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HomeMy WebLinkAbout02 PC REPORT HOUSING ELEMENT UPDATE DocuSign Envelope ID:8006C2A9-22FE-46F4-98BF-7CD88EB1 D270 AGENDA REPORT ITEM 92 MEETING DATE: SEPTEMBER 14, 2021 TO: PLANNING COMMISSION FROM: COMMUNITY DEVELOPMENT DEPARTMENT SUBJECT: GENERAL PLAN AMENDMENT (GPA) 2021-0002 (HOUSING ELEMENT UPDATE) APPLICANT: CITY OF TUSTIN 300 CENTENNIAL WAY TUSTIN, CA 92780 LOCATION: CITY-WIDE ENVIRONMENTAL: NEGATIVE DECLARATION REQUEST: GENERAL PLAN AMENDMENT (GPA) 2021-0002 (6t" CYCLE HOUSING ELEMENT UPDATE) RECOMMENDATION: 1. That the Planning Commission adopt Resolution No. 4439, recommending that the City Council adopt a Negative Declaration for GPA 2021-0002. 2. That the Planning Commission adopt Resolution No. 4440, recommending that the City Council approve GPA 2021-0002, updating the Housing Element. APPROVAL AUTHORITY: Government Code Sections 65353 through 65355 require: o The Planning Commission to hold at least one (1) public hearing before approving a recommendation on the amendment to the General Plan. o The Planning Commission to make a 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). o The City Council to hold at least one (1) public hearing prior to amending a General Plan. BACKGROUND: State law requires that each city adopt a General Plan to guide land use and development. Among the seven (7) required "elements" of the General Plan is the Housing Element. The DocuSign Envelope ID:8006C2A9-22FE-46F4-98BF-7CD88EB1 D270 Planning Commission Report GPA 2021-0002 September 14, 2021 Page 2 Housing Element sets forth goals, policies and programs that address the future housing needs for all income levels over an eight (8) year planning period which coincides with a Regional Housing Needs Assessment(RHNA) projection period. The RHNA is mandated by State Housing Law as part of the periodic process of updating local housing elements of the General Plan. RHNA quantifies the need for housing within each jurisdiction during specified planning periods. The City is required by State law to update its Housing Element every eight (8) years. Housing Element planning periods are sometimes referred to as "cycles." The City's existing housing element covers the planning period extending from 2013-2021, which is referred to as the "Fifth Housing Element cycle" in reference to the five (5) required updates that have occurred since the comprehensive revision to the State Housing Element law in 1980. Every city and county in the Southern California Association of Government (SCAG) region is required to prepare a Housing Element update for the sixth planning cycle, which spans the 2021-2029 period (October 15, 2021 — October 15, 2029). The due date for the sixth Housing Element Update is October 15, 2021. The following provides a general timeline describing major milestones in preparing Tustin's draft 2021-2029 Housing Element update: • November 10, 2020 - Planning Commission held a public workshop via Zoom to provide a general overview of the update process. • January 28, 2021 - February 28, 2021 — Bilingual Housing Element community online survey resulted in 194 responses, including two (2) in Spanish. • May 11, 2021 —Joint City Council and Planning Commission public workshop to discuss the Housing Element framework, community outreach efforts and survey results, suitable sites for meeting RHNA, housing programs, and next steps. • June 30, 2021 —Draft 2021-2029 Housing Element draft was transmitted to State Housing and Community Development (HCD) for a 60-day review which coincided with an initial 30-day public review period. • June 30, 2021 —Start of draft Housing Element public comment period. • July 1, 2021 —July 31, 2021 - Housing Element community online survey re-opened and an additional 119 responses were received, including four (4) in Spanish. • August 12, 2021 — City Housing Element update team met with HCD staff to receive preliminary verbal comments on the draft document. • August 12, 2021 — City Housing Element update team initiates the work effort to revise the draft Housing Element to address HCD's verbal comments. • August 17, 2021 —Receive and file report to the City Council which described the inclusion of two (2) additional areas into the suitable sites inventory, specifically The Tustin Market Place and the Enderle Center, to further facilitate the equitable dispersion of housing units for various income levels, in response to public comments. • August 24, 2021 - Initial Study (IS)/Negative Declaration (ND) available for public review which analyzed the potential for significant impacts on the environment resulting from implementation of the 2021-2029 Housing Element Update pursuant to the California Environmental Quality Act (CEQA). The review period concludes September 23, 2021. • August 27, 2021 —As a follow-up to verbal comments received from HCD on August 12, 2021, the City received a written letter from HCD describing changes necessary to the draft document to bring it into compliance with State law. • September 7, 2021 — Receive and file report to the City Council to review revisions to the distribution of residential units previously reviewed at its August 17, 2021 meeting. • September 8, 2021 — City staff completes revisions to draft Housing Element update, in response to HCD's comments, and transmits the revised document to the Planning Commission and posts on City website for public review and comment. DocuSign Envelope ID:8006C2A9-22FE-46F4-98BF-7CD88EB1 D270 Planning Commission Report GPA 2021-0002 September 14, 2021 Page 3 The recommendation provided by the Planning Commission at its September 14, 2021 meeting will be forwarded to the City Council for consideration during its October 5, 2021 meeting. City staff will then transmit the adopted Housing Element Update for review and final certification by HCD. DISCUSSION: The 2021-2029 Housing Element identifies existing and future housing needs (RHNA) of all types for persons of all economic groups in the City. The purpose of the Housing Element requirements is to develop an understanding of the existing and projected housing needs within the community and to set forth policies, programs and schedules that promote the preservation, rehabilitation and development of a variety of housing types and costs throughout Tustin. Cities must carry out an assessment of housing needs and an inventory of resources and constraints pertinent to the meeting of these needs. The draft Housing Element consists of the following four (4) sections and six (6) supporting appendices: • Section I — Describes compliance with State law, General Plan consistency, and public participation; • Section 11 — Describes the City's demographic, economic and housing characteristics and governmental and non-governmental constraints to the production of housing; • Section III — Provides goals and policies that address housing needs; • Section IV— Housing Programs; • Appendix A - Review of the City's past performance in implementing current housing policies and programs; • Appendix B - Identifies sites that, in total, can achieve Tustin's assigned 2021 Regional Housing Needs Allocation (RHNA) by income level for the planning period (2021 —2029); • Appendix C — Identifies resources available for the development, rehabilitation and preservation of housing; • Appendix D — Analyzes barriers that restrict access to opportunity and identification of measures to counter these barriers (Affirmatively Furthering Fair Housing); and • Appendix E — Provides a comprehensive community engagement outreach plan to encourage and solicit public participation and feedback from residents, community members, and stakeholders using a variety of media including an online survey, social media news releases, direct mailings, and web updates. Housing Characteristics, Constraints, Goals, Policies and Programs The Draft Housing Element describes the City's demographic, economic and housing characteristics and governmental and non-governmental constraints to the production of housing and provides goals and policies that address various housing needs which include but not limited to the following housing issue areas: • Provide a broad range of housing types to meet the needs of existing and future residents; • Identify and promote adequate sites for future residential development that are dispersed throughout the City; • Identify ways to address housing-related problems and overcrowding; • Ensure that existing housing is maintained and preserved; and • Promote equal housing opportunity for all. DocuSign Envelope ID:8006C2A9-22FE-46F4-98BF-7CD88EB1 D270 Planning Commission Report GPA 2021-0002 September 14, 2021 Page 4 The goals listed within the Draft Housing Element to address these housing issues areas are listed below, and policies to implement each goal are outlined under Section III of the Housing Element: • Goal 1: Provision of 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 commensurate with the City's identified housing needs in the RHNA allocation; • Goal 2: Promote fair housing opportunities for all people regardless of their special characteristics as protected under State and Federal fair housing laws; • Goal 3: Preserve and improve existing housing supply and prevent displacement of existing tenants; • Goal 4: Conserve and improve the condition of the existing housing; and • Goal 5: Ensure that new housing is sensitive to the existing natural and built environment. The Housing Programs (Section IV of the Housing Element) define the specific actions the City will undertake to achieve the stated goals and policies. The housing programs for addressing community needs are described according to the following four (4) issue areas: • Provision of Adequate Housing Sites • Fair Housing and Special Needs • Preserve and Improve Housing Opportunities • Sustainable Housing Regional Housing Needs Assessment The Regional Housing Needs Assessment (RHNA) is mandated by State law to quantify the need for housing throughout the State. This informs the local planning process to address existing and future housing needs resulting from projected state-wide growth in population, employment, and households. The Housing Element Update must address the housing needs identified by the RHNA prepared by SCAG for Tustin. As the Council of Governments (or regional planning agency), SCAG is responsible for overseeing the RHNA process for the Southern California region, which encompasses six (6) counties (Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura) and 191 cities in an area covering more than 38,000 square miles. In March 2021, SCAG assigned RHNA allocations to Tustin and other Orange County cities. Tustin was assigned a total of 6,782 new housing units which is further distributed into four (4) income categories as follows (Table 1): Table 1 6t" Cycle Regional Housing Needs Allocation for Tustin Units Very-Low Income (<50% of AMI) 1,724 Low Income (50-80% of AMI) 1,046 Moderate Income (80-120% of AMI) 1,132 Above Moderate Income (>120% of 2,880 AMI) Total 6,782 DocuSign Envelope ID:8006C2A9-22FE-46F4-98BF-7CD88EB1 D270 Planning Commission Report GPA 2021-0002 September 14, 2021 Page 5 While the City's draft Housing Element for 2021-2029 identifies adequate sites (Refer to discussion under "Site Inventory") to fulfill the needs established by RHNA, construction of new housing units will depend upon the private market, including a landowner's desire to develop their land, private financing, developer interest and overall market demand. In addition, public housing subsidies, which can assist in promoting housing development, are not necessarily consistent or accessible and will depend upon the availability of government funds — local, county, state, and federal. The responsibility of the City is to encourage the construction of affordable housing by identifying adequate sites suitable for residential development to meet RHNA obligation, providing policies, programs that promote the development of a variety of housing types, and assistance to developers by facilitating the review and approval of development permits. Sites Inventory The City must demonstrate in its Housing Element the ability to meet the assigned housing needs, through the provision of sites suitable for residential development. To meet the assigned housing needs, the Housing Element identifies sites (Table 2) that may be suitable for residential development in the following areas: • Ten (10) Downtown Commercial Core Specific Plan (DCCSP) mixed-use sites; • Four (4) Red Hill Avenue Specific Plan (RHASP) mixed-use sites; • Four (4) Tustin Legacy Specific Plan (TLSP) mixed-use urban residential sites; • The Market Place; and • The Ederle Center In addition, the City estimates the construction of 35 ADUs and the completion of the 132 transitional housing units (125 units at the Village of Hope and 7 units at the House of Ruth) over the eight (8) year planning period based on development trends and entitled projects, respectively. In order to accommodate the additional units to meet RHNA as described in Table 2, an amendment to the TLSP and the creation of overlay zones for The Market Place and Ederle Center will need to be accomplished within the first three (3) years following adoption of the Housing Element, as required by State law. Table 2 6t" C cle Recommended Sites to Meet RHNA ReILmaining Additional Above- Very-Low Low Specific Plan or Site Units/ Units to Total Moderate Moderate Name Entitled meet Units Income Income Income(M) Income Units RHNA (VL) (L) (AM) Tustin Legacy SP 3,325 730 4,055 945 636 699 1,775 Red Hill Ave.SP 500 0 500 124 79 83 214 Downtown 747 0 747 187 117 125 318 Commercial Core SP Enderle Center 0 413 413 102 67 69 175 The Market Place 0 900 900 225 141 150 384 ADUs/JADUs 35 35 9 6 6 14 Transitional Housing 132 132 0 0 0 Total 4,704 2,078 6,782 1,724 1.046 1,132 2,880 DocuSign Envelope ID:8006C2A9-22FE-46F4-98BF-7CD88EB1 D270 Planning Commission Report GPA 2021-0002 September 14, 2021 Page 6 Community Enq .jement and Public Outreach The City of Tustin recognizes the importance of public participation and consultation during the preparation of the 2021 — 2029 Housing Element Update, and as a result, developed a comprehensive Community Engagement Plan (Attachment A) to solicit input from residents, community members, and stakeholders throughout the update process. The following provides a summary of the City's Community Engagement Plan outreach efforts: • Public Meetings - Multiple public workshops and public hearings held, providing opportunities for community and public participation and input, including with residents, stakeholders, Planning Commission and City Council, and options for virtual community participation; • Online Community Survey - Two (2) separate releases of an online community survey in English and Spanish provided to gather public feedback related to local housing needs; • Mailings- Direct mailing and email notifications delivered to Tustin residents, businesses, apartment owners, service providers, and other agencies in English and Spanish; • Stakeholders - Individual stakeholder meetings held with multiple organizations as part of the consultation process; • Website - Creation of a focused webpage on the City's website dedicated to the Housing Element Update which was routinely maintained and updated with pertinent information; • Social Media and Multi-Media News Releases - Specific information, provisions and updates advertised in English and Spanish through the City's website, social media posts, paid advertising via social media and in newspaper and magazine publications, press releases, video features, flyers, postcards, and posters; and • On-going public input - Opportunities for review and comment of the Draft Housing Element update using all the community outreach methods and media listed above. Details of all of the outreach efforts are listed in the Community Engagement Plan (Draft Housing Element - Appendix A). The City conducted two (2) online surveys which solicited comments from Tustin residents and community to gather feedback regarding various housing topics. The online Housing Element Community survey was first opened from January 28, 2021 through February 28, 2021 and the City received 194 responses, including two (2) in Spanish. Following the May 11, 2021 City Council/Planning Commission Housing Element Workshop, the survey was reopened from July 1 — July 31, 2021. City staff received an additional 119 responses, four (4) of those were responses to the Spanish language survey. The re-opening of the survey in July 2021 coincided with the draft Housing Element document public comment period. An overview summary of all of the survey responses is included as Attachment B. On August 24, 2021, the City provided joint notification regarding the availability of the Notice of Intent/Negative Declaration and review of the revised Housing Element in the Orange County Register and notified those on the City's Interested Party List. The Draft Housing Element and its relevant documents have been continuously posted on the City's website to allow the public and interested organizations easy access and the ability to download the draft document and provide comment. DocuSign Envelope ID:8006C2A9-22FE-46F4-98BF-7CD88EB1 D270 Planning Commission Report GPA 2021-0002 September 14, 2021 Page 7 Public Comments The City received fifteen (15) public comments (Attachment C) during the initial review of the Draft Housing Element which was between June 30, 2021 and July 30, 2021. The comments received are summarized below. More than half of the comments expressed concern over the number of units planned, particularly the low-income distribution, being concentrated in one (1) major area (Tustin Legacy) rather than distributed throughout the City. The following summarizes their concerns: • Concern over the apportionment, density and geographic placement of additional low- income housing primarily identified to occur within the Tustin Legacy area. Respondents encouraged the City to consider the overall housing increase, and, particularly the lower- income housing to be more equally apportioned/distributed throughout the City and be available to all rather than concentrated within the Tustin Legacy area. • Affordable housing should be dispersed equitably throughout the community. • Residents within the current Tustin Legacy neighborhood expressed displeasure of current high taxes in addition to the Tustin Legacy identified to being the recipient of the majority of homeless and low-income housing allocations. • Concern that they did not physically receive or receive communication about the available survey. • Concern that the City is not providing enough site capacity for very low-income housing. RHNA requires 1,724 very low-income units and the Draft Element provides a capacity for 1,699; a deficiency. Their suggestion is to provide a fifteen (15) to thirty (30) percent capacity buffer at each level of income to avoid violating the No New Loss requirement. • Concern regarding specific Site 6 being held by one (1) owner and unknown willingness by said owner to sell property to pursue housing which would result in a site inventory deficiency. • Concern that the plan will not realize attainable housing options for residents and workers of Tustin. • Encourage the City to adopt a compliant housing element update by the required due date of October 15, 2021. • Inquiry regarding whether the City plans to build condominiums and small houses for young adults just starting their careers and want to live in the City of Tustin. • Request for information regarding rental assistance programs. • Request update regarding housing developments in Tustin. • Request for the Housing Element Technical Memorandum. In response to these public comments, the draft Housing Element, released in June 2021, was subsequently amended by the City Council at meetings that took place on August 17, 2021 and on September 7, 2021. Specifically, the revisions added and redistributed units to The Tustin Market Place and Enderle Center sites with no increase in the number of units at Tustin Legacy area. These revisions also included adjustments to the distribution of units at various income levels (based on RHNA percentages) evenly and proportionately throughout the sites. On September 7, 2021, the City also received extensive comments from Public Law Center. Due to the extensive nature of the comments, staff is preparing a Response to Comments summary to assist the Commission and the public with the review of the Draft Housing Element. This DocuSign Envelope ID:8006C2A9-22FE-46F4-98BF-7CD88EB1 D270 Planning Commission Report GPA 2021-0002 September 14, 2021 Page 8 summary will be available prior to the September 14, 2021 Planning Commission meeting and will be posted on the dedicated Housing Element webpage: www.tustinca.org/HousingElement . HCD Review On August 27, 2021, the City received a letter from HCD on the review of the Tustin Draft Housing Element (Attachment D). HCD indicated in the letter that although the City's Draft Housing Element addresses many statutory requirements; revisions were necessary to comply with State Housing Element Law. In particular, the site inventory must demonstrate realistic capacity, the constraints section must adequately address a variety of governmental and non-governmental constraints to housing development, and programs require further clarification and/or stronger language and timeframes. The Draft Housing Element (Exhibit A to Attachment F) has been revised to address HCD comments. ENVIRONMENTAL REVIEW: The proposed project GPA 2021-0002 is considered a "project' subject to the terms of the CEQA. Pursuant to the CEQA Guidelines Section 15063, the City has completed an Initial Study and prepared a Negative Declaration for the draft Housing Element for consideration and recommendation by the Planning Commission. The Notice of Intent to Adopt a Negative Declaration (ND) and the Initial Study (IS) were advertised for public review from August 24, 2021 to September 23, 2021. The City provided notification of the availability of the IS and ND to those included on the City's Interested Party List which includes various organizations (i.e. youth, seniors, veterans and disabled), homeless shelters, housing advocates, religious & cultural organizations, fair housing council, service providers, housing builders and developers, homeowners' associations, CDBG recipients, multi-family apartment managers (TEAMs), survey respondents. The IS prepared for this project is included as Exhibit A of Resolution No. 4339 (Attachment E). As of September 1, 2021, one (1) public comment has been received on the ND. The comment questioned whether the adequacy of the environmental analysis conducted based on the City's RHNA allocation and the number of units that could be potentially constructed within the City. In response to this comment, it is important to note that the Housing Element is a planning and policy document that does not approve, permit or entitle any residential development projects. The creation of overlay zones and/or an amendment to Specific Plan(s) will be required in order to accommodate additional housing units to the meet the City's RHNA allocation at the properties identified in the Sites Inventory, and are therefore only considered candidate sites. Additional evaluation and a separate environmental assessment will be completed concurrently with the adoption of an overlay/rezone and/or amendment to the City's General Plan, and is required by State law to take place within three (3) years of the City's adoption of the 2021-2029 Housing Element. As a result, it would be premature to analyze the rezoning and/or amendments for the candidate sites under CEQA and would not foster meaningful environmental review. The Housing Element Update is a policy document, and its adoption would not, in itself, produce environmental impacts. No actual development or re-zoning is proposed as part of the Housing Element Update. The Housing Element Update would not directly result in changes to land use or zoning designations that would place housing within an area of potential exposure to hazardous materials. Development proposed as a result of the Housing Element Update would also be required to obtain City approval on a project-by-project basis for any discretionary action and undergo a separate environmental process to access potential environmental impacts. DocuSign Envelope ID:8006C2A9-22FE-46F4-98BF-7CD88EB1 D270 Planning Commission Report GPA 2021-0002 September 14, 2021 Page 9 Furthermore, mitigation measures that are required by underlying EIR's would be implemented as development is proposed. Therefore, the ND concludes that the draft Housing Element would have no impact. RECOMMENDATION: Based on the above-mentioned information, City staff is recommending that the Planning Commission adopt Resolution No. 4439, recommending that the City Council adopt a Negative Declaration for General Plan Amendment 2021-0002 and Resolution No. 4440 recommending that the City Council approve General Plan Amendment 2021-0002 updating the Housing Element. oigned by: Duoc�utSiignnead by i -(A R. VCA16wvy : . 0Qk&" �08FB188CE3B04C8 � A54A5... Erica H. Demkowicz, AICP Justina L. Willkom Senior Planner Community Development Director DocuSigned by: _I J Vw 6_ �"W} 6v" 2ESAE588F82047F... Irma Huitron Assistant Director - Planning Attachments: A. Community Engagement Plan B. Summary of Online Housing Element Survey Responses C. Public Comments D. Letter from HCD dated August 27, 2021 E. Planning Commission Resolution No. 4439 • Exhibit A: Initial Study/Negative Declaration F. Planning Commission Resolution No. 4440 • Exhibit A: Final Draft General Plan Housing Element and Appendices ATTACH ME NT A COMMUNITY ENGAGEMENT PLAN N I I r w l r „ 0 . . .w yy ti JI Iwo JI MW • • - - • • • Tustin s. 2021-2029 Housing Element Contents Background .........................................................................................................................................3 ProjectPurpose...................................................................................................................................3 Goals & Objectives...........................................................................................................................3 TargetedStakeholders .....................................................................................................................4 Outreach & Engagement Strategies...............................................................................................7 Education & Awareness Strategies...................................................................9 City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan P a g e 1 2 Purpose This COMMUNITY ENGAGEMENT PLAN is for the City of Tustin's 6r"Cycle Housing Element(2021-2029). This Plan describes strategies for engaging with residents and stakeholders through an online survey, education and awareness campaigns, and public meetings. Due to COVID-19 restrictions on in-person meetings,this outreach plan focused on alternatives such as virtual meetings, targeted email blasts, mailings to stakeholders, unpaid and paid social media postings, posters at community facilities, distribution of flyers, dedicated project website, and newspaper advertisements. Background The City of Tustin is preparing the 2021 — 2029 HOUSING ELEMENT UPDATE to evaluate current and future housing conditions, and identify housing sites and programs to meet the community's needs. While updating the housing element is a State requirement, it is also an opportunity to assess its accomplishments and progress toward meeting housing goals put forth in the previous Housing Element in 2013. The 2021- 2029 Housing Element will outline the goals, policies and programs needed to promote the development and preservation of safe, accessible, and diverse housing in the City. Goals and Objectives The GOAL of the COMMUNITY ENGAGEMENT PLAN for the 2021 — 2029 Housing Element Update is to guide the City's community and stakeholder engagement efforts and to provide information about the importance in participating in the Housing Element Update. The OBJECTIVES of the Community Engagement Plan include: Building public awareness of the Housing Element Update, its requirements, and the City's vision and goals to adequately plan to meet housing needs to all of its residents; Educating the Tustin community on the requirements of the Housing Element Update, and progress since the previous Housing Element; Engaging community members and key stakeholder groups to provide input on potential policies and programs that will align with Tustin resident's housing needs; Facilitating discussions with community members and decision makers to identify how and where additional housing could be located within the City; and, Providing a concise document to the Tustin City Council and Planning Commission for adoption, with input and updates from public outreach and engagement activities during the Housing Element Update. Al �t City of Tustin 2021 — 2029 Housing Element Update Community Engagement Plan P a g e 3 Targeted Stakeholders To meet the OBJECTIVES of the City of Tustin's COMMUNITY ENGAGEMENT PLAN, the City requested feedback from a diverse set of stakeholders within the community who represent multiple interests and experiences related to housing.This section of the Community Engagement Plan includes the various organizations and agencies that were included in the City's outreach efforts. A database was maintained and updated with stakeholder contact information throughout the outreach process. The various stakeholders include, but are not limited to: RESIDENTS, APARTMENT OWNERS, SERVICE PROVIDERS, ORGANIZATIONS, and AGENGIES. Isoli Affordable Housing Advocates ASIS Organizations and agencies that advocate for safe and affordable housing opportunities for residents of all ages and abilities within the City of Tustin. This includes but is not limited to: - Kennedy Commission - University of Irvine - Tustin Planning - Habitat for Humanity Partnership - Jamboree Housing - OC Community - Linc Housing Corp. Housing Corp. Apartment/HOA Managers and Owners The TEAM (Tustin Effective Apartment Managers) group, which is a problem-solving community organization comprised of apartment managers, apartment owners, police, school officials, and service providers, and additionally outreached to 99 Home Owner Association property management groups throughout the Tustin area. Community Service Groups Community-based organizations that provide services to historically under-represented community members as well as youth and seniors. This includes but is not limited to: - St. Joseph Hospital - Alzheimer's of OC -Community Health - Lestonnac Free Clinic Initiative of OC - Meals on Wheels -Neighborworks OC -Tustin Community - Tustin Public Schools OC Foundation Foundation Disability Advocates Organizations and agencies that advocate or provide assistance to people with disabilities who rely on safe and accessible housing opportunities. This includes but is not limited to: - Assistance League of - Dayle McIntosh - Learning Disabilities - The Blind Children's Tustin Center Assoc. of Southern Learning Center CA - Regional Center of OC City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan P a g e 4 Economic Development Organizations that represent or advocate for business and employers in Tustin. This includes but is not limited to: - Tustin Chamber of Commerce - Tustin Economic - BIA Orange County - Orange County Development Division Chapter Business Council Environmental Advocates Commissions, agencies, or organizations that advocate for sustainable land use and environmental protection in the Tustin or Orange County area. This includes but is not limited to: - Southern California - Southern California - Southern California Air -OC Fire Authority Gas Edison Quality Management - Regional Water - OC Environmental - Airport Land Use -East Orange Quality Control Health Commission County Water Board District Low-Income Communities Organizations or agencies that represent low-income communities in Tustin. This includes but is not limited to: - Boys & Girls Clubs of - Big Brothers and Big - Goodwill of OC - Legal Aid Society of Tustin Sisters of OC OC - MOMS OC - OC Food Access - Patriots & Paws - Second Harvest Food Coalition Bank of OC - Veterans Legal - YMCA of OC - Community Action - Public Law Center Institute Partnership of OC - Orange County Finance Trust People Experiencing Homelessness Organizations, groups, or agencies that provide services to people experiencing homelessness in Tustin. This includes but is not limited to: - Housing and Homeless - City Net - Families Forward - Family Promise of OC Prevention Unit - Human Options - Olive Crest - OC Gateway to - Second Chance OC Housing - The Eli Home - American Family - OC Social Services - OC Rescue Mission Housing Tustin Family Campus -Orange County Housing Finance Trust Real Estate Affiliated Businesses or agencies that are affiliated with real estate transactions in Tustin. This includes but is not limited to: - Affordable Housing - Consumer Credit -Orange County Clearinghouse Counseling Realtors Association of Professionals City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan P a g e 1 5 Residential Developers Residential or property developers that develop housing sites in Tustin, including affordable housing developers. This includes but is not limited to: - Intracorp Homes -City Ventures -Greystar -Curt Pringle & Assoc. - Century Housing - Civic Center Barrio - William Lyon Homes, -HomeAid Orange County Housing Corp. Inc. - Lennar Corp. - Taylor Morrison - Brookfield Residential - Shea Homes Southern CA Senior Housing and Advocates Agencies or organizations that provide senior housing in Tustin, and agencies that advocate for safe, affordable, and accessible housing options for senior residents living in Tustin. This includes but is not limited to: - Council on Aging - OC Office on -Tustin Housing -Senior Rental OC Aging Authority Properties in Tustin -Community Action -Orange County -County of Orange Partnership of Health Care Agency Senior Services Orange County Religious Institutions Faith-based organizations who provide supportive services to residents living in Tustin. This includes but is not limited to: - St. Paul's Episcopal - Grace Harbor - The Salvation Army -Orange County Church Church & School Rescue Mission Underrepresented Groups Cultural organizations or groups who advocate for the traditionally underrepresented groups in the Tustin area. The City has reached out to these organizations to encourage feedback. This includes but is not limited to: - AIDS Services - Fair Housing - Fair Housing Council of - Tustin Unified Foundation Foundation OC School District City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan P a g e 1 6 Outreach & Engagement Strategies The chart below provides a summary of the scheduled activities, community outreach and engagement strategies that the City implemented to obtain input and build awareness throughout the Housing Element Update. Each strategy encourages participation, facilitates meaningful dialogue with the community, and builds awareness of the challenges and opportunities of implementing housing strategies that meet the State's requirements. Schedule of Activities ► Housing Element Update Community ► Joint Community Workshop with Workshop with the Planning Commission the City Council and Planning ► Draft Document- Public Hearing with the Commission Planning Commission \\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\O O\\\\\\\\\\\\\\\\\\\\\\\\\\\\\ � )UI IUIIA�II �0IM0II \ November ' • September 1 2021 Ar 'A October 2020 2021 A'PF' May 2021 rr ► Community Survey open ► June 30-Reopened the ► Finalize Document- for 30 days Community Survey for 30 days Public Hearing with the ► Draft Housing Element City Council Document available for public review(30 days) and HCD review(60 days) Online Community Survey An online community survey was made available from January 21, 2021 through February 28, 2021, in English and Spanish, to help city staff better understand the communities housing needs and priorities. In total, there were 193 survey respondents, with a majority of the respondents being Tustin residents. The online survey re-opened for another 30 days from June 30, 2021 through July 30, 2021. Planning Commission and Council Meetings and Workshops A total of four community/public meetings are planned with the Planning Commission and City Council as part of the Housing Element preparation process. These virtual workshops and in-person hearings, serve as a method for community members to provide input on the progress of the Housing Element update as well as a venue to inform the Council and Commission on the state requirements, discuss housing needs, and to provide a progress update. November 10, 2020 — Planning Commission Workshop (Via Zoom) - City staff provided an overview of the housing element preparation process, including plans for community outreach. May 11, 2021- City Council and Planning Commission Workshop (via Zoom) - City staff presented its findings from the community outreach and engagement activities, and solicited input on future housing needs. Key topics covered at the meetings included: A Survey results A Reviewed existing housing policies A Potential new housing programs A Opportunity sites for meeting housing requirements ® Project timeline City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan P a g e 1 7 Public Review Period The City is available to the public for a 30-day public review period, from June 30, 2021 through July 30, 2021. During this time, stakeholders and the general public are provided with the opportunity to review and comment on the Draft Housing Element document before it is finalized. The document has also been transmitted to the Department of Housing and Community Development (HCD) on June 30, 2021 for a 60-day review period. The HCD review period concludes on August 30, 2021. Planning Commission and Council Adoption Public Hearings After the final Draft Housing Element is developed, and reviewed by HCD,the City will hold public hearings with the Planning Commission and City Council before submitting the final draft to HCD for certification. Tentative — Planning Commission Hearing on September 14, 2021 Tentative — City Council Hearing on October 5, 2021 City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan P a g e 1 8 Education & Awareness Strategies The City is using many strategies to build education and awareness of the Housing Element Update, and increase participation among community members. The following strategies were implemented to ensure public awareness and to solicit feedback from residents and stakeholders. -CITY WEBSITE SPOTLIGHT FEATURE - Outreach and project information was (.SOCIAL MEDIA POSTS- UNPAID posted as a spotlight feature on the City's website and sent to the web's AND PAID -Social media posts subscriber list in English and in Spanish were made containing information -POSTED FLYERS - Notifications in English and in Spanish were posted on the on public participation City's e-notice board, Library, Senior Center,Tustin Family Youth Center (TFYC), opportunities regarding the and Boys & Girls Club. Additional bundles of flyers were distributed at the Housing Element Update survey, Senior Center (200 flyers),TFYC (200 flyers), and Boys & Girls Club (100 and multiple workshops/meetings, flyers). Additional flyer distribution was offered to individual apartment on all of the City's social meda locations part of the TEAM (Tustin Effective Apartment Managers) group platforms -CITY CALENDAR - Meeting information was posted on the City's Calendar -PRESS RELEASE - A press release •TUSTIN CHAMBER - Tustin Chamber of Commerce advertised meeting dates on was distributed in English and their website. Flyer graphics shared were in English and in Spanish. Spanish, inviting the public to review the Draft Housing Element -EMAIL BLASTS - Multiple email notifications were sent to 268 stakeholders and Update (97 subscribers) interested parties. The City Manager's Office utilized their Community Outreach -VIDEO OUTREACH - Mayor ListSery to e-mail notifications to over 10,000 subsribers. Graphics included and Clark's Corner video advertised attached to email blasts were in English and in Spanish. review of the Draft HEU. Video -POSTCARD MAILINGS - Postcards containing workshop and public participation was posted on all Social Media information in English and in Spanish were mailed to 396 interested parties outlets including YouTube including residents, businesses, property managers, housing advocacy groups, -The Tustin Chamber of Commerce non-profits, religious institutions and others. Information regarding workshop shared workshop/meeting participation was included within the City of Tustin's Strategic Plan postcards information on each of their social which were distributed to 29,885 Tustin residents and 3,457 Tustin businesses. media platforms Notification Methods i Media Posts o *WEBSITE- City developed a -NEWSPAPER ADVERTISEMENTS-To build widespread awareness of the dedicated Housing Element Update Housing Element Update,the City has made publications in local and regional webpage, hosted on the City's news resources in both printed and digital formats website *Website includes a project *Tustin News - distributed to over 7,000 Tustin residents overview, schedule of activities, *Irvine Weekly - distributed to over 8,200 Tustin residents, including a digital and information on how the public distribution, reaching over 33,000 individuals can get involved -PAID SOCIA MEDIA ADS - Paid advertisements on the City's social media *Website updated regularly with platfroms which enabled notification to a larger population than traditional timeline, meeting updates and postings survey information • - • - • • ❑_ • • • • - CCC .... City of Tustin 2021 — 2029 Housing Element Update I Community Engagement Plan P a g e 9 Appendix B Index of Interested Parties Index of Interested Parties Housing Element Survey Respondents r' O CF) an r, O O O O O O N O N O O N N N O O O O N O N 0110 O Q ri O O O N nQ n n n N N N N N N N N N N N N N N N N N N N N N N 0) N LN N N 0) 0) 0) 0) 0) 0) 0) 0) 0) 01 01 an an an an an an an an an 0) 0) Q 01 co U 0) 0) 0) Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q u Q Q Q Q U U U U U U U U U U U U U U U U U U U U U U U Q U U U C C C C C C C C C C C C C C C C C C C C C C w C O (B C C C vn vn vn vn vn vn Ln v vn Ln v vn vn vn vn vn vn vn vn Ln v v M vn M C vn vn vn H H H H H H H H H H H H H H H H H H H H H H 0 H D Ln H H H O > co N O L N— O a) a) � N N O Q L >Q N L U •� M L L L Z � O Ov u O Ln n > N aJ 7 4 L -0 O UCC cO a) M m 'L Ln _ C aJ O dA N C� In x (0 7 G Oo 4. = (n Z J M = Z L� O C Z -a L c a) Q Zu (B J _ U cc Ln GJ (0 C N aJ z (0 c l0 CC� 47 (0 47 C C V •� � c' z Q >> 0 —M w a z m 0 � 2 — � � z =; Q •m L o � Lj- 0 L c7 Q u m H 0 N Q U O O O O O N N N N N N N N O O O O O n n n n n n n n n n n n n n n n n n u N N N N N N N N N N N N N N N N N N m N Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q m U U U U U U U U U U U U U U U U U U i C C C C C C C C C C C C C C C C C C O L V7 V7 V7 V7 V7 V7 V7 V7 V7 V7 V7 V7 V7 V7 V7 V7 V7 V7 O co C v — O m n O Co co co M O LC N c L , co O O co U a) co c O aJ N >Q --,e _ L O � � 5 •L Q J Q L �` L � Q (O i LS a7 a7 J C = cocc = °J a7 a7 +J C 'F, = O a) O O co E co aJ co M O p Q - CCI W co d' W Q Q U C J V1 J 0 Index of Interested Parties Community Development Block Grant Interested Parties List 00 mm -1 0000 0 0000 qt o 0 0 o 0 0 -11 o ONO 0 0 -1 o Nn 0 0 0000 0 0rl' 0rl' 0rl' o p o �D �D r` r` r` 00 r` 00 00 00 r` 00 r` �D �D w r` r` w �D w �D r` r` r` r` �D �D �D w �D r- C14 N N N N N N N N O N N N N N N N N N O N N N N N N N N N N O N N dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q U U U U U U U U U U U U U U U U U U U U U U U U U U U U U U U U U > > U N tV L mL m m m U QJ tV tV tV U l6 c l7 c E u l7 c E c E c E m c c c U c O Q c Qc Q Q Q co Q Q Q Q co > > co m O O M M c m '> '> C M O > c m m m tco •> '> '> c •� c Lnf— U' LnQ J U' LnQ (n L L Q f— LnJ i Q J v) Ln f— v) L L L L N O r` v O O 0 N N N N L O vI v vI m v) v N Ln } Ln vI O U j � a � 0 4J m > � 4J 0 to : L 4J >' (p L U > 0' � Y 4J U L Q U 3 L 7 0 L tV L L L U> III III III Q L O L O' ° ti4 }' L U L v) N L L +-+ v N O U C v L O O In C �n .