ife Stacked Flat Condominium One Bedroom $258,600 $219,900 $107,100 Two Bedroom $259,000 $215,500 $88,600 Three Bedroom $267,100 $218,800 $77,800 Four Bedroom $290,500 $238,300 $86,000 Average $268,800 $223,100 $89,900 Owner Prototype #37 High Density Condominium One Bedroom 5407,500 $368,800 $256,000 Two Bedr000m $432,500 $389,000 $262,100 Three Bedroom SS42,000 $493,700 $352,600 Four Bedroom 5569,400 $517,200 $364,800 Average $487,900 $442,200 $308,900 Owner Prototype #48 Mixed Use, Ground Floor Retail One Bedroom 54910700 $453,000 $340,200 Two Bedr000m 5537,400 $493,900 $366,900 Three Bedr00m $595,000 $546,600 $405,600 Average $541,300 $497,800 5370,900 Source: David Paul Rosen dr Associates City cMstln Affordability Gap and Leveraged Financing Analysis Page 4 A Notes to Table 1: ' Per unit subsidy requirements are calculated as per unit total development cost less affordable home purchase price, based on an occupancy standard of one person per bedroom plus one, per California Redevelopment Law. Affordable home purchase price is calculated based on monthly affordable housing expense, inclusive of mortgage principal and interest, property taxes and insurance, utilities and homeowners association (HOA) dues. Calculations are based on the following assumptions: 30 -year mortgage interest rate of 8 percent; average property tax rate of 1.20 percent; property insurance costs of $50 per month; HOA dues of $175 per month; and a utility allowance calculated based on County of Orange, Housing and Community Services Department utility allowance schedule, effective October 1, 2006. ' Very low income owner affordable housing is cost calculated as 30 percent of 50 percent of AMI, adjusted for household size. Average very low income affordable home purchase price is $70,764. ' Low income owner affordable housing cost is calculated as 30 percent of 70 percent of AMI; adjusted for household size. Avenge low income affordable home purchase price is $116,4S7. ' Moderate Income owner affordable housing cost is calculated as 35 percent of 110 percent of AMI, adjusted for household size. Average moderate income affordable home purchase price Is $249,723. ' Owner Prototype I1 average unit size is 1,296 square feet. Average per unit development cost is $468,663. Per unit development costs are adjusted by unit size/bedroom count ' Owner Prototype 12 average unit size is 1,142 square feet. Average per unit development cost is $339,591. Per unit development costs arc adjusted by unit size/bedroom count. r Owner Prototype 13 average unit size is 1,350 square feet. Average per unit development cost Is $558,617. Per unit development costs are adjusted by unit size/bedroom count s Owner Prototype 94 average unit size is 1,515 square feet. Average per unit development cost is 5608,112. Per unit development costs are adjusted by unit size/bedroom count City of Tustin Affordability Cap and Leveraged Financing Analysis Page 5 0 Table 2 Tenant Per Unit Subsidy Requirements' Rental Housing Prototype: Stacked Flat Apartments City of Tustin 2008 Unit Bedroom Count One Bedrooms Two Bedroom' Three Bedroom' Four Bedroom' Average Renter Prototype Stacked Flat Apartments Very Low Low Moderate Income= Income Income $311,300 $294,6W $211,400 $348,000 $329,300 $235,600 $3,21,800 $301,000 $197,000 $402,000 $379,600 $174,800 $345,775 $326,125 $204,700 Source: David Paul Rosen & Associates. City ofTusdn Affordability Gap and Leveraged Financing Analysis Page 6 :a 0 r: nrd Notes to Table 2: ' Tenant per unit subsidy requirements are calculated as per unit total development cost less per unit tenant supported debt. Tenant supported debt is calculated based on tenant monthly operating income which equals: affordable monthly rent, inclusive of utilities, less a monthly per unit operating cost of $300, property taxes assumed at an average annual rate of 1.20 percent; and a 3 percent vacancy rate. Tenant supported debt calculations are based on a 30 -year mortgage interest rate of 8 percent and a debt coverage ratio of 1.25. Affordable monthly rents are based on household income, adjusted for household size assuming an occupancy standard of one person per bedroom plus one, per California Redevelopment Law. Very low Income renter affordable housing cost is calculated as 30 percent of 50 percent of AMI, adjusted for household size. Average very low income affordable monthly rent is $847. r Low income renter affordable housing cost calculated as 30 percent of 60 percent of AMI, adjusted for household size. Average low income affordable monthly rent is $1,033. ' Moderate income renter affordable housing cost calculated as 30 percent of 110 percent of AMi, adjusted for household size. Average moderate income affordable monthly rent is $1,963. s One bedroom unit is 750 square feet. Per unit total development cost is $321,075. ` Two bedroom unit is 950 square feet. Per unit total development cost is $362,224. ' Three bedroom unit is 1,050 square feet. Per unit total development cost Is $382,799. ° rour bedroom unit is 1,250 square feet. Per unit total development cost Is $423,947. City of Tustin Affordability Cap and Leveraged Financing Analysis Page 7 n Table 3 Average Per Unit Subsidy Requirements Rental Housing Prototypr. Stacked Flat Apartments Leveraged Financing Scenarios City of 76stin 20011 Leveraged Financing Scenaria 9% Tax Credits 4% Tax Credits, Tax - Exempt Bonds 4% Tax Credits, Tax- Exempt Bonds, Multi - Family Housing Program (MHP) Renter Prototype Stacked Flat Apartments $S7,000 $140,100 s• .ss Source~ David Mul.Rosen & Associates. City o( Tustin Affordability Cap and Leveraged Financing Analysis Page 8 This page intentionally left blank. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN Appendix to Housing Element CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN Appendix to Housing Element 77iis page intentionally left blank. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN APPENDIX C PUBLIC PARTICIPATION MAILING LIST CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN This page intentionally left blank. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN Veterans Service Dept. Dayle McIntosh Center Orange Coast Interfaith Shelter 4220 Lemon Street 13272 Garden Grove 1963 Wallace Street Riverside, CA 92501 Garden Grove, CA 92843 Costa Mesa, CA 92627 YMCA of Orange County 13821 Newport Ave., Suite #200 Tustin, CA 92780 Tustin Area Historical Society & Museum 395 El Camino Real Tustin, CA 92780 Probation Community Action Assoc. 18627 brookhurst Street #425 Fountain Valley, CA 92708 -6748 Helen Anderson Hunger Coalitions 14452 Wildeve Lane Tustin, CA 92780 Diane Aust Tustin Area Council for Fine Arts P.O. Box 145 Tustin, CA 92781 Vanessa Bruner Learning for Life - Orange County 1211 East Dyer Santa Ana, CA 92705 Holly Hagler .ommunity Services Programs Inc. 1200 N. Knollwood Circle Anaheim, CA 92801 Keith Rhodes Big Brothers & Sisters of OC 14131 Yorba Street, Suite 200 Tustin, CA 92780 John Von Glahn Family Service Association 18001 Cowan, Units C -D Irvine, CA 92714 -6801 CITY OF TUSTIN GENERAL PLAN Assistance League of Tustin P.O. Box 86 Tustin, CA 92781 Legal Aid Society of Orange County 2101 N. Tustin Avenue Santa Ana, CA 92705 Mardan Foundation of Educational Therapy 1 Osborn Irvine, CA 92604 Allen Baldwin OC Community Housing Corp. 2024 N. Broadway, 3rd Mr. Santa Ana, CA 92706 -2623 Doug Bistry O.C. Affordable Housing 23861 El Toro Road, Suite 207 Lake Forest, CA 92640 -4733 Jerry Caminti Disability Awareness Coalition 3773 University Drive, #118 Irvine, CA 92612 Donna Core Meals on Wheels 1001 N. Tustin Ave. Santa Ana, CA 92707 John Drew Family Solutions 203 N. Golden Circle Dr., #101 Santa Ana, CA 92705 Jason Suppes Four H Clubs of Orange County 1045 Arlington Dr. Costa Mesa, CA 92626 Families First 12012 Magnolia Street Garden Grove, CA 92641 -3346 Community Services Programs Inc. 1221 East Dyer Rd., Suite 120 Santa Ana, CA 92705 Ronald M. Griffith Century Housing 1000 Corporate Pointe, Suite 200 Culver City, CA 90230 Mary's Shelter P.O. Box 10433 Santa Ana, CA 92711 Civic Center Barrio 980 W. 17th Street, Unit E Santa Ana, CA 92706 Patrick Carroll Life Share 11421 Garden Grove Blvd. Garden Grove, CA 92643 Community Action Partnership of Orange County 11870 Monarch Street Garden Grove, CA 92841 Janie Wolicki Women Helping Women 1800 East McFadden Ave., Suite 1A Santa Ana, CA 92705 Mary Hadley Info Line Orange County 2081 Business Center Dr., Suite 130 Irvine, CA 92715 HOUSING ELEMENT JUNE 16, 2009 Mercy House Transitional Living Dawn Price Elmer Hothus Ctr, Friendship Shelter, Inc. Christian Temporary Housing P.O. Box 1905 P.O. Box 4252 Facility 704 N. Glassell Street Santa Ana, CA 92702 Laguna Beach, CA 92652 Orange, CA 92867 Warren Johnson Judy Johnson Becky Johnson Salvation Army ESA / Corporate Office Alliance for the Mentally Ill 10200 Pioneer Road 23861 El Toro Road, Suite 207 621 S. "B" Street Tustin, CA 92780 Lake Forest, CA 92640 -4733 Tustin, CA 92780 Habitat for Humanity of Orange Tustin Public School Foundation Children's Bureau of Southern County 150 El Camino Real, #140 California 2200 S. Ritchey Street Tustin, CA 92780 50 S. Anaheim Boulevard, Suite. 241 Santa Ana, CA 92705 Anaheim, CA 92805 Orange Children & Parents The Villa Center, Inc. Laura Archuleta Together Jamboree Housing Corp. 1063 N. Glassell Street 910 North French 17701 Cowan Ave., Suite 200 Orange, CA 92867 Santa Ana, CA 92701 Irvine, CA 92614 OCSPCA -Paws Jonathan Stone Theresa Mali P.O. Box 6507 Tustin Chamber of Commerce Legal Aid Society of Orange County Huntington Beach, CA 92615 700 W. First Street, Suite 7 2101 N. Tustin Avenue Tustin, CA 92780 Santa Ana, CA 92705 Charlene M. Ashendorf Easter Seal Society, Inc. Sherry McCulley Laurel House 1570 E. 17th Street Legal Aid Society of Orange County P.O. Box 3182 Santa Ana, CA 92705 2010 N. Tustin Avenue Tustin, CA 92781 Santa Ana, CA 92705 Barbara Resnick Jim Miller Ellen Waild OC Council on Aging American Family Housing Lutheran Social Service of Southern 1971 E. 4th Street, #200 15161 Jackson Street California Santa Ana, CA 92705 Midway City, CA 92655 -1432 2560 North Santiago Blvd. Orange, CA 92867 Santa Ana, CA 92799 Orange, CA 92867 Donald VerLeur Boys & Girls Club of Tustin Denise Y. Cato Olive Crest 580 W. Sixth Street Fair Housing Council of OC 2130 E. Fourth Street, Suite 200 Tustin, CA 92780 201 S. Broadway Santa Ana, CA 92705 18542 -B Vanderlip Ave. Santa Ana, CA 92701 Barbara Resnick Joyce Riley Rich Gorham Western Dev. For Affordable Learning Disabilities of Southern St. Vincent de Paul Center for Housing California Reconciliation 112 E. Champan Avenue P.O. Box 25772 1505 E. 17th Street, Suite 109 Orange, CA 92867 Santa Ana, CA 92799 Santa Ana, CA 92705 Orange County Homeless Issues Kathleen Buehler Susan Stokes Task Force The Blind Children's Learning Turning Point Center for Families 1770 N. Broadway Center 2101 E. 4th Street, #150 -B Santa Ana, CA 92706 18542 -B Vanderlip Ave. Santa Ana, CA 92705 -3814 Santa Ana, CA 92705 CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN JUNE 16, 2009 Donald Taylor Ed Gerber Lynne Tsuda 'eteran Charities of Orange County Lestonnac Free Clinic Central Orange County YWCA 201 S. Sullivan Street 1215 E. Chapman Ave. P.O. Box 689 Santa Ana, CA 92704 Orange, CA 92866 Orange, CA 92865 Service People in Need 151 Kalmus #H -2 Costa Mesa, CA 92626 Tim Wells Episcopal Service Alliance 525 Main Street Huntington Beach, CA 92648 Lorri Galloway The Eli Home, Inc. 1175 N. East Street Anaheim, CA 92805 Vickie Talley OC Housing Providers 25241 Paseo de Alicia #120 Laguna Hills, CA 92653 Steve PonTell [National Community Renaissance 9065 Haven Ave., Suite 100 Rancho Cucamonga, CA 91730 Debbie Phares Orange County Congregation Community Organization P.O. Box 2 Anaheim, CA 92805 Maury Ruano Mercy Housing 2240 W. Lincoln Avenue Anaheim, CA 92801 Mike Balsamo BIA Orange County Chapter 17744 Sky Park Circle, #170 Irvine, CA 92614 Kenneth W. Babcock Public Law Center 601 Civic Center Drive West Santa Ana, CA 927014002 Clyde Weinman Irvine Temporary Housing 6427 Oak Canyon Irvine, CA 92620 Randy Wenz Orange County Council BSA 1211 E. Dyer Street Santa Ana, CA 92705 Carol Anne Williams Interval House P.O. Box 3356 Seal Beach, CA 90740 Hunter L. Johnson LINC Housing 110 Pine Street, Suite 500 Long Beach, CA 90802 Patrick McCabe William Lyon Homes, Inc. 4490 Von Karman Ave. Newport Beach, CA 92660 Karen Weisenberger Consumer Credit Counseling Service P.O. Box 11330 Santa Ana, CA 92711 Thomas Whaling Shelter for the Homeless 24621 Ridgewood Circle Lake Forest, CA 92630 Pilgrimage Family Therapy 23201 Mill Creek Road, #220 Laguna Hills, CA 92653 William O'Connell Colette's Children's Home 17301 Beach Blvd., Suite 23 Huntington Beach, CA 92647 Steven Johsz Orange County Social Services, Tustin Family Campus 1152 E. Fruit Street, Suite 550 Santa Ana, CA 92701 Glenn Hayes Maria I. Marquez Neighborhood Housing Services of Adult Mental Health Services Orange County 405 West Fifth Street, Suite 550 198 W. Lincoln Ave., 2nd Floor Santa Ana, CA 92701 Anaheim, CA 92805 Randy Gibeaut Community Housing Resources 1411 North Broadway Santa Ana, CA 92706 Bart G. Hess Affordable Home Owners Alliance 2 Park Plaza, Suite 100 Irvine, CA 92614 -5904 Kelly Lupro OC Housing & Community Development 1770 N. Broadway Santa Ana, CA 92706 Brenda Rodriguez Affordable Housing Cleaminghouse 23861 El Toro Road, Suite 401 Lake Forest, CA 92630 Jim Palmer Orange County Rescue Mission 1 Hope Drive Tustin, CA 92782 Karen Roper OC Housing & Community Development 1770 N. Broadway Santa Ana, CA 92706 CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN JUNE 16, 2009 Captain Lee Lescano The Salvation Army 10200 Pioneer Road Tustin, CA 92782 Cynthia Campbell Human Options, Inc. (DOVE Housing) P.O. Box 9376 Newport Beach, CA 92658 Sheri Barrios Orange Coast Interfaith Shelter 1963 Wallace Avenue Costa Mesa, CA 92627 Cesar Covarrubias The Kennedy Commission 17701 Cowan Ave., Suite 200 Irvine, CA 92614 Lucy Dunn Orange County Business Council 2 Park Plaza, Suite 100 Irvine, CA 92614 CITY OF TUSTIN GENERAL PLAN Maya Dunne SHJHS Foundation & Community Outreach 500 S. Main St., Suite 1000 Orange, CA 92868 Margie Wakeham Families Forward 9261 hvine Blvd. Irvine, CA 92618 Linda Tang Kennedy Commission 17701 Cowan Ave., Suite 200 Irvine, CA 92614 David Levy 14331 Browning #24 Tustin, CA 92780 Jacqui Kerze Regional Center of Orange County P.O. Box 22010 Santa Ana, CA 92702 -2010 Scott Larson HomeAid Orange County 17744 Sky Park Circle, #170 Irvine, CA 92614 Joan B. Bargol Orange Coast Interfaith Shelter 1963 Wallace Avenue Costa Mesa, CA 92627 Affirmed Housing Group 13520 Evening Creek Dr. North, #160 San Diego, CA 92128 John H. Cochrane, III be.group - Senior Living 516 Burchett Street Glendale, CA 91203 HOUSING ELEMENT JUNE 16, 2009 Appendix to Housing Element APPENDIX D CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN Appendix to Housing Element This page intentionally left blank. CITY OF TUSTIN HOUSING ELEMENT GENERALPLAN Appendix to Housing Element REFERENCES A. Documents 1. 2000 Census Report. U.S. Department of Commerce, Bureau of the Census. 2. 2010 Census Report. U.S. Department of Commerce, Bureau of the Census. 3. 2007 -2011 American Community Survey. U.S. Department of Commerce, Bureau of the Census. 4. Comprehensive Housing Affordability Strategy for Fiscal Years 2007 -2008 to 2017 -2018, David Paul Rosen & Associates (DRA). 5. Marine Corps Air Station (MCAS) Tustin Specific Plan /Reuse Plan, Adopted February 2003, Amendments through June 2007. 6. California State Department of Finance, 2013, E -5 Population and Housing Estimates. 7. Orange County Projections 2010 Modified, Center for Demographic Research at California State University, Fullerton. 8. Orange County Ten - Year Plan to End Homelessness, 2012, County of Orange. 9. Southern California Association of Governments, Regional Housing Needs Assessment, 2012. 10. City of Tustin, Zoning Ordinance. 11. City of Tustin, General Plan, as amended through November 2012. 12. City of Tustin 2010 -2015 Consolidated Plan. 13. City of Tustin Comprehensive Annual Financial Report For the Year Ended June 30, 2011, 14. City of Tustin Consolidated Annual Performance and Evaluation Report, September 26, 2012. 15. Market Overview Report for City of Tustin, Realfacts. 16. Third Five -Year Implementation Plan for The Town Center and South Central Redevelopment Project Areas (FY 2005 -06 to 2009 - 2010), Tustin Community Redevelopment Agency, December 2004. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN Appendix to Housing Element 17. Final Environmental Impact Statement/ Environmental Impact Report (EIS /EIR) for the Disposal and Reuse of MCAS -Tustin (Program EIS /EIR for MCAS - Tustin), January 16, 2001. 18. Response to Comments, Final Volume 2 and 3 of Final Environmental Impact Statement/ Environmental Impact Report (EIS /EIR) for the Disposal and Reuse of MCAS- Tustin. 19. City Council Staff Reports for St. Anton and Irvine Company projects, November 6, 2012. 20. State of California, Department of Housing and Community Development, Website. 21. Orange County Client Management Information System Year End Progress Report, Orange County Housing Partnership, December 2007 22. Orange County Department of Education, Division or School and Community Services, McKinney -Vento Homeless Education Assistance Act, 2006 -07. 23. 2013 State Income Limits, State Department of Housing and Community Development. 24. Marshall & Swift 25. State of California Government Code Sections 65580 et seq. B. Persons and Organizations 1. Elizabeth A. Binsack, Community Development Director Community Development Department, Tustin (714) 573 -3031 2. Jerry Craig, Program Manager Tustin Successor Agency (714) 573 -3121 3. Justina Willkom, Assistant Director - Planning Community Development Department, Tustin (714) 573 -3115 4. Scott Reekstin, Principal Planner Community Development Department, Tustin (714) 573 -3016 CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN Appendix to Housing Element 5. Edmelynne Hutter, , Associate Planner Community Development Department, Tustin (714) 573 -3174 6. Lieutenant Steve Lewis Tustin Police Department (714) 573 -3271 6. Ben Savill Community Housing Advisory Council Regional Center of Orange County 7. John Luker Orange County Rescue Mission Village of Hope (714) 247 -4300 CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN Housing Element TUSTIN TECHNICAL October 2013 Adopted by Resolution No. 13-86 Tltis page in ten tionally left blank. TABLE OF CONTENTS Section Page INTRODUCTION.................................................................................................. ..............................1 STATE LAW AND GENERAL PLAN GUIDELINES 1 SOURCES OF INFORMATION 5 SUMMARY OF HOUSING ISSUES, NEEDS, OPPORTUNITIES, AND CONSTRAINTS........ 6 HOUSING NEEDS ASSESSMENT ..................................................................... ............................... 8 POPULATION /EMPLOYMENT TRENDS 8 HOUSEHOLD CHARACTERISTICS 13 HOUSING STOCK CHARACTERISTICS 27 ASSISTED HOUSING PRESERVATION ANALYSIS 35 CONSTRAINTS TO THE DEVELOPMENT, IMPROVEMENT AND MAINTENANCE OF HOUSING ..................................................................... ............................... 45 GOVERNMENTAL CONSTRAINTS 45 MARKET CONSTRAINTS 63 ENERGY CONSERVATION ............................................................................. ............................... 67 SUMMARY OF PREVIOUS HOUSING ELEMENT PROGRAMS .............. ............................... 69 PROGRESS IN IMPLEMENTING THE 1989 GOALS AND OBJECTIVES 69 REVIEW OF PAST PERFORMANCE 70 APPENDICES: A. AFFORDABILITY GAP ANALYSIS B. REFERENCES C. MAJOR EMPLOYERS IN TUSTIN CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM i LIST OF TABLES CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM ii Page TABLE HTM -1: Population Growth 2000 - 2012 City of Tustin, Nearby Jurisdictions and Orange County 9 TABLE HTM -1A: Population Projections 2015 - 2035 10 TABLE HTM- 2: Age Trends 2000 -2011 City of Tustin 10 TABLE HTM- 3: Race and Ethnicity: 1990, 2000, 2010 City of Tustin 11 TABLE HTM- 4: Employment by Occupation 2011 City of Tustin 12 TABLE HTM- 5: Employment by Industry 2011 City of Tustin 12 TABLE HTM- 6: Household Type: 1990 - 2011 City of Tustin 13 TABLE HTM- 7: Household Size 1990 Through 2011 City of Tustin 14 TABLE HTM- 8: Households in Overcrowded Conditions 2011 City of Tustin 15 TABLE HTM- 9: Median Household Income: Tustin and Surrounding Areas 2011 15 TABLE HTM -10: Household Income Distribution City of Tustin 2011 16 TABLE HTM -11: Household Income Distribution by Household Tenure 2011 17 TABLE HTM -12: Households Overpaying for Shelter 2011 City of Tustin 18 TABLE HTM -13: Household Size Distribution City of Tustin 2011 21 TABLE HTM -14: Households with Five or More Persons City of Tustin 2011 22 TABLE HTM -15: Summary of Homeless Accomodation Zoning Regulations 25 TABLE HTM -16: Emergency Shelter /Transitional Housing Facilities 2013 26 TABLE HTM -17: Housing Growth Trends 1990 - 2010 Tustin and Surrounding Areas 27 TABLE HTM -18: Tustin Residential Unit Mix City of Tustin 1990 - 2013 28 TABLE HTM -19: Vacancy Rates 2000 -2013 City of Tustin 28 TABLE HTM- 20: Tenure 1990 and 2011 City of Tustin 29 TABLE HTM- 21: Age of Housing Stock City of Tustin 30 TABLE HTM- 22: New and Resale Price of Homes and Condominiums Tustin and Neighboring Jurisdictions 2012 31 TABLE HTM- 23: Average Rental Rates, 2013 -16t Quarter City of Tustin 32 TABLE HTM- 24: Affordable Net Rents 2013 City of Tustin 33 CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM ii TABLE HTM- 25:2014-2021 Housing Needs City of Tustin 34 TABLE HTM- 26: At Risk For Conversion in 2006 -2014 City of Tustin 36 TABLE HTM- 27: Assisted Housing Inventory 37 TABLE HTM- 28: 2013 Fair Market Rents, Orange County 43 TABLE HTM- 29: Affordable Rents, City of Tustin 2013 43 TABLE HTM- 30: Cost of Providing Rental Subsidy for Very Low Income Households 44 TABLE HTM- 31: General Plan Residential Land Use Categories City of Tustin 46 TABLE HTM- 32: Summary of Residential Zoning Regulations City of Tustin 49 TABLE HTM- 33: Summary of Homeless Accomodation Zoning Regulation 56 TABLE HTM- 34: Summary Table: Effectiveness of Housing Element Programs, 2006 -2014 69 TABLE HTM- 35: Effectiveness of Housing Element Programs 2006 -2014 71 TABLE HTM- 36: Progress Towards Objectives 2006 -2014 City of Tustin 113 CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM iii This page intentionally left blank. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM iv INTRODUCTION This memorandum is a reference document intended to provide background data that will serve as a partial basis for policies and programs in the Housing Element. In accordance with State law, a significant amount of data is required in this memorandum. Where possible, the data has been summarized in graphic form for easy reference. The reader is urged to use the table of contents at the front of this document as a guide. Once the Housing Element has been completed, the Technical Memorandum will be incorporated therein. State law largely determines the content of this Technical Memorandum. Five sections follow the introduction. The Summary of Housing Issues, Conditions, Opportunities and Constraints provides an overview of the key issues facing the City, which are addressed by the goals, policies and programs of the Housing Element. The Housing Needs Assessment section addresses housing needs. More specifically, it discusses how the population has grown and changed, how households are changing (i.e., size, composition), and how the housing supply is changing. This section also analyzes the potential loss of assisted lower income housing units in the City. The third section addresses governmental and non- governmental constraints, such as market condition, and natural environment, to housing development. The fourth section addresses energy conservation. Finally, the fifth section summarizes the housing issues, opportunities, and constraints that have emerged through background research and public meetings and which must be addressed in the Housing Element. STATE LAW AND GENERAL PLAN GUIDELINES The State of California provides very specific requirements and guidelines for preparing Housing Elements. This section describes those requirements and explains the relationship between this element and the rest of the General Plan. The State of California requires that each jurisdiction prepare and adopt a Housing Element. The State Requirements for Housing Elements are far stricter and more detailed than for any other General Plan Element. State Planning law requires local governments to review their housing elements as frequently as appropriate and to revise the elements as appropriate, not less than every eight years. The fifth revision date for jurisdictions within the Southern California Association of Governments (SCAG) is October 15, 2013. The planning period for the Regional Housing Needs Assessment (RHNA) as prepared by SCAG, is from January 1, 2014 to October 1, 2021, a seven and three CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 1 quarter year period. The implementation period covered by this element is October 2013 to October 2021. Organization of the Housing Element Under the provisions of Section 65583 of the Government Code, the Housing Element shall generally consist of an identification and analysis of existing and projected housing needs and a statement of goals, policies, quantified objectives, and scheduled programs for the preservation, improvement, and development of housing. The Housing Element shall identify adequate sites for housing, including rental housing, factory-built housing, and mobile homes, and shall make adequate provision for the existing and projected needs of all economic segments of the community. More specifically, the Housing Element must meet the requirements outlined below. A. An assessment of housing needs and an inventory of resources and constraints relevant to meeting these needs. The assessment and inventory shall include the following: • Analysis of population and employment trends and documentation of the locality's existing and projected housing needs for all income levels. These existing and projected needs shall include the locality's share of the regional housing needs in accordance with Section 65584. • Analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. • An inventory of land suitable for residential development, including vacant sites and sites having potential for redevelopment, and an analysis of the relationship of zoning and public facilities and services to these sites. • Identification of a zone or zones where emergency shelters are allowed as a permitted use • Analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures. • Analysis of potential and actual non - governmental constraints upon the maintenance, improvement, development of housing for all income levels, including the availability of financing, the price of land, and the cost of construction. • Analysis of any special housing needs, such as those of, persons with disabilities (including developmental disabilities), the elderly, large families, CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 