+-+ c6 L O L U I.f) Y v U> m m Ln rIjW W n' T r` r, m tV T ° co ° o > Ln °o U 0 t t 3 mn mn mn 0 {A W v) U U a-' c Y a-+ m O ° m X i i Z a-+ X X X tV U l6 LJ rl N w w > (� w Q Q O w Z w U XO > w J E m O O 000 000 000 W W tD 00 In c-I > c-I In 00 r, In O c-I Z O > Z Z omo r- In qt 000 000 N r-Ao0 O O 00 O O N W O O � O tDD O 0 0 00 O O O O � o N Q N c-I N c-I In r- c-I In qt —i —i —i —i N D- Lr) —i N m 00 M d 4 —1 N d d d lD —i —i C � 7 � O C U :3 v O pO U c v > ti4 N O 0 o c O O > > U p O U L n c c v U -C O ate-+ � -C ° E 7 0 ° v +>,+ ° C 4J Fo L > U L U L U +�+ +�+ U 0 0 D N U U o 'o o v 0 0 ao O a 4J C ° L b4 L C �"� U O (n •O •� L L U C O tV C U U U ++ 0 tLo v ao ° a0' c�0 ° .0 O v c ago ago a0o C -0 > J 0 O C C � c6 - m 7 v >, v U v v L C L -C O O O L v }+ tV tV U E N Ll6 L 0) 4J N M 43 L L C C C N 0 0 p Co03 v - •> � Q = J- N ao 0 0 >- U W 3 N - O O L o_ o_ O_ J y U L v v L �n N +-+ +-+ > +-+ O > C v C C O O _a O O - Q Q Q 0 O ^I c c +� c c c c o : " v , , N a � _ _ co O O O = v b4 c N 1° 0 0o Q U v v o .� vI 3 0 o o •c f0 L vI v m �n z c O E CLc > 0 i0 NO L L L }' O O cc� O O E co co co m O O E O Q Q Q Q m m U U U U U U G U U U 0 W W W W W U- 0 O N -0 (6 C N E UO v O •L OC7 -0 Lco UO C OO c �G Q O O O O vL c W cn N CO MMO 6 N7 i _ C uo N tV u U L W QJ U Q C 2 M M m M O C L l6 C -O U 4J M 4J m C N O i0 >, b00 > .V cp C 4J In Q to U L mu C C L �[ CO L m aO ° L L lO uo m -0 C 0 Y 4J C 'L +.+ ° L 4J f0 v m U v E M N UO v O tV N +� •N v L O -0 U L m - v Z m �° �° vI GD u U 2 a w C7 vI 00 U U —M 0 a U 3C(f Ln M �t Lf) I- N M M Ln I- O Ln Ln Ln Ln Ln O Ln lD M 00 N lD 00 lD O Lf) Ln 00 rl lD r-A O O O 0 0 0 0 0 0 0 M O O O O O iD rl � Ln O o0 N rl N 00 O O ri O N o0 00 00 n w o0 � n n n n n n w a0 � n n n n n � � � � n n � � � a0 n 00 t.0 n t.0 n n n N N N N N N N N N N N N N N N N N N N N N N N N N O N N N N N N N N dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q U U U U U U U U U U U U U U U U U U U U U U U U U U U U U U U U U U L L U U U 41 41 (6 00 00 O ON l6 l6 L l6 (6 (6 (6 (6 (6 (6 (6 (6 (6 (6 (6 (6 m O O = C U O C C C C C C C C L C C C C C Q OJ Q Q Q Q Q Q OJ O Q Q Q Q Q 00 CCO •� m Q Q (6 L > (6 (6 (6 (6 (6 (6 L (6 (6 (6 (6 (6 (64J � � (0 O 7 O > O p (6 C > (6 O 7 7 7 (n O L (n (n (n (n (n (n O J (n (n (n (n Ln J L. Z 2 2 L f- U L U J (n Q L (n U O O N rNI Ln al N N NO n N _ O U +� N •+�--+ •+�--+ Z-3 O (n OJ ate-+ 00 Li > +-+ co co 7 N N N OJ Z 'i +' 7 :3 N Ln +L., OJ N N (n 7 4J 4J t0 +-+ +-+ +-+ O +-+ 4J 4J 4J m +-+ > c L p p v > O v v v (n v Y '^ ° > (�0 > -C � v Q E N Q Q Q 4J 4J 4J L > QJ - Q > l>6 +.+ +.+ > C L C E C Lf) +-+ +-+ N M O +-+ +-+ +-+ O! +-+ N Q v t OJ p > L > (n N O O! Q O +-+ + CL + + O c c L - L N N N > (n _ O (0 U Y c v ,n L - L Li >, c N M t0 t0 +-' OJ O L L L 0 L O Ln }' O c •i C OJ +-' 'n L7 t0 L ~ U w ~ r-A ro x x + coo E p O L L O U Z w �O Z O > > w w w w w w w m O Q n O Y LL w Z E z Q m w O rl Ln NC) rlJ rl m 00rNI 00rNI O tD O O O rl rl O m r-A O N O O Ln Ln v rl rn Ln M A r-IN 00 O -1 -1 00 N M -1 -1 -1 N M OM N M 00 O 0) O Ln to Ln r-A I- O� r-A O M n N r-A r-A r-A rl D_ rl rl rl rl N N N N r-A r-A r-A D_ M N r-A rl N 00 r-A r-A rl rl N Dl M D- M r-A C O 7 o }0 E >- U - :3 CL c uo u L C N 0) UO O O C t U N N o ~ c ° Q >, O U C02 02 U c :> _ ° c c o L p Q u O uo O O v `� v v (LO U c v v c — O ao Q v m - c O L Ln E c c C c = '� 'C LU ,n :3 :3tL6 O :3 (0 :3 U � C tp0 p � � U � OJ - � U O C p p O = O ° O D_ 7 L p z O ate-+ '� 'O >. U O N l0 U U 4J U U 2 N 3 E O - O N m C 7 i 0 L v OJ H OJ OJ c Y °J T n O T c0 •E E T u Ln •Q +� U Q u v +, t 0) o U o O E ° v a v v c *' U > "' (6 (6 - > +� +� +� D U c>0 D LL U L m i O E E •C (0 (0 E (n OJ +-+ > : L L Q > L O Q O C OJ Q L M OJ >' U ° D_ o = O O o ° 0) 0) 0) U U N c0o0 o c U = o p v = f0 o L L L Q p N N c -c U U U O U v - b4 Q Q U z UO T Q 0U0 00c u_ u O E t0 •+� C C c t0 C w (n > c c c ao o c0 c0 v v O O °p U > > > M U U M +� b4 p >0 m O O v v v v L z z O O O O O O O O a a a (n (n (n (n CL -C -C -C D D D D C O ° +-' C O C L m m OJ c Y Q uo J ° OJ C C C OJ (0 4J E C 4J L >` m L L C O c O U C 3 C (0 QJ N _ v Ln c O f6 a°0 d N C OJ v N �_ c m m Y m UO O U- - - E U 0 J ° 'm c0 •L i J J ° U c t c0 c0 (n cL0 v v �_ o c o v v ° ao E v (0 (0 O U > M O N > C Y 7 l0 +.+ U 7 7 � C -0 N L O C L 4J L l0 E (6 = O - > C (0 U O t (0 (0 (6 (6 (6 (0 L - L N L M Lu M � M Q M Q Z - M U U d' J J W D_ 00 � > L p - p n (0 O CD J J (n m \ 0 0 o m / o 0 / / / / / / / / @ \ \ \ \ \ \ \ \ 9 \ \ K \ \ { _ { \ \ . < 0 < ® E ± » \ a \ / x \ } e % u 7 f 0 / 2 / / / z z co o m z @ @ \ \ \ \ \ \ \ \ _ 2 \ % _ 3 0 u (3)0 » » a § E § § >- \ § / / / \ \ \ \ / S S E 2 G E E % % \ \ E \ L k / / U = 0 § _ = 0 0 § § M: » / E / / \ Ln \\ \ \ \ 7 7 _ g / @ E \ \ \ \ 2 a> 3 \ >< / \ / \ \ ƒ / \ \ Index of Interested Parties Outside Agencies and Developers List `o 0 E o v $ 0 E v a v 0 a a v 9 w E ° `o p E E `0 a 0 E ° a v q p l 3 o Q o 0 < 9 E 3 w o :0 `0 _ - u u t J W " O O O O O - O O O O O O r o m m o0 0 0o ui o o m m v o m m o0 o m o � �n o m m o0 o m o o 00 00 0 0 00 � n n m o m o n v o 00 m n n v m �n o m in m n m m o m y o o0 m r r �n in o moo ui o r m v oo v m in v o0 oyo m o v m n �n m m v m �n m v m m m m m m m y r Z � � � v v oo O v m v v v v m v m o v v v v v v m m v v v m y o v v v v 00 v N � m 0o m v m .. m o g � 55 � 5g � g � `° gm m' < u ° " ' 5ga5 � � � � g � � 55 H V V ru QmQ m m j mQ Y mQ m o o m " m m Q m m �' V �Q' '� a a V V ru ra U U ra ra V ni ni n, G m V ni V V n, 4 o V n, iJ n, U n, n, n, v V V v n, a a - a s a a a �-' a ai a �-' m a > o a a a a ai ai a -°omo -°omo U ¢ V H H H .n .n �° .n .n H .n l7 vi l7 vi `J° H vi H O vi - 2 H LL H V O O V 0 0 •' o N m N UI Vl > UI vi ai v v v ai -° v a a> v r v a> a > m° N a <> 0 0 0 > ° .r". r ° -c oLvo a r� y r o N v c n m o `°° 3 "' o y°o 0 n --vo o -°0� '° o w o ,°, " 3 > n, E x N > vii m = v E E O t7 LD r 0 1O o t7 m ¢ - .n .�Y. m 3 v 1O -0 O Z 3 Z z m �° v 3 Z m° 3 0 ^ o m° o z Z m° a 3 m w a w m Y o �n N �" n W m o o ":' m o 0 0 "' T > V O c Q o C 00 U E UO v=Oi i V O u o r o 0 0n o V v o v . ° L 071 - „ o r 0. v m r m v v v Y O - O wO O " O V - v� >. o m o > W V v - c 0 O c m o Y o v " 3 w " '" o v LL v c w o u c 0 2 a 0 = a V o .L V ,� u c v D v v u v - o u E o o - o N 3 c o 071 c m �° 2 v o v o z �i u r v o > L V ",� m 2 2 c � -" o m Y c > a e v v V V c ._ o v v > E ,� v '" ¢ o u a V v v .0 a i o J 2 vi Q '" - V m ¢ 071 "o_ E _ -O o N E - V ra N = v oo Q v r v `° o > 0 0 0 ° r > vri " - 3 ,0 �_ -0 c V V O v v oo LL 2 U E ., v c v >' c r 2 °- 4 0 V V o v �' v L a s O a v a v o a s c v E a a v r`a o o L o a v L �° c° _ - - E :a -o ,°., c° v ._ u '^ E m E - c° > a° a v > ro Yn E 0 c ro V Yn � v v E o0 0 v = Yn ro v E v V E >'J - v J v o > D O a H �i a tw 0 0 H D J 2w u m 3 LL v, = H O H O J O a J 0 m° �v, - v, V O V UI W � J — N v F— a v 3 a a o o E N ° ° c m v o E c v J ° v v m N v ° r a > E v U r V V v a _ j '° _ ° _ > v "' o ami w E z m - LD v v _ > m v v v 3 w om = ¢ o a x° u �i 3 w o ° ° ° o o w v `o a o 0 0 0 E a o o a -E o a o a 0 3 0 o v E o E 0 E u E a o v o t °' _ _ u u a w o t o E v o ° @ E 9 c o - E o 0 w w 2 0 r r m o 00 0 0 � m r m m Q m o umi r Q U � o v `T No o r r g ° ggVmEo � a ° g55 � � � g � � � 5 � g � � 55 � 5 tg = u m V v m m m m m m m m m m tg m m o v a ai pv gai gai .m g u<_ .m vo o E Vaai VLLLL sai Ev mvoo a gai gai V- a_ rmvoo v o ° c c c o .L .L c .L .� .L o .L c .L .L c c c .L .L c o c .L .L c o a _ zv a ^ _ ^ _ _ _ _ a _ _ 0 m a o ov o oto 0 Yo N N o Y V v z ._ Y m 'y m > U > ' a m > Y m a m V > a r -° c o n N > v ip O0 0 N ~ Q V >' m = a > g Q m a 3 v 3 r t r > Uj > v o0 `E l7 m l7 w 0 _ m ry w Y in - a ui z m N = o z Y n ? o E o V wo V y z° o �' 3 a a w ° o >° ° u = V `° o .`n. l m m m v m m m m n o O m O m m � m m o o m n m o0 o ui ui "' O v o m o- E V T T E> V EO m T UI O u O 1 O V v J m ` 0 0 ° o Q v o ov°o m n, - ., - , U,- x G°o >te "O o° L V ooo o oo UU3a OE . Vc l7 ?N pV O L - V N m mix �w m O O Eo f EV � m u v v o o °° J mo V ° ° o00 ° v ° = zovuoo' v - aE otV o V c o � L vv co oo- ° V o V JV ° V V x > > V V O E v v E E o o vV avo V o E x° o EE ` ow° � � bu z 65 a uu ooc�_0 w w v m `o p `o `o LV i Ll u D O D D 0 x a > v > v v v v v v v v w XX wV vOi w a w a 90 O Oo E v o v O O L i L O O L > > O = o E ° 2o w - No oro o o m w v LD ¢ u a o v w v w v m �j N c o m mv ° o Y -° m o V m° m ° 2 m Y z V w w w m a .n l7 l7 a l7 vi E O v v v > a 0 3 � a r Y 0 0 0 ov m m umi v N v o1Oo T r r m r m m o ° w m m ° o 0 Oi Oi W Oi Oi Oi Oi Oi W Oi Oi Oi Oi O Q� Q�Q m W W U Oi W W Oi Oi W Oi > Q Ol Ol NO Q Q l0 Q Q Q Q Q Q O U U Q U UV V V V V U V V V v m N U U U N 01 U vi V V N E d d g °' g v 16 1 '° ov `L' tg tg 5 t0 g g g a v d N a v o a a v a '- Q` Q` " m o o .L � � v c a o Z 2 V - H H 2i .n H O V .n .n - O .n V 0 0 m 0o v o v UI UI Y Y O ^ V Ll v N a s Y v"vi ai o Q > m > v w v Q m Q Q > m° v v v '^ v > a } > v > 3 Q v o d a Q ro D Q O Q Q 3 �n Q ° a - - n ^ > o V' - ° .n .n .n .n '^ Q o 3 o N D a o m m v v ° `� c c m 0 3 m 0 c c L v o L L L L o - v �7 L o 3 ° v V v c °- v v N m LL LL v .^Yi ,� ~ v v v v - `^ Y m v O r"a V v `0 ° u 3 z° z° z m° m° 3 3 w Y w w w m` a a ° E o o z z w 3 j 3 oo w w 0o m m 0 �'' 0 0 o w o .. o m o o �" o m w > �'' .. v -° .n .n .n m n n o m m o o v o m .N. 5 v'^i oo J v - � u > V N H 3 V O F Om >' u o v O O > - c O u O V L ziip o o N a N 0 J C w N N N V m V - E -O } V O O O LL V V ° >' >' m o m:E sm V E o v o o mw Tm vi o 2 o o m m v ° u u v O v x 3 0 Y o - v > v o o v x N ° `° a '" o O O o o N ra o >. '^ v E - v `0 v ro `° m v o V o n .-> c 0 0 o o. ° a 3 a c o E v O u a ° o ° .� w .� °' 'o d - = m mo 0 0 - O ° v v v -° w `�°, V u o E - V ._ v o V > 3 3 v O - `0 a ¢ 0 0 o LL o v V = ° a Q a - O w v o 0 0 0 E E °o °o E v O O .� �.i > > > V u °u > v ;' .� n c .n > > Y w - _ m t7 t7 t7 = z z O o o O O O a vv, o vv, > > v v, o v v O v 0 > o z - ¢ o `o v 0 o n o v o p v v " o c c o 'o _ O > oo=o a` J Vo m v w v E u uin v min v L a > a c a Y u ° a v o v v = E v V Y Y } m Q D Q Z D V V m d 0 - W Y Y W N N Index of Interested Parties Adjacent Jurisdictions, Utilities, and College Districts List E L O w- U U N v 'C N N O C O 0 N C O Z V01 >i N OU O 4 } Y T N J J6 m m O T C m O m "O C C N m m 3 m L m L +@' L L C U L m M "O N m +' v � N U Q Y U Y V1 Q Q V1 0 K r V1 U Y Q U U U O E v >O E L O m O U E U 0 0 O O j j C v 0 u w "JO v 3 O t O m0 O u m -° o > 0 u y u °1 L O o c `° 0 0 0 Y m u O c o f O E u u o u 3 u u Y Ou o 0 U m - v - Oi o O O p E O-Oo O m °Lou E c Y NE L W m Y vii m E oo oo N a U m Y O bmp N O N to O m O < N N Q Q Ol N C p p U �o Q Ol N Q m N op m p U l0 �p C U O V1 p � V N N oo N O ` 'E O I� M o m oo O V/ N Q N - N U Ol U c-1 V O O v o Q o o m U u m o U N r C O C Ol C V O N Q I� E oo oo l0 V V O N N N Q O 0 N 12 Q Q p r C N C Q O m 0 o) N ry ry U O o)j O Q m U O O m u m Np Q o^0 U x U N Q U w C r-, M 0 0 0 0 N O m N LL C op V1 = I- U N m N Ol Qr U N N N m U m O C C N V1 V '12 O j Ol m N V1 bA Uc C "O m Ol Ol Ol C C N M m N O p X C N ` U bmp C U N N 6 m "O >i `""� N V1 > m m O J C C C O M -O ~ > 3 L U c > O m m m N m0 2 m C N "00 Index of Interested Parties Orange County Housing Developers List 0 O E 0 $ v E v o g ° o r o v E 0 oo a " E U N U i m t O0 p C ; }+ O m y v 0 L a>' 0@0 , 3 u r c +t Nmu c .o Y°o v v 3 0 v Y $ v o 3 v = c m c m E c v Y 0 0 0 o o v o 3 0 E o o c W c c c -E c w v c c c c o 3 m m oo 0 ll1 , O N .--I O oo 0�0 O m r r 2 - m V . � m M 0 lco 00 l00 N l00 l00 l00 N l00 l00 T l0 T M r M l0 l0 `""� T Ol N T T V V N N ry N V oo op Ol Ol I� m N N N Ol Ol .y ry m 0) U M M 0) 0) 'C V1 l0 l0 V N U U op oo N � U U r Q `� U v O O D U ° O1 01 m N m m m l0 m I� Ol w m m 0 L m c-I c-I L L m Ol N C Ol C ry m m ry Ol N ry m m ry O ry m m ry ry U m m 0) m m O1 Q 0) f6 O) N m m 0) v 0) m c 0) 0) t m m m U o o a aUa ma U p p U v U U m �o �o U c U o w U U am o o J a v v 5 3 3 5 12 -5 o > Q 3 3 > _o 3 c > > m 3 3 0 m '> N N ` o � p N N ` '` N 7 '` '` N N p m > C z z _ O U _ z z _ _ z x _ _ �n z z >- vi L Q Oo O O N O OO N O O w 0 ON 0N N N N 0 O O O 0 �N c-I jaj O O m j C c > ` N M r > > 0 OO N aj ? N V1 N > N > 0mo 3 U m ° 3 c c c Yn Yn > u j u o u v v v m v v m . = a o a m > u > 3 u v a t U v o21 m 0 v U U v o 0 5; a; t 'E u a t c Q ova o m a aD a m •cCc .mV.�-1I l0Z3 ov oo --� (o r o n 12 > U 0 o o z . m O 0) m oO O0 @ ym 0) 0 moO O O O0) 0) O0) V V oo oo MO vNnri N V V m C _O = N m E = N m m OI C = L J ra U � Y C N O E C ° Y O D ECL c x t! p u N C U x C O N u U Q U C C C ob N C O! u w =uE va = cm Od m uDuD ' ? c-Di E E EE Eo aio nmi O ° ° ° ^ � 0 Q o ° = x =ouao o u E E oO Cm ° 0 - z u ' o - Iz o : c Eu ¢ta m u mr U° m > Index of Interested Parties Tustin Home Owners Association/Property Management Companies List c n! C m J T 0 m T c on O -E T m m N O fa E N O O E = E y m c v c w m 3 c m E c v m c LL u °i c m v c r m m c m m o m o m a v o a U ° ° m v m C1 t c c c > LL o m O > ^ = O m o = m° T m° = t c T E m c v m a v _ N t m N N Y } E T U N U L m 0 m 01 �' c C 01 m r 01 t bD C m ° m J J O LL N t m m m m a m a O m p O m m m m _N N m O a a Y V1 V1 Y x Q Q Y Q V1 U Q U } p V1 U Q V1 � > r O O 0 M 0 M p M ap M M N V/ NrnU NON N N Ol O O O Om m0 0 0omrn � � mmaUmmOrnmmmaoOmrn ArnN QmOmNma ° �° amOOmOmU O �0 ° U wM = W N m N U U a ( N N N a > E m o nj C p � m C C nj C C L C C m C C C C C p C m c m nj C C C C nj nj C C C C C �a Q C nj nj o > j s o m o > > j °�° 'o Y Y Y Y Y Y c Y v c o :c :c c c m Y Y Y O 3 :c c c a r U m n U r r �° ° Q, E c E v E v E °' a o ° a E w W W c m c m °�° v E E T o c v m aci ' c v c c E m " c `c w E m J m o' a m E a E m V c v v m m u o T c v m m E > a m m °' `° c m o a v m a c m aci 3 c E m C u c w c u atv u O E a m c omn w : 'u c O m v — v Q m c m v E � c E a � O v a 3 E p m n a O m o v E > YQl m y m y aci g m m o. f6 m m \ a a p o c c u o E m O cc o 3 u : v m T m_0 Q.'- -P c m O` to T m U T U d V�1 m U U T.0 O "p Q T c Q m m U U bvU - c � N m U O W c t c o m v u c Cw c at o c m m e u c m e ° o = v O C Q 2 o „ c c S ° a° a m o > ° v E w o a ° o c ovn a :� m c ° o .m > o o T a a T c c� ai7 m m N u 2 u p_Y c m '^ in 'u 'E E 2 0 12tuna m v u N Q Q a o mo->m u p O u 3 v uYO a o a a E u > o LL a o a m a 0. m u a 'o -` o ° a T T m v E u a m v a o r O T a� v "' 'c ° o O u v ° p D u J a t u a > .�Q ° O O ° = = ° O p . E m O E U Q u m v u O u v m u u m E u ° o u u 'c O w u E ' v ` v m a o Q Q v 0 3 QO O 'c o ° E E o 'u c a o m Q O c O m E O E m c o c O O O aci " x0 m O c o x w p E x p E v u o QO Q °'z v Q Q c c E O E a c 6 x o p "O Q m O Q x b u r N E u EO c U 0 c x O m O m x E o " x U - v > U` in u ., u O = O -p in m v > E U m N U Q a Q " m O m - 0 Y v1 m x a x x O — c O O O m O T T m -O Y a \ a > = O! fa U r Q C yj w C ° Q J J = v c U m x O C T O N Y O U U U '? a= C v L O y N U 0 m m m o - o E m � > U o m .2 m a Y 3 m c 3 3 v m N o 6 ° v v v o m 4 v v E v a m 3 v E E v c m c m O v a m-p ` E p 3 > r v a s m a) s o m x v m m m > > °i ° m +m' E N o m = u v m c m c c c E E E � a m m ° m o 0 0 w e ° v O m m m m m m o 0 o v c v 0 0 Q Q Q a` Q m m m m m` m` m U U U U w w w w C7 C7 (D � �° �° � : � r a a a a a a a C � C T o O a O N 3 a o m o E c t E 6 ° T ° °U T ° L C U 6 t "O N N C E N L YO ° E m° E n m r o x i r r m o v o v `c c m o v �_ o c m y Ca v v u = N T w C m C in T to C m m t6 T t6 N t6 C O`a Y U O`a u m C m O c != N m o m C O m C O m m J "O O N C O m ro N E .m N t m N FC 0 m m Z V1 m X m U 0 Y Y Q D U Q m m m O r Y V1 Y V1 x m m N N N O00 N M M M Ol M Ol O N ONO U u m mU m U m Q ^ l0 Q ^ l0 Q N U mw Q ^ M m M mm mQ ry m m r O 0 mrnm M m M M M M 0) 0) 0) 0) 0) 0) 0) l0 rn - rn U rn " rn v U u U a 0) 0)a a Q Q a a v U a a a = a Q a = a Q c 'i a = a c Q a c Q Q > U Q Q Q o U o U U o U U U o m E Q U U m a m a a C a a U N N Y C t N to C m N C ba N C N C N t6 C N t6 C N O m t t6 C N C N j > > > > -m O > > > N m C > t6 J m > m12 > J > m> m J > t6 JS V > m C �Ca O > J > Q z r z r r r U — z Q �n r a O r — �n r �n r �n Q �n U r T c m a i, O v 3' at +� c r oa c m c u p U E c c m m m v c c - v o a E cm E ar p ar o U c E c E v m m� v c m 01 E w ° a o >, a c E E �,c�7 °m° v p m 0 v °m° c v c �n m U c g m c a' Ewcw T oa v, c _ ° Q a .� o m e a T ¢ a m 01 > E m c E aT C >, O. N t6 N bva C m m C C E E T m m O >,to O ° \ U T m N N C C w a! p c Q E Q v a m T c m o� E >' O m U 3 Q o >, T om, o v o " " 'u v u m c E c v c o m v o °- E c v f6 a T m v m ° m c T a O m .� a o.m c c c a p C m o 'a — a a a o` � a u —u O w 'u v °i 'u >, r O O O 4 m m v c 'U o Q 2 m a T E N Q o o U N O a o a °- m an d 'U c 2 ° U ai a E u E o v a c '.' o u >. 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L •u dJ 'v-� p w C rC O Q L i P E Q _ Q v 0ui d = o yd J o L7 N SO- ° c ¢ a3i z u F CL: u rc 2 W ^ N M 'IT, C7 H CU O E 0 N E �' 41 co ❑ _ E C11 cs a 7 —_ r Q 0- 0 rrS Cd C V C7- O ❑ d V1 q V d rid r � ` � � Q N o o •E o N OcD 4 N M _ O O _ C V7 y •' -M7 N d C �� 41 O N � U'7 V V C � .Cl) V � Ln jp d t3 p d w c N .2 ❑ fy d7 V S] 4J d Cll = o V E N E 7 Q rUI'�� ~ d N sN,. OV ID CZ CD 0 Cl) G "' O ON 'a G C (C 10 N ��, O O Lh ], C 'O rC ID V N p CC O � L7 Lo Y c +-' � � � O � 7 � O ❑ � O � � 72 N N G C CI7 Q _ ID y d _ d [C U7 V d V) ¢ qCq 2 z EL 2 � .� LL FZ z O LLJ U7 T S U 2 m CL: M LrJ cD f� Q7 67 p H N M �r Lo CO f- CO 03 N N N N N N N M M M M M M M M M M ATTACHMENT C PUBLIC COMMENTS From: Bill Netro To: Housina Element Subject: City of Tustin Housing Element Coments Date: Thursday,July 1,20218:55:57 AM The Tustin Housing Element places about 70.5°/% of all of the low to moderate-income housing needs at Tustin Legacy which is about 4,786 units. I find that shocking and very unfair. My home in Tustin Legacy (Greenwood) is currently valued at over$1.9M. I never would have purchased a home in this area had I known that the City of Tustin would place so many low to moderate-income housing units in the area, and devalue property values in the process. It is bad enough that we pay an extremely high Mello Roos tax, and receive very little police support in our HOA neighborhood. We have to pay to maintain our streets, and we even have a community park that we have to open to the public while we pay the full cost to maintain it. This prevents us from installing gates in the community to protect us from nearby apartments and condominiums who park on our private streets (because they don't have enough parking), and rising crime (stolen packages, break-ins to our pool, damages to cars, etc.) A disproportionate share of low-income housing will only make our problems worse and decrease property values. Please do the right thing and fairly apportion the additional low-income housing equally throughout Tustin. Kind regards, Bill Netro 122 Evelyn Place Tustin, CA 92782 From: Janel Bommaiah To: Housina Element Subject: More fair distribution requested Date: Thursday,July 1,20219:02:58 AM Good morning. Thank you for the opportunity to provide feedback to the housing recommendations. My personal request is tp reconsider the distribution allocated to Tustin Legacy.There is already multiple lower income/low income housing offerings in the TL area of Tustin. The new proposal is suggesting more than half of the new requirements be placed in Tustin Legacy. Please reconsider and distribute the allocation more fairly across the city. Thank you, Janel Bommaiah Sent from my Whone From: Michael Ricialiano To: Housina Element Subject: Draft Housing Element Date: Thursday,July 1,20213:12:18 PM do you have any rental assistance programs ? Michael Ricigliano, Broker CA DRE# 00683546 NMLS#2123923 Your One Stop Shop For All Your Real Estate Needs Since 1977 17341 Irvine Blvd., Suite 110 Tustin, CA 92780 Phone: 714-337-0658 Fax: 800-249-3899 From: Mike Na To: Housina Element Subject: Housing Element Date: Thursday,July 1,20214:32:18 PM Hi, I am writing today regarding a Housing Element report issued by the city of Tustin. I see that the city plans to add close to 7,000 low income housing units, which appears to be greatly needed. However, I also noticed that 70% of those units are planned for Tustin Legacy, which seems unfair. This is not the first time the city has tried to dump all of its problems on the Tustin Legacy community. Can you please explain the city's logic in trying to continually place the majority of the burden on one community instead of spreading the responsibility across all communities within the city? Sincerely, Mike Ng Tustin Legacy Resident From: Scott Brail To: Housina Element Cc: City Council Subject: Equity in availability of affordable housing Date: Thursday,July 1,2021 5:21:22 PM Dear Mayor Letitia Clark and Members of the City Council: I would like to thank the city for all it has done to provide affordable housing here in Tustin. We all live in a wonderful city that is the epicenter of the entire county. It has come to my attention that the draft housing element isolates all the to be built affordable housing units on the Tustin Base. This essentially discriminates against the rest of Tustin by NOT having the affordable units available and spread throughout the city. Why is the City not making this an inclusive, broad based housing policy? The affordable housing issue is a citywide, countywide, statewide and nationwide problem. The solution should not be limited to just one part of our city, state or nation. Everyone should be able to benefit from the availability of affordable housing. In fact, there is a bill (AB 491) by Assemblymember Ward (D-San Diego) that would prohibit "a mixed-income multifamily structure from isolating the affordable housing units within the structure to a specific floor or an area on a specific floor." The bill also requires the following, "a mixed-income multifamily structure provide the same access to the common entrances, common areas, and amenities of the structure to occupants of the affordable housing units in the structure as is provided to occupants of the market-rate housing units." The same should be true and applicable to Tustin. Please amend the Housing Element so that affordable units are more equitably distributed throughout the city and available to all. Isolating them in one location does not do justice or equity to those in need of affordable units. Thank you. Scott Brail From: adewev224(aicox.net To: Housing Element;City Council Subject: Low Income Housing in Tustin Legacy Date: Sunday,July 4,20213:08:06 PM Hi, I purchased a home in Columbus Square about four years ago. I love my home and the neighborhood but never would have purchased it if I had known how awful we would be treated by the city. I was willing to pay higher taxes and mello roos because I mistakenly believed the area was going to be developed in a thoughtful way to create a really nice area. Instead, it seems we have had to fight homeless shelters at our doorstep and now low income housing that may increase crime (which has already increased) and greater crowding. I am very disappointed and feel defrauded and misled. I don't think it is right to charge people the highest taxes in the entire city and then force those people to bear the brunt of all of the homeless and low income housing. I assume I will have a loss on my home when I sell and have learned to never trust any area in CA that is not already developed. Hopefully, I can sell and leave soon because this is very stressful. I need to live in a safe area and am unwilling to pay huge prices for rising crime and rising density. Thank you. Alicia Dewey From: Eric Rumlev To: Housina Element Cc: City Council Subject: Tustin Legacy and Regional Housing Needs Date: Tuesday,July 6,20213:59:06 PM I write to comment on the proposal to build an additional 1,461 housing units on top of the 3,325 units already zoned for construction at Tustin Legacy which will include 1,552 very low and low income housing units. The proposal to develop such a high proportion of low/very low income units at Legacy is unreasonable in that such housing should be reasonably distributed across the whole of Tustin and I believe there are alternative sites that could accommodate a proportion of this class of housing. When we first considered moving to the Legacy we were encouraged by the plans for developing the area contained in the City document of December 2013. What we are looking at now is a far cry from that vision. We have already seen Levity developed as a high density area instead of the medium density housing initially envisaged. The future, if this plan is implemented is one where high density housing dominates with all its attendant problems of traffic congestion,parking issues etc. The District shopping center is ill equipped to cope with the addition of such a large new population. Where are the parks and trails that would have added so much to the ambience of the area? By proceeding in the proposed direction the City would lose for ever the opportunity to develop Legacy in a thoughtful manner incorporating large open spaces and parks, attracting companies that would bring jobs to the city. Overly dense housing has been seen to ultimately create "ghetto" type conditions over time in many places and we don't want to see the original vision for Legacy translate into that. I hope that the City will consider these factors and adopt an equitable distribution of required affordable housing across the whole city. Sincerely, Eric Rumley eric.rumle�gmail.com 714-904-6739 From: Maya Krua To: Housina Element Subject: Low income housing unit Date: Tuesday,July 6,2021 11:39:28 PM To the Tustin city council, I am a Greenwood resident writing to express my concerns regarding a recent survey sent out to potentially allocate 70% of all low income housing units to Tustin Legacy. Firstly, I did not receive such a survey and this is of concern. The Greenwood community is relatively small, with many renters and the thought of some voters not being captured is alarming. Secondly, I understand there are state mandates to provide low income housing, but this should be allocated equitably amongst all Tustin neighborhoods. I sincerely hope that being fair to all residents within the city of Tustin is considered in this matter. I certainly did not purchase my home here to build a family and to be faced with such disparity within the community. Sincerely, The Krug Family Sent from Yahoo Mail for iPhone From: Jeffrey Maaanis To: Housina Element Cc: City Council;Suoattra Lerknant Subject: Against High Density Affordable Housing Burden in Tustin Legacy Date: Wednesday,July 7,20212:34:08 PM Hi City of Tustin, I'm a new homeowner in Tustin Legacy. I find it very unfair that the city is putting the burden on us homeowners. I specifically chose this neighborhood because of my I and 3 year old who I let freely play in our park and safely walk around the block with. I've lived many years in high density "affordable" apartments and it is not family friendly for those who take pride and joy in a quiet, safe neighborhood. I'm all for affordable housing but it should NOT be burdened by the Tustin Legacy tract. I plan on moving and no longer supporting Tustin if you move forward with this. Respectfully, Jeffrey Maganis From: Jimmy Pham To: Housing Element;City Council Subject: Tustin Legacy and Regional Housing Needs Date: Wednesday,July 7,20212:02:47 PM Dear Housing Element Dept. & Tustin City Council; I write to comment on the proposal to build an additional 1,461 housing units on top of the 3,325 units already zoned for construction at Tustin Legacy which will include 1,552 very low and low income housing units. The proposal to develop such a high proportion of low/very low income units at Legacy is unreasonable in that such housing should be reasonably distributed across the whole of Tustin and I believe there are alternative sites that could accommodate a proportion of this class of housing. When we first considered moving to the Legacy we were encouraged by the plans for developing the area contained in the City document of December 2013. What we are looking at now is a far cry from that vision. We have already seen Levity developed as a high density area instead of the medium density housing initially envisaged. The future, if this plan is implemented is one where high density housing dominates with all its attendant problems of traffic congestion, parking issues etc. The District shopping center is ill equipped to cope with the addition of such a large new population. Where are the parks and trails that would have added so much to the ambience of the area? By proceeding in the proposed direction the City would lose for ever the opportunity to develop Legacy in a thoughtful manner incorporating large open spaces and parks, attracting companies that would bring jobs to the city. Overly dense housing has been seen to ultimately create"ghetto" type conditions over time in many places and we don't want to see the original vision for Legacy translate into that. I hope that the City will consider these factors and adopt an equitable distribution of required affordable housing across the whole city. Sincerely, Jimmy Pham From: Stan China To: Housina Element Subject: Affordable Housing Allocation Date: Wednesday,July 7,20219:54:08 AM Affordable housing should be dispersed equitably throughout the community. Stan Ching 31 Meadow Place Tustin July 14, 2021 Tustin City Council Tustin City Hall 300 Centennial Way Tustin, CA 92780 Dear Councilmembers: Thank you for the opportunity to comment on the process of updating the housing element of Tustin's general plan. I am writing on behalf of YIMBY Law regarding Tustin's 6th Cycle housing element update. YIMBY Law's mission is to make housing in California more accessible and affordable through enforcement of state housing law. We support more housing at all levels of affordability and reforms to land use and zoning codes, which are needed in order to make housing more affordable, improve access to jobs and transit, promote greater environmental sustainability, and advance racial and economic equity. We have reviewed the City's draft Housing Element, and have major concerns about the City of Tustin's ability to meet its state-mandated RHNA targets. The following issues are of particular concert for us: 1. TUSTIN DOES NOT PROVIDE ENOUGH SITE CAPACITY FOR VERY LOW INCOME HOUSING. Tustin has not provided sufficient site capacity to accommodate the state mandated minimum amount of very low income housing. "[T]he share of a city or county of the regional housing need shall include that share of the housing need of persons at all income levels". "[A]ctions should be taken by local and regional governments to ensure that future housing production meets, at a minimum, the regional housing need" (emphasis added). Cal. Gov't Code § 65584(a)(1) - (2). The statute language makes it clear that regional housing needs are a mandated minimum, rather than a suggestion. The 6th Cycle RHNA Plan requires that Tustin provide enough site capacity to accommodate 1,724 very low income housing units. However, Tustin's housing element provides capacity for only 1,699 very low income housing units. Thus Tustin has not provided enough housing capacity for very low income units. To remedy this situation, the city should ensure that enough housing capacity is created to provide 15-30% capacity buffers at each level of income, including very low income, to avoid violating the No Net Loss requirement. See Cal. Gov't Code § 65863(c)(1). Otherwise, the County risks falling afoul of the No Net Loss requirement, making it vulnerable to mid-cycle rezoning, a costly process in terms of time, money, and political will. 2. NON VACANT SITES IDENTIFIED IN THE SITE CAPACITY ARE OWNED BY A SINGLE FAMILY AND APPEARS UNLIKELY TO BE REDEVELOPED. Tustin listed Site 6 located at 14081 — 14231 Red Hill Avenue as a potential site that can be redeveloped into 104 homes. The city's draft housing element notes the site is owned by "the same family, yielding a more favorable redevelopment potential." (Tustin Draft Housing Element,Appendix B, Page B-6). Assembly Bill 1397 (2017) requires cities to provide an accurate assessment of realistic site capacity, including "the city's or county's past experience with converting existing uses to higher density residential development, the current demand for the existing use, and an analysis of existing leases or other contracts that would perpetuate the existing use or prevent redevelopment." While California Housing Element Law does not expressly use the term "likelihood of development,"AB 1397 (2017), when read in conjunction with other recent statutes, requires cities to discount sites' capacity by the sites'probability of development during the planning period. (Christopher S. Elmendorf et al., Making It Work: Legal Foundations for Administrative Reform of California's Housing Framework, SSRN Electronic Journal (2019)). The legislature has also vested HCD with the authority to resolve ambiguities about the definition or calculation of site capacity. Specifically SB 6 (2019) authorizes HCD to promulgate, "standards, forms, and definitions," for the site inventory and associated assessment of site capacity and constraints. Providing an accurate assessment of the site inventory's realistic housing development rate and realistic housing capacity is necessary to ensure that this housing element is effective. The housing element does not make any findings showing the site owner is willing, much less likely, to sell the site. The very fact that the owner has not yet sold the property only serves as evidence that they may be hesitant to sell the land. We ask that Tustin make at least minimal findings that the Site 6 owner, Huber G. Wilson, is willing to sell the property. If the site is not sold, Tustin will only have enough site inventory for 6,677 units, which is 105 units short of the state mandated Regional Housing Needs Allocation. Tustin has a legal obligation to sufficiently plan to meet current and future residents' housing needs, in a way that guarantees access to opportunity for Californians of all racial and ethnic backgrounds. The issues that we've highlighted above suggest that Tustin is not on a path to fulfilling this legal obligation. We urge you to change course and actively embrace this opportunity to provide a variety of attainable housing options for the residents and workers of Tustin. Finally, state law imposes penalties on jurisdictions that fail to adopt a compliant 6th Cycle housing element update by October 15, 2021. On that date, noncompliant jurisdictions will forfeit the right to deny residential projects on the basis of local zoning, so long as projects include at least a 20% set-aside for below market-rate units or are 100%moderate-rate projects. Noncompliant jurisdictions may also lose the ability to issue building permits, including permits for kitchen and bath renovations. Jurisdictions that want to maintain local control over new development and maintain the ability to permit kitchen and bath renovations should therefore plan to adopt a compliant housing element update on time. Kind regards, Ross Johnson YIMBY Law *YIMBY Law is a 501(c)(3) non-profit corporation. YIMBY Law is not a law firm. I am not a lawyer.Nothing in this letter should be construed as legal advice. Instead, I am a California resident reporting my concerns after reviewing publicly available information. From: Ross Johnson To: Housing Element; housinaelementsCabhcd.ca.aov Subject: Major Concerns with Draft Housing Element Date: Thursday,July 15,202112:53:16 PM Attachments: Tustin Letter.odf Hi Tustin and HCD, Thank you so much for allowing the public to comment on Tustin's draft housing element. YIMBY Law has major concerns regarding Tustin's draft housing element. A letter is attached outlining several parts of the housing element are not in compliance with state law. We respectfully request that Tustin's housing element not be certified until they remedy the concerns mentioned in the letter. All the best, Ross Johnson YIMBY Law DiLeva, Adrianne From: Chan Phan <chanphan@cox.net> Sent: Saturday, July 24, 2021 11:56 AM To: Housing Element Cc: chanphan@cox.net Subject: Draft Housing Element Hello, Do we plan to build condominiums, small houses for the young adults, just start out in their careers and wanting to live in City of Tustin? Please add me to that mailing list of new small houses and condominiums. Thank you, Chan "What do we live for if not to make the world a bit better for each other"- George Eliot. 1 DiLeva, Adrianne From: geniephan56@yahoo.com Sent: Monday, July 26, 2021 1:35 PM To: Housing Element Subject: Interest in New housing in Tustin Hello, I am interested in receiving updates on we housing developments in Tustin. Thank you! Genie Phan i Maldonado, Jorge From: Bill Netro <ortenw@gmail.com> Sent: Wednesday, August 25, 2021 3:20 PM To: Housing Element Subject: Re: RE; Initial Study-Negative Declaration Released for Public Review- City of Tustin Housing Element Update 2021-2029 1 was surprised to see the Initial Study (IS) /Negative Declaration (ND). Given the density of house, traffic, parking congestion that will result, an Environmental Impact Report (EIR) should be required. Regards, William Netro 122 Evelyn PI, Tustin, CA 92782 On Wed, Aug 25, 2021 at 2:15 PM Demkowicz, Erica <EDemkowicz@tustinca.org>wrote: Good Afternoon, This email is to inform you that the City has released an Initial Study/Negative Declaration analyzing the potential environmental impacts associated with the City's draft Housing Element Update 2021-2029. This document is available for public review and comment from August 24, 2021-September 23, 2021 and can be viewed and downloaded on the City's Housing Element webpage: www.tustinca.org/housingelement. A hard copy of the document can also be reviewed, by appointment, in the Community Development Department located at City Hall, 300 Centennial Way, Tustin, CA 92780. Comments must be submitted, in writing, via email to: housingelement@tustinca.org. Comments may also be mailed to: City of Tustin Attention: Housing Element Comments 300 Centennial Way Tustin, CA 92780 To review the Initial Study/Negative Declaration and the associated draft Housing Element, please visit: www.tustinca.org/housingelement. i If you should have any additional questions? Please call me at (714) 573-3127. Ayuda en espanol (lame (714) 573- 3174. Regards, Erica H. Demkowicz, AICP Senior Planner City of Tustin Community Development Department 300 Centennial Way Tustin, CA 92780 (714) 573-3127 edemkowicz@tustinca.org 2 Maldonado, Jorge From: Jill Hassett <jrhkiwi@gmail.com> Sent: Friday, August 27, 2021 4:26 PM To: Housing Element Subject: Housing element Hello, I am a home owner in Tustin Meadows for 27 years. The proposed development would create more traffic and more pollution, trash, etc.which has increased tremendously over the years already. My husband's commute to work has more than doubled over the years. This development could affect the housing cost in my neighborhood. My family is against this proposal. Jill 1 PUBLIC ' LAW CENTER Providing Access to Justice For Orange County's Low Income Residents September 7, 2021 Mayor Letitia Clark Mayor Pro Tem Austin Lumbard Members of the City Council City of Tustin CityCouncil@tustinca.org HousingElement@tusfinca.org CC: Colin Cross, Land Use &Planning Analyst Land Use and Planning Unit HousingElements@hcd.ca.gov Colin.Cross@hcd.ca.gov RE: City of Tustin Draft 6th Cycle Housing Element Dear Mayor Clark, Mayor Pro Tem Lumbard, and Members of the City Council, Public Law Center("PLC")is a 501(c)(3)legal services organization that provides free civil legal services to low-income individuals and families across Orange County. Our services are provided across a range of substantive areas of law, including consumer, family, immigration, housing, and health law. Additionally, PLC provides legal assistance to community organizations. Further, the mission of our Housing and Homelessness Prevention Unit includes preserving and expanding affordable housing. Thus, we write on behalf of individuals in need of affordable housing in Orange County to comment on the City of Tustin ("the City")Draft 6th Cycle Housing Element. Government Code Section 65583 requires that a housing element consist of an identification and analysis of existing and projected housing needs and a statement of goals, policies, quantified objectives, financial resources, and scheduled programs for the preservation, improvement, and development of housing.' Additionally, the housing element shall identify adequate sites for housing, including rental housing, factory-built housing, mobilehomes, and emergency shelters, and shall make adequate provision for the existing and projected needs of all economic segments of the community.2 Here, we provide comment on the City's Draft 6th Cycle Housing Element that was submitted to California Department of Housing and Community Development("HCD") for review on July 1, 2021 in connection with the City's review of revisions of the Draft on the agenda for the City Council meeting dated September 7, 2021. Many of our comments are in line 'Cal.Gov.Code Section 65583. 2 Cal.Gov.Code Section 65583. 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 2 with HCD's Review Letter dated August 27, 2021 ("HCD Review Letter").3 While we recognize that the Agenda and Staff Report for the September 7, 2021 City Council Meeting references addressing some of the issues raised in the HCD Review Letter, it is impossible to respond to such changes or determine if they are adequate since, to our knowledge, no copy of the revised Draft has been made available for public review. As of the finalization and submission of this letter, it was not available as part of the Agenda for the City Council Meeting or on the City's website regarding the Housing Element Update.4 As a reminder, the "City must proactively make future revisions available to the public, including any commenters,prior to submitting any revisions to HCD."5 Emergency Shelters The housing element shall include the identification of a zone or zones where emergency shelters are allowed as a permitted use without a conditional use or other discretionary permit.6 The identified zone or zones shall include sufficient capacity to accommodate the need for emergency shelter.7 Additionally, each local government shall identify a zone or zones that can accommodate at least one year-round emergency shelter.$ The local government may identify additional zones where emergency shelters are permitted with a conditional use permit.9 A local government with an existing ordinance or ordinances that comply with these requirements shall not be required to take additional action to identify zones for emergency shelters.10 The housing element must only describe how existing ordinances, policies, and standards are consistent with these requirements.11 The City states that"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."12 The City has identified a number of organizations that serve its homeless population, including several shelters: • Temporary Shelter,Inc.: 57 beds for men, women, and families with children;13 • Village of Hope: undetermined number of beds;14 • Laurel House: unspecified number of beds for teenagers.15 s California Department of Housing and Community Development,Letter re:Review of the City of Tustin's 61 Cycle(2021-2029)Draft Housing Element,August 27,2021 ("HCD Review Letter"). 4 See https://www.tustinca.org/121141ousing-Element-Update,last checked September 7,2021. s HCD Review Letter,Page 13. 6 Cal.Gov.Code Section 65583(a)(4)(A). Cal.Gov.Code Section 65583(a)(4)(A). 'Cal.Gov.Code Section 65583(a)(4)(A). 9 Cal.Gov.Code Section 65583(a)(4)(A). 10 Cal.Gov.Code Section 65583(a)(4)(D). 11 Cal.Gov.Code Section 65583(a)(4)(D). 12 Cal.Gov.Code Section 65583(a)(4)(A);Cal.Gov.Code Section 65583(a)(4)(D);City of Tustin,Draft Housing Element 2021-2029,II-27(June 2021). 13 City of Tustin,Draft Housing Element 2021-2029,A-3 (June 2021). 14 City of Tustin,Draft Housing Element 2021-2029,A-3;D-60-62(June 2021). 15 City of Tustin,Draft Housing Element 2021-2029,D-62(June 2021). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 3 However, the City has not described the existing ordinances that comply with the requirements above or described how its existing ordinance and shelters can accommodate its housing need.16 The City must provide more information about its ordinance to meet this requirement or the City must include a program to amend its zoning code within one year of adoption of the housing element to identify zones with sufficient capacity to accommodate the housing needs of the City's unhoused populations. Assessing Emergency Shelter Need The need for emergency shelter shall be assessed based on the capacity necessary to accommodate the most recent homeless point-in-time count conducted before the start of the planning period, the need for emergency shelter based on number of beds available on a year- round and seasonal basis, the number of shelter beds that go unused on an average monthly basis within a one-year period, and the percentage of those in emergency shelters that move to permanent housing solutions.17 The need for emergency shelter may be reduced by the number of supportive housing units that are identified in an adopted 10-year plan to end chronic homelessness and that are either vacant or for which funding has been identified to allow construction during the planning period.18 The City only used the 2019 Point-In-Time count to determine that its homeless population consists of 95 unsheltered and 264 sheltered people.19 However, the City has not fully analyzed its emergency shelter need.20 First, the City does not consider the number of beds that go unused or the percentage that move to permanent housing.21 Second, the City should consider its ability to accommodate its sheltered homeless population. If there are limits to how long a person may stay at a shelter, some of the sheltered individuals may become unsheltered. Third, while the City identifies various shelters and facilities serving the unhoused populations of Tustin, it does not analyze whether there is sufficient capacity to accommodate the individuals identified in its Point-In-Time count. The City does not specify how many emergency shelter beds (not including transitional housing)there are at Village of Hope or Laurel House. In discussing Village of Hope in the City's Review of Past Performance, the City described the Village of Hope as"a 192-unit emergency and transitional housing project . . . at the former MCAS Tustin" and that they have "increased their transitional housing capacity to up to 387 beds, an increase of 195 beds."22 However, the City also describes Village of Hope as providing 262 units for transitional housing.23 The City must differentiate between emergency shelter beds and transitional housing 16 Cal.Gov.Code Section 65583(a)(4)(D). "Cal.Gov.Code Section 65583(a)(7). 18 Cal.Gov.Code Section 65583(a)(7). 19 City of Tustin,Draft Housing Element 2021-2029,II-14(June 2021). 20 Cal.Gov.Code Section 65583(a)(7). 21 Cal.Gov.Code Section 65583(a)(7). 22 City of Tustin,Draft Housing Element 2021-2029,A-3 (June 2021). 23 City of Tustin,Draft Housing Element 2021-2029,D-26(June 2021). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 4 units at Village of Hope to accurately determine its emergency shelter need.24 Similarly, Laurel House is described as shelter for homeless teenagers but does not specify how many beds are available. The City must identify the specific capacity and utilization of beds at Laurel House to assess its emergency shelter need. Based on the limited information provided, it is impossible to realistically determine how much of the City's homeless population is actually sheltered. The City must reanalyze its emergency shelter need. Multijurisdictional Agreements A local government may satisfy all or part of its requirement to identify a zone or zones suitable for the development of emergency shelters by adopting and implementing a multijurisdictional agreement, with a maximum of two other adjacent communities, that requires the participating jurisdictions to develop at least one year-round emergency shelter within two years of the beginning of the planning period.25 The agreement shall allocate a portion of the new shelter capacity to each jurisdiction as credit toward its emergency shelter need, and each jurisdiction shall describe how the capacity was allocated as part of its housing element.26 Each member jurisdiction of a multijurisdictional agreement shall describe in its housing element all of the following: • How the joint facility will meet the jurisdiction's emergency shelter need.27 • The jurisdiction's contribution to the facility for both the development and ongoing operation and management of the facility.28 • The amount and source of the funding that the jurisdiction contributes to the facility.29 The aggregate capacity claimed by the participating jurisdictions in their housing elements shall not exceed the actual capacity of the shelter.30 The City lists the Sheepfold Shelter 31 as an emergency shelter that serves its unhoused women and children survivors of domestic violence and recognizes that the shelter serves 24 Village of Hope and Laurel House are both Christian-oriented programs and facilities. See https://www.rescuemission.org/shelter/village-of-hope/(last visited August 18,202 1)and https://hopeharbor.org/ (last visited August 18,2021).While we do not doubt these programs provide an important and vital service to the community they serve,the religious affiliation of the programs limits who may access and benefit from these services.Individuals and families who are not Christian or who do not ascribe to any faith or religion would likely not be able to meaningfully access or benefit from these services. 25 Cal.Gov.Code Section 65583(d)(1). 26 Cal.Gov.Code Section 65583(d)(2). 27 Cal.Gov.Code Section 65583(d)(3)(A). 28 Cal.Gov.Code Section 65583(d)(3)(B). 29 Cal.Gov.Code Section 65583(d)(3)(C). 30 Cal.Gov.Code Section 65583(d)(4). "Additionally,the Sheepfold Shelter is a non-denominational Christian program that requires attendance to daily Bible study and Sunday church services. As mentioned previously with regards to Village of Hope and Laurel House,while there is no doubt this program provides an important and vital service to the community it serves,the religious requirements and affiliation of the program limit who may access and benefit from these services. Individuals and families who are not Christian or who do not ascribe to any faith or religion would likely not be able to meaningfully access or benefit from these services. See https:Hthesheepfold.org/the-sheepfold.php?Our-Program- 5(last visited August 18,2021). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 5 portions of Orange and San Bernardino counties.32 The City does not claim that there is a multijurisdictional agreement with the other jurisdictions that use this shelter to house its homeless population.33 Further, the City does not provide any of the information listed above that would enable the City to count Sheepfold's beds towards its emergency shelter need pursuant to a multijurisdictional agreement.34 Without this information, the City cannot claim that the Sheepfold Shelter houses any of its homeless population. Emergency Shelter Standards The local government shall also demonstrate that existing or proposed permit processing, development, and management standards are objective and encourage and facilitate the development of, or conversion to, emergency shelters.35 Although the City identifies the Tustin Legacy Specific Plan and other unspecified sites as containing zones that permit emergency shelters, the City does not indicate whether development standards for these zones are objective.36 The City must provide the details of its emergency shelter standards to demonstrate that they are objective and encourage and facilitate the development of emergency shelters to comply with California law.37 Special Housing Needs The housing element must analyze special housing needs, such as those of the elderly; persons with disabilities, including a developmental disability;38 large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter.39 An analysis of special housing needs by a city or county may include an analysis of the need for frequent user coordinated care housing services.40 The City references each group with special housing needs, but fails to fully analyze their demographics or their housing needs.41 And while the City does identify some programs that may be considered to address these special housing needs, such programs are inadequate and generally vague and noncommittal. 32 City of Tustin,Draft Housing Element 2021-2029,D-60(June 2021). 33 Cal.Gov.Code Section 65583(d)(1);Cal.Gov.Code Section 65583(d)(2). 34 Cal.Gov.Code Section 65583(d)(3). 35 Cal.Gov.Code Section 65583(a)(4)(A). 36 Cal.Gov.Code Section 65583(a)(4)(A);City of Tustin,Draft Housing Element 2021-2029,11-27(July 2021). 37 Cal.Gov.Code Section 65583(a)(4)(A). 38"`Developmental disability' means a disability that originates before an individual attains 18 years of age, continues,or can be expected to continue,indefinitely,and constitutes a substantial disability for that individual.As defined by the Director of Developmental Services,in consultation with the Superintendent of Public Instruction, this term shall include intellectual disability,cerebral palsy,epilepsy,and autism.This term shall also include disabling conditions found to be closely related to intellectual disability or to require treatment similar to that required for individuals with an intellectual disability,but shall not include other handicapping conditions that are solely physical in nature." Cal. Welfare and Institutions Code Section 4512. 39 Cal.Gov.Code Section 65583(a)(7). 40 Cal.Gov.Code Section 65583(a)(7). 41 Cal.Gov.Code Section 65583(a)(7). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 6 For example, Program 1.19 Fees, Exactions, and Permit Procedures states that the City will "consider waiving or modifying various fees or exactions normally required where such waiver will reduce the affordability gap associated with providing housing of the elderly and for very-low- and low-income households.42 However, the City simply states it will consider taking certain actions then vaguely describe the actions it will take. Program 2.4 Housing for Persons with Disabilities states that the City will "continue to work with the Regional Center for Orange County to develop and implement an outreach program . . . that informs families within the City of affordable housing and services available for persons with developmental disabilities."43 The City does not explain how the outreach program will operate, such as how the City will identify these residents. Although the City has Program 2.5 to affirmatively further fair housing and numerous programs generally encouraging affordable housing, the City does not specifically address how it will assist large households that might have lower incomes, face overcrowding, and have limited availability of adequately sized affordable units;44 female parent households that often have lower incomes and difficulty obtaining affordable childcare, healthcare, and supportive services;45 or farmworkers with lower incomes and are seasonally employed.46 The element provides employment statistics for farmworkers, but fails to analyze the housing needs of this group. Cal. Gov. Code Section 65583(c)(9)(1)(C) states that a program is necessary to provide for sufficient sites to meet the need with zoning that permits farmworker housing use by right, including density and development standards that could accommodate and facilitate the feasibility of the development of farmworker housing for low- and very low income households. In its next draft, the City must describe how it can address the needs of all its special housing groups by making firm commitments to take a detailed set of actions. The City must more fully analyze the required special housing populations and their unique needs and then develop programs with specifics that actually commit the City to addressing those needs. Reducing RHNA By Units Built A city may reduce its share of the regional housing need by the number of units built between the start of the projection period and the deadline for adoption of the housing element.47 If the city does so, the city shall include a description of the methodology for assigning those housing units to an income category based on actual or projected sales price, rent levels, or other mechanisms establishing affordability.48 The City describes three housing developments that have been approved or entitled and counts these units toward its RHNA.49 However, none of these units will be built between the 42 City of Tustin,Draft Housing Element 2021-2029,IV-12(June 2021). 43 City of Tustin,Draft Housing Element 2021-2029,IV-15(June 2021). 44 City of Tustin,Draft Housing Element 2021-2029,11-13(June 2021). 45 City of Tustin,Draft Housing Element 2021-2029,11-13(June 2021). 46 City of Tustin,Draft Housing Element 2021-2029,11-13(June 2021). 47 Cal.Gov.Code Section 65583.1(d). "Cal.Gov.Code Section 65583.l(d). 49 City of Tustin,Draft Housing Element 2021-2029,B-1-2(June 2021). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 7 start of the projection period and the deadline for adoption of the housing element.50 Therefore, the City cannot count any of these units toward its RHNA.51 Even if it could, the City did not describe its methodology for assigning those housing units to an income category based on actual or projected sales price, rent levels, or other mechanisms establishing affordability.52 Additionally, it is unclear whether some of the units,particularly those that are a part of Village of Hope, would actually be considered units that count toward the City's RHNA, as Village of Hope is described as a"transitional housing facility."53 Constraints Governmental Constraints The housing element must contain an analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in Section 65583(c)(1),54 and for persons with disabilities,55 including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, local processing and permit procedures, and any locally adopted ordinances that directly impact the cost and supply of residential development.56 The analysis shall also demonstrate local efforts to remove governmental constraints that hinder the locality from meeting its share of the RHNA and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters.57 In addressing governmental constraints, the City discusses land use controls, fees and improvements, building codes and enforcement, and local processing and permit procedures.58 However, the City only touches on how land use controls can be both constraints and tools for housing and describes residential land use designations and their associated zoning and densities.59 The City only notes that height limits may be a constraint on housing and does not explain how the City might mitigate this constraint.60 The City continues to describe specific plan areas, overlay zones, other types of districts, and density bonus law but does not analyze 50 Cal.Gov.Code Section 65583.1(d). 51 Cal.Gov.Code Section 65583.1(d). 52 Cal.Gov.Code Section 65583.1(d). 53 City of Tustin,Draft Housing Element 2021-2029,B-2(June 2021). 54"Housing for all income levels,including multifamily rental housing,factory-built housing,mobilehomes, housing for agricultural employees,supportive housing,single-room occupancy units,emergency shelters,and transitional housing." Cal. Gov. Code Section 65583(c)(1). ss"'Developmental disability' means a disability that originates before an individual attains 18 years of age, continues,or can be expected to continue,indefinitely,and constitutes a substantial disability for that individual. As defined by the Director of Developmental Services,in consultation with the Superintendent of Public Instruction, this term shall include intellectual disability,cerebral palsy,epilepsy,and autism.This term shall also include disabling conditions found to be closely related to intellectual disability or to require treatment similar to that required for individuals with an intellectual disability,but shall not include other handicapping conditions that are solely physical in nature." Cal. Welfare and Institutions Code Section 4512; Cal.Gov.Code Section 65583(a)(7). 56 Cal.Gov.Code Section 65583(a)(5). 57 Cal.Gov.Code Section 65583(a)(5). 58 Cal.Gov.Code Section 65583(a)(5). 59 City of Tustin,Draft Housing Element 2021-2029,11-22-23(June 2021). 60 Cal.Gov.Code Section 65583(a)(5);City of Tustin,Draft Housing Element 2021-2029,11-23(June 2021). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 P. 8 constraints associated with these land use controls. Instead, the City generally claims that its "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."61 However, the City must address how it will mitigate the height limit constraint, analyze how its other named land use controls may be constraints, and explain how it came to the conclusion that its land use regulatory mechanisms do not constrain new development. Regarding housing for persons with disabilities, the City claims that its definition of "family" is not a constraint, that the City follows California law in developing multi-family complexes, that the City allows residential care facilities, and that improvements for disability accommodations only need a building permit. The City also asserts that it"previously amended the Zoning Code to remove governmental constraints to reasonable accommodation for the disabled. ,62 The City should explain how it analyzed its zoning code for constraints, how it removed governmental constraints, and whether there is any room for improvement, especially in light of Program 1.5. Although the City claims it already removed constraints to housing in its zoning code, Program 1.5 Zoning Code Streamlining Program states the City will "evaluate and implement when possible, zoning code amendments that will facilitate application streamlining" and "evaluate and consider amendments to existing commercial and industrial Specific Plans for potential inclusion of additional residential units within the respective areas."63 The City should clarify the constraints associated with the zoning code that warrant the creation of Program 1.5 and, instead of implementing"when possible" and"considering" amendments, the City must make commitments to take detailed actions that address such constraints. In addressing fees and improvements, the City states that, although"development fees are not considered a constraint to housing," fees and site improvements "contribute to the total cost of development," "impact the final purchase or rental price," and"can significantly add to the cost of producing housing."64 First, the City should explain why it does not consider development fees a constraint when they actively raise the price of housing. Second, the City must revise Program 1.19 Fees, Exactions, and Permit Procedures, stating that the City will "consider waiving or modifying various fees or exactions normally required where such waiver will reduce the affordability gap associated with providing housing of the elderly and for very- low and low-income households," to remove noncommittal language.65 The City acknowledges that building codes "have the potential to increase the cost of housing construction and/or maintenance."66 The City attempts to justify this additional cost by 61 City of Tustin,Draft Housing Element 2021-2029,II-27-28(June 2021). 62 City of Tustin,Draft Housing Element 2021-2029,II-29(June 2021). 63 City of Tustin,Draft Housing Element 2021-2029,IV-5(June 2021). 64 City of Tustin,Draft Housing Element 2021-2029,II-30(June 2021). 65 City of Tustin,2021-2029 Housing Element Draft,IV-12(June 2021). 66 City of Tustin,2021-2029 Housing Element Draft,II-34(June 2021). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 P. 9 explaining that"the City of Tustin's building codes are based on regulations necessary to protect the public health, safety, and welfare of its residents" and that it adopted the 2019 California Building Code with minor amendments, "none of which are expected to pose a constraint to development."67 However, the City does not explain how its building codes protect its residents or how it concluded the California Building Code contains no constraints to housing. Further, Program 1.2 Objective Design Standards states that the City will adopt"objective design standards for clarity to development community and facilitate high quality residential development citywide."68 The City does not explain what objective design standards it will develop or how these standards will address any of the constraints discussed and must do so in its next draft. Regarding local processing and permit procedures, the City explains that"the evaluation and review process required by the City procedures contributes to the cost of housing" and that "City policies provide for the minimum processing time necessary to comply with legal requirements and review procedures" according to State law.69 Although the City does not analyze how this process acts as a constraint on housing, Part of Program 1.11 Development and Permit Streamlining states that the City will"use technology and revise internal processes to reduce processing time, which in turn reduces development costs."70 If the City did not consider its process a constraint, this program would not be necessary. The City must conduct a full analysis of its process and procedures, explain how they act as constraints, and specifically address how Program 1.11 and other programs can mitigate the constraints. The City also identifies "the number of staff and amount of staff time available for processing development projects" as a governmental constraint and explains that"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."71 However the City does not explain how it can mitigate this constraint in any of its programs and must do so as it revises its Draft. Nongovernmental Constraints The housing element must also analyze potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by Section 65583.2(c), and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality's share of the RHNA.72 67 City of Tustin,2021-2029 Housing Element Draft,II-34(June 2021). 68 City of Tustin,2021-2029 Housing Element Draft,IV-4(June 2021). 69 City of Tustin,2021-2029 Housing Element Draft,II-34(June 2021). 70 City of Tustin,2021-2029 Housing Element Draft,IV-8(June 2021). 71 City of Tustin,2021-2029 Housing Element Draft,II-35-36(June 2021). 72 Cal.Gov.Code Section 65583(a)(6). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 P. 10 The analysis shall also demonstrate local efforts to remove nongovernmental constraints that create a gap between the locality's planning for the development of housing for all income levels and the construction of that housing.73 In addressing nongovernmental constraints, the City discusses construction costs, land costs, and availability of financing.74 Here, the City discussed how the high cost of construction materials can be a constraint for building affordable housing but claims that costs can be reduced by reducing the amount of amenities to a number that is just above the minimum needed for "health, safety, and adequate performance."75 The City does not describe what amenities will not be included and should include information on how the reduced amenities will still provide a sufficient quality of life to residents in the units. The City also claims that"raw land and improvement costs comprise approximately 40-50 percent of the total development costs of a residential unit," and that land costs have increased, which can make homeownership unattainable for some people.76 Although the City claims that the land costs are more a function of the site than the jurisdiction, it does not include any additional information about steps it will take to ensure that high land costs do not increase the rent or associated costs for residents.77 Finally, the City claims that variable rate mortgages can cause a constrained housing market and raise prices and includes tables showing the change in median home prices for Tustin and other jurisdictions from Q2 2019 to Q2 2020, which are often"out of reach of Tustin's low and very low-income households."78 However, the City does not include any information about how they plan to ensure that these variable rates do not create home prices that are too high for lower income residents. The City also simply mentions that credit worthiness plays in home- ownership by forcing those with poor credit to accept higher interest rates or insufficient loan amounts.79 It does not discuss how it will address these issues. The City must provide more details about these constraints on housing and describe specific actions it will take to address them.80 Site Inventory The housing element must include an inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality's housing need for a designated income level.81 73 Cal.Gov.Code Section 65583(a)(6). 74 Cal.Gov.Code Section 65583(a)(6);City of Tustin,2021-2029 Housing Element Draft,II-18(June 2021). 75 City of Tustin,2021-2029 Housing Element Draft,II-18(June 2021). 76 City of Tustin,2021-2029 Housing Element Draft,II-19(June 2021). 77 Cal.Gov.Code Section 65583(a)(6). 78 City of Tustin,2021-2029 Housing Element Draft,II-20(June 2021). 79 City of Tustin,2021-2029 Housing Element Draft,II-21 (June 2021). 80 Cal.Gov.Code Section 65583(a)(6). 81 Cal.Gov.Code Section 65583(a)(3);Cal.Gov.Code Section 65583.2(a). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 P. 11 Determining Site Capacity Based on the information provided in the site inventory, a city or county shall determine whether each site in the inventory can accommodate the development of some portion of its share of the regional housing need by income level during the planning period.82 To determine the number of housing units that can be accommodated on each site when local law or regulations require the development of a site at a minimum density, the HCD shall accept the planning agency's calculation of the total housing unit capacity based on the established minimum density.83 To determine the number of housing units that can be accommodated on each site when the jurisdiction does not adopt a law or regulation requiring the development of a site at a minimum density, the jurisdiction shall demonstrate how the number of units determined for that site will be accommodated.84 The number of units that can be accommodated on each site shall be adjusted as necessary based on the potential and actual governmental constraints upon maintenance, improvement, or development of housing, including land use controls and site improvements; the realistic development capacity for the site; typical densities of existing or approved residential developments at a similar affordability level in that jurisdiction; and the current or planned availability and accessibility of sufficient water, sewer, and dry utilities.85 Because the City does not adopt a law or regulation requiring the development of a site at a minimum density, the jurisdiction must demonstrate how the number of units determined for that site will be accommodated.86 Here, the City appears to use a"defined default density" of 30 du/ac when calculating the expected capacity of each of its sites.87 However, the City does not explain how it calculates the number of units that can be accommodated on each listed site, and does not address any of the other required factors.88 Instead, the City merely claims that"[all] 16 identified sites to meet RHNA have appropriate zoning to allow residential development, at densities to achieve the estimated capacities and, without inhibitors, such as stringent standards, that inhibit residential development."89 In particular, when discussing Site 2, the City describes housing currently built within the Site area, but does not discuss the density of the existing housing, or make any connection between current density in the area and expected future density.90 The City must provide actual analysis regarding how it determined the site capacity of each of its sites in its next draft, including analysis regarding constraints. 82 Cal.Gov.Code Section 65583.2(c). "Cal.Gov.Code Section 65583.2(c)(1). 84 Cal.Gov.Code Section 65583.2(c)(1). "Cal.Gov.Code Section 65583.2(c)(2). 86 Cal.Gov.Code Section 65583.2(c)(1). 87 City of Tustin,2021-2029 Housing Element Draft,B-13(June 2021). 88 Cal.Gov.Code Section 65583.2(c)(2). 89 City of Tustin,2021-2029 Housing Element Draft,B-12(June 2021). 90 City of Tustin,2021-2029 Housing Element Draft,B-5(June 2021). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 12 In addition, the City provides a chart, titled "Sites to Meet RHNA Estimated Income Distribution Reference."91 This chart explains how very-low-income, low-income, moderate- income, and above-moderate-income units will be distributed among Sites IA, 1B, 2, 3-6 (grouped together), and 7-16 (grouped together).92 However, the City fails to designate any units for extremely-low-income housing. Without this information, it is impossible to determine whether the City will be able to meet its housing needs for all income levels. Lastly, it is impossible to determine how the City will allocate units because the City groups several sites together in its chart, and many of these sites also contain multiple lots. For example, the City states that Sites 3, 4, 5, and 6 will accommodate 168 very-low-income units, 30 low-income units, 83 moderate-income units, and 219 above-moderate-income units.93 Together, Sites 3 through 6 contain twelve individual parcels; the City does not provide any information regarding how units are distributed among these parcels. The City must provide further information regarding how it will distribute housing for all income levels among its sites, and among the lots within each site, in its next draft. Site Inventory The inventory of land must include the following: (1) a listing of properties by assessor parcel number;94 (2)the size of each property;95 (3)the general plan designation and zoning of each property;96 (4) a description of existing or planned water, sewer, and other dry utilities supply, the availability and access to distribution facilities;97 (5)whether the utilities are available and accessible to support housing development or if there is an existing general plan program or other mandatory program or plan, including a program or plan of a public or private entity providing water or sewer service, to secure sufficient water, sewer, and dry utilities supply to support housing development;98 (6) a map that shows the location of the sites included in the inventory;99 (7)the number of units that can realistically be accommodated on that site;100 and (8)whether the site is adequate to accommodate lower income housing, moderate-income housing, or above moderate-income housing.101 The City's site inventory is incomplete. First, the City fails to include assessor parcel numbers for the lots within Site 1B.102 Second, the City lists zoning designations for each larger project, not for individual parcels.103 Third, the City does not describe existing or planned utilities for any of the sites within its inventory.104 Fourth, while the City does provide maps 91 City of Tustin,2021-2029 Housing Element Draft,B-10(June 2021). 