2 farm workers, families with female heads of households, and families and persons in need of emergency shelter. Analysis of opportunities for energy conservation with respect to residential development. • Analysis of existing assisted housing developments that are eligible to change from low- income housing uses during the next 10 years. B. A statement of the community's goals, quantified objectives, and policies relative to the maintenance, preservation, improvement, and development of housing. It is recognized that the total housing needs identified pursuant to Section 65583(a) may exceed available resources and the community's ability to satisfy this need within the content of the general plan requirements. Under these circumstances, the quantified objectives need not be identical to the identified existing housing needs, but should establish the maximum number of housing units that can be constructed, rehabilitated, and conserved over a five -year time frame. C. A program which sets forth a schedule of actions over the implementation period that the local government is undertaking or intends to undertake in order to implement the policies and achieve the goals and objectives of the housing element through the administration of land use development controls, provision of regulatory concessions and incentives, and the utilization of appropriate federal and state financing and subsidy programs when available. In order to make adequate provision for the housing needs of all economic segments of the community, the program will incorporate the following: • Identify adequate sites which will be made available through appropriate zoning and development standards and with public services and facilities needed to facilitate and encourage the development of a variety of types of housing, factory -built housing, mobile homes, emergency shelters and transitional housing in order to meet the community's housing goals. • Assist in the development of adequate housing to meet the needs of extremely low, very low, low- and moderate - income households. • Address and, where appropriate and legally possible, remove governmental constraints to the maintenance, improvement, and development of housing. • Conserve and improve the condition of the existing affordable housing stock. Promote housing opportunities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, or color. The program shall include an identification of the agencies and officials responsible for the implementation of the CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 3 various actions and the means by which consistency will be achieved with other general plan elements and community goals. The local government shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the housing ,element, and the program shall describe this effort. In addition, an amendment to housing element law (Chapter 1451, Statutes of 1989) requires all housing elements to include additional need analyses and programs to address the potential conversion of all Federal, State and locally assisted housing developments that are eligible to convert to market rate use during the next ten -year period. Such units are considered to be "at risk' of being lost as part of the affordable housing stock. Relationship to Other General Plan Elements The preparation of the City's Housing Element must conform to Section 65580 of the California Government Code. The Legislature has established a policy that the availability of housing in a suitable environment is of vital statewide importance, and a priority of the highest order. State policy requires local governments to address the housing needs of all economic segments, while considering the economic, environmental and fiscal factors and community goals set forth in the General Plan. While a city must consider housing needs for all economic segments, it must also maintain internal consistency among the various elements of the General Plan. Neither the Housing Element nor any other element may supersede any other required element of the Tustin General Plan. The Housing Element relates to other elements in a variety of ways. The Land Use Element directly relates to the Housing Element by designating areas of the City in which a variety of residential types and densities may exist. The Housing Element's relationship to the Conservation, Open Space, and Recreation Element is conditioned by the need to serve a growing population's recreational needs, especially in the areas of the City with the highest density. The Circulation Element attempts to provide an efficient and well- balanced circulation system. This system must be designed to accommodate allowed land uses, including residential uses, and the intensity of allowable uses must not exceed the ultimate capacity of the circulation system. The Safety Element relates to the Housing Element by designating areas that are deemed unsafe for development, such as the Alquist -Priolo Zones and floodplains. Similar to the Safety Element, the Noise Element relates to the Housing Element by addressing a health related issue area. Techniques for reducing noise often involve buffers between land uses to reduce noise. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 4 The Growth Management Element overlaps the issues raised in the Housing Element in its efforts to ensure that the planning, management, and implementation of traffic improvements and public facilities are adequate to meet the current and projected needs of Orange County. SOURCES OF INFORMATION A variety of sources were used to prepare this Technical Memorandum. The most recent source of population and housing counts is the State Department of Finance (DOF) population and housing estimates for January 2013. The population, household and employment statistics are taken from the 2010 Census and the American Community Survey. Other estimates of population characteristics are provided by the Center for Demographic Research at California State University, Fullerton. The 2012 Southern California Association of Governments (SCAG) Regional Housing Needs Assessment (RHNA) provided information regarding existing needs and projections regarding future housing needs. Data regarding housing costs have been obtained from local newspapers, local developers, and financial institutions. Other data sources are listed in the Reference section of this document. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 5 SUMMARY OF HOUSING ISSUES, NEEDS, OPPORTUNITIES, AND CONSTRAINTS The following issues, needs, opportunities, and constraints have been identified in Tustin. • Tenure. The City contains disproportionately large amounts of multi- family housing units when compared to nearby jurisdictions and the County overall. • Historic Resources. Tustin features numerous historic homes that add character and charm to the City but may be in need of ongoing maintenance and rehabilitation. • Home Ownership Affordability Gap. Ownership housing costs are increasingly beyond the reach of the City's lower- and moderate - income households. • Housing Condition. Many owner- and renter - occupied units in the City need rehabilitation, including minor and major repairs. Landlords and owners of these units may need financial assistance in order to make necessary repairs. • Units at Risk of Conversion to Market Rate. By State law, the City must document and develop programs to address affordable housing units in the City that are at risk of converting to market rate housing between 2013 -2021. For the 2014 -2021 RHNA planning period, the Regional Housing Needs Assessment indicates that there are 100 assisted units at risk of conversion to market rate housing. • Large Households. Large households comprised approximately 15.4 percent of all Tustin households (owner and renter) in 2011. Large families and households are a population of concern due to both the difficulty of finding adequately sized housing units and the high costs associated with these larger units. • Overcrowding. According to the California Department of Finance, the average number of persons per household in the City was 3.02 in 2013. The American Community Survey 2007 -2011 data indicates that a total of2, 508, or 10 %, of all households were suffering from overcrowding. ° Rental Affordabilihj Gap. Based upon a review of rental units, it is difficult to find apartments in the City with more than two bedrooms, and those that are available are beyond the price range of low- income households. Therefore, large families with low incomes (less than $83,250 for a family of five) would have difficulty finding affordable housing in Tustin. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 6 Housing Problems. 20115 -year American Community Survey data estimates that there were 12,462 overpaying households, of which 36.8 percent had an annual household income of less than $35,000, which was about 48 percent of Tustin area median income. Elderly. As the City's population ages, the number of elderly persons will increase. This underscores an increasing need to address the special housing needs of the elderly. Age of Housing Stock. Even though the City's housing stock is relatively young and in good condition, by year 2020, approximately 62 percent of the City's housing stock will be over 30 years old -the age at which housing typically begins to require major repairs. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 7 HOUSING NEEDS ASSESSMENT Since the 1960s, the City's population has soared from about 2,000 persons to 77,983 in 2013. Thus, the vast majority of the City's housing stock has been constructed within the last 50 years. Unlike most of Orange County, where about half of the housing stock consists of single - family detached homes, nearly two- thirds of Tustin's housing stock is multi- family or single - family attached (i.e., condominiums/ townhouses). Tustin also has a proportionately higher percentage of renters compared to Orange County as a whole. Over the last two decades, the City's population has been impacted by many of the same trends observed regionally: a substantial increase in minority populations, especially Latinos; an increase in the average size of households; and, a surge in housing costs. As the City continues to grow and change, its housing policies must be re- examined in light of these changes. This chapter examines the important demographic changes that have occurred in the City since 2000 that affect housing needs. The chapter includes four main sections: population/ employment trends, household characteristics, housing characteristics, and assisted housing preservation. The Population/ Employment Trends section analyzes how the population has grown and explores resident employment patterns. The Household Characteristics section looks at changes in household size and composition, examines income and overcrowding, and evaluates housing affordability and special housing needs groups. The Housing Stock Characteristics section examines changes in the housing stock, particularly the number of units, condition, and type. The fourth section concerning assisted housing preservation responds to State legislation that requires local jurisdictions to prepare an inventory and implement programs to promote the preservation and /or replacement of government- assisted lower - income housing. POPULATION/EMPLOYMENT TRENDS This section examines population growth, age characteristics, racial /ethnic composition, and employment characteristics of Tustin's population. Population Growth As shown in Table HTM -1, between 2000 and 2010 the City's population grew from 67,504 to 75,540, an increase of approximately 11.9 percent. Between 2010 and 2012, population growth slowed significantly, falling 41.2 percent from the yearly average of 1.2 percent between 2000 and 2010 to .7 percent over the past 2 years. The City of Tustin's growth rate between 2010 and 2012 was slightly slower than the County CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 8 growth rate but faster than the nearby cities of Garden Grove, Orange, and Santa Ana. Recent projections released by the Center for Demographic Research, CSUF (Orange County Projections 2010 Modified, January 26, 2012), indicate that Tustin's population will increase by an annual rate of approximately 0.7 percent during this implementation period, bringing the total population to 83,534 by the year 2025. Table HTM -1 compares the City's growth rate between 2000 and 2012 with other Orange County cities and the County as a whole. A large percentage of Tustin's population growth can be attributed to annexations that have occurred since 1980. The remainder can be attributed to a variety of other factors, including shifts in family structures from smaller to larger families, redevelopment of existing developed areas, infill development, and residential construction in East Tustin. Substantial population and housing growth will continue during this planning period with the continued development at Tustin Legacy (former Marine Corps Air Station [MCAS] Tustin). TABLE H'I'M -1 Population Growth 2000 -2012 Citv of Tustin, Nearbv Turisdictions and Orange Countv Jurisdiction 2000 2010 2012 Percent Growth 2000 -2010 2010 -2012 Tustin 11.9% 1.4% 67,504 75,540 76,567 Anaheim 2.5% 2.2% 328,014 336,265 343,793 Garden 3.4% 1.0% Grove 165,196 170,883 172,648 Irvine 48.4% 5.3% 143,072 212,375 223,729 Orange 128,821 136,416 138,010 5.9% 1.2% Santa 4.0% 1.0% Ana 337,977 324,528 327,731 Orange 5.$% 1.5% County 2,846,289 3,010,232 3,055,792 sources: ' 2000 U.S. Census 2010 U.S. Census Department of Finance estimates 2012 Population projections are shown in Table HTM -lA. According to Orange County Projections (OCP) 2012 data, the population in the City of Tustin is expected to CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 9 increase by approximately 6.3 percent from 77,965 persons in 2015 to 82,878 persons by the year 2035, after a peak population of 83,944 in 2030. The decrease in the last five years of the projections is attributed to general countywide demographic characteristics, such as the age structure of the population, declining fertility rates, low housing growth, and declining immigration. TABLE HTM -IA Population Projections 2015 -2035 Source: OCP 2010 Modified, January 26, 2012 Age Characteristics Table HTM -2 shows the proportions of the City's population represented by age groups in 2000 and 2011. The table shows that the proportions of the population in each age group have begun to transition over time. Like the rest of Orange County, Tustin has begun to experience an aging of the population. The 25 -34 age group has fallen almost 5 percentage points, while the 55+ age group have increased by a total of 3.8 percentage points. With the significant loss of residents in the 25 -34 age group Tustin has seen a 1.4 percentage point fall in the 0-4 age group. TABLE HTM- 2 AGE TRENDS 2000 - 2011 CITY OF TUSTIN Age Group 2015 2020 2025 2030 2035 Percent Change 2015 -2035 Tustin 77,965 81,310 83,534 83,944 82,878 6.30% Source: OCP 2010 Modified, January 26, 2012 Age Characteristics Table HTM -2 shows the proportions of the City's population represented by age groups in 2000 and 2011. The table shows that the proportions of the population in each age group have begun to transition over time. Like the rest of Orange County, Tustin has begun to experience an aging of the population. The 25 -34 age group has fallen almost 5 percentage points, while the 55+ age group have increased by a total of 3.8 percentage points. With the significant loss of residents in the 25 -34 age group Tustin has seen a 1.4 percentage point fall in the 0-4 age group. TABLE HTM- 2 AGE TRENDS 2000 - 2011 CITY OF TUSTIN Age Group 2000 % Total 2011 % Total 0-4 5,815 8.6°A 5,401 7.2% 5-14 9,916 14.7% 10,940 14.6% 15 -24 8,685 12.8% 10,792 14.4% 25 -34 13,798 20.4% 11,785 153% 35 -54 19,710 29.2% 22,343 29.9% 55-64 4,776 7.1% 6,873 9.3% 65-74 2,745 4.1% 3,806 5.1% 75+ 2,059 3.1 % 2,715 3.7% Total 1 67,504 1 100.0% 74,625 100.0% Sources: U.S Bureau of Census, 2000,2007-2011 American Community Survey. Race and Ethnicity The City's racial and ethnic composition has changed significantly since 1980. The trends experienced in the 1990's have continued through the early 2000's, though at a less rapid rate. As shown in Table HTM -3, minority populations in the City have CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 10 grown significantly. The Hispanic population increased about 30 percent between 2000 and 2010, becoming the dominant population in the City accounting for almost 40 percent of the total population. Asian/Pacific Islanders and Blacks comprised about 20.4 percent and 2.0 percent of the population in 2010, respectively. These shifts in racial and ethnic composition may have important implications in terns of household characteristics and income. For example, Hispanic households are typically larger than other households; therefore, an increase in the number of Hispanic households may indicate a need for larger housing units. Also, to the extent that minority populations tend to have lower incomes than their Caucasian counterparts, there may be a greater need for affordable housing for these groups. TABLE HIM- 3 RACE AND ETHNICITY: 1990, 2000, 2010 CITY OF TUSTIN Race and Ethnicity 1990 2000 2010 Population Total Po ulation Total Po ulation Total White 37,127 73.2% 30,264 44.8% 26,317 34.8% Black 21895 5.7% 1,785 2.6% 1,535 2% American Indian and Alaska Native 274 0.5% 199 .3% 142 .2% Asian Pacific Islander 5,260 10.4% 10,194 15.1% 15,391 20.4% Other 5,133 10.1°% 1,952 2.9°% 2,131 2.8% Hispanic (10,508) (20.7 %) 23,110 342°% 30,0241 39.7% Total 50,689 1 100% 1 67,504 100% 1 75,540 100% 1 1990 Census 3 2000 Census 9 2010 Census + The Census contains a separate question related to whether the householder was of Spanish /Hispanic "origin". Origin is defined as the ancestry, nationality group, lineage, or country in which the persons ancestors were bom prior to their arrival to the United States. Persons of Spanish origin could be of any of the five racial categories. Employment According to 2007 -2011 American Community Survey data, the City of Tustin had 41,761 residents in the labor force, of which 38,308 (91.7 percent) were in the labor market. Of these, 83.7 percent were private wages and salary workers. Table HTM -4 shows the number of employees by occupation. In 2011, the largest occupational category was management, business, science and arts occupations, in which a total of 15,698 were employed. The second largest category was the sales and office occupations, employing 10,214. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 11 TABLE HTM- 4 EMPLOYMENT BY OCCUPATION 2011 CITY OF TUSTIN Occupational Category Number % Management, business, science, and arts occupations 15,698 41.0% Service occupations 6,429 16.8% Sales and office occupations 10,214 26.7% Natural resources, construction, and maintenance occupations 2,189 5.7% Production, transportation, and material moving occupations 3,778 9.9% Total 34,906 100.0% Source: U.a. census: ewi -[vt t American �-omtnumty Survey In terms of industry, the Educational services, and health care and social assistance, and Professional, scientific, and management, and administrative and waste management services sectors employed the largest number of persons with 6,947 (18.1 percent) and 5,606 (14.6 percent) employees, respectively. Table HTM -5 is a summary of the number of employees by industry. Due to its favorable location, demographics, and business environment, Tustin is home to several large employers. Appendix C lists major employers in the City of Tustin. The City's top ten employers include: Young's Market Co. LLC, Tustin Unified School District, Lamppost Pizza Corp., Ricoh Electronics Inc., Toshiba America Medical Systems, Rockwell Collins Inc., Costco, Cherokee International Inc., City of Tustin, and Raj Manufacturing Inc. TABLE HTM- 5 EMPLOYMENT BY INDUSTRY 2011 CITY OF TUSTIN Industry Number % Agriculture, foresLxy, fishing and huntinZ and mining 224 0.60°/ Construction 1,999 5.20% Manufacturing 4,907 12.80% Wholesale trade 1,116 2.90% Retail trade 4,842 12.60% Transportation and warehousing, and utilities 1,174 3.10% Information 777 2.00% Finance and insurance, and real estate and rental and leasing 3,985 10.40% Professional, scientific, and management, and administrative and waste management services 5,606 14.60% Educational services, and health care and social assistance 6,947 18.10% Arts, entertainment, and recreation, and accommodation and food services 3,842 10.00% Other services, except public administration 1,777 4.60% Public administration 1,112 2.9% TOTAL 38,308 1 100.0% Source: U.S. census: mul -mii American community Survey CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 12 HOUSEHOLD CHARACTERISTICS This section addresses household composition, size, overcrowding, income, affordability, and special needs groups. Definitions The Census Bureau uses several terms with respect to housing which are important to understand. A housing unit is defined as a house, apartment, mobile home or trailer, group of rooms, or single room occupied or intended for occupancy as separate living quarters. A household is an occupied housing unit. Households are further broken down into family households and non - family households. A family household is a household shared by two or more persons related by birth, marriage or adoption. A non - family household is one consisting of a single individual or unrelated persons living together. Household Composition According to the U.S. Census, the City of Tustin contained 25,203 households in 2010. From 2000 to 2011, census data shows that the number of households increased by 2,114, representing an increase of approximately 8.8 %. TABLE HTM- 6 HOUSEHOLD TYPE: 1990 — 2011 CITY OF TUSTIN Household Type 1990 2000 2011 No. of Households 0% of Total No. of Households °/ of Total No. of Households % of Total Family 12,317 67.2% 16,055 67.4% 17,529 67.6% Non-Family 6,015 32.8% 7,776 32.6% 8,416 32.4% Total 18,332 100% 23,831 100% 25,945 100% U.S. Dept. of Commerce, Bureau of the Census, 1990 Census. 2 U.S. Dept. of Commerce, Bureau of the Census, 2000 Census 3 U.S. Census, 2007 -2011 American Community Survey Table HTM -6 shows that 12,317, or about 67 %, of the City's households were classified as family households in 1990. The percentage of family households remained relatively the same in 2000 and 2011. Moreover, as shown in Table HTM -7, the average household size in Tustin has increased from 2.66 persons per household in 1990 to an estimated 2.82 persons per household in 2000 and 2.97 persons per household in 2011. This increase may be attributed CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 13 to a variety of factors, including: more doubling -up, or sharing, of units in order to defray increased housing costs; and, an increase in the supply of larger units, especially new units in East Tustin and Tustin Legacy. TABLE HTM- 7 HOUSEHOLD SIZE 1990 THROUGH 2011 CITY OF TUSTIN Jurisdiction 1990 2000 2011 Tustin 2.66 2.82 2.97 Orange County 2.87 3.00 2.99 ' U.S. Dept. of Commerce, Bureau of the Census, 1990 Census Report. 2 U.S. Dept. of Commerce, Bureau of the Census, 2000 Census Report. 3 U.S. Census, 2007 -2011 American Community Survey Overcrowding HUD defines overcrowding as more than one person per room, excluding bathrooms and kitchens. For example, a one - bedroom apartment with living room, kitchen, and bathroom would be considered overcrowded if more than two persons occupied it. The 2007 -2011 American Community Survey data showed 2,508 (10 percent) households living in overcrowded conditions. Of the households living in such conditions, 78 percent were renters. Overall renter households had a significantly higher incidence of overcrowding than owner households: 16.5 percent of renter and 4.2 percent of owner households were overcrowded. Table HTM -8 illustrates the numbers of all Tustin households living in overcrowded conditions. It should be noted that there are no federal or California State legal standards for overcrowding. In a reasonable effort to allocate scarce financial resources for affordable housing, housing programs typically use occupancy standards, which allow for up to "two persons per bedroom plus one" (e.g., five persons in a two - bedroom unit). The California Health and Safety Code standard is one person per bedroom plus one (e.g., three persons in a two- bedroom unit). Overcrowding is often reflective of one of three conditions: 1) either a family or household is living in a dwelling that is too small; 2) a family chooses to house extended family members (i.e., grandparents or grown children and their families living with parents, termed doubling); or 3) a family is renting living space to non- family members. TABLE HTM- 8 HOUSEHOLDS IN OVERCROWDED CONDITIONS 2011 CITY OF TUSTIN CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 14 Owner 553 13,112 Renter 1,955 11,833 Total 2,508 24,945 Source: U.S. Census: 2007 -2011 American Community Survey Income Household income is an important determinant of housing affordability. While upper income households have more discretionary income to spend on housing, low and moderate income households are more limited in the range of housing they can afford. The presence of a large number of low and moderate income households in a region where housing costs are high is likely to result in many households paying more than they can afford for housing. According to 2011 American Community Survey data, the median household income for the City of Tustin was $73,231. Table HTM -9 compares median household and family incomes between the City of Tustin and nearby jurisdictions, counties, and the State of California. In 2011, the City's median household income was about 3% lower than the median household income for the County as a whole ($75,762). Table HTM -9 demonstrates that at $80,963, Tustin's 2011 median family income was also below the Orange County median ($85,009). This trend was consistent as well for median family income in the above - mentioned jurisdictions. TABLE HTM- 9 MEDIAN HOUSEHOLD INCOME: TUSTIN AND SURROUNDING AREAS 2011 jurisdiction Median Household Income Percent Above/Below County Median Median Family Income Percent Above/Below County Median Tustin $73,231 -3.3% $80, %3 4.8% Anaheim $59,330 -21.70/. $63,180 -25.7% Garden Grove $60,036 -20.8% $62,820 -26.1% Irvine $92,599 222% $109,762 29.1% Santa Ana $54,399 - 28.2% $53,111 375 ° /a Orange County $75,762 1 $85,009 State of California $61,632 -18.7% 1 $70,231 -17.4% Source: U.S. Bureau of Census, 2007 -2011 American Community Survev As shown in Table HTM 10, an estimated 6.8 percent of TusthYs households had incomes of less than $15,000 in the year 2011. Another 7.2 percent had incomes of between $15,000 and $34,999. hi addition, 29.6 percent had incomes between $35,000 and $74,999, and 48.9 percent had incomes of $75,000 or more. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 15 HOUSEHOLD INCOME DISTRIBUTION CITY OF TUSTIN Less than $14,999 1,696 6.8% 6.8% $15,000 to $24,999 1,796 7.2% 14.0% $25,000 to $34,999 1,921 7.7% 21.7% $35,000 to $49,999 3,068 12.3% 34.0°% $50,000 to $74,999 4,315 17.3% 51.3°% $75,000 to $99,999 3,617 14.5% 78.7% More than $100,000 8,581 34.4% 100.2°% TOTAL 24,945 100.0°% Median Household Income, $73,231 City of Tustin Median Household Income, $75,762 Orange Countv i Derived by applying the percentage of households by income level from 51901 to total number of households shown as 24,945. x Due to rounding in census data percentages, the total of percent households equals 100.2 percent. SOURCE: U.S. Census: 2007 -2011 American Community Survey Owner households had higher incomes than did renter households in 2011, as shown in HTM -11. Approximately 31.4 percent of the renter households earned less than $35,000 annually, compared to only 12.9 percent of owner households. Furthermore, 48.6 percent of renters earned less than $50,000 in 2011, compared to only 20.7 percent of owners. While a higher proportion of renter households (19.4 percent) than owner households (15.4 percent) earned between $50,000 and $74,999, only 32 percent of renter households had incomes of more than $75,000 annually, compared to 64.0 percent of owner households. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 16 OWNER HOUSEHOLDS TABLE HTM -11 HOUSEHOLD INCOME DISTRIBUTION BY HOUSEHOLD TENURE 25% $10,000 to $19,999 CITY OF TUSTIN 3.7% 6.20% $20,000 to $34,999 2011 6.7% 12.90% Tenure/Income Range Number' Percent Cumulative '% RENTER HOUSEHOLDS 2,017 15A% 36.10% Less Than $10,000 651 5.5% 5.5% $10,000 to $19,999 1,027 8.7% 14.20% $20,000 to $34,999 2,036 17.2% 31.40% $35,000 to $49,999 2,040 17.2% 48.60% $50,000 to $74,999 2,294 19.4% 68.00% $75,000 to $99,999 1,554 13.1% 81.10% $100,000 or More 2,234 18.9% 100.0% Total Renters 11,833 100.0% OWNER HOUSEHOLDS Less Than $10,000 326 2.5% 25% $10,000 to $19,999 485 3.7% 6.20% $20,000 to $34,999 876 6.7% 12.90% $35,000 to $49,999 1,017 7.8% 20.70% $50,000 to $74,999 2,017 15A% 36.10% $75,000 to $99,999 2,059 15.7% 51.80% $100,000 to $149,999 2,554 19.5% 71.30% $150,000 or More 3,778 28.8% 100.0% Total Owners 13,112 100.00/0 1 Derived by applying the percentage of household tenure by household income from to 2011 ACS 5 year file B25118 total number of renter households shown as 11,883 and owner households as 13,112 Sources: U.S. Census: 2007 -2011 American Community Survey Housing Affordability The U. S. Department of Housing and Urban Development (HUD) defines the threshold of overpayment for housing as 30% or more of household income. That is, when households pay more than 30% of their income for housing, they have insufficient remaining funds for other necessities such as food, clothing, utilities and health care. HUD recognizes, however, that upper income households are generally CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 17 capable of paying a larger proportion of their income for housing, and therefore estimates of housing overpayment generally focus on lower income groups'. Table HTM -12 reflects 2011 5 -year American Community Survey data, which estimates that there were 12,462 overpaying households, of which 36.8 percent had an annual household income of less than $35,000, about 48 percent of Tustin area median income. While these extremely low income households are currently housed, they are in a precarious position, particularly those overpaying for housing in light of the current housing market, and could face the threat of homelessness. Table HTM -12 also distinguishes between owner and renter households overpaying for housing. This distinction is important because while homeowners may over- extend themselves financially to afford the option of home purchase, the owner maintains the option to sell at market rate; on the other hand, renters are limited to the rental market and are generally required to pay the rent established in that market. The table shows that among households making less than $50,000, or 68.3 percent of median household income in the City overpaying for housing, 5,170 or 73.4 percent were renters. TABLE HTM -12 HOUSEHOLDS OVERPAYING FOR SHELTER 2011 CITY OF TUSTIN Tenure Less than $35,000 $35,000 to $49,999 $50,000 to $74,999 $75,000 or more Total Over- a Total All Households Over- pay Total Over- pay Total Over- pay Total Ove a Total Owner 1,217 1,612 648 1,017 1,230 2,017 2,750 8,391 5,845 13,112 Renter 3,368 3,445 1,802 2,028 986 2,272 461 3,743 6,617 11,833 Total 4,585 5,057 2,450 3,045 2,216 4,289 3,211 12,134 12,462 24,945 Source: U.S. census: 2007 -2011 American Community Survey. Special Needs State Housing Law requires that the special needs of certain disadvantaged groups be addressed. The needs of the elderly, persons with disabilities (including developmental disabilities), large families, female heads of household with children, homeless persons, and farm workers are important in relation to overall community Some agencies and organizations consider Moderate Income households to be overpaying when housing costs exceed 35 percent of gross income, with the maximum income representing 110% of the median county income. Under these assumptions, overpayment occurs in fewer households in the City of Tustin when compared to figures presented in this document that are based upon State and Federal standards. Source: Strategies for Planning and Development: California Affordable Housing Handbook, California Redevelopment Association, 2000. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 18 health. These groups may maintain special needs related to housing construction and location. The Elderly: As noted previously (Table HTM -2), in 2011, 6,521 persons or 8.8% of the total population in Tustin were 65 years of age or older. In addition, senior households represented 15.7percent (3,910) of total households in Tustin. According to the American Community Survey, approximately 14 percent of elderly households in Tustin earned less than $25,000 annually or about 37 percent of AMI for a household of two persons in 2011. Although the senior population may often be living in a single - family home too large for their needs, with little or no mortgage payment, selling the home and buying a smaller unit may be too expensive. Thus, this population needs housing that is both affordable and located in close proximity to public services and transportation. The Disabled: Physical and developmental disabilities can hinder access to housing units of traditional design as well as limit an individual's ability to earn an adequate income. According to the 2009 -2011 ACS, a total of 2,192 persons in Tustin between 18 and 65 years of age reported a disability. In addition, 1,745 persons over age 65 reported a disability in 2011. Disabled persons often require specially designed dwelling units to permit access not only within the dwelling unit, but also to and from the unit. Special modifications to permit free access are very important in maintaining independence and dignity. California Administrative Code Title 24 Requirements set forth access and adaptability requirements for the physically disabled. These regulations apply to public buildings such as motels, and require that ramp ways, door widths, restroom modifications, etc., be designed to enable free access to the handicapped. While such standards do not apply to new single - family residential construction, they do apply to new multi- family residential construction. Most existing housing units in Tustin have not been designed with consideration for these requirements of adaptability and access. The majority of housing units are either single - family or two -story apartments with no elevator access. The adaptability of units to meet the needs of disabled persons remains a challenge for Tustin and other communities. However, as additional housing units are provided in the Tustin Legacy area, accessibility is considered as part of a project's design as required by law. Additionally, as units in multiple - family areas are rehabilitated, units may be retrofitted to accommodate the handicapped. New construction may offer some relief because the mandatory requirements are evenly applied to all projects. The use of mixed development types and higher density limits at Tustin Legacy area will further require development of even more handicapped - accessible units. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 19 Persons With Developmental Disabilities: As defined by federal law, "developmental disability" means a severe, chronic disability of an individual that: • Is attributable to a mental or physical impairment or combination of mental and physical impairments; • Is manifested before the individual attains age 22; • Is likely to continue indefinitely; • Results in substantial functional limitations in three or more of the following areas of major life activity: a) self -care; b) receptive and expressive language; c) learning, d) mobility; e) self - direction, f) capacity for independent living; or g) economic self - sufficiency; • Reflects the individual's need for a combination and sequence of special, interdisciplinary, or generic services, individualized supports, or other forms of assistance that are of lifelong or extended duration and are individually planned and coordinated. The U.S. Census Bureau does not record developmental disabilities. According to the U.S. Administration on Developmental Disabilities, an accepted estimate of the percentage of the population that can be defined as developmentally disabled is 1.5 percent. Many developmentally disabled persons can live and work independently within a conventional housing environment. More severely disabled individuals require a group living environment where supervision is provided. The most severely affected individuals may require an institutional environment where medical attention and physical therapy are provided. Because developmental disabilities exist before adulthood, the first issue in supportive housing for the developmentally disabled is the transition from the persons living situation as a child to an appropriate level of independence as an adult. The State Department of Developmental Services (DDS) currently provides community-based services to approximately 243,000 persons with developmental disabilities and their families through a statewide system of 21 regional centers, four developmental centers, and two community-based facilities. The Regional Center of Orange County (RCOC) is one of 21 regional centers in California that provides point of entry to services for people with developmental disabilities. The RCOC is a private, non - profit community agency that contracts with local businesses to offer a wide range of services to individuals with developmental disabilities and their families. Any resident of Orange County who has a developmental disability that originated before age 18 is eligible for services. Services are offered to people with developmental disabilities based on Individual Program Plans and may include: CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 20 Adult day programs; advocacy; assessment /consultation; behavior management programs; diagnosis and evaluation; independent living services; infant development programs; information and referrals; mobility training, prenatal diagnosis; residential care; respite care; physical and occupational therapy; transportation; consumer, family vendor training, and vocational training. RCOC also coordinates the state - mandated Early Start program, which provides services for children under age three who have or are at substantial risk of having a developmental disability. According to the RCOC February 2010 Facts and Statistics data, the RCOC currently serves approximately 16,728 individuals. Large Families: Under Census Bureau guidelines, a family household containing five or more persons is considered a large family. Large family households generally require larger dwelling units with more bedrooms to meet their housing needs. But family households with five or more persons often face limitations in being below national poverty levels, and often experience difficulty securing adequate housing suitable for their expanded needs. Thus, large families typically suffer disproportionately from both overcrowding and inability to pay. Moreover, because multifamily rental units are typically smaller than single - family units, larger families who are also renters face more difficulties in securing housing large enough to accommodate all members of the household. Table HTM -13 is a summary of Tustin's household size. The 2011 data shows 15.4% of Tustin households had five or more persons residing in a unit. TABLE HTM -13 HOUSEHOLD SIZE DISTRIBUTION CITY OF TUSTIN 2011 Household Size Number of Households % of Total Households 1 Person 5,792 23.2% 2 Persons 6,787 27.2% 3 Persons 4,461 17.9% 4 Persons 4,053 16.2% 5Persons 2,019 8.1% 6 Persons 1'128 4.5% 7 or more Persons 705 2.8% Total Households 24,945 100.0% Source: U.S. Census Bureau, 2007 -2011 ACS. Table HTM -14 shows the number of households with five or more persons in Tustin according to the 2007 -2011 ACS. There were 1,835 owner households with five or more persons, representing 14 percent of all owner households. Tustin also had 2,017 renter households with five or more persons, representing 17 percent of all CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 21 renter households. Overall, large households comprised approximately 15.4 percent of all Tustin households in 2011. TABLE HTM -14 Households with Five or More Persons City of Tustin 2011 Number of % of Total Renter or Owner Households Households Owners 1,835 14% of Owner Households Renters 2,017 17% of Renter Households Total Households 3,852 15.4% of Total Households Source: U.S. Census Bureau, 2007 -2011 ACS. The primary need of large families is to provide enough rooms for each member of the family to avoid overcrowding. According to the American Community Survey, in 2011, 21% of the City's housing units contained four or more bedrooms. Of owner- occupied housing units, 37% contained four or more bedrooms. Renter - occupied units accounted for 8% of units with four or more bedrooms. Taking into account that much of Tustin's housing stock consists of apartments, and that the majority of Tustin's large families are renters, this there is a need for more spacious apartment units to accommodate such families. Female - Headed Parent Households: Single- parent families tend to have low incomes, limiting their ability to find affordable housing. These families also have a large need for affordable child care. For these households, ideal housing is severely restricted. Due to financial constraints, the family is often not able to find housing that is close to needed services, schools, and public transportation. As of the 2010 U.S. Census there were 2,120 female- headed households with children under 18 living at home. These households represented 20.5 percent of all families with children under 18 in Tustin in 2010. The Homeless: Measuring the extent of the homeless population specifically in Tustin remains a challenge for community leaders. To complicate the challenge of meeting homeless persons' needs, the issue of homelessness is considered regional in nature. Nomadic tendencies of homeless persons make it difficult to assess the population accurately on a citywide basis; therefore, homelessness should be addressed on a countywide basis, in conjunction with cities and local non - profit organizations. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 22 The Orange County Housing and Community Services Department (HCS) defines homelessness as not having a permanent address, sleeping in places not meant for habitation, not having ample food and medical attention or a place to change clothes or bathe. Per this definition, HCS 2011 OC Homeless Census & Survey estimates there are nearly 18,325 homeless in the County on an annual basis. The County's homeless population is comprised of about 75 percent individuals and 25 percent families, including an estimated 2,932 homeless children. For those 18,325 homeless, there are only about 3,357 available beds, including 1,156 emergency shelter beds and 2,201 beds in transitional housing facilities, according to the Orange County Ten -Year Plan to End Homelessness 2012. The homeless population is comprised of subgroups, which include: 1. The economic homeless who lack financial resources to pay rent; 2. The situational homeless who have suffered economic or personal trauma and find themselves in personal disorganization; and, 3. The chronic homeless who are unable to care for themselves due to chronic illness, disability or debilitating substance abuse. The City of Tustin's 2010 -2015 Consolidated Plan states that, according to police reports and windshield surveys performed within the City of Tustin, most homeless persons migrate through Tustin to other parts of the County rather than stay for extended periods of time within the City. The City's Police Department estimates that there are 10 -12 homeless persons residing in the City at any given time. Although there are no established areas where unsheltered homeless persons congregate in the City, there are several homeless services facilities in the City. The Village of Hope was completed on five acres at the Tustin Legacy site. The Village of Hope provides housing for a total of 192 homeless men, women and children. It includes dorm rooms, a child development center, playground, parent education center, vocational training classrooms, health care facility, donation warehouse, and support offices. There also is a cafeteria with an outdoor dining area, and vegetable gardens. There are numerous factors that contribute to homelessness in Tustin and Orange County. The known causes of homelessness include unemployment, limited skills, and a breakdown in the family as a social and economic unit. Additionally, cutbacks in social service programs and the de- institutionalization of the mentally ill during the 1980s have contributed to the homeless population. A new trend, however, is emerging as a significant contributing element to homelessness: a fast - growing lack of affordable housing, which could exacerbate any of the above conditions, but may increasingly become a standalone cause of homelessness. One of the shelters in Tustin, the 45 -bed Sheepfold shelter provides shelter, food, clothing, job training, and job - referral services primarily to battered women and CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 23 children. Guests are admitted on a first -come, first - served basis. Usually all beds are fully occupied. The shelter services a large area including many portions of Orange, Riverside, and San Bernardino Counties. Within the City of Tustin, there are a variety of Non -Profit Organizations (NPOs) that provide direct housing and related services to homeless persons. These include Village of Hope, an emergency/ transitional home; Sheepfold, a feeding program affiliated with the United Way; Families Forward, a homeless provider; Olive Crest, transitional homes and services for abused and neglected children, a and Laurel House, an emergency shelter and transitional housing provider for homeless youth in the City. A significant portion of the MCAS- Tustin is located within the City. The MCAS Tustin facility was identified by the U.S. Department of Defense for closure in July 1999. In accordance with the Base Closure Redevelopment and Homeless Assistance Act of 1994 (Redevelopment Act), the City of Tustin was formally recognized as the Local Redevelopment Authority (LRA) for the MCAS Tustin. The Redevelopment Act provides a process that aims to balance the needs of the homeless with other development interests in the communities directly affected by closure of the installation. The Act requires the LRA to prepare a reuse plan and Homeless Assistance Plan (HAP), which is submitted to the federal Department of Housing and Urban Development (HUD). HUD reviews and determines whether the documents balance the needs of the homeless in communities in the vicinity of the installation with the need for economic development. A Homeless Assistance Plan has been established for MCAS, Tustin that is consistent with the continuum of care model embodied in the Consolidated Plans for the Cities of Tustin and neighboring Irvine. The fundamental components of the continuum of care system implemented with the MCAS, Tustin Reuse Plan: • Provide emergency shelter beds and intake assessment • Offer transitional housing and services • Provide opportunities for permanent affordable housing by the private sector. In Tustin Legacy, four homeless service providers including the Salvation Army, Orange Coast Interfaith Shelter, Families Forward, and Human Options currently are operating 48 family units. The Orange County Rescue Mission operates a 192 - unit transitional/ emergency shelter (Village of Hope) and the Orange County Social Services Agency operates a 90 bed - facility for abused and neglected children and their families. Numerous other agencies provide shelter and other services to the homeless in the nearby cities of Santa Ana, Irvine, and Orange. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 24 Table H'I'M -15 provides a summary of zoning regulations pertaining to emergency shelters, transitional, and supportive housing, which are designated as permitted uses within the City of Tustin. TABLE HTM -15 SUMMARY OF HOMELESS ACCOMMODATION ZONING REGULATIONS Housing Type Permitted/ Zoning Conditionally Permitted Transitional Home Permitted Planning Area 3 of WAS Tustin Specific Plan Emergency Shelters Permitted Planning Area 3 of WAS Tustin Specific Plan Supportive housing Permitted Planning Areas f and 3 of WAS Tustin Specific Plan Community Care Facility for six (6) or Permitted All residentially zoned fewer oronerties Family care home, foster home, or group home for six (6) or fewer' Permitted All residentially zoned properties I Includes congregate care facility, single room occupancy hotel, and children's intermediate care shelter Source: City of Tustin, WAS Tustin Specific Plan CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 25 Table HTM -16 is a list of organizations in Tustin that provide homeless services. TABLE HTM -16 EMERGENCY SHELTER/TRANSITIONAL HOUSING FACILITIES 2013 CITY OF TUSTIN Facility Services Provided Sheepfold Provides shelter, food, clothing, job training, and job - referral services to women with children. Laurel House Temporary housing for teenagers in crisis. The facility also provides food, informal counseling, and access to medical care and clothing. St. Cecilia's Distributes food supply to needy populations. Red Hill Lutheran Operates emergency food program where a person can receive food supply. Tustin Presbyterian Collects food supplies and distributes the food to various organizations involved in providing homeless services. Alders ate Refers interested persons to Ecumenical Services Alliance in Santa Ana. Village of Hope Operates a food service program and 192 units transitional home at the Village of Hope operated by the Orange County Rescue Mission 90 beds intermediate care shelter for abused children and their parents Tustin Family Campus operated by the Orange County Social Services Agency. Salvation Army Six (6) transitional units at Tustin Field I operated by Salvation Army Acquisition of 16 transitional units in Buena Park operated by Salvation Salvation Army Army. The City assisted in acquisition and contributed grant funds to acquire the units Families Forward' Fourteen (14) transitional units at Columbus Grove operated by Families Forward, formerly Irvine Temporary Housing in Irvine. Human Options Six (6) transitional units at Columbus Grove operated by Human Options Orange Coast Interfaith Six (6) transitional units at Columbus Grove operated by Orange Coast Shelter Interfaith Shelter. Tustin Family and Youth Distributes food supplies to needy populations. Center Although these units we located in the City of Irvine, these units were negotiated as part of the base realignment /conveyance process which Tustin is the Local Redevelopment Agency. Source: City of Tustin, 2013 CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 26 HOUSING STOCK CHARACTERISTICS A housing unit is a dwelling intended for occupancy as separate living quarters. Single - family houses, apartments, condominiums, mobile homes, and single room occupancy (SRO) hotels are all types of housing units. This section examines housing unit growth, age, type, tenure (owner v. renter), and costs in Tustin. Housing Growth While Tustin has experienced significant growth in population and housing units since 1990, the growth rate between 2000 and 2010 was significantly less than during the previous decade. This change is attributed to the closure of MCAS Tustin and the demolition of military housing units. The loss of these units was offset by new construction in the early 2000's and the beginning of the redevelopment of MCAS Tustin for civilian uses, which includes the eventual construction of over 4,000 new housing units. Table HTM -17 compares the growth in housing units in Tustin to nearby cities and the County as a whole. It should be noted that much of the City's previous housing unit growth is attributable to annexations that occurred during the 1980s and 1990s. TABLE HTM -17 HOUSING GROWTH TRENDS 1990 - 2010 TUSTIN AND SURROUNDING AREAS jurisdiction Number of Housin Units Percent Change 1990 2000 20102 1990-00 2000.10 Tustin 19,300 25,501 26,476 32% 3.8% Anaheim 93,177 99,719 104,237 7% 4.5% Garden Grove 45,957 46,703 47,755 1.6% 2.3% Irvine 42,221 53,711 83,899 27% 56.2% Santa Ana 75,000 74,588 76,896 -0.5% 3.1% Orange Coun 1 875,072 969,484 1,048,907 1 1% 8.2% ' U.S. Department of Commerce, bureau of the Census, 1990 Census Keport. 22000 Census Report, 7010 Census Report. Housing Unit Type Table HTM -18 demonstrates the mix of housing types in Tustin. The distribution of housing units by type has changed over this period, with single - family homes steadily increasing and multifamily housing steadily decreasing as a proportion of Tustin's housing units. In 2013, Tustin's housing stock is comprised of equal proportions of single - family homes and multifamily housing, each making up 48.3 percent. Mobile homes make up the remaining 3.4 percent. The 2013 composition of housing units in the City includes approximately 35 percent single- family detached, CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 27 13 percent single- family attached, 15 percent multi- family (2 -4 units), 33percent multi- family (5+ units), and 3 percent mobile homes. Compared to Orange County as a whole, Tustin has a significantly higher proportion of multi- family housing. According to 2013 Department of Finance Estimates, the County contained approximately 62.9 percent single- family detached/ attached units and 33.9 percent multi- family units, whereas Tustin contained 48.3percent multi- family units. TABLE HTM -18 TUSTIN RESIDENTIAL UNIT MIX 1990 - 2013 CITY OF TUSTIN * Totals do not equal 100% due to rounding error. Source: California Department of Finance; Comprehensive Affordable Housing Strategy 2008 -2018. The overall rental vacancy rate for Tustin in 2011 was 5.6 percent, up considerably from 4.3 percent in the first quarter of 2007. Generally, a vacancy rate of 5 percent is considered to reflect a "tight" housing market. As shown in Table HTM -19, Department of Finance data for Tustin as of January 2013 show a vacancy rate of 4.8 percent for all housing types in Tustin (single- and multi- family, owner and rental). TABLE HTM -19 VACANCY BATES 2000 -2013 Source: California Department of Finance Comprehensive Affordable Housing Strategy 2008 -2018. Housing Tenure The tenure (owner versus renter) distribution of a community's housing stock influences several aspects of the local housing market. Residential mobility is influenced by tenure, with ownership housing typically sustaining a much lower turnover rate than rental housing. Housing overpayment, while experienced by many households regardless of tenure, is far more prevalent among renters. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 28 Number of Housing Units Percent Change Housing a 1990 % 2000 % 2013 1 % 2000 -2013 Single-Family Detached 5,351 27.7% 8,075 30.6% 9.454 35.1°/ 17.1% Single-Family Attached 2,530 111% 3,459 10.8% 3,564 13.2% 3.0% Multi-Family 2-4 units 3,089 16.0% 3,836 12.8% 4,048 15.0% 5.5% Multi-FamO (5+ units) 7,678 39.5% 9,223 43.0% 8,983 33.3% -2.6% Mobile Homes 707 3.60/6 908 2.9% 909 3.4°% 0% Total 19,300 99.9 %* 25,501 100.1 %* 100% N/A * Totals do not equal 100% due to rounding error. Source: California Department of Finance; Comprehensive Affordable Housing Strategy 2008 -2018. The overall rental vacancy rate for Tustin in 2011 was 5.6 percent, up considerably from 4.3 percent in the first quarter of 2007. Generally, a vacancy rate of 5 percent is considered to reflect a "tight" housing market. As shown in Table HTM -19, Department of Finance data for Tustin as of January 2013 show a vacancy rate of 4.8 percent for all housing types in Tustin (single- and multi- family, owner and rental). TABLE HTM -19 VACANCY BATES 2000 -2013 Source: California Department of Finance Comprehensive Affordable Housing Strategy 2008 -2018. Housing Tenure The tenure (owner versus renter) distribution of a community's housing stock influences several aspects of the local housing market. Residential mobility is influenced by tenure, with ownership housing typically sustaining a much lower turnover rate than rental housing. Housing overpayment, while experienced by many households regardless of tenure, is far more prevalent among renters. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 28 Ownership and rental preferences are primarily related to household income, composition, and age of the householder. In 2011, 52.5% of the City's 24,945 occupied housing units were owner - occupied, with the remainder renter - occupied. Compared to the County as a whole, which had 60.3% owner - occupied units and 39.7% renter - occupied units, the City of Tustin had a relatively high proportion of renter - occupied units. This is significant because renters tend to have lower incomes than owners, and are more susceptible to housing cost increases. The tenure figures show a shift in the City of approximately 9% to more owner - occupied units from 1990 to 2000. Table HTM -20 is a summary of tenure in the City and the County. TABLE HTM- 20 TENURE 1990 AND 2011 CITY OF TUSTIN 2000 2011 Housing Tenure Number I Percent I Number Percent Owner-Occupied 11,829 49.6% 13,112 52.5% Renter - Occupied 12,002 50.4% 11,833 47.5% Total Occupied Units 23,831 100.0% 24,945 100.0% Countv of Orange Owner- Occupied 574,456 61.4% 595,444 60.3% Renter-Occupied 350,831 38.6 °� 391,720 39.7% Total Occupied Units 935,287 100.0% 987,164 100.0% Source: U.S. Census Bureau: 2007 -2011 American Community Survey. Age and Condition of Housing Stock Housing age is a factor for determining the need for rehabilitation. Without proper maintenance, housing units deteriorate over time. Also, older houses may not be built to current housing standards for fire and earthquake safety. Table HTM -21 shows the distribution of housing units by year built in Tustin through 2011. Reflecting the conversion of land from agricultural to residential use and the construction of housing on the MCAS Tustin base during the 1960s and 1970s, 27.4 percent of Tustin's units were built during the 1960s and 22.6 percent were built during the 1970s. As a result, potential rehabilitation and continued maintenance may be required for these units that are over 30 years in age. The City's rapid population growth in the 1990s is reflected in the number of housing units built during that period, a total of 5,855 units representing 22.2 percent of Tustin's total housing stock. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 29 TABLE HTM- 21 AGE OF HOUSING STOCK CITY OF TUSTIN Time Period Units Built Number of Units % of Housing Stock 2005 or later 1,348 25.1% 2000 to 2004 1,236 4.7% 1990 to 1999 5,855 22.2% 1980 to 1989 3,122 118% 1970 to 1979 5,974 22.6% 1960 to 1969 7,236 27.4% 1950 to 1959 923 3.5% 1940 to 1949 268 1.0% 1939 or earlier 456 1.7% Total 26,418 1000/0 Source: 2007 -2011 American Community Survey The overall City of Tustin housing stock is generally in good condition. According to the City's Code Enforcement staff and the Neighborhood Improvement Task Force (NITF) which is comprised of staff from various city departments, less than ten (10) percent of the City housing stock is in need of minor repairs. Only two (2) percent of the total housing units, particularly existing Four - plexes within the City's southwest neighborhood, may be considered in need of substantial rehabilitation. To date the City has not identified any housing unit in need of replacement. The City of Tustin takes a proactive approach toward housing conditions through the City's Housing Rehabilitation program (discontinued with the dissolution of redevelopment), Code Enforcement program and the Neighborhood Improvement Task Force (NIFT) program. Together, these programs allow the City to identify housing units in need of repair and provide needed assistance to maintain the City's housing stock in good conditions. Housing Costs Ownership Housing- Southern California, in line with the nation, is experiencing a recent significant increase in the volume of single - family and condominium sales, placing upward pressure on home prices. According to DataQuick, an on -line research firm, 34,380 homes sold countywide in 2012, an increase of 16.9% compared to 2011. In addition, the median price for all 2012 countywide sales was $439,000, up 3.9% over 2011, and the highest annual median price since 2008. During 2012, the annual median home price, increased in 57 Orange County ZIP codes, was unchanged in six ZIP codes, and dropped in 20 ZIP codes. The median price change in Tustin was mixed, with a 5.9% increase reported in the 92780 ZIP code and a 4.6% decrease in the 92782 ZIP code. The decrease in the 92782 ZIP code may reflect a smaller percentage of new homes sold in 2012 compared with 2011. In 2012, the median new and resale home prices for zip codes in the City of Tustin ranged from $360,000 to $476,000. In comparison, the median resale home prices CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 30 for cities presented in Table HTM -22 ranged from $200,000 to $925,000. Overall, median new and resale home prices in Tustin were similar to those occurring throughout Orange County. TABLE HTM- 22 NEW AND RESALE PRICE OF HOMES AND CONDOMINIUMS TUSTIN AND NEIGHBORING iURISDICTIONS 2012 Data mclude all home sales, new and resale, and cmdonuniums. 2 Includes Lemon /Cowan Heights Source: Omnge County Register, January 23, 2012 Rental Housing: According to Realfacts, the average rent for Tustin in the first quarter of 2013 was $1,567. Studio and one - bedroom rental units had monthly rents between $1,237 and $1,340. Two - bedroom rentals had monthly rents of $1,448 and CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 31 Zip Median Home %, Change city Code Price-2(112' from 2011 Tustin 92780 $360,000 +5.9% Tustin 92782 $476,000 4.6% 92801 $305,000 +3.4% 92802 $330,500 +0.2% 92804 $330,000 +4.8% Anaheim 92805 $314,000 +4.7% 92806 $370,000 +1.9% 92807 $430,000 +0.2% 92808 $479,000 +0.8% 92840 $325,000 -1.5% 92841 $355,000 -1.3% Garden Grove 92843 $320,000 +1.6% 92844 $290,000 -3.3% 92845 $420,000 -1.4% 92602 $555,000 -5.1% 92603 $925,000 +14.5% 92604 $477,500 -2.3% 92606 $550,000 +5.8% Irvine 92612 $485,000 +12.5% 92614 $451,500 +3.1% 92618 $613,750 +12.7% 92620 $575,000 -5.6% 92865 $400,000 -2.2% 92866 $458,000 +1.8% Orange 92867 $470,000 +4.7% 92868 $300,000 +6.2% 92869 $440,000 +4.0% 92701 $200,000 +22.5% 92703 $275,000 +7.8% Santa Ana 92704 $290,000 0.0% 92705 $589,5002 +12.3% 92706 $365,000 0.0% 92707 $252,000 +7.2% Data mclude all home sales, new and resale, and cmdonuniums. 2 Includes Lemon /Cowan Heights Source: Omnge County Register, January 23, 2012 Rental Housing: According to Realfacts, the average rent for Tustin in the first quarter of 2013 was $1,567. Studio and one - bedroom rental units had monthly rents between $1,237 and $1,340. Two - bedroom rentals had monthly rents of $1,448 and CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 31 above while three -or -more bedrooms had monthly rents in excess of $2,391. Table HTM -23 presents a summary of the rental rates. TABLE HTM- 23 AVERAGE RENTAL RATES 2013 -1sT QUARTER CITY OF TUSTIN Number of Bedrooms Number of Units Average Square Footage Average Rent Studio 200 521 $1,267 lbd lba 2,303 732 $1,340 2bd TH 194 1,079 $1,695 2bd lba 625 976 $1,448 2bd /2ba 1,924 1,021 $1,828 3bd TH 20 1,516 $1,845 3bd /2ba 210 1,172 $2,391 Total 5,810 889 $1,567 TH = Town house unit 'Rental survey represents data only for large, investment grade rental properties. Smaller rental properties represent a large segment of the rental market and offer larger, more affordable units. Source: RealFacts. When a household (adjusted for family size) pays more than 30% of its gross income for housing, it is considered an overpayment. Based on HUD's figures on affordability, households in the Very Low - income category have affordable rent of $763 for one bedroom units to $1,090 for a four - bedroom unit. In Tustin, the average rent for a one - bedroom unit is $1,340 to $2,391 for three - bedroom units. It is also important to note that many of the households in the Very -Low income category are large families, thus a one - bedroom unit at $1,340 would not only be in excess of what they could afford, but would also be inadequate in size. For households in the Low- Income category (51 % -80% of County median) affordable rental rates are $916 to $1,308 per month for housing. The rental survey shows that only studio apartments are affordable to this group (see Table HTM -23). It is important to note, however, that the rental survey considered only large, investment -grade rental properties and did not report prices of smaller rental properties. According to City staff, smaller rental properties represent a large segment of the rental market and offer three - bedroom units that are affordable to low - income households. In summary, the preceding information suggests that, while rental housing is available in the City at rents that are affordable to all income groups, certain types of rental housing, such as single- family homes and condominium/ townhouses, are generally not affordable to the City's lower - income households. Perhaps most importantly, rental rates for units with two or more bedrooms are beyond the reach of the City's Very -Low and Low income households. This means that a Very -Low C17 Y OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 32 and Low income household consisting of three or more persons would have a difficult time finding affordable housing of adequate size. Table HTM -24 is an illustration of affordable net rents for 2013. TABLE HTM- 24 AFFORDABLE NET RENTS 20131 CITY OF TUSTIN Unit Size No. of bedrooms SVery Low 50% Low 51 -80% Moderate 81110% 1 Bedroom $763 $916 $1,679 2 Bedroom $872 $1,046 $1,918 3 Bedroom $981 $1,178 $2,159 4 Bedroom $1,090 $1,308 $2,398 I Based on HCDs Orange County Income Limits, 2013. Source: Tustin Housing Authority. Share of Region's Housing Needs Section 65584 of the Government Code requires each locality's share of the existing and future housing needs to be determined by the appropriate council of governments. Each jurisdiction's allocation represents its fair share of the regional housing needs. The City of Tustin's current and projected housing needs are derived from the Regional Housing Needs Assessment (RHNA) prepared by the Southern California Association of Governments (SLAG). The components of the RHNA are divided between "existing needs" and future "construction needs." Existing needs were discussed earlier in the housing affordability section of this report. Construction needs are defined as the number of units that would have to be added to accommodate the forecasted growth in the number of households by October 2021, as well as the number of units that would have to be added to compensate for anticipated demolitions and to achieve an "ideal" vacancy rate. Construction need includes all income groups (from very low to upper) and not just those households that require assistance. The total need figure is then distributed among the four income groups. The allocations of housing needs by income group are adjusted to avoid Lower - Income "impaction' - the over - concentration of Lower - Income households in a jurisdiction. SCAG's RHNA fair -share allocation for the 2014 -2021 period is 1,227 units. The closure of the MCAS has presented the City of Tustin with a total of 947.7 acres available for residential re -use and development. Amongst other types of uses, the City plans to add a total of 4,210 housing units of mixed density and housing type throughout the area. The City of Tustin also created a Redevelopment Project Area for the MCAS -Tustin project. Based on former State Redevelopment Law requirements, at least fifteen (15) percent of the units constructed within a Redevelopment Project Area were required to be affordable to Very Low, Low, and CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 33 Moderate - income households. Accordingly, from the potential new units to be built on the MCAS site, the creation of a redevelopment project area would result in up to 445 units (253units plus 192 transitional housing units) being allocated for Very Low - income housing and an additional 379 units be created for Low- and Moderate Income households. To meet its fair share of the region's housing needs during the 2014 -2021 RHNA planning period, the City's allocation for new construction housing units is 1,227 (refer to Table HTM -25). Of these, 23.1% must be affordable to Very Low income households (earning less than 50% of the County median), 15.9% must be affordable to Low - Income households (earning between 50% and 80% of the County median), 18.3% must be affordable to the Moderate - Income households (earning between 80% and 120% of County median income) and 42.8% must be affordable to Above - Moderate Income groups (earning over 120% of County median income). Table HTM -25 is a summary of housing need distribution for the 2014 -2021 RHNA planning period. TABLE HTM- 25 2014-2021 HOUSING NEEDS CITY OF TUSTIN Income Category # of Units % of Total Very Low (<50% County Median 283 23.1% Low 50% - 80% County Median 195 15.9% Moderate 80 %- 120 % County Median 224 18.3% Above Moderate 120% County Median 525 42.8% Total 1,227 100% Source: SLAG RHNA, 2012 CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 34 ASSISTED HOUSING PRESERVATION ANALYSIS State law (Chapter 1451, Statutes of 1989) requires all housing elements to include needs analyses and programs to address the potential conversion of Federal, State, and locally assisted housing developments ( "units at risk ") to market rate housing. For example, the federally subsidized loans provided too many low- income housing projects during the 1970s contained provisions that allow the owner to "prepay" the loans after 20 years, thereby removing the low- income subsidy from the project. As part of the "units at risk' analysis, the State requires that local jurisdictions perform the following tasks: • Needs Analysis: to include an inventory of units at risk of converting to market rate housing for period covered by the Housing Element; an analysis of the potential for loss of affordability controls; a cost analysis of preserving or replacing the at -risk units; identification of agencies willing to acquire and manage these projects; and, identification of funding sources available to preserve or replace them. • Quantified Objectives: A quantification of the units to be conserved, and explanation of any difference between the number of units at risk and the number to be conserved. Housing Programs: A description of programs to preserve the units at risk. Tustin has one project that contain units "at risk' of converting to unrestricted market rate rents. Tustin Gardens is a 101 -unit Section 223(a) (7)/221(D) (4) project with a Section 8 contract for 100 units. In 2003, the owners of Tustin Gardens signed a five -year agreement with the U.S. Department of Housing and Urban Development (HUD). This agreement serves as a one -year Section 8 contract that automatically renews for four additional one -year terms, provided that funds are available. The current contract expires on July 13, 2014. The project owners have indicated that they intend to renew the contract. Projects financed under the Section 221(D) (4) market rate program alone have no binding income use restrictions. The conversion of this project would have an adverse impact for the elderly who may face substantial rent increase or possible displacement. Table HTM -26 lists all of the Federal, State, and locally assisted low - income housing projects located in the City of Tustin due to expire by 2021. Table HTM -27 is an inventory of all units assisted under federal, state, and /or local programs, including HUD programs, state and local bond programs, and local in- lieu fee, inclusionary, density bonus, or direct assistance programs. The inventory includes all units that are eligible to convert to market rate housing due to termination of subsidy contract, mortgage prepayment, or expiring use restrictions. 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Z'a ) 0 {{ a�\ (tea ))ƒ \%\ )(( ) ( 28J ( \ g \ § B Q § ( \ \� »\ Q §/ (U SM Replacement/Acquisition and Rehabilitation Analysis: The City of Tustin has identified the preservation of existing affordable housing units as one of the most cost - effective methods of maintaining the stock of affordable housing, therefore a high- priority program for the City. The City has identified 100 units of at -risk housing at Tustin Gardens with expiring use restrictions within the planning period, including 100 units of very low income housing. Given the relative weakness of economic conditions and the housing market currently, the City will proceed to attempt to negotiate the extension of affordability restrictions on these units in advance of the specific expiration dates for these units. The amount of assistance provided will be negotiated based on the specific economics of each development and the potential availability of leverage financing, such as tax - exempt bonds and 4% tax credits. Funds were previously allocated to this program in prior planning periods. However, as a result of the dissolution of Redevelopment, the Low and Moderate Income Housing Funds, allocated to this program were recaptured by the State and transferred to the Orange County Auditor - Controller for distribution to the appropriate taxing entities. Local Rental Subsidy. An option for preservation of at -risk units assisted by either project based Section 8 funds and /or bond financing would be a local rental subsidy to residents. This option could be used to retain the affordable status of the units, by providing assistance to residents when their affordable units convert to market rate. Rent subsidies using state, local (the use of HOME funds or other funding sources) can be used to maintain the affordability of these at -risk units. Rent subsidies can be structured to mirror the Section 8 program. There are several funding sources that could be used to provide subsidies to residents. Under the project based Section 8 program, HUD pays owners the difference between what tenants can pay (defined as 30% of household income) and what HUD and the local Housing Authority estimate to be Fair Market Rent (FMR) on the unit. Section 8 assistance is only available to very low- income households earning less than 50% of the County median income. The 2013 HUD median income in Orange County is $87,200. The analysis also assumes the average very low- income household has an actual income of 50% of the County median income, adjusted for household size. The cost of providing subsidies for all 100 at -risk units with potential to expire during the planning period to maintain subsidized rents assumes that none of the at -risk units are preserved. The cost of providing subsidies is based on a comparison between fair market rents (FMR) and rents that are affordable for low and very low - income families. Affordability is defined as rents that do not exceed 30% of a household's monthly income. The 2013 FMRs for Orange County, which encompasses the City of Tustin, are shown in Table HTM -28. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 42 TABLE HTM- 28 2013 FAIR MARKET RENTS ORANGE COUNTY Efficiencv" I 1 Bedroom 1 2 Bedroom 1 3 Bedroom 1 4 Bedroom FMRs include utility costs Source: U.S. Department of Housing and Urban Development Table HTM -29 indicates that affordable rents for very low income households would be approximately $763 for a one bedroom unit, $872 for a two bedroom unit, and $981 for a three bedroom unit. To simplify the analysis, the one bedroom senior units at -risk in Tustin Gardens (100 one- bedroom units) are assumed to be comprised of one - person households. TABLE HTM- 29 Affordable Rents City of Tustin 2013 Unit Size Very Low Moderate (No. of Bedrooms) 50 0/6 AMI ow 80% AMI 120% AMI 1 Bedroom 2 Bedrooms 3 Bedrooms $763 $916 $1,679 $872 $1,046 $1,918 $981 $1,178 $2,159 4 Bedrooms $1,090 $1,308 $2,398 ' U.S. Department of Housing and Urban Development published 2013 very low income limits, adjusted proportionally for 60% of percentage of AMI category. Gross rents are calculated assuming an occupancy standard of 1 person per bedroom plus one. Rents are calculated assuming 30% of gross income spent on rent, including utilities. Source: Tustin Housing Authority The costs of providing a rental subsidy for all 100 at -risk units affordable to very low income households is shown in Table HTM -30 to be approximately $53,100 per month and $637,200 annually. Actual subsidies required would vary from this estimate, as some households earn below the assumed 50% of the County median and therefore require higher subsidies, while other households may be comprised of a different number of persons and therefore, the assumed baseline affordable rent may be higher or lower, depending on household size. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 43 TABLE HTM- 30 COST OF PROVIDING RENTAL SUBSIDY FOR VERY LOW INCOME HOUSEHOLDS 1 Affordable rent includes all utilities Sources: County of Orange Section 8 Program, Tustin Housing Authority. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 44 Affordable No. Differen Total Unit FMR Rent r Units ce Monthly Annual 1 Bedroom $1,294 $763 $100 $531 $53,100 $637,200 2 $1,621 $872 $0 $749 $0 $0 Bedroom TOTAL $53,100 $637,200 1 Affordable rent includes all utilities Sources: County of Orange Section 8 Program, Tustin Housing Authority. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 44 CONLiTRAINTS TO THE DEVELOPMINT, IMPROVEMENT AND MAINTENANCI: OI" HOUSING This chapter examines the various constraints to housing development in Tustin. These include governmental constraints and non - governmental constraints GOVERNMENTAL CONSTRAINTS Sections 65583(a) (4) of the Government Code require the Housing Element to include an analysis of potential and actual governmental constraints upon the maintenance, improvement or development of housing for all income levels. The following analysis fulfills this requirement. Land Use Controls The State Planning and Zoning Law (Sec. 65860) requires consistency of the zoning ordinances with the General Plan. The existing Land Use Element of the General Plan establishes single - family, multi- family and planned residential districts. The zoning ordinance is consistent with the Land Use Element in that areas of the City are designated for Single - Family, Multi- Family, Specific Plan and Planned Community Districts. An analysis of residential development potential will be provided in the Housing Element. As shown in Table HTM -31, the City's existing General Plan allows a range of residential densities, from a range of 1 - 7 dwelling units per acre in the Low Density Residential designation up to 25 dwelling units per acre in the High Density Residential designation, which corresponds to the R -3 Multiple Family Residential District in the Zoning Code. Up to 10 units per net acre are permitted in the MHP (Mobile Home Park) District. The Zoning Code standards in the residential zones establish a front yard setback requirement of a range between 15 and 20 feet, the side yard setback requirement is 5 feet for interior side yards and 10 feet for corner lots, and the rear yard setback requirement ranges between 5 and 25 feet. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 45 TABLE HTM- 31 ( iEiNLRAL PLAN RESIDENTIAL LAND USE CATEGORIES CITY OF TUSTIN Maximum density in dwelling units per acre is prescribed by individual Planned Community Documents. Effective dwelling units per acre for low, medium, and high density residential are 4.485,11.834, and 17.39, respectively. r Low Density (1 -7 du /ac), Medium Density (8 -15 du /ac), Medium High Density (1625 du /ac) In Neighborhood D, the maximum density on an individual parcel may exceed 25 units per acre as long as the total dwelling units allocated to Neighborhood D is not exceeded. Source: City of Tustin General Plan, Land Use Element, 2001. According to the General Plan build -out table (Table LU -3) in the Land Use Element, a total of 29,821 dwelling units are anticipated within the City limits. The Department of Finance (DOF) reports there are 26,958 dwelling units (as of January 2013) within the City. As developed through the adoption of AB 2348, Statutes of 2004, a metropolitan city of Tustin's size is allowed to use "default" density standards of at least 30 dwelling units per acre as determined in the Government Code Section 65583.2 to accommodate the City's share of regional housing need for lower income households. The General Plan Land Use Element's policy plan provides goals for future land development within the City. These goals and policies are reflections of the direction and images the City seeks for the future. The goals and policies include: 1. Achieve balanced development, 2. Ensure that compatible and complementary development occurs; 3. Revitalize older commercial, industrial, and residential development; 4. Promote economic expansion and diversification, CITY OFTUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 46 Effective Dwelling Unit per Density Designation Description Acreage Range Low Density Residential Detached single-family dwellings 5.61 1 -7 Medium Density Residential Multi- family dwellings including 15.0 8 -15 duplex, condominiums, townhomes, and apartments. High Density Residential Multi- family dwellings including 21.53 15 -25 duplex, condominiums, townhomes, and apartments. Mobile Home Park Mobile homes 6.31 1 -10 Planning Community (PD) Low, medium, and high - density residential developments. MCAS Tustin Specific Plan Low, medium, and medium high- density residential developments. Maximum density in dwelling units per acre is prescribed by individual Planned Community Documents. Effective dwelling units per acre for low, medium, and high density residential are 4.485,11.834, and 17.39, respectively. r Low Density (1 -7 du /ac), Medium Density (8 -15 du /ac), Medium High Density (1625 du /ac) In Neighborhood D, the maximum density on an individual parcel may exceed 25 units per acre as long as the total dwelling units allocated to Neighborhood D is not exceeded. Source: City of Tustin General Plan, Land Use Element, 2001. According to the General Plan build -out table (Table LU -3) in the Land Use Element, a total of 29,821 dwelling units are anticipated within the City limits. The Department of Finance (DOF) reports there are 26,958 dwelling units (as of January 2013) within the City. As developed through the adoption of AB 2348, Statutes of 2004, a metropolitan city of Tustin's size is allowed to use "default" density standards of at least 30 dwelling units per acre as determined in the Government Code Section 65583.2 to accommodate the City's share of regional housing need for lower income households. The General Plan Land Use Element's policy plan provides goals for future land development within the City. These goals and policies are reflections of the direction and images the City seeks for the future. The goals and policies include: 1. Achieve balanced development, 2. Ensure that compatible and complementary development occurs; 3. Revitalize older commercial, industrial, and residential development; 4. Promote economic expansion and diversification, CITY OFTUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 46 5. Coordinate development with the provision of adequate public facilities and services; 6. Strengthen the development character and mixture of uses in the Old Town/ First Street area; and 7. Promote an integrated business park character for the Pacific Center East area. Some suggest that low- income housing could be developed in the absence of land use controls related to density. It is true that the reduction or absence of land area requirements per housing units would result in lower land costs per unit, if all factors were constant. However, an analysis of development costs shows that the value of the land is related to its potential yield. For example, an acre of land that was authorized for four (4) dwelling units will be priced at a lower value than an acre of land authorized for six (6) dwelling units. The same analogy holds for multi- family sites whereby the land costs are related directly to the potential yield in terms of unit density. Tustin has a high percentage of multi- family units where only 35.1% of the housing stock is devoted to single- family detached units and 61.5% to attached and multi - family units. (The remaining percentage consists of mobile homes). Current land use controls restrict development in single - family residential zones to one dwelling unit on parcels less than 10,000 square feet in the E-4 zone and parcels less than 7,200 square feet in the R -1 zone. However, the Planned Community District has authorized residential subdivisions with single- family lots of less than 5,000 square feet, which has significantly increased density potential to approximately 8 -13 units per acre. In addition, the provisions for Second Residential Unit adopted in 2003 allow a second unit to be constructed without discretionary permit approval provided that the site complies with criteria contained in the Zoning Ordinance. Within the multi- family district (R -3), a 35 -foot height limitation and maximum 65% lot coverage precludes the development of high -rise housing projects. In the interest of protecting adjoining single - family lot owners, multi- family structures above 20 feet in height require a conditional use permit when the structures are within 150 feet of single - family residentially zoned lots. There are approximately 20 properties with an R -3 zoning designation that abut Single Family Residential (R -1) zoning comprised of a variety of older apartment units and several parcels within Old Town Tustin that are adjacent to the First Street commercial zoning areas. While these height limits may place some restrictions on housing development, these limits are designed to maintain compatibility of land use intensity and are commonly used by local governments as a development tool to further this ideal. When designed properly with features such as limited windows and door openings along the walls facing single family zoned properties or using stepped building heights and design CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 47 to minimize intrusion to the privacy of existing residents, Conditional Use Permits to allow such development projects have been granted. Although, it should be noted that this restriction would not impact areas where future residential development are targeted within this planning period, since the City's RHNA quantified objective identified preservation of existing units and new construction units at Tustin Legacy where the 20 foot limitation would not be applicable. Conversely, within Planning Area D of the MCAS Tustin Specific Plan, a 150 foot height limitation up to 180 foot, if approved by the Community Development Director, would be allowed. This provides for layering products (i.e. stacked flats, podium style, etc.) with mixed use developments, thereby providing opportunities for the development of higher density residential products. Projects are also able to take advantage of the Planned Community District application process where special considerations are needed. Parking requirements for residential uses are typically two (2) spaces per dwelling unit. In multiple family residential districts, additional one (1) space for each four (4) units is required for guest spaces. Carports for multi- family units are permitted which would reduce development costs in contracts to the provision of garages. Furthermore, affordable and senior housing development meeting the State Density Bonus Law would be eligible to use the reduced parking standards under the State Law. Table HTM -32 is a summary of the City's residential zoning regulations. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 48 C v �i M ad F v FC W O s F 0 U W W H w1� 'I U UH a 0o a .� o°a m Cl Y C Op 'V •U N .r` Ca y` o" N N H Q i N N Y 4 U'.p0 `0'�' e b S y `Oh ti� M H h of h e�0 wY >- 0 N N N N N �•-i N M , x v N d Q Iqi CyyI V tyyJ NV y�y yUy C y � y Q N O ppN O N O O O h p�p • r: N � n ttj trj ri ryj a r ° ° a¢ wq as zA rio zx ao W W H w1� 'I U UH G \ A 2f §} / ) \ a 0 ( % k ( § 2 ) / 2 @§ /) )k ) §4 k\ t( } { \} ( \) \ }L ƒ }) )}( ] i} ]a § ` 2/\ a;e U§ ) \) \2\ 7 * �k\ ( � ) §} .a ) /9 ƒ� ( % k ( § 2 ) / 2 @§ /) )k ) §4 Housing for Persons with Disabilities/Reasonable Accommodation The City of Tustin recognizes the importance of addressing the housing needs for persons with disabilities. The City's Zoning Code defines "family" as "an individual or two (2) or more persons living together as a single housekeeping unit in a dwelling unit" This definition accommodates unrelated persons living together in a dwelling unit; thus, the City's definition for a family would not constrain the development and rehabilitation for persons with disabilities. The City requires each development to comply with Title 24 of the California Code. All multi- family complexes are required to provide accessible parking spaces based upon the prescribed State code requirements. For development of special needs housing such as housing for the disabled, senior housing, etc., parking requirements would be determined based upon parking demand analysis which by nature would allow for lower parking ratio in comparison to those required for multiple family residential units. In addition, an off - street parking ordinance adopted by the City allows for the reduction in parking due to an American with Disabilities Act (ADA) upgrade. The Community Development Director is authorized to allow the reduction in the number of required parking spaces when the site is brought up to ADA standards. This provision provides incentives to property owners to provide reasonable accommodation to the disabled. The City also requires new multi- family housing units and apartment conversions to condominiums to comply with State specifications pursuant to SB 520 for accommodation of the disabled. A Residential Care facility serving six (6) or fewer persons is a permitted use in all residential districts. The City's Zoning Ordinance does not contain maximum concentration requirements for a residential care facility serving six (6) or fewer persons. The City recognizes the need of disabled persons to retrofit their residences to allow for mobility such as wheelchair ramps, widened doorways, grab bars, and access ramps. When these improvements meet development standards, only a building permit is required. In 2011, the City amended the Zoning Code to remove governmental constraints to reasonable accommodation for the disabled. The amendment provides a process in which deviations from the development standards associated with physical improvements to accommodate the disabled would be accommodated with administrative approval and without the need of a public hearing. Homeless Accommodation Homelessness is a statewide concern that affects many cities and counties. Throughout the country, homelessness has become an ongoing problem. Factors CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 51 contributing to homelessness include the general lack of housing affordable to Low and Moderate income persons, increases in the number of persons whose incomes fall below the poverty level, reductions in public subsidy to the poor, and the deinstitutionalization of the mentally ill. The issue of homelessness is considered regional in nature. Nomadic tendencies of homeless persons make it difficult to assess the population accurately. According to the 2009 Orange County Homeless Census and Survey, the County has 8,333 homeless individuals of which an estimated 5,724 are unsheltered, 962 are in emergency shelters and 1,647 are in transitional shelters. The Census and Survey estimated that 21,479 people in Orange County experience homelessness annually. Of these individuals, 3,578 are identified as chronically homeless, 1,904 as severely mentally ill, 68 are suffering from HIV /AIDS, 475 are victims of domestic violence and 2,683 suffer from chronic substance abuse. Within the City of Tustin, Police reports and windshield surveys indicate limited numbers of persons on the street and have shown that there are no established areas where homeless persons congregate in the City and that most persons migrate through Tustin to other areas within Orange County, rather than stay for extended periods of time. The Orange County Partnership, a non -profit organization whose purpose is to strengthen public and private agencies serving the homeless and those at risk of homelessness, reported that in 2009 there were 10 homeless persons who identified Tustin as the city of last known permanent address. The McKinney -Vento Homeless Education Assistance Act reported 55 homeless children and youth enrolled in the Tustin Unified School District during 2006 -07. SB 2 defines the following: "Emergency Shelters' as housing for homeless purposes intended for occupancy of less than six (6) months, where no person is denied occupancy because of inability to pay. "Transitional housing" is rental housing for stays of at least six (6) months where the units are re- circulated to another person after a set period. "Supportive Housing" has no limit on the length of stay, provides supportive services and is occupied by low- income persons with disabilities and certain other disabled persons. SB 2 requires the city to identify the needs for emergency shelters in its Housing Element and to designate zoning districts adequate to accommodate the need. In those districts, emergency shelters must be allowed without a conditional use permit or other discretionary approvals. The city may apply certain written, objective development and management standards, such as number of beds and length of stay, if no zoning district exists that meets this standard. Alternatively, a community may require a conditional use permit for emergency shelters if they already have enough shelters to satisfy the need; or have entered into partnership agreement with up to two other communities to develop an emergency shelter that CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 52 will meet their collective needs. Supportive and transitional housing must be treated as a residential use of property, subject to only to same restrictions that apply to other housing of the same type in that zone. With the closure of the Marine Corps Air Station (MCAS) Tustin, the City was provided with opportunity to address homeless accommodation. As part of the conveyance process and under the Base Closure Community Redevelopment and Homeless Assistance Act of 1994 (The "Redevelopment Act'), the City of Tustin as, the Local Redevelopment Agency (LRA) was required to consider the interest of the homeless in buildings and property on the base in preparing the Reuse Plan (MCAS Tustin Specific Plan/Reuse Plan). In developing the Reuse Plan, one criteria the Secretary of Housing and Urban Development (HUD) utilized to determine the adequacy of the Reuse Plan was whether the Plan considered the size and nature of the homeless population in the communities, in the vicinity of the installation, and availability of existing services in such communities to meet the needs of the homeless in such communities. At the time of the preparation of the Reuse Plan, it was estimated that there was a total net homeless need of 411 persons in the City of Tustin and City of Irvine (A portion of the MCAS Tustin is located within the City of Irvine jurisdiction). A large portion of this homeless need was identified as necessary to support emergency transitional housing for youth and individuals. The local homeless need as described in both Tustin and Irvine's Consolidated Plans also indicated a gap in the continuum of care in the areas of vocational and job training/ educational opportunities, some emergency and transitional housing units for individuals and families, support services, and affordable ownership units. Accordingly, the Homeless Assistance Plan for MCAS Tustin was adopted to addresses the problem of homelessness by utilizing the continuum of care model promulgated by HUD for accommodating the needs of the homeless in a manner which is consistent with the Consolidated Plans approved for the cities of Tustin and Irvine. The fundamental components of the continuum of care system implemented with the MCAS Tustin Reuse Plan: • Provides emergency shelter beds; • Offers transitional housing and services which enable homeless persons to progress to self - sufficiency; and • Provides opportunities for permanent affordable housing by the private sector. As a result, the adopted MCAS Tustin Specific Plan provided sites and designated land uses to accommodate the identified homeless needs. The following sites were set aside in implementing the homeless accommodation at Tustin Legacy (formerly MCAS Tustin): CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 53 • An approximate five (5) acre transitional/ emergency shelter site was set - aside for accommodation of the homeless at MCAS Tustin. The City acquired a site from the Department of Navy; initially ground leased the site, and ultimately conveyed the site to the Orange County Rescue Mission at no cost and facilitated the construction of Village of Hope, a 192 unit transitional housing facility, without the need for a Conditional Use Permit. The project has been completed. • A four (4) acre site was recommended by the City of Tustin and deeded directly by the Department of Navy at no cost to the Orange County Social Services Agency for the development of an abused and neglected child and emancipated youth facility with 90 beds capacity. The project is complete. • A total of 50 transitional housing units were originally included in the Base Reuse Plan. Based on further negotiations with non - profit homeless providers, a total of 32 new transitional housing units were constructed and conveyed at no cost to non - profit homeless providers at Tustin Legacy. These units are dispersed throughout the Tustin Legacy community to allow integration into the community. The sites are designated as residential sites and the units were constructed in conjunction with market rate units subject to only those restrictions that apply to other residential uses. The units are transparent since the units are developed identical to those of market rate units in terms of size, materials, locations, etc. No special or other entitlement applications were required for the creation of these units other than those typically required for development of residential units at Tustin Legacy. In addition to the homeless accommodation on -site at Tustin Legacy, the City also facilitated the purchase of a 16 unit transitional housing facility off -site for one of the homeless providers. The City subsidized the creation of these units through the use of housing set aside funds and Federal HUD Homeless Assistance funds. In addition to the homeless accommodation, the City also encourages support services to support the community of continuum of care model to end the cycle of homelessness and to provide participants with tools to once again become contributing members of the community as follows: • Private sector opportunities are provided to create a balanced mix of housing types on the base. Through inclusionary Zoning standards in the MCAS Tustin Specific Plan, a total of 8792 affordable units or 20.8 percent of 2 Includes 32 transitional housing units set aside for non -profit homeless providers. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 54 total authorized units at Tustin Legacy are required to allow participants with opportunity to achieve self - sufficiency. Specific affordable housing requirements would be established at the time of development project approval to ensure conformity with the Housing Element of the City's General Plan and any provisions of California Community Redevelopment Law. • The Navy will be transferring a child care facility at the former MCAS Tustin to the City of Tustin, which will provide opportunities for access for all to mainstream child care facilities, including early child care and education programs, Head Start, etc. • Adult education and training opportunities will be provided by the South Orange County Community College District within the educational village. Emergency Shelters, Transitional Housing, and Supportive Housing SB 2 defines "Emergency Shelters" as housing for homeless purposes intended for occupancy of less than six (6) months, where no person is denied occupancy because of inability to pay. In the City of Tustin, emergency shelters are designated as permitted uses within Planning Area 3 of the MCAS Tustin Specific Plan. Planning Area 3 is a five (5) acre site that had been a no cost conveyance to the Orange County Rescue Mission for the development of an emergency/ transitional shelter that is known as Village of Hope. The City facilitated the development of the Orange County Rescue Mission Village of Hope and waived permits fees as this was a public /private partnership. The project consists of 192 units available for emergency and transitional needs. As of April 30, 2013, the Orange County Rescue Mission Village of Hope was at 90% capacity, with a total of 173 homeless individuals consisting of homeless single men, single women, single women with children, single men with children, and two parent families. The largest homeless sub - population on the Village of Hope campus is single women with children. The Orange County Rescue Mission Village of Hope priority is to serve Tustin homeless population prior to taking any other referrals from other cities or the County. The Tustin Police Department actively refers individuals to the Village of Hope upon encounter. The Orange County Rescue Mission Village of Hope also provides a food service program of approximately 550 meals daily to the Armory. Based upon the available data obtained from the Orange County Partnership and McKinney Vento Homeless Education Assistance Act, approximately 34-55 individuals reported either Tustin as their last known permanent address or CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 55 enrolled within the Tustin Unified School District. This means that the City of Tustin is accommodating 137 -158 homeless persons beyond its jurisdictional boundaries thereby accommodating a regional need. The City interviewed the Orange County Rescue Mission Village of Hope representative and the City was told that there are generally 5 vacant units and a minimum of five (5) percent vacancy is available at any given time. The Orange County Rescue Mission Village of Hope also indicated that the shelter has met above and beyond the City's conservative estimate of 55 homeless persons and that the shelter could accommodate the year -round needs and seasonal fluctuation in the amount of available beds. Transitional housing is defined as rental housing for stays of at least six (6) months where the units are re- circulated to another person after a set period. This housing can take several forms, including group housing or multi- family units, and often includes supportive services component to allow individuals to gain necessary life skills in support of independent living. The Tustin's Zoning Code accommodates transitional housing within several zoning districts depending on the project's physical structure: 1) transitional housing operated as a residential care facility is permitted /conditionally permitted depending on the number of occupants in residential districts; and 2) transitional housing operated as rental apartments, it is permitted by right as a multi- family residential uses where multifamily housing is permitted. Supportive housing is defined as permanent (no limit on the length of stay), provides supportive services and is occupied by low- income persons with disabilities and certain other disabled persons. Services may include assistance designed to meet the needs of the target population in retaining housing, career counseling, mental health treatment, and life skills. The Tustin's Zoning Code permits supportive housing as a residential use, provided supportive services are ancillary to the primary use. Within the City of Tustin, the following emergency shelters, transitional, and supportive housing are designated as permitted uses as follows: TABLE HTM 33 SUMMARY OF HOMELESS ACCOMMODATION ZONING REGULATIONS Permitted/ Housing Type Conditionally Zoning Permitted Planning Area 3 of WAS Tustin Transitional Home Permitted Specific Plan Emergency Shelters Permitted Planning Area 3 of MCAS Tustin Specific Plan CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 56 Supportive housing Permitted Planning Areas 1 and 3 of MCAS Tustin Specific Plan Community Care Facility for six (6) or Permitted All residentially zoned properties fewer Family care home, foster home, or erouv home for six 161 or fewer[ Permitted All residentially zoned properties I Includes congregate care facility, single room occupancy hotel, and children's intermediate care shelter Source: City of Tustin, MCAS Tustin Specific Plan The following are transitional homes that have been provided in the City at Tustin Legacy. 1. A 192 beds transitional home at the Village of Hope operated by the Orange County Rescue Mission. 2. A 90 beds intermediate care shelter for abused children and their parents operated by the Orange County Social Services Agency. 3. Six (6) units at Tustin Field I operated by Salvation Army. 4. Acquisition of 16 units in Buena Park operated by Salvation Army. The City assisted in acquisition and contributed grant funds to acquire the units. 5. Fourteen (14) units at Columbus Grove operated by Families Forward, formerly Irvine Temporary Housing.3 6. Six (6) units at Columbus Grove operated by Human Options. 7. Six (6) units at Columbus Grove operated by Orange Coast Interfaith Shelter. With the exception of the transitional homes, these units are transparent and dispersed throughout the Tustin Legacy community consistent with the City's goals and policies to provide adequate supply of housing to meet the need for a variety of housing types and the diverse socio - economic and to promote the dispersion and integration of housing for all socio - economic throughout the community. Building Codes As required by State law, the City of Tustin has adopted the 2010 Construction Codes which includes "2010 California Building Code" and the "2010 California Mechanical Code" published by the International Conference of Building Officials, the "2010 California Residential Code," the "2008 California Energy Code," and the 3 Although these units are located in the City of Irvine, these units were negotiated as part of the base realignment /conveyance process in which Tustin is the Local Redevelopment Agency. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 57 "2010 California Green Building Code. ". Other codes adopted by the City include the "2010 California Plumbing Code," the "2010 California Electrical Code," the "2010 California Historical Building Code," and the "2010 California Existing Building Code." While the codes are intended to protect the public from unsafe conditions they result in an increase in the cost of housing in various ways. The codes establish specifications for building materials and incorporate seismic safety standards that add to construction costs. The technical details of construction, requirements for state licensed contractors to perform the work, plan check, permit processing and field inspections all contribute to the increased cost of housing. In general, in states and counties where building codes have not been adopted, the cost of housing is less than comparable housing costs in California. Where individuals are permitted to construct shelters to their own specifications and within the limits of their individual construction skills, there will be a much greater proportion of low- income housing available than in those areas which adopt and enforce uniform building codes. It is noted; however, in those areas that have not adopted and enforced building codes, the low -cost housing may resulted in the creation of substandard building conditions and practices conditions that threaten the health and safety of the residents. Unquestionably, building codes are a governmental constraint to the construction of low- income housing. The question to be resolved is the conflicting values between health and safety and low -cost shelter. Originally in 1988, the City of Tustin adopted the State Historical Building Code as required by State law. The State Historical Building Code requires relaxation of Uniform Building Code requirements for historic structures. This will reduce rehabilitation costs and may encourage rehabilitation of housing units which have historic value and preserve much needed housing units in the Old Town Area. Site Improvements The restricted and limited ability to tax property in an amount equal to the cost of services and public improvements has shifted site improvement costs to the developer who passes them on to the housing consumer. The philosophy is expressed that no new development should impose a financial liability upon the existing community residents. The voters have expressed this conviction through the adoption of growth control measures and Proposition 13. An increased awareness of environmental amenities creates a public demand for improvements of not only the building site but of the surrounding environment which consists of drainage channels, landscaped parkways, arterial roads to serve the area, recreation facilities, preservation of open space, school facilities, and recreation amenities, all of which add to the cost of housing. Site development standards and requirements in the City of Tustin include clearing and grading the land; dedication and improvement of public right -of -way to CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 58 include paving, curbs and gutters, sidewalks, drainage, street trees, streetlights and fire hydrants. On -site improvements include the under grounding of cable TV, water, sewer, gas, telephone and electric utilities. Subdivisions and multifamily developments are required to provide landscaping, drainage, perimeter walls, covered parking, landscaping, irrigation systems, and to submit materials and project design for review to assure architectural compatibility. Applicable multi- family structures are required to provide housing and parking accommodations for the disabled pursuant to State law. The review process is used to facilitate the land use and development compatibility objectives of the City and provide developers the opportunity to explore project alternatives, which could decrease development costs in the long run by avoiding costly mistakes. In the development of subdivisions, the developer is required to dedicate and improve roadways to serve the area; to provide or improve area drainage channels; to extend water, sewer and other utilities to the site; to dedicate land or pay in -lieu fees for parks and open space for private use in multiple - family projects; and to dedicate land or pay in -lieu fees for public facilities such as schools and fire stations. Developers are allowed to construct private streets or to modify street standards to reduce construction costs, and this encourages and will encourage affordability of housing units in former MCAS Tustin. An additional cost of site development results from the installation of noise attenuation devices and materials as required by State law. Perimeter walls and /or berms are required for subdivisions to reduce the noise levels from external surface sources such as railroads, freeways and arterial highways for sites that are located within 65 dB (CNEL) Noise Levels. Some of these costs can be reduced by the use of special State and Federal grant funds to produce low- and moderate - income housing units. Significant public facilities will be needed to accommodate the new and proposed housing development at the former MCAS Tustin. According to the MCAS Tustin Reuse Plan/Specific Plan, water, sewer, storm drainage, electrical, natural gas, and telephone and cable backbone systems that serve future housing sites will need to be constructed. All housing sites will also have to pay their proportionate share for new backbone utilities, roads, and traffic improvements required in conjunction with development of the WAS Tustin site and as mitigation for the adopted Final Joint Environmental Impact Statement/ Environmental Impact Report for the Disposal and Reuse of MCAS- Tustin and its Addendum. Fees and Exactions By law, the City's building and development fees are restricted to the costs of performing the services. The building and planning fee schedules of the City of Tustin were last revised in 2008. These fees still remain considerably below those of surrounding communities in the County. These fees may be and have been waived CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 59 by the City Council for projects where extraordinary benefits are derived such as low- income housing projects, but are typically required to offset City expenses. The fee schedule adopted by the City of Tustin has a minimal impact upon the cost of housing within the City. The argument can be made that the cost of inspecting and serving new developments exceeds the fees and revenues that are exacted for these developments. This is justified as a public service to protect the public health, safety and welfare of the future inhabitants and is partially borne by the general revenues of the City. Additional revenue sources are increasingly important since the passing of Proposition 13. Recognizing that housing for the elderly and low - income families is a community objective, the park land dedication ordinance provides the option to the Council to waive these fees for qualifying projects. The City might also consider exploring fast - tracking (preferential scheduling) or fee waivers for critical projects such as those providing affordable housing or housing which addresses special housing needs. In addition to the City's fees, a considerable amount of school fees are also applicable to residential projects. The respective school district should explore waiving all or portion of the school fees for affordable housing projects. The City, in conjunction with the preparation of the 2009 Housing Element also prepared the Affordable Gap and Leveraged Financing Analysis (Appendix A of the Housing Element Technical Memorandum attached hereto). The analysis evaluated development costs to arrive to per unit affordability gap in producing affordable units. Table 12 and Table 13 of the analysis summarize average per unit development processing and impact fee of $29,277 to $37,530 per unit for owner housing prototype and $25,586 per unit for rental housing prototype (See Appendix A for specific development processing fees and analysis). In response to the recent economic downturn, the City Council also adopted an economic stimulus program which allowed the payment of specific development fees for construction of new residential units to be deferred until either prior to final inspection or issuance of certificate of occupancy. This program provided direct and indirect assistance to developer of residential units in that reduced on -hand cash flow were required at time of permit issuance. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 60 Processing and Permit Procedures The City recognizes that the myriad of agencies and permit approvals required for a development results in a time- consuming and expensive process. The value of land increases when entitled for development and all necessary permits have been obtained for construction. State law establishes maximum time limits for project approvals and City policies provide for the minimum processing time necessary to comply with legal requirements and review procedures. The Community Development Department serves as the coordinating agency to process development applications for the approval of other in -house departments such as Police, Public Works/ Engineering, and Parks and Recreation. These departments work together to simultaneously review projects to ensure a timely response to developers and act as the City's Design Review Committee. Pre - application conferences with the Community Development Department provide the developer with information related to standards and requirements applicable to the project. For the more complicated development projects in the Special Management Areas, Specific Plans provide a standard Design Review Process. Application packages are provided to developers and include the processing chart and copies of pertinent information such as street improvement construction standards, subdivision and landscape requirements that aid developers in the preparation of their plans. All projects are processed through plan review in the order of submission. Recognizing that profit margins are reduced and risks are increased by processing delays, the City has assigned priority to plan review and permit issuance for low - income housing projects. Additionally, contracts for plan check services provide additional staff to process projects in a timely fashion. If a complete application is submitted, plans are simultaneously reviewed by all Design Review Committee members and plan checking departments rather than one agency reviewing plans at a time. The Design Review application does not require a public hearing or Planning Commission approval. The Tustin City Code authorizes the Community Development Director to approve development plans when findings can be made that the location, size, architectural features and general appearance of the proposed development will not impair the orderly and harmonious development of the area. In making such findings, the Zoning Code provides items to be considered such as height, bulk, setbacks, site planning, exterior materials and colors, relationship of the proposed structures with existing structures in the neighborhood, etc. This code provision affords the developers with tools to design their projects and thus increase certainty of project's design review and approval. Project application which complies with all the development standards prescribed by the district in which the project is located would not be required to go through any other discretionary approval. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 61 For Tustin Legacy, developments under the former Master Developer footprint (approximately 800 acres) are subject to the Legacy Park Design Guidelines to ensure compatibility of products proposed by vertical builders. The design guidelines present minimum design criteria for the achievement of functional, quality, and attractive development expected at the Tustin Legacy. The guidelines are intended to complement the MCAS Tustin Specific Plan district regulations and to provide staff, builders, design professionals, and other users with a concise document when dealing with Design Review process to avoid ambiguity. Together the Zoning Code, Design Review provisions, the Legacy Park Design Guidelines, and the 'one- stop" processing system provide certainty to developers seeking approval for the development of residential projects. Additionally, for projects of significant benefit to the low- income community, such costs can be waived by the City Council. Workload Another governmental constraint is the number of staff and amount of staff time available for processing development projects. Since the workload is determined by outside forces (economy and market for housing), a shortage of staff time may occur during strong economic conditions which could lead to increased processing time for development projects. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 62 MARKET CONSTRAINTS The availability of housing is affected by the interrelationships within the market place of price, income of buyer, and interest rates. The non - governmental constraints upon the maintenance, improvement or development of housing in the City relate primarily to low- and moderate - income families. High - income families have the option of selecting housing accommodations that meet their preferences. Since environmental amenities such as hillsides with views and beach access attract high -value developments, high- income families gravitate to the foothills and beach communities. The provision for housing opportunity to all income segments is further emphasized in the East Tustin development whereby single - family attached and detached homes are proposed for moderate- and higher- income households. Additionally, multi- family projects such as apartments and condominiums in East Tustin are provided for the low- and moderate - income groups. The same is true at the former MCAS Tustin area, where provisions for affordable units are required at an average of 20.9 percent. Market rate homes are proposed to accommodate diverse populations from all income levels. Financing Interest rates can have an impact on housing costs. Some mortgage financing is variable rate, which offers an initial lower interest rate than fixed financing. The ability of lending institutions to raise rates will cause existing households to overextend themselves financially, and create situations where high financing costs constrain the housing market. An additional obstacle for the first -time homebuyer is the minimum down - payment required by lending institutions. Even if Tustin homebuyers are able to provide a 3 percent down- payment and obtain a 3.6 percent 30 -year loan (average loan rate for FHA or VA guaranteed loans for May 2013), monthly mortgage payments on median priced single - family detached homes in the City place such homes out of the reach of moderate and lower - income households in the City. At a 3.6 percent interest rate, monthly mortgage payments on median priced condominiums and townhouses can place such units out of reach of Tustin's low and very low income households (see Tables HTM -22 and HTM -23). The greatest impediment to homeownership, however, is credit worthiness. According to the Federal Housing Authority, lenders consider a persons debt -to- income ratio, cash available for down payment, and credit history, when determining a maximum loan amount. Many financial institutions are willing to significantly decrease down payment requirements and increase loan amounts to persons with good credit rating. Persons with poor credit ratings may be forced to accept a higher interest rate or a loan amount insufficient to purchase a house. Poor credit rating can be especially CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 63 damaging to lower - income residents, who have fewer financial resources with which to' qualify for a loan. The FHA is generally more flexible than conventional lenders in its qualifying guidelines and allows many residents to re- establish a good credit history. Profit, Marketing and Overhead According to the Comprehensive Affordable Housing Strategy4, minimum developer profit is estimated at 12 percent of development costs, based on input from developers and the Building Industry Association. This level is considered a baseline profit or "hurdle rate," representing the minimum necessary for the deal to proceed. In the past, due to high market demand in communities like Tustin, developers were able to command for higher prices and realized greater margins for profit. As demand increased and prices rose, this profit margin was impacted by the escalating costs of land resulting from a shrinking supply of land. Marketing and overhead costs also add to the price of homes. The Comprehensive Affordable Strategy 2008 estimated developer overhead is at 4 percent of total development costs. The factor having the greatest impact on the price of land is location. To a lesser degree, the price of land is governed by supply, demand, yield, availability, cost of the infrastructure, and the readiness for development as related to governmental permits. Within the developed infill areas of the City, there is a scarcity of land available for residential development. The supply of land is largely limited to the former MCAS Tustin area since the East Tustin Specific Plan area has been built out. Land zoned for commercial or industrial development may not be appropriate for residential development. The development of additional housing accommodations within the urbanized area will require the demolition and /or redevelopment of existing structures, since there are very few vacant lots remaining. The unavailability of land within the developed areas of the City and the price of land on the fringes are constraints adding to the cost of housing and pricing housing out of the reach of low- and moderate - income families. Cost of Construction One important market- related factor in the actual cost for new housing is construction costs. These costs are influenced by many factors such as the cost of labor, building materials, and site preparation. According to Marshall & Swift estimates, the cost of residential wood frame construction averages $96.30 per 4 City of Tustin Comprehensive Affordable Housing Strategy, David Rosen and Associates, 2008 CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 64 square foot. Therefore, the costs attributed to construction alone for a typical 2,200 square foot, wood frame home would be at minimum $211,860. A reduction in amenities and quality of building materials (above a minimum acceptability for health, safety, and adequate performance) could result in lower sales prices. Additionally, pre- fabricated, factory built housing may provide for lower priced housing by reducing construction and labor costs. An additional factor related to construction costs is the number of units built at the same time. As the number of units developed increases, construction costs over the entire development are generally reduced, based on economies of scale. This reduction in costs is of particular benefit when density bonuses are utilized for the provision of affordable housing. Although it should be noted that the reduced costs are most attributed to a reduction in land costs; when that cost is spread on a per unit basis. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 65 This page intentionally left blank. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 66 ENERGY CONSERVATION As the price of power continues to rise, households have through necessity been devoting more of the household income to energy cost. This condition has further eroded the affordability of housing. No relief is in sight, as one representative from Southern California Edison reinforced in a news article: "higher rates are necessary to assure reliable supplies of electricity in the years ahead." The City can explore possible partnership with utility companies to promote energy rebate programs. There are energy conservation measures the City of Tustin can promote and others that are mandated by State laws. The State of California has adopted energy conservation standards for residential building in Title 25 of the California Administrative Code. Title 25 applies to new residential construction or an addition to an existing housing unit. Active solar systems for water heating can be encouraged but they are still rather expensive and can only be used as a back -up to an electric or gas system. They are cost efficient in the long run but pose a short -term impact to affordable housing. Permits for solar systems can be approved ministerially by the Community Development Department, and permits are issued same -day whenever possible. The City can also explore and streamline permits processing for approved green building. Other energy conservation method could be contributed to site and building design. For an example through proper lots placement at subdivision and buildings' orientation, maximum day lighting can be achieved. Light- colored "cool roofs" can also be applied to new homes or roof replacement projects to promote energy savings. Water- efficient landscapes, efficient irrigation, and use of permeable paving materials also would contribute to energy saving. This can be achieved through updates to the City's landscape and irrigation guidelines. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 67 This page intentionally left blank. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 68 ;UMMARY OF I'RLVIOUS HOUSING ELEMENT PROGRAMS To develop appropriate programs to address the housing issues identified in this Housing Element Update, the City of Tustin has reviewed the housing programs adopted as part of its 2009 Housing Element, and evaluated the effectiveness of these programs in delivering housing services. By reviewing the progress in implementation of the adopted programs, the effectiveness of the last element, and the continued appropriateness of these identified programs, a comprehensive housing program strategy has been developed. The following section reviews the progress in implementation of the programs, the effectiveness of the 2009 Element to date, and the continued appropriateness of the identified programs. The results of the analysis provided the basis for developing the comprehensive housing program strategy for the future planning period, as well as goals for the planning period in progress. PROGRESS IN IMPLEMENTING THE 2009 GOALS AND OBJECTIVES Table HTM -35 presents a comparison of the quantified objectives of the previous element and actual achievements since 2006. Table HTM -34 contains a list of projects by program area during the 2006 - 2014 period. The 2007 SCAG Regional Housing Need Assessment indicated a new construction need in Tustin by 2014 of 2,381 units, of which 512 units were for very low income households, 410 for low income, 468 for moderate income and 991 above moderate income. TABLE HTM- 34 SUMMARY TABLE EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS, 2006 -2014 I Although goals were not allocated to specific income group, the City attempted to utilize RHNA percentages to fulfill RHNA objectives. Source: The City of Tustin, Housing Element, 2009; Effectiveness of Housing Element Programs, 2008. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 69 New Constructi on Rehab/Preservation Housing Assistance Income Group Goal Actual Goal' Actual Goal' Actual Very-Low 512 362 198 166 2,079 2,329 Low 410 127 200 135 35 0 Moderate 468 189 72 4 15 0 Above Moderate 991 1,424 0 0 0 Total 2,381 2,102 470 305 4129 2,329 I Although goals were not allocated to specific income group, the City attempted to utilize RHNA percentages to fulfill RHNA objectives. Source: The City of Tustin, Housing Element, 2009; Effectiveness of Housing Element Programs, 2008. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 69 REVIEW OF PAST PERFORMANCE State law establishes an eight -year cycle regulating housing element updates. In compliance with the SCAG cycle, the Tustin Housing Element was updated in 1989 at which time it was found to be in compliance with State law, and was updated again in 1994. In 1997, the City of Tustin initiated a comprehensive General Plan update, and the Housing Element was again updated to accommodate the MCAS Reuse Plan and to ensure consistency with other General Plan Elements, as well as to address recent changes in State law. These amendments were adopted on January 16, 2001. In 2002 and 2009, the City updated its Housing Element and was certified by The State's Housing and Community Development Department in compliance with State's Law. Review of Past Housing Element Objectives Tables HTM -33 and HTM -34 summarize the performance of the 2009 Element's goals and objectives. Table HTM -35 provides program by program review of the previous Housing Element, containing a discussion on the effectiveness and continued appropriateness of each program. The time period covered in this analysis is 2006 -2014. The following discussion is a brief highlight of the progress, effectiveness and appropriateness of the past Housing Element Objectives. 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Sources: (1) Effectiveness of Housing Programs 2006.2014, City of Tustin; (2) Five Year Implementation Plan for the Town Center and South Central Redevelopment Project Areas for Fiscal Years 2005 -2006 to 2009 -2010 CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 114 APPENDIX A AFFORDABILITY GAP ANALYSIS CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM City of Tustin Affordability Gap and leveraged Financing Analysis 1.0 Executive Summary The City of Tustin retained David Paul Rosen & Associates (DRA) to prepare an affordability gap analysis and evaluation of leveraged financing options for new residential development in Tustin. The "affordability gap" methodology determines the difference between the supportable mortgage on the unit at affordable rents and sales prices and the actual development cost of the unit. The gap analysis provides planning -level estimates of the typical per unit subsidized required to make different types of housing affordable to households at alternative income levels. The per unit affordability gaps calculated in this report are based on housing Prototypes that are 100% affordable to households at each of the income levels modeled (or in the case of the leveraged financing analysis, at the mix of income levels necessary to meet the requirements and/or competitive standards of the leveraged financing programs). However, the results can be used in estimating subsidy requirements for mixed income housing developments as well. Under the assumption that the market rate units are financially feasible without subsidy, the subsidy requirement for a mixed income development can be estimated by multiplying the number of affordable units by the appropriate per unit affordability gap. The results of the gap analysis provide a useful tool to the City of Tustin and Tustin Redevelopment Agency for capital planning purposes. DRA recommends that the subsidy Provided to any individual housing development be determined based on analysis of the specific economic conditions pertaining to that project The first step in the gap analysis establishes the amount a tenant or homebuyer can afford to contribute to the cost of renting or owning a dwelling unit based on established State and Federal standards. Income levels, housing costs and rents used in the analysis are defined below using 2007 published data for Tustin. The second step estimates the costs of new housing construction in Tustin. For this purpose, DRA, in collaboration with City staff, formulated five prototypical housing developments (one rental development and four owner developments) suitable for the Tustin market today. DRA estimated the cost to develop these housing prototypes in Tustin under current housing conditions using information on actual recent housing developments provided by Tustin and Orange County area developers. The third step in the gap analysis establishes the housing expenses borne by the tenants and owners. These costs can be categorized into operating costs, and financing or mortgage obligations. Operating costs are the maintenance expenses of the unit, including utilities, property maintenance and/or Homeownership Association (HOA) fees, property taxes, management fees, property insurance, replacement reserves, and insurance. For the rental prototype examined in this analysis, DRA assumes that the City of Tustin Affordability Gap and Leveraged Financing Analysis Page t r landlord pays ail but certain tenant -paid utilities as an annual operating cost of the unit paid from rental income. For owner prototypes,' DRA assumes the homebuyer pays all operating and maintenance costs for the home. Financing or mortgage obligations are the costs associated with the purchase or development of the housing unit itself. These costs occur when all or a portion of the development cost is Financed. This cost is always an obligation of the landlord or owner. Supportable Financing is deducted from the totalydevelopment cost, less any owner equity or downpayment, to determine the gap between the supportable mortgage on the affordable units and the cost of developing those units. For the rental housing prototype, the gap analysis calculates the difference between total development costs and the conventional mortgage supportable by net operating income from restricted rents. For owners, the gap is the difference between development costs and the supportable mortgage plus the buyer's down payment. Affordable housing costs for renters and owners are calculated based on California Redevelopment Law definitions and occupancy standards. Household income is adjusted based on an occupancy standard of one person per bedroom plus one. The gaps for the owner prototypes'are summarized in Table 1. The gaps have been calculated for the following three income levels:. r" Affordable Income Limit Housing Cost 1. Very Low Income 50% of Area Median Income (AMI), adjusted 30% of 50% AMI for household size 2. Low Income 801/o of AMI, adjusted for household size 30`yo of 70% AM] 3. Moderate Income 120% of AMI, adjusted for household size 35% of 110% AMI Depending upon the source of subsidy for ownership housing, the gaps may vary. For example, Federal HOME funds do not require deduction of a utility allowance in the calculation of affordable mortgage payment However, under California Redevelopment Law, owner affordable housing expense is defined to include monthly utility costs. This increases the ownership gaps. The affordability gaps shown in Table 1 include utility allowance deductions. The gaps for the rental prototype, without non -local leveraged financing, are summarized in Table 2. The gaps have been calculated for the following three income levels: ., City of Tustin Affordability Gap and Leveraged Financing Analysis Page 2 F Affordable Housing Income Limit Cost 1. Very Low Income 50% of Area Median Income (AMI), AMI 30 /o o of 5090 adjusted for household size 2. Low Income 80% of AMI, adjusted for household size 30% of 60% AMI 3. Moderate Income 120% of AMI, adjusted for household size 30% of 110% AMI DRA produced, under separate cover, a comprehensive review of Federal, State, and private sources of funding that mi ?ht be used to subsidize affordable rental and ownership housing in Tustin. For ownership housing, per unit mortgage assistance, as available, generally reduces the gap on a dollar for dollar basis. For rental developments, the use of the Low Income Housing Tax Credit •Program and/or tax- exempt bonds is more complicated, because of the formulas for calculating tax credits and the specific income targeting required. Therefore, for the rental prototype, we have examined the following leverage scenarios: 1. 