92 City of Tustin,2021-2029 Housing Element Draft,B-10(June 2021). 93 City of Tustin,2021-2029 Housing Element Draft,B-10(June 2021). 94 Cal.Gov.Code Section 65583.2(b)(1). 95 Cal.Gov.Code Section 65583.2(b)(2). 96 Cal.Gov.Code Section 65583.2(b)(2). 97 Cal.Gov.Code Section 65583.2(b)(5)(A-B). 98 Cal.Gov.Code Section 65583.2(b)(5)(A-B). 99 Cal.Gov.Code Section 65583.2(b)(7). ioo Cal.Gov.Code Section 65583.2(c). 101 Cal.Gov.Code Section 65583.2(c). 102 Cal.Gov.Code Section 65583.2(b)(1);City of Tustin,2021-2029 Housing Element Draft,B-16(June 2021). 103 Cal.Gov.Code Section 65583.2(b)(2). 104 Cal.Gov.Code Section 65583.2(b)(5)(A-B). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 13 showing the location of each site included in the inventory, the maps are low-resolution and difficult to read.105 Moreover, the maps do not specify which APN (when applicable) is assigned to which lot within the map. It is generally possible to determine which APN is assigned to which lot by comparing acreages: for example, the map for Site 1A106 does not specify which APN is assigned to which lot, but this information is possible to deduce since the acreage varies from 0.002 to 36.17, and the lots are clearly different sizes.107 However, the maps should specify this information without the reader having to make their own deductions and calculations. Fifth, the City does not provide the number of units that can realistically be accommodated on each parcel but allocates capacity based on the larger site.108 Finally, because the City does not assign sites to individual parcels, it cannot assign these sites to income levels.109 The City must provide the requisite information for each individual parcel in its next draft. Lower Income Sites If a jurisdiction designates sites that have been previously identified, sites smaller than half an acre, or sites larger than ten acres to accommodate its lower income housing needs, the sites must satisfy extra criteria.I10 Previously Identified Sites A vacant site that has been included in two or more consecutive planning periods that was not approved to develop a portion of the locality's housing need cannot be deemed adequate to accommodate a portion of the housing need for lower income households unless the site is zoned at an appropriate density and the site is subject to a program in the housing element requiring rezoning within three years of the beginning of the planning period to allow residential use by right for housing developments in which at least 20% of the units are affordable to lower income units.111 City identified Sites 1B, 2, 11, and 12 to accommodate its RHNA.112 The lots within these Sites are vacant, and were included in the 4th and 5th cycle planning periods and were not approved to develop a portion of the City's 5th Cycle RHNA.113 These sites cannot be deemed adequate to accommodate a portion of the City's lower income RHNA unless the site is zoned as an appropriate density and the site is subject to a program in the housing element requiring rezoning within three years of the beginning of the planning period to allow residential use by right for housing developments in which at least 20% of the units are affordable to lower income units.114 However, it is unclear whether these sites were zoned at an appropriate density. The City must identify appropriate densities for each site in its next draft to keep these sites on its inventory. 105 Cal.Gov.Code Section 65583.2(b)(7). 106 City of Tustin,2021-2029 Housing Element Draft,B-24(June 2021). 107 City of Tustin,2021-2029 Housing Element Draft,B-16(June 2021). 108 Cal.Gov.Code Section 65583.2(c). 109 Cal.Gov.Code Section 65583.2(c). 110 Cal.Gov.Code Section 65583.2(c). 111 Cal.Gov.Code Section 65583.2(c). 112 City of Tustin,2021-2029 Housing Element Draft,B-16 to-20(June 2021). 113 Cal.Gov.Code Section 65583.2(c). 114 Cal.Gov.Code Section 65583.2(c). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 14 Site Size If a site is smaller than half an acre or larger than ten acres, it cannot be deemed adequate to accommodate lower income housing unless the locality can demonstrate that sites of an equivalent size were successfully developed during the prior planning period for an equivalent number of lower income housing units as projected for the Site.115 Alternatively, the locality may provide other evidence to HCD that the site is adequate to accommodate lower income housing.116 The City identified several sites smaller than half an acre:117 • Site IA, APN 430-381-38 • Site 2, APN 430-391-59 • Site 2, APN 430-391-60 • Site 3, APN 500-141-09 • Site 4, APN 500-022-09 • Site 6, APN 432-041-17 • Site 6, APN 432-041-14 • Site 9, APN 401-583-01 • Site 9, APN 401-583-15 • Site 10, APN 401-601-05 • Site 10, APN 401-601-06 • Site 10, APN 401-601-07 • Site 10, APN 401-601-09 • Site 11, APN 401-584-04 • Site 11, APN 401-584-05 • Site 11, APN 401-584-06 • Site 11, APN 401-584-07 • Site 11, APN 401-584-08 • Site 11, APN 401-584-09 • Site 13, APN 401-573-13 • Site 14, APN 401-622-18 • Site 15, APN 432-074-08 • Site 16, APN 401-631-13 • Site 17, APN 500-071-12 These sites cannot be deemed adequate to accommodate lower income housing unless the locality can demonstrate that sites of an equivalent size were successfully developed during the prior planning period for an equivalent number of lower income housing units as projected for the site or can provide other evidence to HCD that the sites are adequate to accommodate lower income housing.118 The City does not provide any analysis regarding sites of equivalent size, or any other evidence that the site is adequate, such as developer interest or similar uses on adjacent lots. In particular, regarding the small site within Site IA, the City cites a recently entitled 15 Cal.Gov.Code Section 65583.2(c)(2). 16 Cal.Gov.Code Section 65583.2(c)(2). 117 City of Tustin,2021-2029 Housing Element Draft,B-16 to-21 (June 2021). 118 Cal.Gov.Code Section 65583.2(c)(2). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 15 market-rate development in neighboring Site 1B.119 However, one market-rate development is not evidence that the area can support non-market-rate, low-income housing. The City also identified several sites larger than ten acres:120 • Site IA, APN 430-381-95 • Site 1B, Tract 18197 (25.437 acres) • Site 1B, Tract 18197 (19.424 acres) • Site 2, Unidentified parcel (46.748 acres) • Site 2, APN 430-391-03 • Site 10, APN 401-601-01 Again, these sites cannot be deemed adequate to accommodate lower-income housing unless the locality can demonstrate that sites of an equivalent size were successfully developed during the prior planning period for an equivalent number of lower income housing units as projected for the site or can provide other evidence to HCD that the sites are adequate to accommodate lower income housing.121 Since the City does not provide the requisite evidence or provide any analysis regarding how it plans to ensure that these large lot sizes will accommodate low-income housing, these sites cannot be deemed adequate to accommodate lower-income housing. The City must provide extensive analysis regarding both small and large lot sizes in its next draft, and provide evidence that these sites are adequate to support low-income housing. Calculating the Number of Lower Income Units In determining site capacity for lower income units, the City has not explicitly met either of the following requirements: (1)provide an analysis demonstrating how the adopted densities accommodate this need, including, but not limited to, factors such as market demand, financial feasibility, or information based on development project experience within a zone or zones that provide housing for lower income households;122 or (2) fall into a density deemed appropriate to accommodate housing for lower income households.123 The City must provide the requisite analysis or clarify whether sites for lower income units fall into the appropriate residential density. Nonvacant Sites If a jurisdiction designates a site that is nonvacant, it must describe the existing use of the property.124 If a nonvacant site is owned by the city or county, the description shall also include whether there are any plans to dispose of the property during the planning period and how the city or county will comply with the Surplus Lands Act.125 119 City of Tustin,2021-2029 Housing Element Draft,B-4(June 2021). 120 City of Tustin,2021-2029 Housing Element Draft,B-16 to-19(June 2021). 121 Cal.Gov.Code Section 65583.2(c)(2). 122 Cal.Gov.Code Section 65583.2(c)(3)(A). 123 Cal.Gov.Code Section 65583.2(c)(3)(B). 124 Cal.Gov.Code Section 65583.2(b)(3). 125 Cal.Gov.Code Section 65583.2(b)(3). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 16 For nonvacant sites, the jurisdiction shall specify the additional development potential for each site within the planning period and explain the methodology used to determine the development potential.126 The methodology shall consider multiple factors, including: (1) the extent to which existing uses may constitute an impediment to additional residential development; (2)the jurisdiction's past experience with converting existing uses to higher density residential development; (3)the current market demand for the existing use; (4) an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development; (5) development trends; (6)market conditions; and(7)regulatory or other incentives or standards to encourage additional residential development on these sites.127 First, the City has not identified the existing uses for each individual parcel and must do so to allow for a more accurate analysis of sites.128 Second, the City identifies one nonvacant site that is owned by the City as available to accommodate its housing need.129 The City states that the building currently occupying this lot, the Tustin War Memorial, is "currently vacant and permanently closed."130 However, the City does not explicitly state whether it will dispose of the property during the planning period, and does not state if or how the city will comply with the Surplus Lands Act.131 To continue using this site to meet its RHNA needs, the City must specifically state how it plans to comply with the Surplus Land Act;particularly, how it plans to dispose of the property on the site during the planning period. Third, the City identifies several other nonvacant sites within Sites 4, 5, 6, 7, 8, 9, 10, 16, and 17, but does not specify the additional development potential or explain the methodology it used to determine the potential.132 For example, Site 4 is within the Red Hill Avenue Specific Plan (RHASP) Area.133 Sites within this area are "prime for revitalization," because while currently it is primarily a commercial and retail corridor, mixed-use residential is now allowed in the area.134 However, while the city does specify the additional development potential for Site 4, and claims that there have been "development interest discussions" in the past regarding the site, the City does not explain its methodology, or consider any of the required factors mentioned above.135 The City must address how it plans to address and quantify the additional development potential of the multiple nonvacant sites it claims will be suitable to accommodate its housing needs. Moreover, the City must provide robust analysis regarding the methodology it uses to 126 Cal.Gov.Code Section 65583.2(g)(1). 127 Cal.Gov.Code Section 65583.2(g)(1). 128 Cal.Gov.Code Section 65583.2(b)(3). 129 City of Tustin,2021-2029 Housing Element Draft,B-19(June 2021). 130 City of Tustin,2021-2029 Housing Element Draft,B-8(June 2021). 131 Cal.Gov.Code Section 65583.2(b)(3). 132 Cal.Gov.Code Section 65583.2(g)(1). 133 City of Tustin,2021-2029 Housing Element Draft,B-5 to-6(June 2021). 134 City of Tustin,2021-2029 Housing Element Draft,B-5(June 2021). 135 Cal.Gov.Code Section 65583.2(g)(1). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 17 quantify the development potential. The City should provide this data in its draft; otherwise, it should remove these sites from its RHNA. Presumption of Impeding Additional Residential Development An existing use shall be presumed to impede additional residential development, absent findings based on substantial evidence that the use is likely to be discontinued during the planning period.136 Here, the City has failed to overcome the presumption that the existing uses impede residential development because it has not provided substantial evidence that the existing uses are likely to be discontinued during the planning period.137 First, regarding Sites 4 and 5, which are under the same ownership, the City claims that"[past] development interest discussions have ensued with the owners, interested developers and the City regarding this property."138 However, nebulous assertions of past"interest," without any timeline for development or other quantifiable goal, is insufficient evidence that the current property use is likely to be discontinued. Site 6 also has current residential uses, and the City says there is currently a "shopping center with commercial, retail, restaurants and service stations (only one active)" on the lot.139 While only one service station being active may imply a certain amount of inactivity, it is not enough to compensate for the fact that the lot is still being actively used. Second, Sites 7 and 8 are currently occupied by a physical therapy business and a hotel, respectively,140 and while the City says that a major tenant on the lot in Site 10 vacated in 2015-2016,141 it does not mention what, if anything, will become of the other current commercial tenants in Site 10. Lastly, regarding Site 16, the City mentions "significant owner and developer interests" and previous mixed-use residential plans submitted to the City, but does not provide any substantial evidence that the current commercial activity on the site will cease during the planning period.142 The City has failed to provide any convincing evidence that the owners of these properties will cease their existing uses, and it seems very unlikely that these properties will be actually available for residential use. The City must provide evidence that these properties' existing uses will not impede residential development or remove the sites from its next draft. Accessory Dwelling Units A jurisdiction may count an ADU for purposes of identifying adequate sites for housing.143 The number of ADUs identified is based on the number of ADUs developed in the prior housing element planning period, whether or not the units are permitted by right; the need for these units in the community; the resources or incentives available for their development; and any other relevant factors determined by HCD.144 To estimate the number of ADUs that will be developed in the planning period, a jurisdiction must generally use a three-part approach 136 Cal.Gov.Code Section 65583.2(g)(2). 137 Cal.Gov.Code Section 65583.2(g)(2). 138 City of Tustin,2021-2029 Housing Element Draft,B-6(June 2021). 139 City of Tustin,2021-2029 Housing Element Draft,B-6(June 2021). 140 City of Tustin,2021-2029 Housing Element Draft,B-7(June 2021). 141 City of Tustin,2021-2029 Housing Element Draft,B-8(June 2021). 142 City of Tustin,2021-2029 Housing Element Draft,B-9(June 2021). 143 Cal.Gov.Code § 65852.2(m);Cal.Gov.Code § 65583.1(a). 11 Cal.Gov.Code Section 65583.1(a). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 P. 18 addressing (1) development trends, (2) anticipated affordability, and (3)resources and incentives.145 The City has estimated that 100 ADUs will be created during the 6th Cycle.146 The City based this project on"the recent past performance as well as the new legislation," "the City's efforts to allow and encourage such units" and that"a current S132 grant funded project will result in the preparation of citywide accessory dwelling unit design guidelines with accompanying examples."147 However, the City does not consider the need for these units in the community; any other resources or incentives available for ADU development; or the availability of ADUs and JADUs that will be part of the rental stock, rather than used as offices or guest houses.148 If the City intends to use its own analysis to estimate its 6th Cycle ADU production, it must explain how it considered these additional factors in its next draft. Otherwise, the City may utilize one of the approaches that HCD Staff has stated they would accept without further analysis or incentives: (1) average, yearly ADU applications from the beginning of the 5th Cycle to 2017, multiplied by five; or(2) average ADU applications per year since 2018, multiplied by eight. If jurisdictions anticipate a higher ADU production, HCD will require more analysis and incentives to show the higher production can be met. However, it is impossible to determine whether the City has estimated its 6th Cycle ADU production accurately under these formulas. First, the City has provided conflicting information about these 27 ADUs from its recent past performance. In its review of past performance, the City specifies that 15 ADUs were constructed, 4 were under construction, and 8 "are in the plan check process."149 This would mean that only 15 ADUs were actually constructed during the 5th Cycle and 12 were in progress when the 5th Cycle ended. Then in its evaluation of its progress towards its 5th Cycle RHNA, the City states that only 12 ADUs at undefined income levels were approved and under construction, seemingly referencing the 12 ADUs that were in progress at the end of the 5th Cycle.150 It appears that these 12 ADUs were identified separately from the 100 projected ADUs in the City's Summary of RHNA Credits and Remaining Need.151 This means that the City is taking one of these two approaches: (1) calculating its 6th Cycle ADU estimate using only the 15 constructed ADUs from the 5th Cycle, or(2) calculating its 6th Cycle estimate using all 27 ADUs in various stages of construction from 5th Cycle, while simultaneously counting the 12 in- progress ADUs towards its 6th Cycle RHNA. 145 HCD,ADU Handbook, 19(December 2020). 146 City of Tustin,2021-2029 Housing Element Draft,B-3(June 2021). 147 City of Tustin,2021-2029 Housing Element Draft,B-3(June 2021). 148 Cal.Gov.Code Section 65583.l(a);HCD,Accessory Dwelling Units(ADU)and Junior Accessory Dwelling Units(JADUs),Requisite Analysis,https://hcd.ca.gov/community-development/building-blocks/site-inventory- analysis/accessory-dwelling-units.shtml(last visited Mar.21,2021). 149 City of Tustin,2021-2029 Housing Element Draft,A-2,A-13(June 2021). 150 City of Tustin,2021-2029 Housing Element Draft,A-61 (June 2021). 151 City of Tustin,2021-2029 Housing Element Draft,B-3(June 2021). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 P. 19 Second, the City has partially based its 100 ADU estimate on its overall ADU production from the 5th Cycle rather than its average ADU production, as HCD Staff's formulas require.152 If the City intends to use one of HCD Staff's recommended formulas, the City must calculate its average ADU production from the 5th Cycle and explain which 5th Cycle ADUs it takes into account. In doing so, the City cannot use the 12 in-progress ADUs to calculate its 5th Cycle average while simultaneously using the 12 in-progress ADUs towards its 6th Cycle RHNA. Anticipated Affordability Although the City utilized the Southern California Association of Governments' ("SCAG') affordability assumptions to assign its estimate ADUs to income categories, as allowed, the City must apply these affordability assumptions to a revised number of estimated ADUs, as discussed above.153 Resources and Incentives The housing element must include a plan that incentivizes and promotes the creation of ADUs that can offer affordable rents for very low, low-, or moderate-income households.154 Resources and incentives include policies and programs to encourage ADUs, such as: • Prototype plans;155 • Reduce or eliminate building permit/development fees;156 • Expedited procedures;157 • Affordability monitoring programs;158 • Incentives for affordability;159 • Financing— construction&preservation;160 • Outreach,promotion, and educational materials;161 and • Amnesty programs (SB 13). The City estimated 100 ADUs for the 6th Cycle "based on the recent past performance as well as the new legislation and the City's efforts to allow and encourage such units" and that"a current S132 grant funded project will result in the preparation of citywide accessory dwelling unit design guidelines with accompanying examples."162 To that end, Program 1.8 Accessory Dwelling Units Programs states that the City will first"promote the construction of accessory dwelling units in new and existing residential areas by updating City codes in compliance with State law, and focusing on education and 152 City of Tustin,2021-2029 Housing Element Draft,A-2,B-3 (June 2021). 153 SCAG,6r'Cycle Housing Element Update Technical Assistance—ADU Affordability Analysis Presentation,9 (August 27,2020). 154 HCD,ADU Handbook, 19(December 2020);Cal.Gov.Code § 65583.1(a);Cal.Health and Safety Code § 50504.5. 155 HCD,ADU Handbook, 19(December 2020). 156 SCAG,Accessory Dwelling Units(ADUs),SCAG Housing Element Digital Workshop,6(August 27,2020). 157 HCD,ADU Handbook, 19(December 2020). 151 HCD,ADU Handbook, 19(December 2020). 159 SCAG,Accessory Dwelling Units(ADUs),SCAG Housing Element Digital Workshop,6(August 27,2020). 160 SCAG,Accessory Dwelling Units(ADUs),SCAG Housing Element Digital Workshop,6(August 27,2020). 161 SCAG,Accessory Dwelling Units(ADUs),SCAG Housing Element Digital Workshop,6(August 27,2020). 162 City of Tustin,2021-2029 Housing Element Draft,B-3 (June 2021). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 20 awareness."163 The City states it will create a"website with ADU permit guidance."164 Second, Program 1.8 states the City will "establish a partnership with a non-profit(i.e. Casita Coalition) or OCCOG to develop [an] ADU accelerator program to create a one-stop-shop comprehensive resources for homeowners interested in developing an ADU" with an emphasis on helping seniors and people with disabilities.165 Third, Program 1.8 states the City will "establish an Accessory Dwelling Unit Legalization and Delay of Enforcement program to allow owners with existing unpermitted ADUs to legalize the structure" per State law.166 Finally, Program 1.8 will create an"ADU Monitoring Program and Database."167 The City also states that"City staff is currently developing citywide ADU design guidelines and updating the Zoning Code to streamline the ability to construct ADUs as an affordable housing option."168 However, this program is vague and, as written, it cannot be determined whether it will actually incentivize and encourage ADU production.169 The City does not explain what its ADU permit guidance will contain or how this guidance will work to incentivize or encourage ADU production. The City also does not state whether it has reached out to Casita Coalition or OCCOG about such a partnership or whether those organizations or any other nonprofits are interested in such a relationship. Further, the City does not explain what resources the one-stop- shop will provide or how those resources will encourage ADUs. The City also does not explain how this one-stop-shop will assist seniors or people with disabilities, such as providing financial assistance or incentives for affordability.170 Similarly, the City does not explain how it will encourage residents with illegal ADUs to participate in its amnesty program, such as with financial assistance.171 The City does not explain how it will monitor ADUs, what the program will monitor, or what information an ADU database will contain, such as affordability monitoring.172 Finally, the City does not explain how its ADU design guidelines will actually incentivize ADU production. Instead, the City should consider providing pre-approved plans,173 reducing or eliminating development fees,174 and create expedited procedures to streamline processing.175 Therefore, to justify a high ADU production estimate, the City must revise Program 1.8 to include more details and more incentives. Programs The housing element must include programs that allow the jurisdiction to achieve its stated housing goals and objectives. Programs must set forth a schedule of actions during the 163 City of Tustin,2021-2029 Housing Element Draft,IV-6(June 2021). 164 City of Tustin,2021-2029 Housing Element Draft,IV-6(June 2021). 165 City of Tustin,2021-2029 Housing Element Draft,IV-7(June 2021). 166 City of Tustin,2021-2029 Housing Element Draft,IV-7(June 2021). 167 City of Tustin,2021-2029 Housing Element Draft,IV-7(June 2021). 168 City of Tustin,2021-2029 Housing Element Draft,A-2,A-13,11-35(June 2021). 169 HCD,ADU Handbook, 19(December 2020);Cal.Gov.Code § 65583.1(a);Cal.Health and Safety Code § 50504.5. 170 SLAG,Accessory Dwelling Units(ADUs),SLAG Housing Element Digital Workshop,6(August 27,2020). 171 SLAG,Accessory Dwelling Units(ADUs),SLAG Housing Element Digital Workshop,6(August 27,2020). 172 HCD,ADU Handbook, 19(December 2020). 173 HCD,ADU Handbook, 19(December 2020). 174 SLAG,Accessory Dwelling Units(ADUs),SLAG Housing Element Digital Workshop,6(August 27,2020). 175 HCD,ADU Handbook, 19(December 2020). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 21 planning period, each with a timeline for implementation.176 The jurisdiction may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the housing element.177 The jurisdiction may do so through the administration of land use and development controls, the provision of regulatory concessions and incentives, the utilization of appropriate federal and state financing and subsidy programs when available, and the utilization of moneys in a low- and moderate-income housing fund of an agency if the locality has established a redevelopment project area pursuant to the Community Redevelopment Law.178 To make adequate provision for the housing needs of all economic segments of the community, the program shall address housing issues such as inadequate site inventories, meeting lower income housing needs, removing constraints, maintaining affordable housing, promoting affirmatively furthering fair housing, preserving assisted housing developments, encouraging accessory dwelling units, and facilitating public participation. To make these programs most effective, HCD recommends jurisdictions include the following: definite time frames for implementation; an identification of agencies and officials responsible for implementation; a description of the local government's specific role in program implementation; a description of the specific action steps to implement the program;proposed measurable outcomes; demonstration of a firm commitment to implement the program; and an identification of specific funding sources, where appropriate.179 Inadequate Site Inventory If a jurisdiction cannot identify adequate sites to accommodate its share of the RHNA for all income levels, its housing element must include a program to identify sites that can be developed for housing within the planning period.180 If the jurisdiction cannot do so without rezoning, the jurisdiction must identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and 176 Cal.Gov.Code Section 65583(c). 177 Cal.Gov.Code Section 65583(c). 178 Cal.Gov.Code Section 65583(c). 179 HCD,Building Blocks:A Comprehensive Housing-Element Guide,Program Overview and Quantified Objectives,https://hcd.ca.gov/community-development/building-blocks/program-requirements/program- overview.shtml(last visited Apr.4,2021). iao Cal.Gov.Code Section 65583(c)(1)(B). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 22 facilities and to comply with the requirements of Section 65584.09.181 The identification of sites shall include all components specified in Section 65583.2.182 Here, the City provides Program 1.1, titled"Residential Development- Available Sites," with the objective to "[prepare], process and adopt TLSP Specific Plan Amendment within three years to allow additional units to meet RHNA."183 This program is intended to rezone Site JA to accommodate residential development.184 However, the City provides almost no details regarding how this program will operate. Instead, the City merely claims that it will be completed by October 2024. For example, there are no details regarding whether the units will have sufficient water, sewer, or dry utilities, as required by law.185 The City must greatly expand on how its rezone program will accommodate its needs for very-low- and low-income housing. Additionally, the City describes how Program 1.7, titled`By-Right Approval of Projects with 20 Percent Affordable Units on"Reuse" Sites," will "explore" approving projects that provide 20 percent or more of its units at rents affordable to lower income households.186 The City also states that the goal of this program is to"Amend Ordinance."187 The City should provide greater detail regarding how this program will accomplish this goal, beyond mere exploration, and describe the resources and incentives it will use to ensure the program is successful. It appears that this Program is required by State Housing Element law, as described above, as such, simply "exploring" the Program is insufficient and the City must actually adopt such a Program as it relates to previously identified sites. Farmworker Housing The City does not specifically identify farmworker housing by right.188 Instead, the City states that"Tustin is an urbanized community with no undeveloped parcels zoned for agriculture as a principal use; however, some residential zones allow a range of agriculture and related uses. "'"For housing elements due pursuant to Section 65588 on or after January 1,2006,if a city or county in the prior planning period failed to identify or make available adequate sites to accommodate that portion of the regional housing need allocated pursuant to Section 65584,then the city or county shall,within the first year of the planning period of the new housing element,zone or rezone adequate sites to accommodate the unaccommodated portion of the regional housing need allocation from the prior planning period."Cal. Gov. Code Section 65584.09(a). "The requirements under subdivision(a)shall be in addition to any zoning or rezoning required to accommodate the jurisdiction's share of the regional housing need pursuant to Section 65584 for the new planning period." Cal. Gov. Code Section 65584.09(b). "Nothing in this section shall be construed to diminish the requirement of a city or county to accommodate its share of the regional housing need for each income level during the planning period set forth in Section 65588,including the obligations to(1)implement programs included pursuant to Section 65583 to achieve the goals and objectives,including programs to zone or rezone land,and(2)timely adopt a housing element with an inventory described in paragraph(3)of subdivision(a)of Section 65583 and a program to make sites available pursuant to paragraph(1)of subdivision(c)of Section 65583,which can accommodate the jurisdiction's share of the regional housing need." Cal. Gov. Code Section 65584.09(c);Cal.Gov.Code Section 65583(c)(1). lag Cal.Gov.Code Section 65583(c)(1)(B). 183 Cal.Gov.Code Section 65583(c)(1)(B);City of Tustin,Draft Housing Element 2021-2029 IV-2(June 2021). 184 City of Tustin,Draft Housing Element 2021-2029 B-5(June 2021). 185 Cal.Gov.Code Section 65583.2(h);Cal.Gov.Code Section 65583(b)(5)(B). 186 Cal.Gov.Code Section 65583.2(h);Cal.Gov.Code Section 65583(c)(3)(B)(iii-iv);City of Tustin,Draft Housing Element 2021-2029 IV-6(June 2021). 187 City of Tustin,Draft Housing Element 2021-2029 IV-6(June 2021). 188 Cal.Gov.Code Section 65583(c)(1)(C). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 23 However, some farmworkers may commute to nearby farming operations outside of the city."189 The City should specifically address the need for farmworker housing in its next draft. Emergency Shelters If the local government cannot identify a zone or zones with sufficient capacity to accommodate the need for emergency shelter, the local government shall include a program to amend its zoning ordinance to meet the requirements of Section 65583(a)(4)(A)within one year of the adoption of the housing element.190 Because the City has not provided details regarding its existing emergency shelter ordinance and has not accurately calculated its emergency shelter need, it is impossible to determine whether the City must include a program to meet statutory requirements.191 Regardless, the City's Program 2.1 (Modified)Emergency, Transitional, and Supportive Housing is intended to address the City's emergency shelter need by "[continuing] to support countywide efforts to assist approved homeless providers as part of the Tustin Legacy Reuse effort" and "[retaining] 192 emergency shelter beds and [expanding] by 125 beds."192 However, this program does not explain how the City plans to support these countywide efforts or how it expects to expand its shelter capacity by 125 beds. To make this program effective, the City should follow HCD recommendations and provide a description of the specific action steps to implement the program,proposed measurable outcomes, and firm commitments to implement the program.193 The City should also include a program to amend its zoning code, if necessary, to ensure that it can accommodate the need for emergency shelters or explain how the current zoning satisfies this requirement. Affirmatively Furthering Fair Housing (AFFH) Housing elements must incorporate the obligation to affirmatively further fair housing in the following sections: (1) outreach, (2) assessment of fair housing, (3) site inventory, (4) identification and prioritization of contributing factors, and (5) goals,policies, and actions. Each section is addressed below.194 Outreach The City forgets several elements of an adequate AFFH outreach analysis. First, although the City lists key stakeholders that it"invited to participate in the planning process,"195 it does not indicate whether any of these stakeholders actually participated. If not a single stakeholder engaged the City during the planning process, stakeholder participation cannot be "meaningful, 189 City of Tustin,Draft Housing Element 2021-2029 II-13 (June 2021). 190 Cal.Gov.Code Section 65583(a)(4)(A). 191 Cal.Gov.Code Section 65583(a)(4)(A). 192 City of Tustin,Draft Housing Element 2021-2029,IV-13(June 2021). 193 HCD,Building Blocks:A Comprehensive Housing-Element Guide,Program Overview and Quantified Objectives,https://hcd.ca.gov/community-development/building-blocks/program-requirements/program- overview.shtml(last visited Apr.4,2021). 194 HCD, Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,21 (April 2021). 195 City of Tustin,Draft Housing Element 2021-2029 D-70,Appendix B Index of Interested Parties(June 2021). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 24 frequent, and ongoing."196 Second, the City's list of key stakeholders does not describe "for what purpose" the City consulted these stakeholders, even though HCD requires such a description.197 Third, the City does not summarize"comments and how comments are considered and incorporated (including comments that were not incorporated),particularly with changes to the housing element."198 Finally, the City does not summarize"issues that contributed to lack of participation in the housing element process by all economic segments,particularly people with protected characteristics, if that proves to be the case."199 Because the City omits these components, which HCD demands in an AFFH outreach section, the City does not meet HCD's standards. Assessment of Fair Housing A fair housing assessment needs to have a summary of fair housing enforcement and capacity.200 In addition, the assessment must analyze these five areas: (1) fair housing enforcement and outreach capacity; (2) integration and segregation patterns and trends related to people with protected characteristics; (3)racially or ethnically concentrated areas of poverty or affluence; (4) disparities in access to opportunity for people with protected characteristics, including persons with disabilities; and (5) disproportionate housing needs within the jurisdiction, including displacement risk.201 Furthermore, each of these analyses must include local and regional patterns and trends, local data and knowledge, and other relevant factors.202 The analyses should each arrive at conclusions and have a summary of fair housing issues.203 Fair Housing Enforcement and Outreach Capacity. The City must supplement its analysis of fair housing enforcement and outreach capacity. While the City analyzes recent fair housing enforcement and outreach capacity,204 the City does not consider"trends in patterns over 196 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,21 (April 2021). 197 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,22 (April 2021). 198 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,22 (April 2021). 199 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,22 (April 2021). 200 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,62 (April 2021). 201 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,27- 28,62(April 2021). 202 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,62 (April 2021). 203 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,62 (April 2021). 204 City of Tustin,Draft Housing Element 2021-2029 D-8(June 2021). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 25 time."205 Additionally, the City presents Tustin-specific data 206 but no regional data about housing-related cases.207 Finally, the City only mentions one organization, the Fair Housing Foundation,208 even though HCD states that the City should include "a listing of local, regional and state agencies and organizations active in the locality."209 The City's long list of key stakeholders 210 implies that the City omitted relevant agencies and organizations from its agency- and-organization listing. This omission leaves the City's analysis incomplete. Until the City adds the above information, the City has not tailored a satisfactory analysis of fair housing enforcement and outreach capacity. Segregation and Integration. The City needs to bolster its segregation-and-integration discussion. First, because the City only considers static data compiled from 2013 until 2019 about persons with disabilities, familial status, and income groups,211 the City does not analyze these groups' integration and segregation "trends in patterns over time."212 Second, the City relies solely on state-provided data throughout the entire section,213 without assessing local data or knowledge or other relevant factors "beyond data that identifies and compares concentrations of groups with protected characteristics."214 If the City's analysis were sufficient, "it would at least" have these data.215 RIECAPs and RCAAs. The City must improve its analysis of racially or ethnically concentrated areas of poverty (R/ECAPs) and racially concentrated areas of affluence (RCAAs). Although the City identifies both regional and local incidence of R/ECAPs and RCAAs,216 the City's examination does not extend to"patterns in trends over time."217 Furthermore, the City 205 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,24 (April 2021). 