9% Low Income Housing Tax Credits (Federal only)'; 2. 4% tax credits with tax - exempt bonds; and 3. 4% tax credits, tax - exempt bonds, and the Multifamily Housing Program (MHP) of the Califomia Department of Housing and Community Development (HCD). The assumptions and findings are described in the following section. The sources and uses for each leveraged rental scenario are summarized in Table 3. ' Since Orange County was designated as a Difficult to Develop Area (DDA) by HUD in 2007, projects in the County are eligible for a 130'% basis boost for the calculation of Federal tax credits but are not eligible for State tax credits City of Tustin Affordability Gap and Leveraged Financing Analysis Page 3 Source: David Paul Rosen & Associates City o(Tustin Affordability Cap and Leveraged Financing Analysis Nge 4 Table 1 Homeowner Per Unit Subsidy Requirements' City of Tustin 2008 Very Low Low Moderate prototyDClUnll Bedroom Count Incomes Incomes Income, Owner Prototype .Cis Attached Townhome Two Bedroom $366,000 $322,400 $195,500 Three Bedroom $387,8011 5339,400 5198,400 Four Bedroom $426,800 $374,600 $222,300 Average $393,500 $345,500 5205,400 Owner Prototype N2s Stacked Fiat Condominium One Bedroom $258,600 $219,900 $107,100 Two Bedroom $259,000 $215,500 $88,600 Three Bedroom $267,100 $218,800 577,800 Four Bedroom $290,500 $238,300 $86,000 Average $268,800 $223,100 $89,900 Owner Prototype #37 High Density Condominium One Bedroom 5407,500 $368,800 $256,000 Two Bedr000m $432,500 $389,000 $262,100 Three Bedroom 5542,000 $493,700 $352,600 Four Bedroom $569,400 $517,200 $364,800 Average $467,900 $442,200 $306,900 Owner Prototype #48 Mixed Use, Ground Floor Retail One Bedroom $491,700 $453,000 5340,200 Two Bedr000m S537,400 $493,900 $366,900 Three Bedroom $595,000 $546,600 $405,600 Average $541,300 $497,800 5370,900 Source: David Paul Rosen & Associates City o(Tustin Affordability Cap and Leveraged Financing Analysis Nge 4 Notes to Table 1: I Per unit subsidy requirements are calculated as per unit total development cost less affordable home purchase price, based on an occupancy standard of one person per bedroom plus one, per California Redevelopment Law. Affordable home purchase price is calculated based on monthly affordable housing expense, inclusive of mortgage principal and interest, property taxes and insurance, utilities and homeowners association (HOA) dues, Calculations are based on the following assumptions: 30 -year mortgage interest rate of 8 percent; average property tax rate of 1.20 percent; property insurance costs of $50 per month; HOA dues of $175 per month; and a utility allowance calculated based on County of Orange, Housing and Community Services Department utility allowance schedule, effective October 1, 2006. 2 Very low income owner affordable housing is cost calculated as 30 percent of 50 percent of AMI, adjusted for household size. Average very low income affordable home purchase price is $70,764. Low income owner affordable housing cost is calculated as 30 percent of 70 percent of AMI, adjusted for household size. Average low income affordable home purchase price is $116,457. Moderate income owner affordable housing cost is calculated as 35 percent of 110 percent of AMI, adjusted for household size. Average moderate income affordable home purchase price Is $249,723. ' Owner Prototype 11 average unit size is 1,296 square feet. Average per unit development cost is $468,663. Per unit development costs are adjusted by unit size/bedroom count. Owner Prototype 12 average unit size is 1,142 square feet. Average per unit development cost is ;339,591. Per unit development costs are adjusted by unit size/bedroom count Owner Prototype 13 average unit size Is 1,350 square feet. Average per unit development cost is $558,617. Per unit development costs are adjusted by unit size/bedroom count. I Owner Prototype 14 average unit size is 1,515 square feet Average per unit development cost is $608,112. Per unit development costs are adjusted by unit size/bedroom count. City of Tustin Affordability Gap and Leveraged Financing Analysis Page 5 Table 2 Tenant Per Unit Subsidy Requirements' Rental Housing Prototype: Stacked Flat Apartments City of Tustin 2008 Unit Bedroom Count One Bedrooms Two Bedroom' Three Bedroom' Four Bedroom' Average Renter Prototype Stacked Flat Apartments Very low Law Moderate Income Income' Income $311,300 $294,600 $211,400 $348,000 $329,300 $235,600 $321,800 $301,000 $197,000 $402,000 $379,600 $174,800 $345,775 $326,125 $204,700 Source: David Paul Rosen & Associates. City of Tustin Affordability Gap and Leveraged Financing Analysis Page 6 Notes to Table 2: ' Tenant per unit subsidy requirements are calculated as per unit total development cost less per unit tenant supported debt. Tenant supported debt is calculated based on tenant monthly operating income which equals: affordable monthly rent, inclusive of utilities, less a monthly per unit operating cost of $300, property taxes assumed at an average annual rate of 1.20 percent; and a 3 percent vacancy rate. Tenant supported debt calculations are based on a 30 -year mortgage interest rate of 8 percent and a debt coverage ratio of 1.25. Affordable monthly rents are based on household income, adjusted for household size assuming an occupancy standard of one person per bedroom plus one, per C2106mla Redevelopment Law. ' Very low income renter affordable housing cost Is calculated as 30 percent of 50 percent of AMI, adjusted for household size. Average very low income affordable monthly rent is $847. ' Low income renter affordable housing cost calculated as 30 percent of 60 percent of AMI, adjusted for household size. Average low income affordable monthly rent is $1,033. ' Moderate income renter affordable housing cost calculated as 30 percent of 110 percent of AMI, adjusted for household size. Average moderate income affordable monthly rent is $1,963. - s One bedroom unit is 750 square feet. Per unit total development cost is 5321,075. s Two bedroom unit is 950 square feet. Per unit total development cost is $362,224. ' Three bedroom unit is 1,050 square feet. Per unit total development cost Is $382,799. s Four bedroom unit Is 1,250 square feet. Per unit total development cost is $423,947. City of Tustin Affordability Gap and Leveraged financing Analysis Page 7 Table 3 Average Per Unit Subsidy Requirements Rental Housing Prototype: Stacked Flat Apartmenb Leveraged Financing Scenarios City of Tustin 20011 Leveraged Financing Scenario 9% Tax Credits 4% Tax Credits, Tax- Exempt Bonds 4% Tax Credits, Tax - Exempt Bonds, Multi - Family Housing Program (MHP) Renter Prototype Stacked Flat Apartmenb $57,000 $140,100 s• .�r fie Source: David Paul Rosen & Associates. City of Tustin Affordability Cap and Leveraged Financing Analysis Page 8 This page intentionally left blank. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM APPENDIX B CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM This page intentionally left blank CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM REFERENCES A. Documents 1. 2000 Census Report. U.S. Department of Commerce, Bureau of the Census. 2. 2010 Census Report. U.S. Department of Commerce, Bureau of the Census. 3. 2007 -2011 American Community Survey. U.S. Department of Commerce, Bureau of the Census. 4. Comprehensive Housing Affordability Strategy for Fiscal Years 2007 -2008 to 2017 -2018, David Paul Rosen & Associates (DRA). 5. Marine Corps Air Station (MCAS) Tustin Specific Plan/ Reuse Plan, Adopted February 2003, Amendments through June 2007. 6. California State Department of Finance, 2013, E -5 Population and Housing Estimates. 7. Orange County Projections 2010 Modified, Center for Demographic Research at California State University, Fullerton. 8. Orange County Ten - Year Plan to End Homelessness, 2012, County of Orange. 9. Southern Califomia Association of Governments, Regional Housing Needs Assessment, 2012. 10. City of Tustin, Zoning Ordinance. 11. City of Tustin, General Plan, as amended through November 2012. 12. City of Tustin 2010 -2015 Consolidated Plan. 13. City of Tustin Comprehensive Annual Financial Report For the Year Ended June 30, 2011. 14. City of Tustin Consolidated Annual Performance and Evaluation Report, September 26, 2012. 15. Market Overview Report for City of Tustin, Realfacts. 16. Third Five -Year Implementation Plan for The Town Center and South Central Redevelopment Project Areas (FY 2005 -06 to 2009 - 2010), Tustin Community Redevelopment Agency, December 2004. 17. Final Environmental Impact Statement/ Environmental Impact Report (EIS /EIR) for the Disposal and Reuse of MCAS -Tustin (Program EIS /EIR for MCAS - Tustin), January 16, 2001. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 18. Response to Comments, Final Volume 2 and 3 of Final Environmental Impact Statement/ Environmental Impact Report (EIS /EIR) for the Disposal and Reuse of MCAS - Tustin. 19. City Council Staff Reports for St. Anton and Irvine Company projects, November 6, 2012. 20. State of California, Department of Housing and Community Development, Website. 21. Orange County Client Management Information System Year End Progress Report, Orange County Housing Partnership, December 2007 22. Orange County Department of Education, Division or School and Community Services, McKinney -Vento Homeless Education Assistance Act, 2006 -07. 23. 2013 State Income Limits, State Department of Housing and Community Development. 24. Marshall & Swift 25. State of California Government Code Sections 65580 et seq. B. Persons and Organizations 1. Elizabeth A. Binsack, Community Development Director Community Development Department, Tustin (714) 573 -3031 2. Jerry Craig, Program Manager Tustin Successor Agency (714) 573 -3121 3. Justina Willkom, Assistant Director - Planning Community Development Department, Tustin (714) 573 -3115 4. Scott Reekstin, Principal Planner Community Development Department, Tustin (714) 573 -3016 5. Edmelynne Hutter, , Associate Planner Community Development Department, Tustin (714) 573 -3174 CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM 6. Lieutenant Steve Lewis Tustin Police Department (714) 573 -3271 6. Ben Savill Community Housing Advisory Council Regional Center of Orange County 7. John Luker Orange County Rescue Mission Village of Hope (714) 247 -4300 CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM This page intentionally left blank. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM APPENDIX C MAJOR EMPLOYERS IN TUSTIN CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM This page intentionally left blank. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM TABLE H -1 LIST OF MAJOR EMPLOYERS IN TUSTIN, CA 2011 Company /Address No. Emp. Product/Service Young's Market Co LLC 2,100 Distributor 14402 Franklin Ave Tustin, CA 92780 Tustin Unified School District 1,728 Education 300 South C St. - Tustin 92780 Lamppost Pizza Corp 1,4001 Corporation 3002 Dow Ave, Tustin, CA Ricoh Electronics, Inc 1,384 Manufacturer 1100 Valencia Ave. - Tustin, 92780 Tosiba America Medical Systems 900 Distributor, 2441 Michelle Dr. - Tustin, 92780 Medical Equipment Rockwell Collins - (714) 317 -8102 600 Manufacturer 14192 Franklin Ave.- Tustin, 92780 Costco Wholesale 450 Wholesale Trade 2700 Park Ave. - Tustin 92780, 2655 El Camino Real, Tustin, CA Cherokee International 350 Power Supplies 2841 Dow Ave. - Tustin, 92780 City of Tustin 300 Government 300 Centennial Way - Tustin 92780 Raj Manufacturing Inc 260 Manufacturing 2692 Dow Ave, Tustin, CA Cash Plus Inc 250 Financial Services 3002 Dow Ave, Tustin, CA Kleen Impressions 250 Cleaning Services 1730017th St # j Pmb 388, Tustin, CA Ricoh Business Solutions 250 Business Services 1123 Warner Ave Tustin, CA 92780 Southern California Pipeline 235 Construction 15991 Red Hill Ave, Tustin, CA Home Depot 203 Retail 2782 El Camino Real - Tustin, 92780 Health South Tustin Rehab Hospital 200 Medical 14851 Yorba St, Tustin, CA Logomark, Inc. 200 Wholesale Trade 1201 Bell Ave. - Tustin 92780 Red Robin Gourmet Burgersz 2001 Retail 3015 El Camino Real, Tustin, CA SMC Corporation of America 200 Manufacturer 14191 M ford Rd. - Tustin 92780 Straub Distributing Company3 200 Wholesale Trade 2701 Dow Ave. - Tustin, 92780 Tustin Toyota 200 Automotive Dealer 36 Auto Center Dr, Tustin, CA SOURCE: City of Tustin Comprehensive Annual Financial Report For the Year Ended June 30, 2011 1 The employee count appears to include those employed at locations outside of Tustin. 0 Red Robin Gourmet Burgers was located at 3015 El Camino Real in 2011 and has relocated to 2667 Park Avenue. 3 Straub Distributing Company was located in Tustin in 2011, but is no longer doing business in Tustin. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM This page intentionally left blank. CITY OF TUSTIN HOUSING ELEMENT TECHNICAL MEMORANDUM ATTACHMENT C PLANNING COMMISSION RESOLUTION NOS. 4227 & 4228 RESOLUTION NO. 4227 A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF TUSTIN RECOMMENDING THAT THE CITY COUNCIL ADOPT A NEGATIVE DECLARATION PURSUANT TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT FOR GENERAL PLAN AMENDMENT 2013-002 (HOUSING ELEMENT UPDATE). The Planning Commission of the City of Tustin does hereby resolve as follows: • The Planning Commission finds and determines as follows: A. Implementation of the Housing Element Update's goals includes proposed housing development within the MCAS-Tustin Reuse Plan area and infill areas outside the Reuse Plan area throughout the City. Since the majority of future housing units identified in the Housing Element Update would be located within the MCAS-Tustin Reuse Plan area, an Initial Study was prepared to determine if impacts to the environment of such housing were analyzed and addressed in the previously approved Final EIS/EIR for the Disposal and Reuse of the MCAS Tustin (Program EIS/EIR for MCAS-Tustin); B. That on January 16, 2001, the City of Tustin certified the Program Final Environmental Impact Statement/Environmental Impact Report (FEIS/EIR) for the reuse and disposal of MCAS Tustin. On December 6, 2004, the City Council adopted Resolution No. 04-76 approving a Supplement to the FEIS/EIR for the extension of Tustin Ranch Road between Walnut Avenue and the future alignment of Valencia North Loop Road. On April 3, 2006, the City Council adopted Resolution No. 06-43 approving an Addendum to the FEIS/EIR. And, on May, 13, 2013, the City Council adopted Resolution No. 13-32 approving a second Addendum to the FEIS/EIR." C. The FEIS/EIR and its Supplement and Addenda is a program EIR under the California Environmental Quality Act ("CEQA"). The FEIS/FEIR and its Supplement and Addenda considered the potential environmental impacts associated with development on the former Marine Corps Air Station, Tustin; D. Pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15063, the City of Tustin has completed an Initial Study (Exhibit 1) and determined that all effects associated with the implementation of the Housing Element Update were evaluated in the Program EIS/EIR for MCAS Tustin, that no new effects would occur, that no substantial increase in the severity of previously identified significant effects would occur, that no new mitigation measures would be required, that no applicable mitigation measures previously not found to be feasible would in fact be feasible, and that there are no new mitigation measures or alternatives applicable to the project that would substantially reduce effects of the project that have not been considered and adopted. II. The Planning Commission of the City of Tustin does hereby find that the proposed project is within the scope of the Final EIS/EIR for the Disposal and Reuse of MCAS Tustin (Program EIS/EIR for MCAS-Tustin), an EIR approved from an earlier project, and that the Resolution No. 4227 Page 2 Program EIS/EIR for MCAS-Tustin adequately describes the general environmental setting of the Housing Element Update, the significant environmental impacts of the implementation of the Housing Element Update, and alternatives and mitigation measures related to each significant effect. III. The Planning Commission of the City of Tustin recommends that the Tustin City Council adopt a Negative Declaration incorporating herein by reference all of the applicable mitigation measures identified in the Program EIS/EIR for MCAS-Tustin. PASSED AND ADOPTED at a regular meeting of the Tustin Planning Commission held on the 13th day of August, 2013. TEV ZAK Chairperson ELIZABETH A. BINSACK Planning Commission Secretary STATE OF CALIFORNIA ) COUNTY OF ORANGE ) CITY OF TUSTIN I, ELIZABETH A. BINSACK, the undersigned, hereby certify that I am the Recording Secretary of the Planning Commission of the City of Tustin, California; that Resolution No. 4227 passed and adopted at a regular meeting of the Tustin Planning Commission, held on the 13th day of August, 2013. ELIZABETH A. BINSACK Planning Commission Secretary RESOLUTION NO. 4228 A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF TUSTIN RECOMMENDING THAT THE CITY COUNCIL APPROVE GENERAL PLAN AMENDMENT 2013- 002, UPDATING THE TUSTIN HOUSING ELEMENT PURSUANT TO GOVERNMENT CODE SECTION 65588. The Planning Commission of the City of Tustin does hereby resolve as follows: I. The Planning Commission finds and determines as follows: A. That California State Law Section 65588 requires each City to review as frequently as appropriate and to revise its Housing Element as appropriate. B. That the City of Tustin adopted an amendment of its Housing Element on June 16, 2009. C. That the Housing Element is required to be updated to reflect new statutory requirements. D. That a public workshop was held on April 23, 2013, to familiarize the general public and the Planning Commission with the purpose and intent of the Housing Element Update. E. That the California Department of Housing and Community Development has reviewed the Draft Housing Element and provided minor verbal comments to the City on August 7, 2013 F. That a public hearing was duly called, noticed, and held on General Plan Amendment 2013-002 on August 13, 2013, by the Planning Commission to consider and provide further opportunity for the general public to comment on and respond to the proposed Housing Element Update. G. That pursuant to the California Environmental Quality Act (CEQA) Guidelines Section 15063, the City of Tustin has completed an Initial Study to evaluate the potential environmental impacts associated with General Plan Amendment 2013-002, and a Negative Declaration was prepared for the project. II. The Planning Commission hereby recommends that the City Council approve General Plan Amendment 2013-002, updating the Housing Element as identified in "Exhibit 1" attached hereto. Resolution No. 4228 Page 2 PASSED AND ADOPTED by the Planning Commission of the City of Tustin, at a regular meeting on the 13th day of August, 2013. TEr OZAK Chairpe on ELIZABETH A. BINSACK Planning Commission Secretary STATE OF CALIFORNIA ) COUNTY OF ORANGE ) CITY OF TUSTIN I, ELIZABETH A. BINSACK, the undersigned, hereby certify that I am the Planning Commission Secretary of the City of Tustin, California; that Resolution No. 4228 was duly passed and adopted at a regular meeting of the Tustin Planning Commission, held on the 13th day of August, 2013. ELIZABETH A. BINSACK Planning Commission Secretary ATTACHMENT D MINUTES FROM THE PLANNING COMMISSION MEETING OF AUGUST 13, 2013 ( MINUTES REGULAR MEETING TUSTIN PLANNING COMMISSION AUGUST 13, 2013 7:00 p.m. CALL TO ORDER INVOCATION/PLEDGE OF ALLEGIANCE: Commissioner Lumbard ROLL CALL: Present: Chair Kozak Chair Pro Tern Thompson Commissioners Altowaiji, Lumbard and Smith Staff Present Elizabeth A. Binsack, Director of Community Development Lois Bobak, Assistant City Attorney Dana L. Ogdon, Assistant Director of Community Development Justina Willkom, Assistant Director of Community Development Scott Reekstin, Principal Planner Amy Stonich, Senior Planner Edmelynne V. Rutter, Senior Planner Ryan Swiontek, Senior Planner Jerry Craig, Economic Development & Housing Manager Adrianne DiLeva-Johnson, Senior Management Assistant PUBLIC CONCERNS: Tina Blenz stepped forward to address the Commission. Ms. Blenz asked questions of the Commission generally regarding HUD, CDBG, liquefaction zones, and nitrates. Approved CONSENT CALENDAR: 1. APPROVAL OF MINUTES — JULY 09, 2013, PLANNING COMMISSION MEETING. RECOMMENDATION: That the Planning Commission approve the minutes of the July 09, 2013, meeting as provided. ( Motion: It was moved by Thompson, seconded by Lumbard to move the I Consent Calendar. Motion carried 5-0. Minutes—Planning Commission August 13, 2013—Page 1 of 5 clarity on the tables; how the goal is set for housing build-out; Il amendments being brought back to the Planning Commission or being forwarded to City Council; what the current status is on our Housing Authority and Former Redevelopment Agency; and clarification on the environmental document's intent. Jerry Craig stepped forward to respond to the Commission's inquiry on the Housing Authority and Former Redevelopment Agency. The public hearing opened at 7:53 p.m. Jacqui Kerze stepped forward to speak representing Regional Center of Orange County. Thanked the City for including a program within the Housing Element to communicate with the Regional Center regarding housing opportunities for those with developmental disabilities. Requested that the word "affordable" be inserted before "housing" within the specified program. Hopes that the City continues to consider those with developmental disabilities. The public hearing closed at 7:56 p.m. IAltowaiji Inquired on the difference between very low and extremely low income; and, compensation for the changes in the availability of affordable homes. Lumbard Commended staff on their work. Is confident that the objectives of the Housing Element were met, and community input has been addressed. He is satisfied with the end result. Smith Agreed with Commissioner Lumbard and applauded staff's efforts. Thompson Noted amendments requested to the tables. Acknowledged for the record that comments from HCD and the Airport Land Use Commission are yet to be added to the report. Kozak Agreed with the comments of his colleagues. Stated the outreach to the community speaks highly of the work done by staff on the Housing Element. Is in support of moving forward with recommendation of the Housing Element to City Council. Motion: It was moved by Thompson, seconded by Altowaiji to adopt Resolution No. 4227 and Resolution No. 4228 as amended. None REGULAR BUSINESS Minutes—Planning Commission August 13, 2013—Page 3 of 5 ( 8:15 p.m. ADJOURNMENT: The next regular meeting of the Planning Commission is scheduled for Tuesday, August 27, 2013, at 7:00 p.m. in the City Council Chamber at 300 Centennial Way. ALL. STE .•ZAK Chairperson I� as Gu a- ELIZABETH A. BINSACK Planning Commission Secretary I Minutes—Planning Commission August 13, 2013—Page 5 of 5 ATTACHMENT E HCD LETTER DATED AUGUST 22, 2013 • - •:ky • •■ 14 : , d\• \ - \ ■11 \• ;ZIP AL • • -In DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT o�"`muNnt. DIVISION OF HOUSING POLICY DEVELOPMENT / :r .) °es, 2020 W.El Camino Avenue,Suite 500 Sacramento,CA 95833 �" z' (916)263-2911 /FAX(916)263-7453 °411k $ www.hcd.ca.gov °gtiroave•• RECEIVED August 22, 2013 AUG 28 2013 Ms. Elizabeth Binsack, COMMUNITY DEVELOPMENT DEPT Director of Community Development City of Tustin 300 Centennial Way Tustin, CA 92780 Dear Ms. Binsack: RE: Review of the City of Tustin's 5th Cycle (2013-2021) Draft Housing Element Thank you for submitting the City of Tustin's draft housing element update received for review on June 24, 2013, along with additional revisions received on August 20, 2013. Pursuant to Government Code Section 65585(b), the Department is reporting the results of its review. The revised draft element meets the statutory requirements of State housing element law. The draft element will comply with State housing element law (Article 10.6 of the Government Code) when the element is adopted and submitted to the Department, pursuant to Government Code Section 65585(g). The Department conducted a streamlined review of the draft housing element based on the City meeting all eligibility criteria detailed in the Department's Housing Element Update Guidance. A telephone conversation on August 7, 2013 and subsequent conversations with you, Mr. Scott Reekstin and Ms. Justina Willkom, of your staff facilitated the review. In addition, the Department considered comments from the Kennedy Commission and Mr. Ben Savill, private citizen pursuant to Government Code Section 65585(c). To remain on an eight year planning cycle, pursuant to Senate Bill 375 (Chapter 728, Statutes of 2008) the City must adopt its housing element within 120 calendar days from the statutory due date of October 15, 2013 for SCAG localities. If adopted after this date, City will be required to revise the housing element every four years until adopting at least two consecutive revisions by the statutory deadline (Government Code Section 65588(e)(4)). For more information on housing element adoption requirements, please visit the Department's website at: http://www.hcd.ca.gov/hpd/hrc/plan/he/he review adoptionsteps110812.pdf. Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City must continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available and considering and incorporating comments where appropriate. • Ms. Elizabeth Binsack Page 2 The Department is pleased to inform the City that prior 4th cycle housing element compliance makes the City eligible to meet one of the threshold requirements of the Housing Related Parks Program (HRP) that rewards local governments for approving housing affordable to lower-income households. The HRP Program, funded by Proposition 1C, provides grant funds to eligible local governments for every qualifying unit permitted since 2010. Grant awards can be used to fund park-related capital asset projects. More specific information about the Program is available on the Department's website at http://www.hcd.ca.gov/hpd/hrpp/. The Department appreciates the hard work and dedication of Mr. Reekstin in preparation of the housing element and looks forward to receiving Tustin's adopted housing element. If you have any questions or need additional technical assistance, please contact Melinda Coy, of our staff, at (916) 263-7425. Sincerely, len A. Campora Assistant Deputy Director ATTACHMENT F CORRESPONDENCE AIRPORT LAND USE COMMISSION ORANGE COUNTY FOR ORANGE COUNTY /Wit 3160 Airway Avenue • Costa Mesa, California 92626 • 949.252.5170 fax: 949.252.5178 RECEIVED September 9, 2013 Scott Reekstin, Principal Planner SEP 1 2013 City of Tustin 300 Centennial Way COMMUNITY DEVELOPMENT DEPT Tustin, CA 92780 Subject: Referral Confirmation Notice for City Tustin Housing Element Update Dear Mr. Reekstin: This is to confirm that the Airport Land Use Commission (ALUC)staff has received the referral request for the proposed City of Tustin General Plan Housing Element Update. Upon examining your submittal package, we noted that it constitutes a request for the ALUC to consider this project. However, prior to accepting the submittal as complete,ALUC staff will need the following information: 1. Building height limits for the neighborhoods within the MCAS Tustin Specific Plan Area. 2. A copy of Figure 2 MCAS Tustin Specific Plan Area from the Initial Study for the Housing Element Update(the figure was not found on your city webpage). 3. A copy of Figure 3 Vacant& Underutilized Land in the City Tustin from the Initial Study for the Housing Element Update(the figure was not found on your city webpage). 4. The maximum height limits for areas V7 and V8 found on Figure 3 Vacant& Underutilized Land in the City of Tustin (if these areas cover more than just the MCAS Tustin Specific Plan Area). Conditional upon the prompt receipt(by 3 p.m. on Wednesday, September 11, 2013) of the additional information described above, and your referral being otherwise complete and sufficient, I would expect your project to be agendized for the meeting of September 19, 2013 for a consistency determination by the Commission. Assuming that the above process is completed in a timely manner, a copy of the staff report regarding your item will be provided to you prior to the Commission meeting. It would be helpful if you or a member of your staff could be at the Commission's meeting. If you have additional questions regarding the submittal process please contact Lea Choum at(949) 252-5123 or at Ichoum c,ocair.com. Sincerely, c ari A. Rigoni Executive Officer STAI E,OF CALIFORNIA—CALIFORNIA STATE TRANSPORTATION AGENCY EDMUND G BROWN Jr. Governor DEPARTMENT OF TRANSPORTATION �t DISTRICT 12 t{ "--,.�i 3347 MICHELSON DRIVE,SUITE 100 RECEIVED - IRVINE,CA 92612-8894 PHONE (949)724-2000 FAX (949)724-2019 AUG .. energy gy e dent! TTY 71 1 O 2�13 Be energy efficient www.dot.ca.gov COMMUNITY DEVELOPMENT DEPT August 15, 2013 Mr. Scott Reekstin File: IGR/CEQA Principal Planning SCH#: None City of Tustin Log#: 3327 Community Development Department SR-261 300 Centennial Way Tustin, CA. 92780 Dear Mr. Reekstin: Thank you for the opportunity to review and comment on Housing Element Update Initial Study. The Housing Element Update addresses housing needs of Tustin residents through the 2013- 2021 planning period. Based on the analysis of vacant land and underutilized land within the City, the majority of the required `fair share' housing units (1,227) would be provided at Tustin Legacy, also known as the former Marine Corps Air Station (MCAS) Tustin. Other units would be provided through scattered infill developments within the City. The Department of Transportation (Caltrans) is a commenting agency on this project and has the following comments for your consideration. • 1. The Department encourages and supports General Plans (and related Element Updates) which foster efficient land-use patterns that(a) support improved mobility and reduced dependency on single-occupant vehicle trips, (b) accommodates an adequate supply of housing for all incomes, (c) reduce impacts on valuable habitat, productive farmland, and air quality, (d) increases resource use efficiency, and (e) results in safe and vibrant neighborhoods. 2. Caltrans District 12 reviewed and commented on the original Final Joint Environmental Impact Statement/Environmental Impact Report (As modified by Final Supplement#1 and Addendum to FEIS/EIR) for the Disposal and Reuse of MCAS Tustin SCH No. 94071005. After the traffic analysis was completed, it was determined that there were no impacts that would require a traffic mitigation agreement with Caltrans. 3. As subsequent areas of the original program FEIS/EIR, such as this Housing Element Update are circulated for review, any significant total net changes to land uses or to agreed-upon traffic/transportation mitigation under the FEIS/EIR would require additional evaluation to determine if there are new direct and/or cumulative impacts to the State Highway System. This Housing Element Update does not propose any significant total net land use changes. "Calirans improves mobility across California" Mr. Reekstin August 12 2013 Page 2 4. The Department recognizes that non-motorized travel is a vital element of the transportation system and healthy, more sustainable communities. We encourage you to consider the inclusion of pedestrian and bicycle routes, especially safe routes to schools and interregional and intermodal trail and commute linkages, thereby expanding streetscape options for a range of users: pedestrians, bicyclists, transit riders, and automobiles. If you have any questions or need to contact us, please do not hesitate to me at (949) 724- 2086. Sincerely, MAUREEN EL 1-IARAKE Branch Chief, Regional-Community-Transit Planning District 12 "Caimans improves mohiliy across Cal(fornia" ,Kennedy August 13, 2013 COMMISSION www.kennedycommi ssion.org 17701 Cowan Ave.,Suite 200 Irvine,CA 92614 949 250 0909 Mr. Scott Reekstin, Principal Planner Fax 949 263 0647 City of Tustin 300 Centennial Way Tustin, CA 92780 RE: Comments on Draft 2014-2021 Housing Element Update (June 2013) Dear Mr. Reekstin: Thank you for the opportunity to review and comment on the City of Tustin's 2014-2021 draft Housing Element. We have reviewed the draft and are submitting this letter to provide public comments. The Kennedy Commission (the Commission) is a broad based coalition of residents and community organizations that advocates for the production of homes affordable for families earning less than$20,000 annually in Orange County. Formed in 2001, the Commission has been successful in partnering and working with Orange County jurisdictions to create effective housing and land-use policies that has led to the new construction of homes affordable to lower income working families. The Commission would like to commend the City for its leadership and commitment in encouraging and facilitating the development of homes affordable to lower income families, especially through the implementation of an inclusionary requirement at Tustin Legacy. In the 2006-2014 Housing Element planning period,the City constructed 282 homes for extremely low-, 80 very low and 127 low-income homes.' The Orange County Rescue Mission Village of Hope was also completed in 2008 and it provides 192 emergency and transitional homes for the homeless. In addition, the City approved the Anton Legacy Apartments which will provide 88 very low- and 73 low-income homes for working families. This new development will not only provide quality homes that will be affordable to workforce families, but it will also create jobs and provide an economic boost to the local economy. As the City moves forward with the draft Housing Element update, the Commission urges the City to continue it's support for the development of affordable homes. The Commission has provided the following recommendations for the City to incorporate: 1. Continue the City's partnership with the Commission to facilitate the development of affordable rental homes for lower income working families in the City. 2. Prioritize and commit potential funding sources (e.g., SERAF repayments and boomerang funds) to proposed extremely low-income affordable rental developments that leverage additional funding sources (e.g., Low-Income Housing Tax Credits). Housing Element Tustin Technical Memorandum,p. 128,June 2013. � �N tF��I m Iit,.v vl.nue(tl'��'�i i��t li Im�� m thrllu-,iul iiUtut�i I titi�in�.1 t1lo Ail Irli lu Ot 1n i�Cuun�io'+'i�u""i iuil"v`+IncuitY ii11ilti use lit 11:�:,� r.7a..[r�.:IT/Rfis^."' Mr. Scott Reekstin, Principal Planner August 13, 2013 Page 2 of 3 3. Provide by-right incentives and concessions of certain development standards that developers are not entitled to in areas outside of the Tustin Legacy, in exchange for a dedication of 15 percent of homes affordable to families at extremely low, very low and low-income levels in the City. This should be considered in the City's proposed zoning studies in 2015 (e.g., Housing Program 1.20). 4. Encourage the development of housing affordable to extremely low-income households through application processing fee waivers for proposed developments with a minimum of ten percent very low-income homes (e.g., please refer to Huntington Beach's 2014- 2021 Housing Element Program 14). For the 2014-2021 Housing Element planning period, the City has a Regional Housing Needs Assessment(RHNA)of 283 very low-and 195 low-income households. To address the lower income RHNA housing goals, the City identified two areas in the Tustin Legacy for the development of new homes affordable to lower income working families:Neighborhood D and Neighborhood G.2 In particular, the proposed development in Neighborhood G, the Anton Legacy Apartments will provide 161 new affordable homes(88 very low- and 73 low-income) that will be counted towards the City's lower income RHNA needs. With the remaining RHNA need of 195 very low-income homes and 122 low-income homes, it is important the City create effective policies and programs that encourage and facilitate the development of rental homes for lower income families. The need to increase quality affordable rental homes should be a high priority in the City. While the economic downturn is slowly recovering and for-sale homes have been on the rise in the County, the cost to rent apartment homes are also on the rise. In the City, the averae rent for a 2-bedroom market rate apartment home ranges between$1,695 to $1,828 a month; however, affordable rent for a very-low income household is$872 a month and$1,046 for a low-income household.4 The gap between market rent and affordable rent places a significant economic burden for very low-and extremely low-income families to continue to financially live and work in this City. Conclusion Given the importance of the draft 2014-2021 Housing Element update, the Commission welcomes the opportunity to continue our dialogue on how we can partner with City staff to ensure that the draft Housing Element includes specific policies that will result in new affordable homes for extremely low, very low and low-income working families. 2 Housing Element Tustin General Plan,p.80,June 2013. ' Housing Element Tustin Technical Memorandum,p.42,June 2013. 4 Housing Element Tustin Technical Memorandum,p.43,June 2013. Mr. Scott Reekstin, Principal Planner August 13, 2013 Page 3 of 3 Please keep us informed of any revisions, updates and meetings regarding the draft 2014-2021 1-Iousing Element and if you have any questions, please free to contact me at (949)250-0909 or cesarc @kennedycommission.org. Sincerely, Cesar Covarrue Executive Director cc: Melinda Coy, California Housing and Community Development Department AIRPORT LAND USE COMMISSION ORANGE COUNTY FOR ORANGE COUNTY -4LUG 3160 Airway Avenue • Costa Mesa, California 92626 • 949.252.5170 fax: 949.252.5178 August 12, 2013 RECEIVED Scott Reekstin, Principal Planner AUG 13 2013 City of Tustin/Planning Department 300 Centennial Way COMMUNITY DEVELOPMENT DEPT Tustin, CA 92780 Subject: General Plan Housing Element Update Dear Mr. Reekstin: Thank you for the opportunity to review the Notice of Intent to Adopt a Negative Declaration for the proposed City of Tustin Housing Element Update in the context of the Airport Land Use Commission's Airport Environs Land Use Plan for John Wayne Airport (AELUP for JWA). The proposed Housing Element Update discusses the City's strategy to preserve and enhance the community's character, expand housing opportunities for the City's various economic segments, and provide the policy guidance for local decision making related to housing. As stated in the initial study, the majority of the housing units required by the Housing Element Update would be provided at the former MCAS-Tustin. Other units would be provided through scattered infill development within the City. That portion of the City falls within the Federal Aviation Regulation (FAR)Part 77 notification and imaginary surfaces for John Wayne Airport (JWA). We recommend that the Housing Element Update include a discussion of issues that should be considered when developing projects surrounding JWA such as height restrictions, safety issues, and noise. A referral by the City to the ALUC may be required for this project due to the location of the proposal within an AELUP Planning Area and due to the nature of the required City approvals (i.e. Housing Element Update)under PUC Section 21676(6). With respect to project submittals, please note that the Commission wants such referrals to be submitted to the ALUC for a determination, between the Local Agency's expected Planning Commission and City Council hearings. Since the ALUC meets on the third Thursday afternoon of each month, submittals must be received in the ALUC office by the first of the month to ensure sufficient time for review, analysis, and agendizing. Thank you for the opportunity to comment on the proposed Housing Element Update. Please contact Lea Choum at 949.252.5123 or via email lehoum@ocair.com if you require additional information. Sincerely, eZ<A761,,thi,_ Kari A. Rigoni Executive Officer Submission to the City of Tustin Housing Element Update Team 5.13.13 Thank you very much for providing this opportunity for members of the public to contribute to the City of Tustin's Housing Element Update. I am a resident of Tustin, an owner of one of the affordable homes in the Tustin Field I development at the corner of Edinger and Harvard, and father of an 8 year old Tustin resident who has a developmental disability. When we first discovered that our son had this disability, one of my first thoughts was 'What will happen to him when my wife and I die? Where will he live? Who will look after him?'. At the time of his birth, we were living in rental accommodation, and one of our first priorities was to buy a house, so that he would have some kind of stable housing for the future. We were lucky enough to qualify for moderate income affordable housing in the City of Tustin, and were able to buy one of the affordable units in Tustin Field I when it came up for re-sale. What we didn't understand at the time that we purchased the house was that our children have no right to inherit the house from us upon our death, so that our developmentally disabled son risks being turned out of the house if the City forces the house to be put up for sale upon our death. But in addition to being concerned about my own son's housing needs, I am concerned about the needs of other children and adults with developmental disabilities living in Orange County, and for that reason I became a member of the Community Housing Advisory Council of the Regional Center of Orange County (RCOC). RCOC is the non-profit agency responsible for coordinating, monitoring and paying for the services required by the over 17,000 people with developmental disabilities in Orange County. RCOC does not itself own or operate housing for the developmentally disabled population of Orange County, but it partners with service providers to support developmentally disabled children and adults to reside where they choose to. The City Council and Planning Commission need to be very clear that if the City helps to provide affordable housing for the developmentally disabled in Tustin, it will not be stuck with the bill for providing the required services and supports for those residents to live successfully in such housing. Needs Analysis Regional Center of Orange County knows of at least 428 children and adults with developmental disabilities living within the City of Tustin. There may be others, in particular those from minority communities, who have chosen not to receive services from Regional Center or who do not know of or understand the service provided by the Regional Center. So the figure is probably closer to 500. A large percentage of Tustin's developmentally disabled persons are virtually 'invisible', since they still reside at home with aging parents and are, thus, not part of any income census. Any assessment of need must include the following considerations: a. the need for VERY LOW, LOW income housing - housing for individuals living on SSI (around $875 per month) or, if working, on a very low wage; b. the need for individuals with Developmental Disabilities to live near community resources (grocery stores, transportation, libraries, recreation, banks etc.); c. the need for these individuals to live in close proximity to others with developmental disabilities, so that they are not socially isolated; d. the need for these individuals to receive services and supports in order to live successfully in the community, services and supports that may be most cost effectively provided if the individuals live in close proximity to each other; e. the need to acknowledge that we are planning for life long residences reflecting the life long disability of this population and therefore, the very low, low income designations need to be memorialized in perpetuity. These needs should be spelled out in the Housing Element Update. Resource Analysis Any analysis of potential resources should include the following resources: • Regional Center of Orange County (RCOC). • Community Housing Resources Inc. (CHRI), a 501(c)3 non-profit corporation founded in 1997 in collaboration with the Regional Center of Orange County, to provide affordable housing options for the County's developmentally disabled population. • Local developers with expertise and experience in developing affordable housing for the developmentally disabled population, such as Jamboree Housing in Irvine. • Acacia Housing and Anaheim Supportive Housing, who are the co- developers of Integrity Cottages (in Anaheim), a community of 48 independent affordable studio apartments for single adults with a developmental disability. • Non-profit agencies that provide services to and/or advocate for the developmentally disabled population in Orange County, such as United Cerebral Palsy of Orange County (UCP-OC), the Down Syndrome Association of Orange County (DSAOC), Goodwill of Orange County, Ability First, YMCA, Grandparent Autism Network etc. • Foundations in Orange County that fund programs for the developmentally disabled population, such as Team Up for Down Syndrome • Parents and families of Tustin residents with developmental disabilities • Landowners and property owners sympathetic to the developmentally disabled population Policy Program & Innovative Solutions The City of Tustin should establish a Stakeholder Task Force to study all options for providing affordable housing for the developmentally disabled population of Tustin. This will help insure that all resources, constraints, and opportunities are identified and explored, that any proposed solutions are appropriate and sustainable, and will provide support to the City in implementing its commitments and obligations under the Housing Element Update. The City should build upon the most successful models from around the State for the creation of affordable housing for persons with developmental disabilities, such as through the use of set-asides, scattered site acquisition, new construction, and pooled trusts. The City should explore options for a village-type affordable housing and community development for the developmentally disabled population, along similar lines to the Villages of Hope for the homeless population in Tustin. If the City of Tustin allows developers to "buy out" of their responsibility to provide X% of affordable housing within each new project, any "buy out" land/funds/resources should be ring-fenced for the provision of affordable housing, with priority for the unmet needs of the developmentally disabled population. Priority should be given to the developmentally disabled population in any new affordable housing developments in the City. Just as the Salvation Army was allocated six affordable housing units in the Tustin Field I housing development to provide transitional housing to homeless families, a non-profit with expertise in managing housing for the developmentally disabled population should be allocated a number of affordable housing units in any new housing development to provide housing for developmentally disabled adults. Any affordable housing that is developed in the City of Tustin should be protected in perpetuity, such as through a City/Community Land Trust. The City should work with partners to establish a program whereby local land-owners, home-owners and business-owners would be encouraged to donate and/or will land and/or property to be used for the provision of affordable housing. The City should work with partners and families to facilitate collective purchases of 4-bedroom homes, which could provide affordable housing for three adults with developmentally disabled adults and one live-in care- worker. The City should work with partners to seek State and Federal monies for direct support of housing construction and rehabilitation specifically targeted for affordable housing for persons with developmental disabilities. The City should consider working with neighboring cities to pool resources to acquire and develop land for affordable housing for the developmentally disabled population. Affordable housing programs in the City should allow parents of children with developmental disabilities to purchase homes on behalf of their children and/or to leave homes to their developmentally disabled children in their wills. Affordable housing developments for the developmentally disabled population in the City should incorporate principles of co-housing, whereby residents have their own personal living space but also shared space for communal cooking, dining, recreation, laundry etc., to encourage social interaction, mutual support and community-building. Any time an existing affordable housing unit in the City comes up for re-sale, priority should be given to a non-profit agency to purchase it for the provision of affordable housing to the developmentally disabled population. Local realtors could be brought in as partners in such a program. The City should be on the look-out for motels and apartment buildings that are being vacated or put up for sale that would be suitable for conversion to affordable housing for the developmentally disabled population. Mobile Homes can be a good option for developmentally disabled adults if they have family members or trusts or a non-profit agency able to purchase the home for them, since Section 8 HUD vouchers can be used to pay the ground rent on mobile homes. Mobile Home parks for seniors should be encouraged to open up to developmentally disabled adults, and should allow family members or trusts or non-profit agencies to buy mobile homes for use by developmentally disabled adults. Home Owners' Association Fees can be a major challenge for those few working developmentally disabled adults who are able to qualify for the purchase of low-income affordable housing units, but who struggle to pay the mortgage, property tax and HOA fee each month. The City should look at ways to address this. For further information, please contact: Ben Savill Work Tel: (714) 796 8168 E-mail: homes4teachers @gmail.com From: Jacqui Kerze fmailto:ikerze@rcocdd.coml RECEIVED Sent: Monday, August 12, 2013 5:03 PM AUG 13 To: Reekstin, Scott 2013 Cc: Ben Savill (homes4teachers @gmail.com) Subject: Housing Element-Developmental Disabilities COMMUNITyDEVELOPMENTDEPT Hi Scott, Thank you for the time you took to speak with me last week. I have reviewed the HE and wonder if you might be able to answer just a couple of questions below? As you know, many of our folks are considered low-low income and have approximately$275.00 per month to spend on rent. We are concerned that there will be a lack of affordable housing in the future. Please let me know if you need any additional information. 1. How many dwelling units in the City of Tustin are currently affordable to people living on 551 (approximately$886 total per month), and how many more such units are there likely to be by the end of this housing element cycle? 2. Will any policies and/or programs be included in the Housing Element Update to ensure that people with developmental disabilities get any of those units? Thanks and look forward to seeing you tomorrow evening. Jacqui Jacqui Kerze, Community Outreach Coordinator 'ad: 714-796-5299 A: 714-796-5200 Jkerze(a.rcocdd.com