206 City of Tustin,Draft Housing Element 2021-2029 D-8(June 2021). 207 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,24 (April 2021). 208 City of Tustin,Draft Housing Element 2021-2029 D-8(June 2021). 209 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,28 (April 2021). 210 City of Tustin,Draft Housing Element 2021-2029 Appendix B Index of Interested Parties(June 2021). 211 City of Tustin,Draft Housing Element 2021-2029 D-20 to-28(June 2021). 212 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,24 (April 2021). 213 City of Tustin,Draft Housing Element 2021-2029 D-8 to-28(June 2021). 214 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,25 (April 2021). 215 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,24 (April 2021). 216 City of Tustin,Draft Housing Element 2021-2029 D-28 to-34(June 2021). 217 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,24 (April 2021). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 26 forgot to include local data and knowledge and other relevant factors.218 The City must add this information before satisfactorily finishing its R/ECAPs and RCAAs analysis. Access to Opportunity. The City's access-to-opportunity section does not answer several required questions. The City does, as is necessary, have a section for disproportionate housing needs for persons with disabilities.219 Also, the City does include sections for educational, economic, transportation, and environmental disparities in access to opportunity.220 However, these sections do not address the following: • Employment Opportunities o Where protected groups live and how that affects their ability to obtain a job o Employment trends by protected groups • Transportation Opportunities o Disproportionate transportation needs for members of protected groups o Combined housing and transportation cost impacts on protected groups • Environmental Opportunities o Consistency with the environmental justice element o Policies,practices, and investments that impact access to environmentally healthy neighborhoods Furthermore, the City neglects to tackle patterns in access to opportunity. To comply with HCD's guidance, the City "should, at minimum," analyze these topics.221 Disproportionate Housing Needs, Including Displacement. The City needs to consider several data sources that it missed in its section on disproportionate housing needs and displacement. Notwithstanding the City's use of federally and state-provided data,222 the City does not employ local data or knowledge or other relevant factors while analyzing substandard housing and displacement risk.223 Since these data sources are"[p]articularly important to this analysis,"224 the City must utilize them before finalizing its disproportionate housing needs and displacement section. 218 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,24-25 (April 2021). 219 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,36 (April 2021). 220 City of Tustin,Draft Housing Element 2021-2029 D-35 to-49(June 2021). 221 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,35-36 (April 2021). 222 City of Tustin,Draft Housing Element 2021-2029 D-49 to-69(June 2021). 223 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,24-25 (April 2021). 224 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,39 (April 2021). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 27 Local Data and Knowledge, and Other Relevant Factors. The City's sections on local data and knowledge and other contributions do not adequately address each of the required areas of analysis. The City has separate sections for local data and knowledge and for other contributions, where the City describes public comments related to the City and other fair housing efforts.225 However, these sections do not specifically address any of the required areas of analysis.226 Therefore, these sections cannot replace local data and knowledge and other relevant factors that specifically pertain to each of the above sections. To satisfy State law, the City must integrate local data and knowledge and other relevant factors into each section of the fair housing assessment. Site Inventory The City must face its problematic site selection. The City admits that"a majority of identified sites are located within" "tracts with low to moderate income households, concentrated minorities, and housing problems."227 This means that the City does not place a single site in its high- or highest-resource areas, as shown in Figure 22.228 Although such site selection might raise segregation and integration concerns,229 the City boasts that it can "accommodate residential development of all income levels to further fair housing."230 For the City's site selection to be "consistent with" its duty to affirmatively further fair housing,231 the City must, in its site inventory discussion, at least examine such concerns about integration and segregation. Ideally, as recommend by HCD, the City should identify sites throughout the City to ensure a more integrated community. Identification and Prioritization of Contributing Factors The City incorrectly identified and prioritized contributing factors. The City lists four factors that"may contribute to" fair housing issues,232 but does not prioritize these factors, as California Government Code Section 65583(c)(10)(iv) requires. And afterwards, the City does not"discuss strategic approaches to inform and strongly connect to goals and actions."233 This mistake becomes apparent as the City identifies"[flack of affordable housing in high opportunity areas" and "concentrated access to opportunity within high resource areas" as contributing 225 City of Tustin,Draft Housing Element 2021-2029 D-71 to-77(June 2021). 226 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,62 (April 2021). 227 City of Tustin,Draft Housing Element 2021-2029 D-79(June 2021). 228 City of Tustin,Draft Housing Element 2021-2029 D-85 Figure 22(June 2021). 229 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,45 (April 2021). 230 City of Tustin,Draft Housing Element 2021-2029 D-79(June 2021). 231 Cal.Gov.Code Section 65583.2(a). 232 City of Tustin,Draft Housing Element 2021-2029 D-86(June 2021). 233 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,49 (April 202 1) 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 28 factors—But none of the City's new goals or actions, except the goals and actions from Orange County's 2020 analysis of impediments, employ mobility strategies.234 If the City strongly connected its contributing factors to actions and goals, it would have featured mobility strategies, since these strategies would overcome lack of access to high-opportunity areas. To fulfill HCD's expectations, the City must align its identified contributing factors with its goals and actions. Goals, Policies, and Actions Many of the City's goals, policies, and actions lack specificity. First, none of the goals and actions copied from Orange County's analysis of impediments have timelines, dates, or objective metrics for completion.235 Take as an example the goal to"[p]rovide fair housing education and information to apartment managers and homeowners on why denial of reasonable modifications/accommodations is unlawful."236 This goal does not state how much or when education will happen, which shows that the goal lacks a timeline and measurable metrics for implementation. The City also identifies programs beyond Orange County's analysis of impediments. And while most of these programs do have sufficient timelines and metrics, some do not. For instance, the City promises to "evaluate and identify zoning and development standards that will allow and encourage the construction and expansion of affordable housing."237 Nevertheless, the City's quantified objective just repeats the goal, and its timeline nearly mirrors the planning period. With such unquantified objectives and amorphous timelines, the City's goals cannot have a"beneficial impact."238 Therefore, the City must amend those goals and actions that lack adequate specificity. Preserving Assisted Housing Developments The housing element shall include a program to preserve for lower income households the assisted housing developments identified pursuant to Section 65583(a)(9).239 The program for preservation of the assisted housing developments shall utilize, to the extent necessary, all available federal, state, and local financing and subsidy programs identified in Section 65583(a)(9), except where a community has other urgent needs for which alternative funding sources are not available.240 The program may include strategies that involve local regulation and technical assistance.241 234 City of Tustin,Draft Housing Element 2021-2029 D-86 to-88(June 2021). 235 City of Tustin,Draft Housing Element 2021-2029 D-86 to-88(June 2021). 236 City of Tustin,Draft Housing Element 2021-2029 D-88(June 2021). 237 City of Tustin,Draft Housing Element 2021-2029 IV-16(June 2021). 238 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements,51-56 (April 2021). 239 Cal.Gov.Code Section 65583(c)(6). 240 Cal.Gov.Code Section 65583(c)(6). 241 Cal.Gov.Code Section 65583(c)(6). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 29 Here, the City claims it will "make efforts to preserve units `at risk' at Tustin Gardens, Westchester Park, Flanders Pointe and Chatham Village."242 The City then explains that preserving these units is more cost-effective than replacing the units with equivalent housing.243 The City also provides details regarding two programs to preserve assisted housing: Program 3.6, titled"Affordable Senior Housing Project and Senior Board and Care Facility," and Program 3.7, titled"Preservation of Assisted Housing."244 However, neither program clearly explains how it will accomplish its goal to preserve housing. For example, Program 3.6 does not explain how it plans to"maintain" housing, while Program 3.7 merely states that the City will coordinate "financial and administrative resources" to preserve units.245 However, neither program describes any financial and subsidy programs it will use to achieve the goals, and neither program describes any other concrete or quantifiable strategies it will use to fulfill the programs' objectives. The City must provide greater detail regarding how these programs will actually serve to preserve assisted housing developments for lower-income households in its next draft. Public Participation The housing element shall include a program that demonstrates a diligent effort by the local government 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.246 The HCD recommends that the local government describe who was invited to participate, who actually participated, general comments received, and how comments were incorporated into the housing element.247 Here, the City failed to demonstrate a diligent effort by the local government 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.248 The City provided extensive information regarding which stakeholders were invited to attend, but did not explain which residents were invited to outreach opportunities.249 While the City provided a list of survey respondents, the information only consisted of names, cities, states, and ZIP codes: no demographic information was included, nor any information to determine if the survey respondents constituted a representative sample of City residents.250 Moreover, the City did not 242 City of Tustin,Draft Housing Element 2021-2029 II-17(June 2021). 243 City of Tustin,Draft Housing Element 2021-2029 II-17(June 2021). 244 City of Tustin,Draft Housing Element 2021-2029 IV-20(June 2021). 245 City of Tustin,Draft Housing Element 2021-2029 IV-20(June 2021). 246 Cal.Gov.Code Section 65583(c)(9). 247 HCD,Building Blocks:A Comprehensive Housing-Element Guide,Public Participation, https://hcd.ca.gov/community-development/building-blocks/getting-started/public-participation.shtml(last visited Mar. 17,2021). 248 Cal.Gov.Code Section 65583(c)(9). 249 HCD,Building Blocks: A Comprehensive Housing-Element Guide,Public Participation, https://hcd.ca.gov/community-development/building-blocks/getting-started/public-participation.shtml(last visited Mar. 17,2021);City of Tustin,2021-2029 Housing Element Draft,Appendix E,4-6(June 2021). 250 City of Tustin,Draft Housing Element 2021-2029 Index of Interested Parties Housing Element Survey Respondents(June 2021). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 RE: City of Tustin Draft 6th Cycle Housing Element September 7, 2021 p. 30 provide any analysis regarding how the survey responses were incorporated into the housing element draft.251 Lastly, the City held only two meetings: one on Tuesday, November 10th, 2020, at 6:00 P.M., and one on Tuesday, May 11th, 2021, at 5:00 P.M.252 Both meetings were held virtually. The City should hold meetings on varied days of the week, and at different times of day, to ensure maximum participation.253 Instead, the City held both meetings on Tuesdays, and at 5:00 or 6:00 P.M. This means it is unlikely that residents who are busy on Tuesdays, or who work in the evenings, will attend. The City should demonstrate that it has endeavored to provide public participation opportunities to all residents, and that it has incorporated public comment into its draft. Conclusion The housing element process is an opportunity for jurisdictions to meet the needs of California's residents, including needs for housing that is accessible to seniors, families, and workers and the needs of extremely-low-, very-low-, and low-income families for affordable housing. We encourage the City to consider carefully the HCD Review Letter and implement the recommendations contained therein. We also add these additional comments in support of those form HCD and look forward to the opportunity to work with the City and review future versions of its Draft 6th Cycle Housing Element to ensure that this opportunity to meet the housing needs of Tustin's most vulnerable residents is not missed. Sincerely, THE PUBLIC LAW CENTER, BY: Richard Walker, Housing and Homelessness Prevention Unit, Senior Staff Attorney Alexis Mondares, Housing and Homelessness Prevention Unit, Legal Fellow Shannon Talbot, Housing and Homelessness Prevention Unit, Summer Clerk Lana Rayan, Housing and Homelessness Prevention Unit, Summer Clerk Adam Snider, Housing and Homelessness Prevention Unit, Summer Clerk 251 HCD,Building Blocks:A Comprehensive Housing-Element Guide,Public Participation, https://hcd.ca.gov/community-development/building-blocks/getting-started/public-participation.shtml(last visited Mar. 17,2021). 252 City of Tustin,Draft Housing Element 2021-2029 Community Engagement Plan Page 7(June 2021). 253 HCD,Affirmatively Furthering Fair Housing:Guidance for All Public Entities and for Housing Elements, 10 (April 2021). 601 Civic Center Drive West•Santa Ana,CA 92701-4002•(714)541-1010•Fax(714)541-5157 ATTACHMENT D LETTER FROM HCD DATED AUGUST 271 2021 STATE OF CALIFORNIA-BUSINESS. CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM. Governor DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT DIVISION OF HOUSING POLICY DEVELOPMENT 2020 W. EI Camino Avenue,Suite 500 ° ° +, .. Sacramento, CA 95833 1 (916)263-2911 /FAX(916)263-7453 www.hcd.ca.gov August 27, 2021 Justina L. Willkom, Community Development Director Community Development Department City of Tustin 300 Centennial Way Tustin, CA 92780 Dear Justina L. Willkom: RE: Review of the City of Tustin's 6t" Cycle (2021-2029) Draft Housing Element Thank you for submitting the City of Tustin's (City) draft housing element received for review on July 1 , 2021 . Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. Our review was facilitated by a telephone conversation on August 12, 2021 with you and Senior Planner Erica Demkowicz. In addition, HCD considered comments from the Tustin Planning Partnership and YIMBY Law pursuant to Government Code section 65585, subdivision (c). The draft element addresses many statutory requirements; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code). In particular, the site inventory must demonstrate realistic capacity with further analysis, the constraints section must adequately address a variety of governmental constraints to housing development, and many programs require further information or stronger language and timeframes. The enclosed Appendix describes these and other revisions needed to comply with State Housing Element Law. To remain on an eight-year planning cycle, the City must adopt its housing element within 120 calendar days from the statutory due date of October 15, 2021 for Southern California Association of Governments (SCAG) localities. If adopted after this date, Government Code section 65588, subdivision (e)(4), requires the housing element be revised every four years until adopting at least two consecutive revisions by the statutory deadline. For more information on housing element adoption requirements, please visit HCD's website at: http://www.hcd.ca.gov/community-development/housing-element/housing-element- memos/docs/sb375 fina1100413.pdf. For your information, some general plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes Justina L. Willkom, Community Development Director Page 2 the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor's Office of Planning and Research at: http://opr.ca.gov/docs/OPR Appendix C final.pdf and http://opr.ca.gov/docs/Final 6.26.15.pdf. Pursuant to Government Code section 65583.3, subdivision (b), the City must utilize standards, forms, and definitions adopted by HCD when preparing the sites inventory. Please see HCD's housing element webpage at https://www.hcd.ca.gov/community- development/housing-element/index.shtml#element for a copy of the form and instructions. The City can reach out to HCD at sitesinventory(a)hcd.ca.gov for technical assistance. Please note, upon adoption of the housing element, the City must submit an electronic version of the sites inventory with its adopted housing element to sitesinventory(a-)-hcd.ca.gov. 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 should 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. Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD's Affordable Housing and Sustainable Communities programs; and HCD's Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. HCD is committed to assisting the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Colin Cross, of our staff, at (916) 820-1275 or colin.cross(a-)-hcd.ca.gov. Sincerely, 1 2�c) :D�C� Shannan West Land Use & Planning Unit Chief Enclosure Review of the City of Tustin's 6th Cycle Draft Housing Element Page 2 August 27, 2021 APPENDIX CITY OF TUSTIN The following changes are necessary to bring the City's housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code. Housing element technical assistance information is available on HCD's website at http://www.hcd.ca.gov/community-development/housing-element/housing-element-memos.shtml. Among other resources, the housing element section contains HCD's latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at http://www.hcd.ca.gov/community-development/building-blocks/index.shtml and includes the Government Code addressing State Housing Element Law and other resources. A. Housing Needs, Resources, and Constraints 1 . Affirmatively furtherfing] fair housing (AFFH) in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2...shall include an assessment of fair housing in the jurisdiction (Gov. Code, § 65583, subd. (c)(10)(A)) The element includes an Assessment of Fair Housing (AFH) that addresses most of the statutory requirements. However, additional information and analysis is needed to address the AFFH requirements in full, including a complete analysis of the element's site inventory and specific, meaningful program actions to address the identified fair housing issues. Fair Housing Enforcement and Outreach: The element describes the City's capacity for fair housing enforcement and outreach at a local level but must also provide information and analysis regarding enforcement and outreach capacity and trends at a regional level. Site Inventory: The element contains an analysis of the site inventory that addresses some AFFH requirements. However, the analysis does not fully account for how the sites are identified to improve or exacerbate conditions or whether the sites are isolated by income group. For example, a large portion of the lower-income regional housing needs allocation (RHNA) is concentrated on a few large sites in the Tustin Legacy Specific Plan. The analysis should address whether this concentration meets the obligation for the sites inventory to affirmatively further fair housing. Goals, Priorities, Metrics, and Milestones: Goals and actions must significantly seek to overcome contributing factors to fair housing issues. Most of the goals contained in the element (pp. D-86 — D-88), especially those that are specific to the City, do not appear to facilitate meaningful change or address AFFH requirements. Currently, the element identifies goals drawn from the 2020 Orange County Analysis of Impediments but provides limited information about the City's own goals (p. D-88). Goals and actions included in the AFH should be drawn directly from the analysis and contributing factors. For example, the element identifies lack of supply of affordable housing in high- Review of the City of Tustin's 6th Cycle Draft Housing Element Page 1 August 27, 2021 opportunity areas as one contributing factor (p. D-86) but includes no program actions that seek to address this. Goals and actions should include the commitment of other programs in the element, complete with timeframes, responsible parties, and objectives. These should also replace unclear language (e.g., "explore", "review", "consider") with specific, meaningful, and measurable actions. The element must include metrics and milestones for evaluating progress on programs, actions, and fair housing results. 2. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality's housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).) The City has a RHNA of 6,782 housing units, of which 2,770 are for lower-income households. To address this need, the element relies on vacant and nonvacant sites, including sites in various specific plan areas. To demonstrate the adequacy of these sites and strategies to accommodate the City's RHNA, the element must include complete analyses: Progress in Meeting the RHNA: The element indicates (p. B-2) that 125 units affordable to extremely low-income households in the Village of Hope project are approved. However, on page A-3, the element describes this project as an emergency and transitional housing project with capacity up to 387 beds (i.e. not units). Please be aware, to count towards progress in meeting the RHNA, the additional approved capacity must meet the Census definition of a unit. The element must clarify whether this additional capacity is for beds or units. In addition, the element must describe the City's methodology for assigning these units to the extremely low-income groups based on actual or projected sales price or rent level of the units or other mechanisms establishing affordability and demonstrate their availability in the planning period. Sites Inventory: The element must include an estimate of the number of units that can be accommodated on each site in the inventory. Currently, the element provides these estimates by grouping the sites into their respective specific plan areas and estimating the number of units to be accommodated in each specific plan area. These estimates should instead be made by income category for each individual site. Zoning for Lower: Pursuant to Government Code section 65583.2, subdividion (c)(3)(A) and (B), the element must identify sites with zoning and densities appropriate to encourage and facilitate the development of housing for lower-income households based on factors such as market demand, financial feasibility and development experience within zones. For communities with densities that meet specific standards (at least 30 units per acre for Tustin), this analysis is not required (Gov. Code, § 65583.2, subd. (c)(3)(B).). The element states that while some sites to accommodate the lower-income RHNA have a maximum density of 25 units per acre based on the general plan, higher densities including 30 units per acre are allowed as long as the maximum units allocated in the specific plan has not been reached. However, on page Review of the City of Tustin's 6th Cycle Draft Housing Element Page 2 August 27, 2021 B-13 the element states that no minimum nor maximum densities are specified in the general plan and specific plan areas. The element must clarify what densities are allowed on these sites and what approvals are required to reach at least 30 units per acre. In addition, the element should specify what the remaining housing unit allotments are in these specific plans and whether the capacity and zoning appropriate to accommodate the lower income can be achieved within the remaining allotment and describe requirements such as phasing or timing requirements that impact development in the planning period. In particular, it is unclear what mechanism would allow a development to exceed the stated maximum general plan density of 25 units per acre. Please note that if the base allowable density does not allow for 30 units per acre, then the element will need to analyze the zoning for appropriateness to accommodate the lower-income RHNA per the above. Realistic Capacity: The element provides various density assumptions for the sites in the inventory, including several high assumptions that exceed 40 dwelling units per acre. The element must provide support for these conclusions by demonstrating how the City arrived at these assumptions for realistic capacity. This should be based on and adjusted for land-use controls and site improvements; typical densities of existing or approved residential developments at a similar affordability level in the City; and on the current or planned availability and accessibility of sufficient water, sewer, and dry utilities; among other factors. This analysis should describe in detail the zoning and development standards applicable for each of the specific plan areas being utilized and the underlying zoning, and how those inform the realistic capacity assumptions. For sites zoned for nonresidential uses (e.g., commercial and mixed-use zones), the element must describe how the estimated number of residential units for each site was determined. This analysis must adjust for the likelihood of nonresidential development in any zones that allow a mix of uses. For example, the element could describe the underlying zoning for sites in the relevant specific plan areas, whether 100% nonresidential development is allowed in these zones, and any relevant programs or policies the City is undertaking to facilitate residential development in nonresidential zones. Suitability of Nonvacant Sites: The element must include an analysis demonstrating the potential for redevelopment of nonvacant sites. To address this requirement, the element describes in general the existing use of each nonvacant site. This alone is not adequate to demonstrate the potential for redevelopment in the planning period. The description of existing uses should be sufficiently detailed to facilitate an analysis demonstrating the potential for additional development in the planning period. The analysis shall consider factors including the extent to which existing uses may constitute an impediment to additional residential development, the City's past experience with converting existing uses to higher density residential development, the current market demand for the existing use, an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development, development trends, market conditions, and regulatory or other incentives or standards to encourage additional residential development on these sites. For example, the element could consider indicators such as age and condition of the existing structure, presence of expiring leases, expressed Review of the City of Tustin's 6th Cycle Draft Housing Element Page 3 August 27, 2021 developer interest, low improvement to land value ratio, and other factors. The element should describe and support (through development trends) the thresholds used to identify sites for redevelopment. In addition, a portion of Site 15 includes a 0.77-acre parcel owned by Caltrans. This site does not appear to be on the State's listing for excess properties. The element must demonstrate that Caltrans has identified this property as surplus or otherwise made it available for the development of housing within the planning period. Large and Small Sites: Several sites consist of large parcels, including Site 1 (39.87 acres), Site 2 (50 acres), Site 10 (16.47 acres). Sites larger than 10 acres in size are deemed inadequate to accommodate housing for lower-income households unless it is demonstrated that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower-income housing units as projected for the site or unless the housing element describes other evidence to HCD that the site is adequate to accommodate lower-income housing (Gov. Code, § 65583.2, subd. (c)(2)(A).). Please note, because the inventory has not yet estimated the number of units by income category for each site, it is unclear whether Site 10 is intended to accommodate the lower-income RHNA. This analysis could describe the implementation of the various specific plans relied on in the inventory or provide information on subdivision or other methods that will be used to facilitate housing development on these sites. Additionally, many sites (including 4, 5, 6, 7, 9, 11 , 12, 13, 14 and 15) consist of aggregated small parcels. For parcels anticipated to be consolidated, the element must demonstrate the potential for lot consolidation. For example, the analysis could describe the City's role or track record in facilitating small-lot consolidation, policies or incentives offered or proposed to encourage and facilitate lot consolidation, conditions rendering parcels suitable and ready for redevelopment, recent trends of lot consolidation, and/or information on the owners of each aggregated site. For parcels anticipated to develop individually, the element must describe existing and proposed policies or incentives the City will offer to facilitate development of small sites. Please note sites smaller than a half-acre in size are deemed inadequate to accommodate housing for lower-income housing unless it is demonstrated that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower-income housing units as projected for the site or unless the housing element describes other evidence to HCD that the site is adequate to accommodate lower- income housing (Gov. Code, § 65583.2, subd. (c)(2)(A).). Adequate Sites Alternatives: The City appears to be relying on preservation of 517 units to accommodate a portion of the City's RHNA (p. B-3). The City may substitute up to 25 percent of its adequate sites requirement by income group by counting existing units preserved through the provision of "committed assistance" to that income category's households at affordable housing costs or affordable rents. (Gov. Code, § 65583.1 , subd. (c).) However, the housing element must demonstrate compliance with all the statutory requirements. This includes, but is not limited to, identification of the specific funding sources that will provide committed assistance to the units whose affordability the City seeks to preserve. Please note, preservation of moderate-income Review of the City of Tustin's 6th Cycle Draft Housing Element Page 4 August 27, 2021 units cannot be counted towards the RHNA obligation. Please review and complete the Adequate Sites Alternative Checklist at https://www.hcd.ca.gov/community- development/building-blocks/site-inventory-analysis/adequate-sites- alternatives/docs/adequate site alt checklist.pdf. Accessory Dwelling Units (ADU): The element assumes 100 ADUs will be constructed during the planning period but does not demonstrate how the City calculated that assumption. The element's analysis and programs do not support the assumption that 100 ADUs will be constructed during the planning period. Specifically, in addition to other methods, HCD accepts the use of trends in ADU construction since January 2018 to estimate new production. Based on past production between 2018 to 2020, the City is averaging about 6 ADUs per year. To support assumptions for ADUs in the planning period, the element could reduce the number of ADUs assumed per year or reconcile trends with HCD records, including additional information such as more recent permitted units and inquiries, resources and incentives, other relevant factors and modify policies and programs as appropriate. Further, programs should commit to additional incentives and strategies, frequent monitoring (every other year) and specific commitment to adopt alternative measures such as rezoning or amending the element within a specific time (e.g., 6 months) if ADU assumptions for the number of units and affordability are not met. Additionally, the element credits 12 ADUs permitted in 2021 towards the RHNA but does not clarify the income level or timeframe of those ADUs. These units must be permitted since the beginning of the RHNA projection period (June 30, 2021) in order to be credited towards the RHNA for the 6th Cycle. Suitability and Availability of Infrastructure: The element must demonstrate sufficient existing or planned water, sewer, and other dry utilities supply capacity, including the availability and access to distribution facilities to accommodate the City's regional housing need for the planning period. To address this requirement, the element provides a table (p. B-12) listing the availability of infrastructure for sites in the inventory, where sites from the Tustin Legacy Specific Plan are labeled as having "some [infrastructure] planned as part of Master Planned Community". This alone is not adequate information to demonstrate the suitability and availability of infrastructure. The element should provide more information regarding the planned infrastructure for the Tustin Legacy Specific Plan. Further, the element should confirm that the infrastructure available for all sites in the inventory includes water, sewer, and dry utilities. For your information, water and sewer service providers must establish specific procedures to grant priority water and sewer service to developments with units affordable to lower-income households. (Gov. Code, § 65589.7.) Local governments are required to immediately deliver the housing element to water and sewer service providers. HCD recommends including a cover memo describing the City's housing element, including the City's housing needs and regional housing need. For additional information and sample cover memo, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/other- requirements/priority-for-water-sewer.shtm I. Review of the City of Tustin's 6th Cycle Draft Housing Element Page 5 August 27, 2021 Environmental Constraints: Per comments from third party stakeholders, HCD understands that some of the sites within the Tustin Legacy Specific Plan may have contamination or need for environmental hazard mitigation. The element must describe and analyze environmental constraints that may impede the development of housing within the planning period on these sites. Sites with Zoning for a Variety of Housing Types: • Emergency Shelters: The element does not identify a zone in which emergency shelters are a permitted use. The element must identify a zone(s) where emergency shelters are permitted without a conditional use permit (CUP) or other discretionary action and with sufficient capacity to accommodate the identified need for shelters. (Gov. Code, § 65583, subd. (a)(4).) If the element cannot demonstrate compliance with the statutory requirements, a program to amend the zoning ordinance to meet the statutory requirements must be completed within one year of the adoption of the housing element. See Finding C1 below for more information regarding a program for compliance. • Transitional & Supportive Housing: The element does not adequately address requirements for transitional housing and supportive housing. Pursuant to Senate Bill 2 (Chapter 633, Statutes of 2007), transitional and supportive housing must be permitted as a residential use in all zones and only subject to those restrictions that apply to other residential dwellings of the same type in the same zone. The element must demonstrate consistency with these statutory requirements and include a program as appropriate. • Housing for Farmworkers: The element must identify sufficient sites to accommodate the need for farmworker housing and include an analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for agricultural employees, permanent and seasonal. For example, the analysis could describe zoning available to accommodate various housing types, such as manufactured homes, apartments, boarding houses, or single-room occupancy units, to address the needs of farmworkers. In addition, the element must demonstrate the City's zoning is consistent with the Employee Housing Act (Health and Safety Code, § 17000 et seq.), specifically, sections 17021 .5 and 17021 .6. Section 17021.5 requires employee housing for six or fewer employees to be treated as a single-family structure and permitted in the same manner as other dwellings of the same type in the same zone. Section 17021 .6 requires employee housing consisting of no more than 12 units or 36 beds to be permitted in the same manner as other agricultural uses in the same zone. • Manufactured Housing: The element must address how and where manufactured housing is allowed, including whether a CUP or other discretionary action is required. 3. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities Review of the City of Tustin's 6th Cycle Draft Housing Element Page 6 August 27, 2021 as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures. The analysis shall also demonstrate local efforts to remove governmental constraints that hinder the locality from meeting its share of the regional housing need in accordance with Government Code section 65584 and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters identified pursuant to paragraph (7). Transitional housing and supportive housing shall be considered a residential use of property and shall be subject only to those restrictions that apply to other residential dwellings of the same type in the same zone. (Gov. Code, § 65583, subd. (a)(5).) Land-Use Controls: The element must identify and analyze all relevant land-use controls impacts as potential constraints on a variety of housing types (e.g., multifamily rental housing, mobilehomes, transitional housing). The analysis must also evaluate the cumulative impacts of land-use controls on the cost and supply of housing, including the ability to achieve maximum densities. In particular, the element should list allowable densities in each zone, in addition to the development standards already provided (p. II-24). The element should also analyze the requirement for two covered spaces in all residential zones, particularly the multi-family zones, as a potential constraint. The analysis should describe past or current efforts to remove identified governmental constraints, and the element should include programs to address or remove the identified constraints. Fees and Exaction: The element must describe all required fees for single family and multifamily housing development and analyze their impact as potential constraints on housing supply and affordability. The element currently identifies impact fees but does not provide information about planning fees and does not analyze either. The analysis should identify the total amount of fees and their proportion to the development costs for both single family and multifamily housing. Local Processing and Permit Procedures: The element must describe and analyze the City's permit processing and approval procedures by zone and housing type (e.g., multifamily rental housing, mobilehomes, housing for agricultural employees, supportive housing). The analysis must evaluate the processing and permit procedures' impacts as potential constraints on housing supply and affordability. For example, the analysis should consider processing and approval procedures and time for typical single- and multifamily developments, including type of permit, level of review, approval findings and any discretionary approval procedures. In particular, the element should clarify how and where multifamily development is allowed and what the process and timing look like for a typical multi-family development, among other details. Design Review: The element must describe and analyze the City's design review guidelines and process, including approval procedures and decision-making criteria, for their impact as potential constraints on housing supply and affordability. For example, the analysis could describe required findings and discuss whether objective standards and guidelines improve development certainty and mitigate cost impacts. The element Review of the City of Tustin's 6th Cycle Draft Housing Element Page 7 August 27, 2021 must demonstrate this process is not a constraint or it must include a program to address this permitting requirement, as appropriate. Constraints on Housing for Persons with Disabilities: The element must demonstrate that the City has a reasonable accommodation procedure for providing exception in zoning and land use. While the element makes reference to reasonable accommodation for persons with disabilities, it does not provide any information on the City's reasonable accommodation procedure. The element should describe the City's reasonable accommodation procedure, including how requests are made and processed, and any approval findings. In addition, the element details that residential care facilities serving six or fewer persons are permitted in all residential zones. However, residential care facilities serving seven or more persons require a CUP. The element should analyze the process as a potential constraint on housing for persons with disabilities and add or modify programs as appropriate to ensure zoning permits group homes objectively with approval certainty. Local Ordinances: The element must specifically analyze any locally adopted ordinances such as inclusionary ordinances or short-term rental ordinances that directly impact the cost and supply of residential development. The analysis should demonstrate local efforts to remove governmental constraints that hinder the locality from meeting its share of the regional housing need and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters. If the City does not have such ordinances, the element should confirm this. 4. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality's share of the regional housing need in accordance with Government Code section 65584. The analysis shall also demonstrate local efforts to remove nongovernmental constraints that create a gap between the locality's planning for the development of housing for all income levels and the construction of that housing. (Gov. Code, § 65583, subd. (a)(6).) The element must address requests to develop housing at densities below those anticipated in the sites inventory and the length of time between receiving approval for housing development and submittal of application for building permits. This analysis must address any related constraints on housing development and programs should be added as appropriate. Additionally, the element must identify any local efforts to address nongovernmental constraints that create a gap in the jurisdiction's ability to meet the RHNA by income category. 5. Analyze any special housing needs such as elderly; persons with disabilities, including Review of the City of Tustin's 6th Cycle Draft Housing Element Page 8 August 27, 2021 a developmental disability; large families, farmworkers; families with female heads of households, and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).) While the element quantifies the number of some special need populations, it must also quantify the number of persons with disabilities, large households, and female- headed households. In addition, the element must analyze the special housing needs of these populations. For a complete analysis of each population group, the element should discuss challenges faced by the population, the existing resources to meet those needs (e.g., availability senior housing units, number of large units, number of deed restricted units, etc.), an assessment of any gaps in resources, and proposed policies, programs, and funding to help address those gaps. 6. Analyze existing assisted housing developments that are eligible to change to non-low- income housing uses during the next 10 years due to termination of subsidy contracts, mortgage prepayment, or expiration of use restrictions. (Gov. Code, § 65583, subd. (a)(9) through 65583(a)(9)(D).) The element identifies four properties at risk of conversion to market rate. While the element addresses some of these requirements, it does not estimate the costs of replacement versus preservation, identify entities with the capacity to oversee preservation, or identify specific funding sources that could be used to preserve the affordability. The element must provide this analysis for the at-risk units identified. C. Housing Programs 1 . Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the housing element through the administration of land use and development controls, the provision of regulatory concessions and incentives, and the utilization of appropriate federal and state financing and subsidy programs when available. The program shall include an identification of the agencies and officials responsible for the implementation of the various actions. (Gov. Code, § 65583, subd. (c).) To address the program requirements of Government Code section 65583, subdivision (c)(1-6), and to facilitate implementation, programs should include: (1) a description of the City's specific role in implementation; (2) definitive implementation timelines; (3) objectives, quantified where appropriate; and (4) identification of responsible agencies and officials. Several programs contained in the element lack one or more of these components. Programs to be revised include the following: • 1 .2a (Objective Design Standards): Modify timeframe to reflect completion date for objective design standards. • 2.1c (Emergency, Transitional, and Supportive Housing): Specify timeframe for expansion by 125 beds. Review of the City of Tustin's 6th Cycle Draft Housing Element Page 9 August 27, 2021 • 2.3a (Senior Housing): Modify to include further details regarding how senior units will be preserved. • 2.4a (Housing for Persons with Disabilities): Add timeframe for implementation of outreach program and completion of related educational materials. • 2.4b (Housing for Persons with Disabilities): Accelerate timeframe to ensure beneficial impact within the planning period. Additionally, all programs should be evaluated to ensure meaningful and specific actions and objectives. Programs containing unclear language (e.g., "Evaluate"; "Consider"; "Encourage"; etc.) should be amended to include more specific and measurable actions. These include Programs 1.1 b (Residential Development — Available Sites), 1 .5 (Zoning Code Streamlining Program), 1 .6 (Mobile Home Programs), 1 .9 (Partnerships with Non-profit Organizations), 1 .14 (Adaptive Reuse of Historic Resources to Facilitate Affordable Housing Production), 1 .19 (Fees, Exactions and Permit Procedures), 2.1 b (Emergency, Transitional, and Supportive Housing), 2.1c, 2.1d, 2.4b (Housing for Persons with Disabilities), 3.2b (Home Ownership Assistance), and 3.8a (Membership of CaICHA). 2. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city's or county's share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single- room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).) As noted in Finding A2, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised as follows: Program 1.1a (Tustin Legacy Specific Plan Implementation): The program commits to rezoning sites to accommodate the City's RHNA but does not include the by-right provisions found in statute (Gov. Code 65583.2(c), subd. (h) & (i).) The program must commit to: • permit owner-occupied and rental multifamily uses by-right for developments in which 20 percent or more of the units are affordable to lower-income households. By-right means local government review must not require a CUP, planned unit development permit, or other discretionary review or approval. • accommodate a minimum of 16 units per site; • require a minimum density of 20 units per acre; and Review of the City of Tustin's 6th Cycle Draft Housing Element Page 10 August 27, 2021 • at least 50 percent of the lower-income need must be accommodated on sites designated for residential use only or on sites zoned for mixed uses that accommodate all of the very low and low-income housing need, if those sites: o allow 100 percent residential use, and o require residential use occupy 50 percent of the total floor area of a mixed-use project. Program 3.7 (Preservation of Assisted Housing): As stated above, the element appears to rely on the preservation of four housing projects to accommodate a portion of the RHNA for lower-income households pursuant to Government Code section 65583.1 , subdivision (c). The element must include a program that commits the City to provide committed assistance through a legally enforceable agreement by the end of the third year of the housing-element planning period. The dollar amount or related in-kind services of the committed assistance must be substantial enough to make the targeted units available for occupancy within two years of the execution date of the agreement. In addition, the program must commit to report the status of the committed assistance program in the annual progress report no later than the fourth year of the planning period. If the City does not enter into an enforceable agreement of committed assistance for all the units initially identified by the end of the third year of the planning period, the local government must adopt an amendment to its housing element, no later than the end of the fourth year of the planning period, identifying additional adequate sites sufficient to accommodate the number of units for which committed assistance was not provided. Program 2.1 a (Emergency, Transitional and Supportive Housing): Specify the changes being made to comply with Assembly Bill 2162 (Chapter 753, Statues of 2018) and all other statutory provisions regarding emergency shelters, supportive housing, and transitional housing, including the requirements under Senate Bill 2 (Chapter 633, Statutes of 2007). Please be aware, actions to adopt zoning that accommodates emergency shelters without discretionary action must be completed within one year of adoption of the element. In addition, actions to amend the zoning ordinance to comply with State law should also take place within one year of adoption. 3. The housing element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate- income households. (Gov. Code, § 65583, subd. (c)(2).) While the programs describe various actions to assist in the development of housing, the element must include a program specifically to meet the needs of extremely low- income households. 4. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).) Review of the City of Tustin's 6th Cycle Draft Housing Element Page 11 August 27, 2021 As noted in Findings A3 and A4, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints. 3. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law. (Gov. Code, § 65583, subd. (c)(5).) As noted in Finding Al , the element does not contain programs that satisfy the AFFH requirements for specific and meaningful actions to overcome fair housing issues. Based on a complete analysis, the element must add or revise programs. D. Quantified Objectives Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd. (b)(1 & 2).) Include quantified objectives estimating the number of housing units by income category that can be constructed, rehabilitated, and conserved over a five-year time period. This requirement could be addressed by utilizing a matrix like the one illustrated below: New Conservation/ Income Construction Rehabilitation Preservation Extreme) Low- Ver Low- Low- Moderate- Above Moderate- TOTAL While the element demonstrates progress towards these objectives from the previous housing element cycle (p. A-7), it must also provide quantified objectives for the 6th cycle. E. Public Participation Local governments 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 element shall describe this effort. (Gov. Code, § 65583, subd.(c)(8).) Review of the City of Tustin's 6th Cycle Draft Housing Element Page 12 August 27, 2021 While the element includes a general summary of the public participation process (Appendix E), it must also summarize the public comments and describe how they were considered and incorporated into the element. In addition, HCD understands the City made the element available to the public concurrent with its submittal to HCD. By not providing an opportunity for the public to review and comment on a draft of the element in advance of submission, the City has not yet complied with statutory mandates to make a diligent effort to encourage the public participation in the development of the element and it reduces HCD's ability to consider public comments in the course of its review. The availability of the document to the public and opportunity for public comment prior to submittal to HCD is essential to the public process and HCD's review. The City must proactively make future revisions available to the public, including any commenters, prior to submitting any revisions to HCD and diligently consider and address comments, including making revisions to the document where appropriate. HCD's future review will consider the extent to which the revised element documents how the City solicited, considered, and addressed public comments in the element. The City's consideration of public comments must not be limited by HCD's findings in this review letter. Review of the City of Tustin's 6th Cycle Draft Housing Element Page 13 August 27, 2021 ATTACHMENT E PLANNING COMMISSION RESOLUTION 4439 RESOLUTION NO. 4439 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 2021-002 (HOUSING ELEMENT UPDATE). The Planning Commission of the City of Tustin does hereby resolve as follows: I. The Planning Commission finds and determines as follows: A. That the California Government Code requires that cities review and update their housing elements every eight (8) years, according to a schedule set forth by the State Department of Housing and Community Development; B. That housing is an important issue with the State of California and as such, each city and county must identify and analyze existing and projected housing needs within their jurisdiction and prepare goals, policies, programs, and quantified objectives to further the development, improvement, and preservation of housing; C. That in accordance with State Law, the City of Tustin has prepared a Draft Housing Element for the 2021-2029 period in accordance with California Government Code Sections 65580-65589.8; D. That in preparation of the 2021-2029 Housing Element, City staff held two (2) public workshops; the first was held on November 10, 2020 and the second was held on May 11, 2021. The City also developed a robust Community Engagement Plan which included a community online survey, and social media posts, social media paid ads, newspaper advertisements, mailings to all City residents and stakeholders. Additional public meetings were held on August 17, 2021 and September 7, 2021 which provided additional opportunities to gather additional public input; E. That on August 17, 2021 the City Council held a public meeting whereby an amendment was made to the Housing Element which included the addition of two (2) new potential housing sites and a subsequent to the City's Sites Inventory based upon public comments; F. That on September 7, 2021, the City Council held a public meeting and further confirmed the amendment to the Sites Inventory and subsequent allocation of units within the different planning areas identified within the Housing Element based upon the California Department of Housing and Community Development's comments. G. That on September 14, 2021, the Planning Commission held a public hearing. A notice of time, place, and purpose of the meeting was given in accordance with the Tustin City Code (TCC). Evidence, both written and oral, was presented to the Planning Commission. Resolution No. 4439 Page 2 H. That implementation of the Housing Element Update's goals includes proposed housing development within the Tustin Legacy Specific Plan area, Red Hill Avenue Specific Plan (RHASP) area, Downtown Commercial Core Specific Plan (DCCSP) area, The Market Place, Enderle Center and construction of Accessory Dwelling Units (ADUs) and transitional housing units within and/or outside of these areas. I. That the proposed project General Plan Amendment (GPA) 2021-0002 is considered a "project" subject to the terms of the California Environmental Quality Act (CEQA). Pursuant to the CEQA Guidelines Section 15063, the City has completed an Initial Study and prepared a Negative Declaration for the draft Housing Element for consideration and recommendation by the Planning Commission. J. 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. On July 5, 2017, the City Council adopted Resolution No. 17-23 approving a second Supplement to the FEIS/EIR. The FEIS/EIR along with its Addenda and Supplements is a program EIR under the California Environmental Quality Act (CEQA). The FEIS/EIR, Addenda and Supplements considered the potential environmental impacts associated with development on the former MCAS, Tustin. K. That on November 6, 2018, the City of Tustin certified the Final Program Environmental Impact Report (EIR) for the RHASP. L. That on July 3, 2018, the City of Tustin certified the Final Program Environmental Impact Report (EIR) for the DCCSP. M. That the proper amendments to the Zoning Map and Specific Plan would be required following adoption of the Housing Element Update to include a zoning overlay over The Market Place and Enderle Center RHNA housing sites, which would allow for residential development in these areas. Potential impacts that could result from proposed amendments would be evaluated under a separate CEQA review process. N. That any development proposed as a result of the Housing Element Update would also be required to obtain City approval on a project-by-project basis for any discretionary action and undergo a separate environmental process to access potential environmental impacts. O. That mitigation measures that are required by underlying EIR's for the Tustin Legacy, RHASP and DCCSP areas would be implemented as development is proposed. Resolution No. 4439 Page 2 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), the RHASP area and the DCCSP area which are previously approved and certified EIRs within the City. Each respective EIR adequately describes the general environmental setting of where additional residential units can be placed which, in turn, coincides with the City's distribution of units and specific allocation. III. The Planning Commission of the City of Tustin recommends that the Tustin City Council adopt a Negative Declaration pursuant to the California Environmental Quality Act (CEQA) of 1970 (Public Resources Code Sections 21000 et seq.) for the Housing Element incorporating herein by reference all of the applicable mitigation measures identified in the Program EIS/EIR for MCAS-Tustin (i.e. Tustin Legacy), the RHASP area and the DCCSP area. Potential impacts that could result from proposed amendments in conjunction with Enderle Center and The Market Place will be evaluated under a separate CEQA review process. PASSED AND ADOPTED at a regular meeting of the Tustin Planning Commission held on the 14th day of September, 2021. AMY MASON Chairperson JUSTINA L. WILLKOM Planning Commission Secretary Attachment: 1. Exhibit A: Initial Study/Negative Declaration for Housing Element 2021-2029 Update Resolution No. 4439 Page 2 STATE OF CALIFORNIA ) COUNTY OF ORANGE ) CITY OF TUSTIN ) I, JUSTINA L. WILLKOM, the undersigned, hereby certify that I am the Recording Secretary of the Planning Commission of the City of Tustin, California; that Resolution No. 4439 passed and adopted at a regular meeting of the Tustin Planning Commission, held on the 141h day of September, 2021. PLANNING COMMISSIONER AYES: PLANNING COMMISSIONER NOES: PLANNING COMMISSIONER ABSTAINED: PLANNING COMMISSIONER ABSENT: JUSTINA L. WILLKOM Planning Commission Secretary TIJTIi CITY OF TUSTIN COMMUNITY DEVELOPMENT DEPARTMENT 300 Centennial Way, Tustin, CA 92780 (714) 573-3100 lal{Ta Y — CUILDMGOuRf'i„u it INITIAL STUDY / NEGATIVE DECLARATION HONORING 01 CITY OF TUSTIN GENERAL PLAN DRAFT HOUSING ELEMENT 2021-2029 GENERAL PLAN UPDATE July 2021 A. BACKGROUND Project Title: Housing Element Update 2021-2029 Lead Agency: City of Tustin, 300 Centennial Way, Tustin, California 92780 Contact Person and phone number: Erica H. Demkowicz, AICP, Senior Planner (714) 573-3127 EDemkowicz@tustinca.org Project Location: City of Tustin Project Sponsor's Name and Address: City of Tustin, 300 Centennial Way, Tustin, California 92780 General Plan Land Use Designation: The City supports a variety of land uses as included in the City's General Plan Land Use Map (2018). Housing sites identified to support the 2021 Regional Housing Needs Allocation (RHNA) are designated with the following land uses: TLSP—Tustin Legacy Specific Plan RHASP — Red Hill Avenue Specific Plan DCCSP — Downtown Commercial Core Specific Plan PCCB - Planned Community Commercial/Business Zoning Designation: The City supports a variety of zone designations as included in the City's City Zoning Map (2018). RHNA housing sites are within the following zoning designations: Page l 1 INITIAL STUDY City of Tustin SP 1 —Tustin Legacy SP 8— East Tustin SP 13— Red Hill Avenue SP 12 — Downtown Commercial Core DA-2 — Development Area 2 DA-3— Development Area 3 DA-4— Development Area 4 DA-6— Development Area 6 PC COM - Planned Community Commercial Project Description: The project is a General Plan Update (GPU) to the City of Tustin (City) Housing Element for the Sixth Cycle planning period from October 15, 2021 to October 15, 2029. The Housing Element, which is part of the City's General Plan is a policy document designed to provide the City a coordinated and comprehensive strategy for promoting the production of housing to meet existing and future housing needs. Surrounding Land Uses and Setting: Tustin is surrounded by the cities of Santa Ana to the west, Irvine to the east and south, and the City of Orange and unincorporated County of Orange area (i.e. North Tustin) to the north. The jurisdictions are highly developed and mostly residential in nature. The City of Irvine contains an abundance of commercial and business uses, as well as John Wayne Airport. Other public agencies whose approval is required: The City of Tustin. No other agency is required to approve the Housing Element update, but it will be reviewed by the HCD for the purpose of determining whether it complies with the requirements of the Housing Element Law. Attachments: Figure 1: Regional Location Map Figure 2: Suitable Sites for Additional Residential Development Figure 3a: Site Identification to Meet RHNA Figure 3b: Site Identification to Meet RHNA (continued) Page 12 INITIAL STUDY City of Tustin 1 INTRODUCTION 1 .1 PURPOSE OF THE INITIAL STUDY This Initial Study has been prepared in accordance with the following: • California Environmental Quality Act (CEQA) of 1970 (Public Resources Code Sections 21000 et seq.); and • California Code of Regulations, Title 14, Division 6, Chapter 3 (State CEQA Guidelines, Sections 15000 et seq.) as amended and approved on December 28, 2018. Pursuant to CEQA, this Initial Study has been prepared to analyze the potential for significant impacts on the environment resulting from implementation of the 2021-2029 Tustin General Plan Housing Element Update. described in greater detail in Section 3.0 below. As required by State CEQA Guidelines ("Guidelines") Section 15063, this Initial Study is a preliminary analysis prepared by the Lead Agency, the City of Tustin, in consultation with other jurisdictional agencies, to determine if a Negative Declaration or an Environmental Impact Report is required for the project. This Initial Study informs City of Tustin decision-makers, affected agencies, and the public of potentially significant environmental impacts associated with the implementation of the project. A "significant effect" or "significant impact" on the environment means "a substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project" (Guidelines Section 15382). Given the project's broad scope and level of detail, combined with previous analyses and current information about the site and environs, the State's intent is to adhere to the following CEQA principles: • Provide meaningful early evaluation of site planning constraints, service and infrastructure requirements, and other local and regional environmental considerations. (Public Resources Code Section 21003.1) • Encourage the incorporation of environmental considerations into project conceptualization, design, and planning at the earliest feasible time. (Guidelines Section 15004[b][3]) • Specify mitigation measures for reasonably foreseeable significant environmental effects and commit the City and applicant to future measures containing performance standards to ensure their adequacy when detailed development plans and applications are submitted. (Guidelines Section 15126.4) Page 3 INITIAL STUDY City of Tustin 1 .2 DOCUMENT ORGANIZATION This Initial Study includes the following sections: Section 1. Introduction Provides information about CEQA and its requirements for environmental review and explains that an Initial Study was prepared by the State of California to evaluate the proposed project's potential impact to the physical environment, and to determine if a Negative Declaration or an Environmental Impact Report (EIR) is required. Section 2. Environmental Setting Provides information about the proposed project's location. Section 3. Project Description Includes a description of the proposed project's physical features and characteristics. Section 4. Environmental Checklist Includes the Environmental Checklist from the CEQA Guidelines and evaluates the proposed project's potential to result in significant adverse effects to the physical environment and identifies if an EIR is required, and if one is, what environmental topics need to be analyzed in the EIR. -------------------------------------------------------------------------------------------------------------------------------------------------------------------- Page 14 INITIAL STUDY City of Tustin 2 ENVIRONMENTAL SETTING 2.1 PROJECT LOCATION The project site is located in central Orange County, within the City of Tustin (see Figure 1). The City of Tustin is surrounded by the Cities of Orange to the north, Santa Ana to the west, Irvine to the south, and the Santa Ana Mountains to the east. Tustin is approximately 30 miles southeast of downtown Los Angeles and 40 miles southwest of downtown San Bernardino. Regional access to the city is provided via Interstate 5 (1-5) and State Route 55 (SR-55). The City has identified 20 sites for RHNA allocation. Sites are located within the Tustin Legacy Specific Plan, Red Hill Avenue Specific Plan, Downtown Commercial Core Specific Plan, Enderle Center, and The Market Place. 2.2 EXISTING LAND USES The City of Tustin encompasses approximately 11 .12 square miles. The Land Use Element provides for seven major land use groupings divided into 15 land use categories or designations. Four of these designations are established for residential development, ranging from low-density single family to high-density multiple family development. Three commercial designations, one industrial, and one public/ institutional, are included. A planned community designation, which includes residential, commercial/business, and public institutional components, is also provided. The City also includes several specific plan areas that include their additional land use designations and specification criteria. 2.3 SURROUNDING LAND USES Tustin is surrounded by the cities of Santa Ana to the west, Irvine to the east and south, and unincorporated County of Orange area (i.e. North Tustin) and Orange to the north. The jurisdictions are highly developed and mostly residential in nature. The City of Irvine contains an abundance of commercial and business uses, as well as John Wayne Airport. 2.4 EXISTING LAND USE AND ZONING The City supports a variety of land uses as included in the City's General Plan Land Use Map (2018). Housing sites identified to support the 2021 Regional Housing Needs Allocation (RHNA) are designated with the following land uses: • TLSP — Tustin Legacy Specific Plan • RHASP — Red Hill Avenue Specific Plan • DCCSP — Downtown Commercial Core Specific Plan • PCCB — Planned Community Commercial/Business Additionally, the City's Zoning Map (2018) includes the following zones underlying identified housing sites: • SP 1 — Tustin Legacy • SP 8 — East Tustin • SP 13 — Red Hill Avenue • SP 12 — Downtown Commercial Core o DA-2 — Development Area 2 Page 15 INITIAL STUDY City of Tustin o DA-3 — Development Area 3 o DA-4 — Development Area 4 o DA-6 — Development Area 6 • PC COM — Planned Community Commercial -------------------------------------------------------------------------------------------------------------------------------------------------------------------- Page 16 Figure 1 w &F I L r,J Ave ORANGE -LL 0""r}nGrovt' Fairhaven Memorial G^ Pa* NORTH TUSTIN J < E San ?'Vint, Blvd— Ni'1X TUSTIN 7a.,Aari. SANTA ANA 4 Hicks Carryon Cr IRVINE City of Irvir�e,,�punty of Los Angeles, Bureau of Land Management,Esn,HERE,Garmira;,J,NCREMENT P,USGS,METI/ -af NASA,EPA,USDA Project Site INITIAL STUDY City of Tustin This page intentionally left blank. Page 18 Figure 2 Suitable Sites for Additional Residential Development II LI 10, dbud�ae��ldo 9. i� ®� IO Suitable Site Locations Downtown Commercial Core Specific Plan � ��� '%�/ . •• Red Hill Avenue Specific Plan ®Tustin Legacy Specific Plan i Enderle Center -Tustin Marketplace Municipal Boundaries N Mile INITIAL STUDY City of Tustin This page intentionally left blank. Page 1 10 SITE IDENTIFICATION Downtown Commercial Figure 3a TO MEET RHNA Core Specific Plan d � $ 9 Q F] 10 �❑❑ �I1/7 11 12 O o N N Tustin Legacy-Specific Plan 00 Red Hill Avenue 18 Specific Plan 5 / v 2 _ r t-� 1B i N N INITIAL STUDY City of Tustin This page intentionally left blank. Page 1 12 SITE IDENTIFICATION Figure 3b TO MEET RH NA Enderle Center (Site #19) od �, a�= N The Market Place (Site #20) N INITIAL STUDY City of Tustin 3 PROJECT DESCRIPTION 3.1 PROJECT OVERVIEW In accordance with State Government Code Section 65580, the legislature has declared that the attainment of decent housing and the provision of a suitable living environment to meet the needs of all economic segments of the population are of the highest priority. The legislature also recognizes that to meet the statewide goal, cooperation between government and the private sector is necessary, and that local and State governments have a responsibility to utilize the powers vested in them to facilitate the development and improvement of housing. The Housing Element is one of the seven mandatory elements of the General Plan. State law requires inclusion of a Housing Element in the General Plan in recognition of the role that land use planning plays in the production of affordable housing. Tustin's General Plan consists of the following six Elements: • Conservation/Open Space/Recreation • Growth Management • Housing • Land Use • Noise/Circulation • Public Safety Specific requirements for data collection and analysis necessary to prepare the Housing Element are set forth in Government Code Section 65583. The Government Code also requires that each draft of the Housing Element be reviewed by the California Department of Housing and Community Development (HCD) and that the Department's findings be incorporated prior to adoption, or that specified findings be made in response to the Department's comments. The 2021-2029 Tustin General Plan Housing Element Update (HEU, Draft HEU) was available for public review and comment from June 30, 2021 to July 30, 2021. The document was also submitted to the HCD on June 30th and discussed preliminary comments with the HCD on a call on August 12th. The Draft HEU continues to be revised to address public and HCD comment. The latest HEU document and information is available on the City's website at nttps://www.tustinca.org/HousingEVement. 3.2 PROJECT DESCRIPTION The proposed project is the 2021-2029 HEU. The purpose of the project is to ensure the City establishes policies, procedures and incentives in its land use planning and redevelopment activities that will result in the maintenance and expansion of the housing supply to adequately accommodate households currently living and expected to live in Tustin. It institutes policies that will guide City decision-making and establishes an action program to implement housing goals through 2029. Sections included in the HEU are summarized in Table 3-1 , Summary of 2021-2029 Housing Element. Page 1 14 INITIAL STUDY City of Tustin Table 3-1: Summary of 2021-2029 Housing Element Section Summary I. Introduction to A background and introduction to contents included in the HEU for the the Housing 2021-2029 planning period. Element: II. Summary of An analysis of identified housing needs within the city, which includes Issues, Needs, a breakdown by special needs groups and other demographics, as Constraints well as an examination of the constraints that could hinder the City's and achievement of its objectives and the resources that are available to Opportunities assist in the provision of housing. III. Housing City goals, policies, and actions related to housing being adopted into Element Goals the City's General Plan for implementation during the planning period. and Policies IV. Housing Existing and new housing programs to be implemented during the Implementation planning period in execution of identified housing goals and policies. Programs Appendix A — Review A review of the continued progress in implementation, the of Past Performance effectiveness of the Housing Element, and the appropriateness of the City's housing goals adopted in the HEU. Appendix B — Housing Identification of sites that, in total, can achieve Tustin's assigned 2021 Sites Inventory RHNA by income level for the planning period (2021 —2029). Assessment Appendix C — Funding sources for a wide variety of major housing assistance Affordable Housing programs available that can assist in meeting the City's housing Resources needs. Appendix D — A summary of fair housing issues in the City of Tustin and an Affirmatively assessment of the jurisdiction's fair housing enforcement, outreach, Furthering Fair potential impediments, and commitments. Housing Appendix E — Public A summary of community engagement and outreach conducted as Participation part of the entire HEU process. (Community Engagement Plan Appendix F — Studies, plans, and documents referenced in development of the References HEU. State Housing Law requires that each jurisdiction establish the maximum number of housing units that will be constructed, rehabilitated, and preserved over the planning period, or the quantified objective. Consistent with state law, the Tustin HEU provides a plan to accommodate the City's fair share of affordable housing known as the Regional Housing Needs Allocation, or RHNA. The RHNA is allocated to each region of the state by HCD in consultation with regional council of governments, which is the Southern California Association of Governments (SCAG) for the Southern California region. RHNA allocated to the City of Tustin includes a total of 6,782 housing units with the following breakdown by income category: • 1 ,724 very low-income units; Page 1 15 INITIAL STUDY City of Tustin • 1 ,046 low-income units; • 1 ,132 moderate-income units; and • 2,880 above moderate-income housing units. As conveyed in Table 3-2, Sites to Meet RHNA Estimated Income Distribution, there are a total of 658 housing units that are captured from approved/entitled, pending and permitted (projects under construction). There are 532 units in three projects with a total of 132 extremely very-low-income transitional housing units (7 units proposed at the House of Ruth and 125 units proposed at the Village of Hope transitional housing facilities) and 400 above-moderate income housing units that were approved/entitled at the time of the preparation of the HEU (located within TLSP Neighborhood D South). Additionally, there is one pending mixed-use project proposed with a total of 137 housing units (6 very-low-income and 131 above-moderate-income). This project is currently under review and anticipates a second reading to City Council in Fall 2021 . In addition, 35 ADUs or JADUs are projected to be constructed during the 2021-2029 planning period. Among other things, the Housing Element establishes the City's strategy to plan for and facilitate the development of housing over the eight-year planning period. It is required by Housing Element Law. Expectations are to provide an inventory of land adequately zoned or planned to be zoned for housing and programs to implement the strategy. The City analyzed and assessed a number of sites and areas throughout the community based on these above-mentioned parameters as well as other considerations. While many sites were considered, 20 sites, two facilities, and one site category have been identified for Tustin's qualifying sites to accommodate RHNA. The City Zoning Code and map would be amended to accommodate two of the sites proposed, Enderle Center and The Market Place, to provide a housing overlay for the provision of residential development. Zoning would be updated following adoption of the HEU. Page 1 16 > H o � m L tiO 00 'IT Ln 'IT Co o O O N V (14 Qc) � N M r � p ' N ' >' ++ O C N M U = � m +N+ i 'IT MLO O N N d O ti 'IT 00 � N C) Ln CO O r ' V N M r r r r o C 3 J E 00 N Il rlqt 'IT Qc) y 0 Qc) r Ln � r r— � CD O I O O ' ++ V N M r r C r r E } O O 'IT > V Ln 'IT CD 'IT � N Ln N N N C O r N N 00 O N OF) M ti ti O r M Ln r r r N r U) 'Z _ 0 r r J � J i+ N Z � r CO 07 N N 00 CO 0') N r Ln co 00 00 co Q N O Ln Il- 'ITm co r ~ ~ r w CO 00 v U o C CUC O ca- U U (B (B -0 O c N c M cu cu cv U > U > cv cv +_ E W cu cuV (B (B (B > > X 0 Z � O > > > r z "T z CO CO W W = Z MLO z z 0 N J N � C Ca) 0 0 U rn D Y o Gr 0 fn fn = J O V O O O O Q Of O O m u`Ti C7 of Q N oO OmO CU U-0- a) nn d 0 <n <n d 0L oz Q Coj _(1) � n � . 0 J of Z ` ` 2N O (B O/ -0 -0 _0 _0 M cu yy ) a) ) a) O U O > > CL r N Co V- � U o � Q U m o m " = �r �q m � � m J O (nJUJ (n 2 U Cep i L i F- Z H I H of 0 W it- 0- 0- < QQQ �z z°in INITIAL STUDY City of Tustin Future residential development in the City of Tustin will take place primarily in five distinct parts of the city and within three Specific Plan areas; Tustin Legacy Specific Plan (TLSP) (formerly the MCAS Tustin Reuse Specific Plan), Downtown Commercial Core Specific Plan (DCCSP),Red Hill Avenue Specific Plan (RHASP), Enderle Center and The Market Place. These five areas are located in different areas of the City and are described below: Tustin Legacy Specific Plan (TLSP) Area Tustin Legacy contains two neighborhoods where residential housing sites will be concentrated for this planning period: Neighborhood D and Neighborhood G. The land is vacant. The zoning for Tustin Legacy is SP 1 and the General Plan designation is TLSP. Neighborhood D has a total of 84.73 acres and is divided into two areas: South (44.86 acres) and North (39.87 acres). Sites within Tustin Legacy do not have a density prescribed to the planning area per the TLSP; however, there is a development cap placed on several of the planning areas. Therefore, a default density of 30 units per acre was applied for areas within the cap limit. A total of 4,786 units have been allocated to this area. Red Hill Avenue Specific Plan (RHASP) Area The RHASP was adopted in 2018. The RHASP area consists of approximately 52 acres centrally located within the city. It is primarily a commercial and retail corridor that is prime for revitalization. With the Specific Plan, mixed-use residential is permitted. The RHASP provides a unique Residential Allocation Reservation (RAR) which is approved either by the Community Development Director or the Planning Commission/City Council, as applicable. The RAR is the mechanism with an associated process and timeline that allocates units to a requested development. The units are drawn from a residential allocation bank which assigns units by area and allows for transferability between areas. The maximum density on an individual parcel may exceed 25 dwelling units per acre (the General Plan's maximum density) as long as the total dwelling units allocated to the Specific Planning Area is not exceeded. Therefore, a default density of 30 units per acre is achievable in the RHASP area. The Zoning is SP 13 and the General Plan designation is RHASP. The maximum allowable building height for residential mixed-use development in the RHASP is 4 stories/50 feet. Four sites within the RHASP area have been identified as relevant sites to meet RHNA. A total of 500 residential units have been allocated to this area. This site also has a pending mixed-use project which was approved on August 18, 2021 by the Tustin City Council. The pending project includes 137 units (114 base density units plus 20% density bonus), of which 131 are market-rate and six are designated affordable to very low-income households. Downtown Commercial Core Specific Plan (DCCSP) Area The Downtown Commercial Core Specific Plan was adopted in 2018 and is centered around the intersection of Main Street and EI Camino Real in Old Town. The DCCSP consists of approximately 220 acres located in the northern and western portion of the City. This area was not previously zoned to accommodate residential development. With the adoption of the DCCSP, the area now allows residential development (primarily mixed- Page 1 18 INITIAL STUDY City of Tustin use residential). Since Specific Plan adoption, 140 residential units have been developed, and 747 allocated units remain. The DCCSP also provides the RAR which is approved either by the Current housing bank allocations which include 45 units to Development Area 1 , 92 units to Development Area 2, 200 units to Development Area 3, 150-units to Development Area 4 and, 260 units to Development Area 6. The maximum density on an individual parcel may exceed 25 dwelling units per acre (the General Plan's maximum density) as long as the total dwelling units allocated to the Specific Plan area is not exceeded. Therefore, a default density of 30 units per acre is achievable in the DCCSP area. The Zoning is SP 12 and the General Plan designation is DCCSP. The maximum allowable building height ranges from two to five stories, depending on Development Area and adjacent land uses. None of the DCCSP sites were identified in either of the past two planning cycles as vacant land available for housing to meet RHNA. A total of 747 residential units have been allocated to this area. Enderle Center The Enderle Center is a commercial center located to the east of State Route (SR) 55 and south of 17th Street. The site includes existing commercial uses and could be developed to include mixed use development in the future that would support residential uses. The site is zoned as PC COM (Planned Community Commercial) and designated as PCCB (Planned Community Commercial/Business) land use. Zoning would be amended to include a housing overlay on the site in order to allow for future residential development. Density has not been established for this area and would be established with the adoption of the planned community. A total of 413 residential units have been allocated to this area. The Market Place/East Tustin Specific Plan (ETSP) The Market Place is a commercial center located north of the 1-5 freeway at Jamboree Road and is divided between the City of Irvine and the City of Tustin. The Tustin portion of the commercial center is located on the west side of Jamboree Road between Bryan Avenue and the 1-5 freeway and the City of Irvine portion is located on the east side of Jamboree Road. The site includes existing commercial uses and could be developed to include mixed use development in the future that would support residential uses. The site is in the East Tustin Specific Plan Area (SP-8) and zoned as PC COM (Planned Community Commercial) and designated as PCCB (Planned Community Commercial/Business) land use. According to the ETSP, the allowable uses for this area include business and employment. Zoning would be amended to include a housing overlay on the site in order to allow for future residential development. Density has not been established for this area and would be established with the adoption of the planned community. A total of 900 residential units have been allocated to this area. Page 1 19 INITIAL STUDY City of Tustin 3.3 DISCRETIONARY ACTION REQUESTED The City of Tustin are expected to use the information contained in this Initial Study for consideration of approvals related to and involved in the implementation of this project. These include, but may not be limited to, the permits and approvals described below. As part of the proposed project, the following discretionary actions are required: • Adoption of Negative Declaration (City of Tustin City Council) • Adoption of Housing Element Page 120 INITIAL STUDY City of Tustin 4 ENVIRONMENTAL CHECKLIST 4.1 BACKGROUND Project Title: City of Tustin General Plan 2021-2029 Housing Element Lead Agency: City of Tustin 300 Centennial Way Tustin, CA 92780 Lead Agency Contact: Erica H. Demkowicz, Senior Planner (714) 573-3127 Project Location: The project site is located in Tustin, California. Project Sponsor Contact: City of Tustin; Erica H. Demkowicz, Senior Planner (714) 573-3127 General Plan and Zoning Designation: Tustin supports a variety of land use and zoning designations, including residential, commercial, industrial, and public/ institutional. Project Description: The City of Tustin proposes to update the General Plan Housing Element to include plans and policies that will cover the timeframe of 2021-2029 Plan, in compliance with California Government Code Section 65580 et. seq.. Surrounding Land Uses and Setting: Tustin is surrounded by the cities of Santa Ana to the west, Irvine to the east and south, and unincorporated County of Orange area (i.e. North Tustin) and Orange to the north. The jurisdictions are highly developed and mostly residential in nature. The City of Irvine contains an abundance of commercial and business uses, as well as John Wayne Airport. Other Public Agencies Whose Approval is Required: Page 121 INITIAL STUDY City of Tustin No other agency is required to approve the HEU, but it will be reviewed by the HCD for the purpose of determining whether it complies with the requirements of the Housing Element Law. 4.2 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED The subject areas checked below were determined to be new significant environmental effects or to be previously identified effects that have a substantial increase in severity either due to a change in project, change in circumstances or new information of substantial importance, as indicated by the checklist and discussion on the following pages. ❑ Aesthetics ❑ Agriculture & Forest ❑ Air Quality Resources ❑ Biological Resources ❑ Cultural Resources ❑ Energy ❑ Geology /Soils ❑ Greenhouse Gas ❑ Hazards & Emissions Hazardous Materials ❑ Hydrology / Water ❑ Land Use / Planning ❑ Mineral Resources Quality ❑ Noise ❑ Population / ❑ Public Services Housing ❑ Recreation ❑ Transportation ❑ Tribal Cultural Resources ❑ Utilities / Service ❑ Wildfire ❑ Mandatory Findings Systems of Significances 4.3 DETERMINATION: 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. Page 122 INITIAL STUDY City of Tustin ❑ 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 DECLARACTION 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" or"potentially significant unless mitigated" impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier analysis 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 req u i red. Signature Date Name and Title Lead Agency Page 123 INITIAL STUDY City of Tustin 4.4 EVALUATION OF ENVIRONMENTAL IMPACTS 1) A brief explanation is required for all answers except "No Impact" answers that are adequately supported by the information sources a lead agency cites in the parentheses following each question.A"No Impact"answer 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 should be explained where it is based on project- specific factors as well as general standards (e.g., the project will not expose sensitive receptors to pollutants, based on a project-specific screening analysis). 2) All answers must take account of the whole action involved, including offsite as well as on-site, cumulative as well as project-level, indirect as well as direct,and construction as well as operational impacts. 3) Once the lead agency has determined that a particular physical impact may occur, 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. 4) "Negative Declaration: Potentially Significant Unless Mitigation Incorporated" applies where the incorporation of mitigation measures has reduced an effect from "Potentially Significant Impact"to a "Less Significant Impact." The lead agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level (mitigation measures from"Earlier Analysis," as described in (5) below, may be cross-referenced). 5) Earlier analysis may be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. Guidelines Section 15063 (c)(3)(d). In this case, a brief discussion should identify the following: (a) Earlier Analysis Used. Identify and state where they are available for review. (b) 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. (c) 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. 6) 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. 7) Supporting Information Sources: A source list should be attached, and other sources used, or individuals contacted should be cited in the discussion. 8) This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies should normally address the questions from this checklist that are relevant to a project's environmental effects in whatever format is selected. 9) The analysis of each issue should identify: (a)the significance criteria or threshold used to evaluate each question; and (b) the mitigation measure identified, if any, to reduce the impact to less than significance. -------------------------------------------------------------------------------------------------------------------------------------------------------------------- Page 124 INITIAL STUDY City of Tustin 5 ENVIRONMENTAL ANALYSIS This section provides evidence to substantiate the conclusions in the environmental checklist. 4.5 AESTHETICS Would the project: Potentially Less Than Less Than No Impact Significant Significant Significant Impact with Impact Mitigation Incorporat ed 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? c) In nonurbanized areas, substantially degrade the ❑ ❑ ❑ existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? d) Create a new source of substantial light or glare ❑ ❑ ❑ which would adversely affect day or nighttime views in the area? a. Have a substantial adverse effect on a scenic vista? No Impact. Scenic vistas consist of expansive, panoramic views of important, unique, or highly valued visual features that are seen from public viewing areas. This definition combines visual quality with information about view exposure to describe the level of interest or concern that viewers may have for the quality of a particular view or visual setting. A scenic vista can be impacted in two ways: a development project can have visual impacts by either directly diminishing the scenic quality of the vista or by blocking the view corridors or "vista" of the scenic resource. Important factors in determining whether a proposed project would block scenic vistas include the project's proposed height, mass, and location relative to surrounding land uses and travel corridors. The City's General Plan identifies scenic resource areas in the Conservation/Open Space/Recreation Element. As new development is considered by City decision makers, public views should be preserved as much as possible. Consideration will be given to Page 125 INITIAL STUDY City of Tustin protecting public views along the ridge lines, views toward the inland mountains (Santa Ana Mountains), and along scenic transportation corridors. Figure COSR-4 of the General Plan Conservation/Open Space/Recreation Element conceptually identifies significant public scenic resources in Tustin. Many of the City's major arterial roadways and freeway buffers have been identified as existing landscape corridor or proposed landscape corridor strengthening/freeway edge landscape buffering, including roadways adjacent to proposed RHNA sites, such as the 1-5 corridor, Jamboree Road, and Newport Avenue. Several policies and programs have been established through the General Plan to protect views of scenic resources within the city. Program 35, Protect Scenic Views and Resources establishes that "Through the Hillside Review process, monitor and limit development of Peters Canyon Ridgeline consistent with the requirements of the East Tustin Specific Plan, Grading and Excavation Code and Grading Manual." ' Additionally, Policy 1 .14 of the General Plan Conservation/Open Space/Recreation Element specifically instructs the City to "Enhance the important role that streetscapes play in defining the character of the City by expanding street planning and design procedure to include aesthetic and environmental concerns, as well as traffic considerations. Develop a circulation system which highlights environmental amenities and scenic areas. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential projects proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential scenic resource impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to protect scenic resources. Where applicable, existing zoning regulations require development setbacks that would ensure that new development would not encroach into roadway corridors. The RHASP and DCCSP both provide a unique Residential Allocation Reservation (RAR) which is approved either by the Community Development Director or the Planning Commission/City Council, as applicable. The RAR is the mechanism with an associated process and timeline that allocates units to a requested development. Development would be reviewed as consistent with City objectives during the RAR review process for Specific Plan areas that do not have existing development standards (DCCSP and RHASP). Generally, all development within the RHNA designated sites (outside of designated SP areas) would be reviewed to ensure compliance with applicable Federal, State and local policies and regulations established to protect scenic resources. Therefore, the project would result in no impact. b. Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? City of Tustin Grading Manual (1990) available at: https://www.tustinca.org/DocumentCenter/View/5029/Grading-Manual-June-1990 Page 126_ INITIAL STUDY City of Tustin No Impact. There are no officially designated State scenic highways within the City. The closest Eligible State Scenic Highway according to the California Department of Transportation (Caltrans) is a portion of SR-91 , located approximately six miles north of the city. Tustin is not visible from the highway. Therefore, the project would result in no impacts on a scenic resource within a state scenic highway. c. In nonurbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? No Impact. The city is generally a developed urbanized area. The City supports a variety of land uses as included in the City's General Plan Land Use Map (2018). Housing sites identified to support the 2021 RHNA are designated with the following land uses: • TLSP — Tustin Legacy Specific Plan • RHASP — Red Hill Avenue Specific Plan • DCCSP — Downtown Commercial Core Specific Plan • PCCB — Planned Community Commercial/Business Additionally, the City's Zoning Map (2018) includes the following zones underlying identified housing sites: • SP 1 — Tustin Legacy • SP 8 — East Tustin • SP 13 — Red Hill Avenue • SP 12 — Downtown Commercial Core o DA-2 — Development Area 2 o DA-3 — Development Area 3 o DA-4 — Development Area 4 o DA-6 — Development Area 6 • PC COM — Planned Community Commercial All zoning designations, with the exception of PC COM (Planned Community Commercial) and SP 8 (East Tustin), encourage mixed-use development and allow for residential uses. The RHASP and DCCSP both provide a unique RAR which is approved either by the Community Development Director or the Planning Commission/City Council, as applicable. The RAR is the mechanism with an associated process and timeline that allocates units to a requested development. The units are drawn from a residential allocation bank which assigns units by area and allows for transferability between areas. Sites within TLSP do not have a density prescribed to the entire specific plan area; however, there is a development cap placed on several of the planning areas. Development would be reviewed as consistent with City objectives during the RAR review process for Specific Plan areas that do not have existing development standards. The HEU would not directly result in changes to land use or zoning designations. The City's Zoning Code would be updated following adoption of the HEU to include a housing overlay over The Market Place and Enderle Center RHNA housing sites, which would allow for the development of residential in these areas. Proposed RHNA sites designated Page 127 INITIAL STUDY City of Tustin as PC COM (Planned Community Commercial) and SP 8 (East Tustin) are in existing developed areas. Potential impacts that could result from proposed Zoning Code changes would be evaluated under a separate CEQA review process. The HEU is a policy document, consisting of a housing program, and its adoption would not, in itself, produce environmental impacts. Development proposed as a result of the HEU would be required to obtain City approval on a project-by-project basis for any discretionary action, such as approval of a grading permit, and undergo a separate environmental process to assess potential air quality impacts. Therefore, the HEU would result in no impact. d. Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? No Impact. The HEU does not directly propose any development. However, implementation of the programs contained in the HEU would accommodate development required to meet the City's RHNA. Any new development proposed on the 20 sites, which include vacant and nonvacant areas, would introduce new sources of light from new building security lighting, streetlights, interior lights shining through building windows, and headlights from nighttime vehicular trips generated from new development. As discussed above, although some of the RHNA sites are vacant, they are surrounded by urban uses and major thoroughfares. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential project proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential light or glare impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable local policies and regulations and would be reviewed by the City to ensure that light and glare would not impact day or nighttime views. Therefore, the project would result in no impact. Page 128 INITIAL STUDY City of Tustin 4.6 AGRICULTURE AND FOREST RESOURCES In determining whether impacts to agricultural Potentially Less Than Less Than No Impact resources are significant environmental effects, lead Significant Significant Significant agencies may refer to the California Agricultural Impact with Impact Land Evaluation and Site Assessment Model (1997) Mitigation prepared by the California Dept. of Conservation as Incorporate an optional model to use in assessing impacts on d 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 the 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? b) Conflict with existing zoning for agricultural use, ❑ ❑ ❑ or a Williamson Act contract? c)Conflict with existing zoning for,or cause rezoning ❑ ❑ ❑ of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))? d) Result in the loss of forest land or conversion of ❑ ❑ ❑ forest land to non-forest use? e) Involve other changes in the existing environment ❑ ❑ ❑ which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use? a. Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? No Impact. The State of California Department of Conservation's (CDOC) Farmland Mapping and Monitoring Program is charged with producing maps for analyzing impacts -------------------------------------------------------------------------------------------------------------------------------------------------------------------- Page 129 INITIAL STUDY City of Tustin on the state's agricultural resources. California's agricultural lands are rated based on soil quality and irrigation status. For CEQA purposes, the following categories qualify as "agricultural land": Prime Farmland, Farmland of Statewide Importance, Unique Farmland, Farmland of Local Importance, and Grazing Land. The City does not currently include any commercial agricultural land uses. Existing zoning in the City of Tustin does not currently allow for commercial agricultural uses. The Residential Agricultural District (RA) allows for light agricultural uses incidental to single- family residential use. Additionally, land within the city is almost entirely designated as Urban and Built-Up Land and a portion of the TLSP area is designated as Other Land per the CDOC Farmland Mapping and Monitoring Program. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential project proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential farmland impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable local policies and regulations and would be reviewed by the City to ensure that farmland impacts would not occur. Therefore, the project would result in no impact. b. Conflict with existing zoning for agricultural use, or a Williamson Act contract? No Impact. The Williamson Act (California Land Conservation Act of 1965) restricts the use of agricultural and open space lands to farming and ranching by enabling local governments to contract with private landowners for indefinite terms in exchange for reduced property tax assessments. Tustin does not include any land that is currently under an active Williamson Act contract. Therefore, development of the project would not result in the cancellation of the contract, and impacts related to a Williamson Act contract would not occur and this topic will not be evaluated in the EIR. Additionally, the HEU does not include goals, programs, or policies that would directly conflict with existing zoning for agricultural use, or any potential future Williamson Act contracts. Therefore, the project would result in no impact. c. Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))? No Impact. "Forest land" is defined as "land that can support 10 percent native tree cover of any species, including hardwoods, under natural conditions, and that allows for management of one or more forest resources, including timber, aesthetics, fish and wildlife, biodiversity, water quality, recreation, and other public benefits."2 "Timberland" is defined as "land, other than land owned by the federal government and land designated 2 California Public Resources Code Section 12220(g). Page 130 INITIAL STUDY City of Tustin by the board as experimental forest land, which is available for, and capable of, growing a crop of trees of a commercial species used to produce lumber and other forest products, including Christmas trees."3 "Timberland Production Zone" (TPZ) is defined as "an area which has been zoned pursuant to Section 51112 or 51113 and is devoted to and used for growing and harvesting timber, or for growing and harvesting timber and compatible uses, as defined in subdivision (h)." The City of Tustin includes eucalyptus groves within the hillside areas of the ETSP area. Sites identified to accommodate RHNA housing development includes one site that falls within the ETSP area; however, the area where future housing is proposed is within a completely developed area, The Market Place, that does not include forest land or timberland land uses and would not directly or indirectly impact the existing eucalyptus groves. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential project proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential forest land impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable local policies and regulations and would be reviewed by the City to ensure that forest land impacts would not occur. Therefore, the project would result in no impact. d. Result in the loss of forest land or conversion of forest land to non-forest use? No Impact. As discussed above, the project does not propose development within an area containing forest land. Therefore, the proposed project would not result in the loss or conversion of forest land to non-forest use. e. Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non- agricultural use or conversion of forest land to non-forest use? No Impact. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential project proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential farmland or forest land impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable local policies and regulations and would be reviewed by the City to ensure that farmland or forest land impacts would not occur. Therefore, the project would result in no impact. , California Public Resources Code Section 4526. Page 131 INITIAL STUDY City of Tustin 4.7 AIR QUALITY Where available, the significance criteria Potentially Less Than Less Than No Impact established by the applicable air quality Significant Significant Significant management or air pollution control district may be Impact with Impact relied upon to make the following determinations. Mitigation Would the project: Incorporat ed a) Conflict with or obstruct implementation of the ❑ ❑ ❑ applicable air quality plan? b) 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? c) Expose sensitive receptors to substantial ❑ ❑ ❑ pollutant concentrations? d) Result in other emissions (such as those leading ❑ ❑ ❑ to odors)adversely affecting a substantial number of people? a. Conflict with or obstruct implementation of the applicable air quality plan? No Impact. The City of Tustin is located within the South Coast Air Basin (Basin). The Basin includes all of Orange County and portions of Los Angeles, Riverside, and San Bernardino Counties. Air quality within the Basin is under the jurisdiction of the South Coast Air Quality Management District (SCAQMD) and the California Air Resources Board (CARB). Standards for air quality within the Basin are documented in the SCAQMD's Air Quality Management Plan (AQMP). The main purpose of an AQMP is to describe air pollution control strategies to be taken by a city, county, or region classified as a nonattainment area in order to bring the area into compliance with federal and State air quality standards. SCAQMD's 2016 AQMP is based on regional growth forecasts for the Southern California Association of Governments region. Whether the project would exceed the growth assumptions in the AQMP is, in part, based on projections from local general plans. A project is consistent with the regional AQMP if it does not create new violations of clean air standards, exacerbate any existing violations, or delay a timely attainment of such standards. The HEU would not directly result in changes to land use or zoning designations. The City's Zoning Code would be updated following adoption of the HEU to include a housing overlay over The Market Place and Enderle Center RHNA housing sites, which would allow for the development of residential in these areas. Potential impacts that could result from proposed Zoning Code changes would be evaluated under a separate CEQA review process. The HEU is a policy document, consisting of a housing program, and its adoption would not, in itself, produce environmental impacts. Development proposed as a result of the HEU would be required to obtain City approval Page 132 INITIAL STUDY City of Tustin on a project-by-project basis for any discretionary action, such as approval of a grading permit, and undergo a separate environmental process to assess potential air quality impacts. Therefore, the HEU would result in no impact. b. 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 which exceed quantitative thresholds for ozone precursors)? No Impact. The Basin is designated under the California and National Ambient Air Quality Standards (NAAQS) as nonattainment for ozone (Os), coarse inhalable particulate matter (PMlo), fine inhalable particulate matter (PM2.5), nitrogen oxides (NOx) (California standard only), and lead (Los Angeles County only). As discussed above, the HEU is a policy document, consisting of a housing program, and its adoption would not, in itself, produce environmental impacts. However, implementation of the programs contained in the HEU would accommodate development required to meet the City's RHNA. The volume of air quality emissions generated by the new development would depend on the specifics of the units constructed and the types of construction that would occur. Development proposed as a result of the HEU would be required to obtain City approval on a project-by-project basis for any discretionary action, such as approval of a grading permit, and undergo a separate environmental process to assess potential air quality impacts. For specific development projects, issues related to potential long- and short-term emissions and impacts to air quality would be assessed at the time the projects are proposed. Measures that are required by underlying Specific Plan EIRs, as well as new measures specific to the development and reduce emissions would then be adopted, as necessary. Therefore, the HEU would result in no impact. c. Expose sensitive receptors to substantial pollutant concentrations? No Impact. An impact is potentially significant if emission levels exceed the State or Federal ambient air quality standards, thereby exposing sensitive receptors to substantial pollutant concentrations. Sensitive receptors are locations where uses or activities result in increased exposure of persons more sensitive to the unhealthful effects of emissions (such as children and the elderly). City supports residential, school, park and other land uses that include sensitive receptor populations. There is a school located within a RHNA site identified within the TLSP area and several schools surrounding the other RHNA housing sites. The HEU consists of housing policies and programs designed to facilitate provision of housing to meet State requirements. The HEU is a policy document that does not propose site specific development and adoption of the HEU would not result in physical effects to the environment. Future housing development implementing the HEU would be required to obtain City approval on a project-by-project basis and would still be subject to all existing City and State standards, including the development standards contained in the Zoning Code. Furthermore, discretionary actions, such as approval of a development permit or grading permit, would be subject to environmental review that would evaluate the specific development proposal and the related air quality emission to ensure that the project would not exceed SCAQMD thresholds. Measures that are required by underlying Specific Plan EIRs, as well as new measures specific to the development would be Page 133 INITIAL STUDY City of Tustin adopted to reduce emissions that could expose sensitive receptors to substantial pollutant concentrations as necessary. Therefore, the project would result in no impact. d. Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people? No Impact. The proposed project would not emit other emissions, such as those generating objectionable odors, that would affect a substantial number of people. The threshold for odor is identified by SCAQMD Rule 402, Nuisance, which states: A person shall not discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property. The provisions of this rule shall not apply to odors emanating from agricultural operations necessary for the growing of crops or the raising of fowl or animals. The HEU provides guidance for the future development of residential uses and does not involve land uses that are typically associated with the creation of objectionable odors (such as rendering plants, landfills, treatment plants, etc.). The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential project proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential emission impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable local policies and regulations and would be reviewed by the City to ensure that emission impacts would not occur. Therefore, the project would result in no impact. Page 134 INITIAL STUDY City of Tustin 4.8 BIOLOGICAL RESOURCES Would the project: Potentially Less Than Less Than No Impact Significant Significant Significant I mpact with I mpact Mitigation Incorporat ed 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 US Fish and Wildlife Service? c) Have a substantial adverse effect on state or ❑ ❑ ❑ federally protected wetlands (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? a —f. No Impact. The City's Conservation/Open Space/Recreation Element of the General Plan Identifies areas as "important natural resources" within Figure COSR-2. Since the natural resources areas have been designated, new development has occurred throughout the city. Areas identified as important natural resources are located at the northern and southern ends of the city. Natural resources to the north include open space areas, Lower Peters Canyon Retarding Basin, Eucalyptus Windrow, and Redwood Grove. This area also includes Coastal Sage Scrub habitat. The natural habitats to the north support sensitive or Page 135 INITIAL STUDY City of Tustin endangered species such as the California Black-tailed Gnatcatcher, the San Diego Cactus Wren, and the San Diego Coast Horned Lizard. Within southern Tustin, agricultural land is identified as an important natural resource based on the CDOC's previous designation of the land as important farmland. However, the area has since been adopted into a specific plan (TLSP) and is no longer utilized for agricultural purposes. Additionally, Peters Canyon is a predominant riparian feature within the city. Several mitigation measures were adopted for Peters Canyon as part of the ETSP. These mitigation measures continue to reflect City policy. For several years, the Lower Peters Canyon Retarding Basin contained a small riparian habitat.4 This habitat has severely deteriorated in recent years. The City works with the County of Orange, which recently constructed a replacement dam, to preserve the riparian area and implement active measures to increase water supply to restore the habitat area. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential project proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. One RHNA site is located in the ETSP; however, the site is currently developed and is outside of areas containing sensitive biological habitat. Potential biological resource impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to protect biological species. Therefore, the project would result in no impact. 4 City of Tustin General Plan Conservation/Open Space/Recreation Element, available at https://www.tustinca.org/DocumentCenter/View/713/City-of-Tustin-General-Plan- PDF?bidld= mPage 36 _ INITIAL STUDY City of Tustin 4.9 CULTURAL RESOURCES Would the project: Potentially Less Than Less Than No Impact Significant Significant Significant I mpact with I mpact Mitigation Incorporat ed a) Cause a substantial adverse change in the ❑ ❑ ❑ significance of a historical resource pursuant to §15064.5? b) Cause a substantial adverse change in the ❑ ❑ ❑ significance of an archaeological resource pursuant to §15064.5? c) Disturb any human remains, including those ❑ ❑ ❑ interred outside of formal cemeteries? a — c No Impact. The City of Tustin contains several designated historic resources and resources of historic age that could be eligible for designation. Tustin's historic preservation program was established by Tustin City Code Section 9252 "Cultural Resources District," and is supported by Residential Design Guidelines and Commercial Design Guidelines established by the City. It is also supported by the Secretary of Interior's Standards for the Treatment of Historical Properties.5 Together, these documents establish criteria and procedures for the designation, preservation and maintenance of cultural resources throughout the City of Tustin. The City's Conservation/Open Space/Recreation Element of the General Plan Figure COSR-2 identifies areas sensitive to cultural resources. The City has very detailed standards and requirements for grading that are designed to protect sensitive topographic, soil, paleontologic, and archaeologic resources. The Tustin Grading Manual prescribes appropriate measures to protect the earth by controlling erosion, sedimentation, and storm damage. Proper grading, soil management, and open space standards will work to preserve these areas sensitive to cultural resources. Sensitive locations are identified, and their preservation is a high priority for the City during any project review. As new resources are identified in the City, they will be documented as features or resources the City desires to preserve. As per the City's General Plan, a records search will be performed prior to any development. If no record of resources exists, a field survey will be performed. Any proposed project which is located within a 5 Tustin Residential Design Guidelines and Commercial Design Guidelines available at htt[)s://www.tustinca.org/l 039/Resources Page 137 INITIAL STUDY City of Tustin sensitive area as defined by Figure COSR-2, or is identified through a subsequent study, will require a licensed paleontologist or archaeologist to be present on the site to observe grading or other earthwork per the City's General Plan. California Health and Safety Code Section 7050.5, CEQA Section 15064.5, and Public Resources Code Section 5097.98 mandate a process to be followed in the event of an accidental discovery of any human remains in a location other than a dedicated cemetery. Specifically, California Health and Safety Code Section 7050.5 requires that if human remains are discovered within the project site, disturbance of the site shall remain halted until the coroner has conducted an investigation into the circumstances, manner, and cause of death, and made recommendations concerning the treatment and disposition of the human remains to the person responsible for the excavation, or to his or her authorized representative, in the manner provided in Section 5097.98 of the Public Resources Code. If the coroner determines that the remains are not subject to his or her authority and if the coroner has reason to believe the human remains to be those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential projects proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Measures that are required by underlying Specific Plan EIRs will be implemented. Potential cultural resource impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to protect cultural resources. Therefore, the project would result in no impact. Page 138 INITIAL STUDY City of Tustin 4.10 ENERGY Would the project: Potentially Less Than Less Than No Impact Significant Significant Significant I mpact with I mpact Mitigation Incorporat ed a) Result in potentially significant environmental ❑ ❑ ❑ impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? b) Conflict with or obstruct a state or local plan for ❑ ❑ ❑ renewable energy or energy efficiency? a and b. No Impact. No Impact. Implementation of the programs contained in the HEU would accommodate development required to meet the City's RHNA. The new residential units developed through the HEU would generate demand for electricity, natural gas, as well as gasoline for motor vehicle trips. Operational use of energy includes the heating, cooling, and lighting of the residences, water heating, operation of electrical systems and plug-in appliances, and outdoor lighting, and the transport of electricity, natural gas, and water to the residences where they would be consumed. This use of energy is typical for residential development, no additional energy infrastructure would be required to be built to support the HEU, and no operational activities would occur that would result in extraordinary energy consumption. Construction of future development would be required to comply with CARB's regulations established in 2014 to restrict the idling of heavy-duty diesel motor vehicles and govern the accelerated turnover of oldest and dirtiest equipment to newer, cleaner models and prevent fleets from adding older, dirtier equipment. All residential projects would be required to meet the current Title 24 energy efficiency standards. The City's administration of the Title 24 requirements includes review of design components and energy conservation measures that occurs during the permitting process, which ensures that all requirements are met. Typical Title 24 measures include insulation; use of energy- efficient heating, ventilation, and air conditioning equipment (HVAC); solar-reflective roofing materials; solar panels. energy-efficient indoor and outdoor lighting systems; reclamation of heat rejection from refrigeration equipment to generate hot water; and incorporation of skylights, etc. In addition to requiring compliance with Title 24, the City maintains several policies and requirements for development under Goal 6, Environmental Sensitivity, that promote energy-efficient design in new development and the use of solar energy. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential projects proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed Page 139 INITIAL STUDY City of Tustin and zoned for mixed use development. Potential energy resource impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Measures that are required by underlying Specific Plan EIRs will be implemented. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to promote energy efficiency and the use of renewable energy. Therefore, the project would result in no impact. Page 140 INITIAL STUDY City of Tustin 4.11 GEOLOGY AND SOILS Would the project: Potentially Less Than Less Than No Impact Significant Significant Significant Impact with Impact Mitigation Incorporat ed a) Directly or indirectly cause 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? ❑ ❑ ❑ b) Result in substantial soil erosion or the loss of ❑ ❑ ❑ topsoil? 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 offsite landslide, lateral spreading, subsidence, liquefaction or collapse? d) Be located on expansive soil, as defined in Table ❑ ❑ ❑ 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? 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? f) Directly or indirectly destroy a unique ❑ ❑ ❑ paleontological resource or site or unique geologic feature? -------------------------------------------------------------------------------------------------------------------------------------------------------------------- Page 141 INITIAL STUDY City of Tustin a. i — iv and c. No Impact. The City of Tustin General Plan Conservation/Open Space/Recreation Element identifies several geologic hazards that could impact the community. Figure COSR-1 of the Conservation/Open Space/Recreation Element depicts the areas in the community which require special planning considerations to avoid potential hazards. Three geologic hazards identified are seismic hazards, soil liquefaction, and landslides. As none of the geologic fault systems within Tustin are known to be active, they are not identified on Figure COSR-1; however, the EI Modena Fault is an inactive fault within the city. The city is not located within an Alquist-Priolo Earthquake Fault Zone. Much of the southern portion of Tustin, surrounding the TLSP area, is identified as high liquefaction potential. Areas to the southeast along Peters Canyon Wash/Channel are identified as being in a 100-year flood plain. The western portion of Tustin, surrounding the DCCSP area, is identified as 500-year flood plain and high liquefaction potential to the north. Several of the proposed RHNA housing sites overlap identified hazard areas. Structures built in the City are required to be built in compliance with the California Building Code (CBC) (California Code of Regulations, Title 24, Part 2) that provides provisions for earthquake safety based on factors including building occupancy type, the types of soils onsite, and the probable strength of ground motion. Compliance with the CBC would require the incorporation of 1) seismic safety features to minimize the potential for significant effects as a result of earthquakes; 2) proper building footings and foundations; and 3) construction of the building structure so that it would withstand the effects of strong ground shaking. All of the proposed RHNA housing sites are located within a specific plan area or part of a planned development area that has undergone previous environmental review. Each of the specific plan areas include policies and measures to be implemented by future development that would reduce potential geologic hazards to less than significant levels. Additionally, the General Plan includes several requirements for future development that would further reduce the risk of loss, injury, or death, such as • Policy 8.5 of the Conservation/Open Space/Recreation Element: Review applications for building and grading permits, and applications for subdivision for adjacency to, threats from, and impacts on geological hazards arising from seismic events, landslides, or other geologic hazards such as expansive soils and subsidence areas, and • Policy 8.8 of the Conservation/Open Space/Recreation Element: Require geotechnical studies for developments that are proposed for steep slopes and where geological instability may be suspected. Where a precise location of the EI Modena fault is determined, appropriate building setbacks shall be established per State law. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential projects proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. The HEU would not directly result in changes to land use or zoning designations that would place housing within an area of geologic hazard. The City's Zoning Code would be updated following adoption of the HEU to Page 142 INITIAL STUDY City of Tustin include a housing overlay over The Market Place and Enderle Center RHNA housing sites, which would allow for the development of residential in these areas. Potential impacts that could result from proposed Zoning Code changes would be evaluated under a separate CEQA review process. Potential risk of loss, injury, or death impacts due to geologic hazard would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to prevent or reduce impacts due to geologic hazard and measures that are required by underlying Specific Plan EIRs will be implemented. Therefore, the project would result in no impact. b. Result in soil erosion or the loss of topsoil? No Impact. Although the majority of the proposed RHNA sites are currently developed, future development would result in ground disturbing activity associated with construction activities and there would be an increased potential for soil erosion of excavated and loosened soils. All proposed development construction would be required to comply with the California Regional Water Quality Control Board (RWQCB) Order No. R8-2010-0033, National Pollutant Discharge Elimination System (NPDES) Permit No. CAS618033— Construction General Permit requirements. Requirements include installation of Best Management Practices (BMPs), which establishes minimum stormwater management requirements and controls. To reduce the potential for soil erosion and the loss of topsoil, a Stormwater Pollution Prevention Plan (SWPPP) is required by the RWQCB regulations to be developed by a QSD (Qualified SWPPP Developer). The SWPPP is required to address site-specific conditions related to specific grading and construction activities. The SWPPP would identify potential sources of erosion and sedimentation to prevent loss of topsoil during construction, and to identify erosion control BMPs to reduce or eliminate the erosion and loss of topsoil, such as use of silt fencing, fiber rolls, or gravel bags; stabilized construction entrances/exits; hydroseeding, and similar measures. In addition to RWQCB requirements, proposed development would need to comply with the City of Tustin Grading Manual procedures. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential projects proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential erosion impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Measures that are required by underlying Specific Plan EIRs will be implemented. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to reduce soil erosion and the loss of topsoil. Therefore, the project would result in no impact. d. Be located on expansive soil, as defined in in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? No Impact. Expansive soils contain certain types of clay minerals that shrink or swell as the moisture content changes; the shrinking or swelling can shift, crack, or break Page 143 INITIAL STUDY City of Tustin structures built on such soils. Arid or semiarid areas with seasonal changes of soil moisture experience, such as southern California, have a higher potential of expansive soils than areas with higher rainfall and more constant soil moisture. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential projects proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. The HEU would not directly result in changes to land use or zoning designations that would place housing within an area of geologic hazard. The City's Zoning Code would be updated following adoption of the HEU to include a housing overlay over The Market Place and Enderle Center RHNA housing sites, which would allow for the development of residential in these areas. Potential impacts that could result from proposed Zoning Code changes would be evaluated under a separate CEQA review process. Potential risks to life or property due to expansive soil would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to prevent or reduce impacts due to expansive soil, including Policy 8.5 of the Conservation/Open Space/Recreation Element mentioned above, which requires City review of threats from expansive soils during the development review process. Therefore, the project would result in no impact. 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? No Impact. Proposed RHNA sites would be served by the City sewer utilities and would not include the use of septic tanks or alternative wastewater disposal systems. Therefore, the project would result in no impact. f. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? No Impact. The City's Conservation/Open Space/Recreation Element of the General Plan Figure COSR-2 identifies areas sensitive to cultural resources. None of the proposed RHNA sites are located in an area identified by the General Plan a sensitive to paleontological resources. The City has very detailed standards and requirements for grading that are designed to protect sensitive topographic, soil, paleontologic, and archaeologic resources. The Tustin Grading Manual prescribes appropriate measures to protect the earth by controlling erosion, sedimentation, and storm damage. Proper grading, soil management, and open space standards will work to preserve potential paleontological resources. Sensitive locations are identified, and their preservation is a high priority for the City during any project review. As new resources are identified in the City, they will be documented as features or resources the City desires to preserve. Per the City's General Plan, a records search will be performed prior to any development. If no record of resources exists, a field survey will be performed. Any proposed project which is located within a sensitive area, as defined by Figure COSR-2, or is identified through a subsequent study, will require a licensed paleontologist or archaeologist to be present on the site to observe grading or other earthwork. Page 144 INITIAL STUDY City of Tustin The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential project proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential paleontological resource impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to protect paleontological resources. Therefore, the project would result in no impact. Page 145 INITIAL STUDY City of Tustin 4.12 GREENHOUSE GAS EMISSIONS Would the project: Potentially Less Than Less Than No Impact Significant Significant Significant Impact with Impact Mitigation Incorporat ed 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? a. and b. No Impact. Implementation of the programs contained in the HEU would accommodate development required to meet the City's RHNA allocation of 6,782 housing units within the 2021 to 2029 planning period. This additional housing would result in direct and indirect GHG emissions, the volume of which would depend on the specifics of the units constructed. Direct emissions include consumption of natural gas, heating and cooling of buildings, landscaping activities and other equipment used directly by land uses. Indirect emissions include the consumption of fossil fuels for vehicle trips, electricity generation, water usage, and solid waste disposal. Future development would be required to comply with Clean Energy and Pollution Reduction Act of 2015 (SB 350), AB 1007 (Pavley 2007), Title 24 Energy Efficiency Standards, and the California Green Building Standards, and the City would enforce local energy policies to encourage energy-efficient design through the development permitting process as specific above under Section 4.10, Energy. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential project proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential GHG impacts would be evaluated on a project-by-project basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to minimize GHG impacts. Therefore, the project would result in no impact. Page 146 INITIAL STUDY City of Tustin 4.13 HAZARDS AND HAZARDOUS MATERIALS Would the project: Potentially Less Than Less Than No Impact Significant Significant Significant Impact with Impact Mitigation Incorporat ed 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? 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 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 or excessive noise for people residing or working in the project area? Page 147 INITIAL STUDY City of Tustin f) Impair implementation of or ❑ ❑ ❑ physically interfere with an adopted emergency response plan or emergency evacuation plan? g) Expose people or structures, ❑ ❑ ❑ either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires? a — c. No Impact. A hazardous material is defined as any material that, due to its quantity, concentration, or physical or chemical characteristics, poses a significant present or potential hazard to human health and safety or to the environment if released into the workplace or environment. Hazardous materials include, but are not limited to, hazardous substances, hazardous wastes, and any material that a business or the local implementing agency has a reasonable basis for believing would be injurious to the health and safety of persons or harmful to the environment if released into the workplace or the environment. Hazardous materials are transported through the city via highway, rail, and pipeline. Public facilities and numerous businesses located in the city store and use varying types and quantities of hazardous materials, as disclosed in the City's Emergency Operations Plan.6 The haulers and users of hazardous materials are listed with the Orange County Fire Authority and are regulated and monitored under the auspices of the County. There are no production facilities for the manufacture of hazardous materials in the City. The planning basis for response to a hazardous material incident in Tustin is the Orange County Hazardous Materials Area Plan. The plan is executed within the contract services of the Orange County Fire Authority under the Orange County-City Hazardous Material Emergency Response Authority, a joint powers agency. Adoption of the HEU would not result in a significant hazard to the public or the environment through routine transport, use, or disposal of hazardous material, nor 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. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential projects proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. The HEU would not directly result in changes to land use or zoning designations that would place housing within an area of potential 6 City of Tustin Emergency Operations Plan (2019) available at: https://www.tustinca.org/DocumentCenterNiew/570/Emergency-Operations-Plan-PDF Page 148_ INITIAL STUDY City of Tustin exposure to hazardous materials. The City's Zoning Code would be updated following adoption of the HEU to include a housing overlay over The Market Place and Enderle Center RHNA housing sites, which would allow for the development of residential in these areas. Potential impacts that could result from proposed Zoning Code changes would be evaluated under a separate CEQA review process. Potential risks due to hazardous materials would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to prevent or reduce impacts due to hazardous materials. Therefore, the project would result in no impact. 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? No Impact. There are no sites on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 (Cortese List) that are currently identified within Tustin. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential project proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential hazardous impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to minimize hazardous materials impacts. Therefore, the project would result in no impact. e. For a project 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 or excessive noise for people residing or working in the project area? No Impact. The Airport Land Use Commission (ALUC) for Orange County has responsibility under state law for formulating a comprehensive airport land use plan (ALUP) for the anticipated growth of each public use airport and its surrounding vicinity. General Plans for cities affected by an ALUP must be consistent with that plan. The purpose of the ALUP is to safeguard the general welfare of the inhabitants within the vicinity of airports and to ensure the continued operation of the airports. The ALUC for Orange County has adopted the Airport Environs Land Use Plan (AELUP)governing John Wayne Airport, AFRC Los Alamitos Fullerton Airport, and Heliports. Proposed RHNA sites identified within the TLSP area are approximately two miles northeast of John Wayne Airport and within the AELUP planning area. The HEU will be submitted to ALUC for a consistency determination, per ALUC requirement, during the review process since the proposed RHNA sites fall within the John Wayne ALUP planning area. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential project proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential impacts due to proximity of John Wayne Airport would be evaluated on a site-by-site basis and mitigation measures, if necessary, Page 149 INITIAL STUDY City of Tustin would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to minimize safety hazard or excessive noise for people residing or working in an airport land use plan area. Therefore, the project would result in no impact. f. Impair implementation of an adopted emergency response plan or emergency evacuation plan? No Impact. As previously mentioned, the City adopted an Emergency Operations Plan. The plan outlines operational duties and procedures for various positions. Additionally, the City's Safety Element, as contained within the City of Tustin General Plan, includes policies and procedures to be administered in the event of a disaster.' The Safety Plan seeks interdepartmental and inter-jurisdictional coordination and collaboration to be prepared for, respond to and recover from every day and disaster emergencies. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential projects proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential impacts due to conflict with an adopted emergency response plan, such as emergency response times, would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to minimize impacts to emergency response. Therefore, the project would result in no impact. g. Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires? No Impact. According to the CalFire Fire Hazard Severity Zone Map, the City of Tustin contains very high fire severity zones in the northeast portion of the City$. The 20 proposed RHNA sites are not located within a fire hazard zone. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential project proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential impacts due to wildfire would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to minimize impacts due to wildfire. Therefore, the project would result in no impact. General Plan Safety Element (2017) available at: https://www.tustinca.org/DocumentCenter/View/713/City-of-Tustin-General-Plan- PDF?bidld= 8 Cal Fire Hazard Severity Zone Viewer https://egis.fire.ca.gov/FHSZ/ Page 150 INITIAL STUDY City of Tustin 4.14 HYDROLOGY AND WATER QUALITY Would the project: Potentially Less Than Less Than No Impact Significant Significant Significant Impact with Impact Mitigation Incorporate d a) Violate any water quality ❑ ❑ ❑ standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? b) Substantially decrease ❑ ❑ ❑ groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin? c) Substantially alter the ❑ ❑ ❑ existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would: i) result in a substantial ❑ ❑ ❑ erosion or siltation on- or off- site; ii) substantially increase ❑ ❑ ❑ the rate or amount of surface runoff in a manner which would result in flooding on- or offsite; Page 151 INITIAL STUDY City of Tustin iii) 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; or iv) impede or redirect flood ❑ ❑ ❑ flows? d) In flood hazard, tsunami, or ❑ ❑ ❑ seiche zones, risk release of pollutants due to project inundation? e) Conflict with or obstruct ❑ ❑ ❑ implementation of a water quality control plan or sustainable groundwater management plan? a. and c. (i — iv). No Impact The HEU is a policy document that identifies strategies and programs to meet the existing and future housing demands within the city. Future development, that has not been proposed at this time or has been/is currently being evaluated through a separate environmental review process, would add new uses and increase housing density within the City. The addition of new housing units could increase pollutant loads being discharged to local surface or ground water resources, degrading overall water quality of the resources. All existing and future development would be required to comply with RWQCB Order No. R8-2010-0033, National Pollutant Discharge Elimination System (NPDES) Permit No. CAS618033 — Construction General Permit requirements. Requirements include installation of BMPs, which establishes minimum stormwater management requirements and controls. To reduce the potential for soil erosion and the loss of topsoil, a SWPPP is required by the RWQCB regulations to be developed by a QSD. The SWPPP is required to address site-specific conditions related to specific grading and construction activities. The SWPPP would identify potential sources of erosion and sedimentation to prevent loss of topsoil during construction, and to identify erosion control BMPs to reduce or eliminate the erosion and loss of topsoil, such as use of silt fencing, fiber rolls, or gravel bags; stabilized construction entrances/exits; hydroseeding, and similar measures. In addition to RWQCB requirements, proposed development would need to comply with the City of Tustin Grading Manual procedures. Page 152 INITIAL STUDY City of Tustin New development would also be required to be undertaken in accordance with Orange County Drainage Area Management Plan (DAMP), per Tustin City Code, Section 4902, Control of Urban Runoff.9 The County DAMP is the Permittees' primary policy, planning, and implementation document for municipal NPDES Stormwater Permit compliance, which the City is permitted under. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential project proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential impacts due to water quality would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to minimize impacts due to water quality. Therefore, the project would result in no impact. b. and e. No Impact. Tustin Water Services utilizes groundwater and imported water to supply domestic water to more than 14,100 service connections through approximately 172 miles of water mains.10 The groundwater is pumped from the City's 14 groundwater wells. Imported water from the Colorado River is provided by the Metropolitan Water District of Southern California. Little to no water is provided by way of the State Water Project. Tustin Water Services customers receive a blend of surface and groundwater from these sources. In 2013, Tustin Water Services supplied over 3.98 billion gallons of water to its customers. The City has multiple storage reservoirs located throughout the service area that allows for the storage of water during low demand periods for use during peak demand periods by Tustin Water Services customers. Implementation of the programs contained in the HEU would accommodate development required to meet the City's RHNA allocation of 6,782 housing units within the 2021 to 2029 planning period. The development of new housing would place additional demand on existing water resources. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential project proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential impacts due to groundwater supply and management would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies 9 Orange County, 2003 Drainage Area Management Plan (DAMP), available at: https://cros.ocgov.com/gov/pw/watersheds/documents/damp/mapplan.asp 10 City of Tustin, Water Supply & Quality, available at https://www.tustinca.org/227/Water- Supply-Quality Page 153 INITIAL STUDY City of Tustin and regulations established to minimize impacts due to groundwater supply and quality. Therefore, the project would result in no impact. b. In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation? No Impact. The City of Tustin General Plan Conservation/Open Space/Recreation Element identifies several geologic hazards that could impact the community. Figure COSR-1 of the Conservation/Open Space/Recreation Element depicts the areas in the community which require special planning considerations to avoid potential hazards. Areas in southeast Tustin along Peters Canyon Wash/Channel are identified as being in a 100-year flood plain. The western portion of Tustin, surrounding the DCCSP area, is identified as 500-year flood plain. Several of the proposed RHNA housing sites overlap identified hazard areas. Current Federal Emergency Management Agency (FEMA) Federal Insurance Rate Maps (FIRM) maps that cover the city (panel 06059C0l64J and 06059CO277J) identify majority of the city as within Zone X, areas of 0.2 percent annual chance flood; areas of 1 percent chance flood with average depths of less than 1 foot or with drainage areas less than 1 square mile, and areas protected by levees from 1 percent annual chance flood." The city is eight miles inland of the Pacific Ocean and is not subject to impacts due to tsunami. Additionally, the city and surrounding areas do not contain nearby bodies that would subject future development to risk of seiche. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential project proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential impacts due to inundation would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to minimize impacts due to project inundation. Therefore, the project would result in no impact. 11 Federal Emergency Management Agency (2009), Federal Insurance Rate Maps (Panels 06059C0164J and 06059CO277J ), available at: https://msc.fema.gov/portal/home Page 154 INITIAL STUDY City of Tustin 4.15 LAND USE AND PLANNING Would the project: Potentiall Less Than Less No y Significan Than Impact Significan t with Signific t Impact Mitigation ant Incorporat Impact ed a) Physically divide an established ❑ ❑ ❑ community? b) Cause a significant environmental ❑ ❑ ❑ impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? a — b. No Impact. The Land Use Element of the General Plan contains a Land Use Plan which indicates the types and intensities of land use permitted throughout the City. The Land Use Element also establishes goals and policies that provide the framework for land use planning and decision-making in the City. The physical division of an established community could occur if a major road (expressway or freeway, for example) were built through an existing community or neighborhood, or if a major development was built which was inconsistent with the land uses in the community such that it divided the community. The environmental effects caused by such a facility or land use could include lack of, or disruption of, access to services, schools, or shopping areas. The HEU would not directly result in changes to land use or zoning designations. To accommodate RHNA, the City has identified 20 sites that could be developed with residential housing upon future project approvals. Development proposed as a result of the HEU would be required to obtain City approval on a project-by-project basis for any discretionary action. In addition, the City Zoning Code and map would be amended to accommodate two of the sites proposed, Enderle Center and The Market Place, to provide a housing overlay for the provision of residential development. Zoning would be updated following adoption of the HEU. Potential impacts that could result from proposed Zoning Code changes would be evaluated under a separate CEQA review process. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential project proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential land use impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Measures that are required by underlying Page 155 INITIAL STUDY City of Tustin Specific Plan EIRs will be implemented. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to reduce impacts to land use. Therefore, the project would result in no impact. Page 156 INITIAL STUDY City of Tustin 4.16 MINERAL RESOURCES Would the project: Potentially Less Than Less Than No Impact Significant Significant Significant Impact with Impact Mitigation Incorporat ed a) Result in the loss of availability of ❑ ❑ ❑ a known 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-important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? a — b. No Impact. The Conservation/Open Space/Recreation Element identifies one mineral resource within the Tustin Planning Area known as Mercury-Barite in Red Hill. However, this resource is not utilized. In addition, the 20 sites are not located within the mineral resource area and future development would not affect the availability of Mercury-Barite. Future development within the RHASP area could be located along Red Hill.. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential project proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential mineral resource impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to reduce impacts to mineral resources. Therefore, the project would result in no impact Page 157 INITIAL STUDY City of Tustin 4.17 NOISE Would the project: Potentially Less Than Less Than No Impact Significant Significant Significant Impact with Impact Mitigation Incorporat ed a) Generation of a substantial ❑ ❑ ❑ temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? b) Generation of excessive ground ❑ ❑ ❑ borne vibration or ground borne noise levels? c) For a project located within the ❑ ❑ ❑ vicinity of a private airstrip or 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? a — c. No Impact. The City's Noise Ordinance (Ord No. 828) contained in Chapter 6 of the Tustin City Code establishes exterior and interior noise standards that apply to all properties within specified zones. The Noise Element of the General Plan outlines goals and policies to reduce excessive noise in the City resulting from mobile sources and stationary sources. The construction and operation of future development under the HEU would increase noise levels in the City. Construction associated with future development would result in the potential for temporary or periodic increases in noise levels and/or ground-borne noise and vibration on or adjacent to the 20 RHNA sites. Future residential development would also have the potential to increase noise levels long-term through increased vehicular traffic or new stationary sources of noise. Future development would adhere to the City's Noise Ordinance and General Plan Noise Element. In addition, future Page 158 INITIAL STUDY City of Tustin development within the 20 RHNA sites would undergo noise assessments that would be analyzed on a project-by-project basis. As discussed in Section 4.13, ALUC for Orange County has responsibility under state law for formulating a comprehensive ALUP for the anticipated growth of each public use airport and its surrounding vicinity. General Plans for cities affected by an ALUP must be consistent with that plan. The purpose of the ALUP is to safeguard the general welfare of the inhabitants within the vicinity of airports and to ensure the continued operation of the airports. The ALUC for Orange County has adopted the AELUP governing John Wayne Airport, AFRC Los Alamitos Fullerton Airport, and Heliports. Proposed RHNA sites identified within the TLSP area are within the AELUP planning area and approximately two miles northeast of John Wayne Airport. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential project proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential noise impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Measures that are required by underlying Specific Plan EIRs will be implemented. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to reduce impacts to noise levels. Therefore, the project would result in no impact. Page 159 INITIAL STUDY City of Tustin 4.18 POPULATION AND HOUSING Would the project: Potentially Less Than Less Than No Impact Significant Significant Significant Impact with Impact Mitigation Incorporat ed a) Induce substantial unplanned ❑ ❑ ❑ 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)? b) Displace substantial numbers of ❑ ❑ ❑ existing people or housing, necessitating the construction of replacement housing elsewhere? a — b. No Impact. RHNA is mandated by State Housing Law as part of the periodic process of updating local housing elements of the General Plan. RHNA quantifies the need for housing within each jurisdiction during specified planning periods. SCAG is in the process of developing the 6th cycle RHNA allocation plan which will cover the planning period October 2021 through October 2029. RHNA does not necessarily encourage or promote growth, but rather allows communities to anticipate growth, so that collectively the region and subregion can grow in ways that enhance quality of life, improve access to jobs, promotes transportation mobility, and addresses social equity and fair share housing needs. Future development that occurs upon implementation of the HEU would increase the population in the City. However, the 20 designated sites are on underutilized parcels in an urban area that would not necessitate the need for extension of roads or other infrastructure. In addition, future development would be analyzed on a project-by-project basis. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential project proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential recreation impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to reduce impacts to public services. Therefore, the project would result in no impact. Page 160 INITIAL STUDY City of Tustin 4.19 PUBLIC SERVICES a) Would the project result in Potentially Less Than Less Than No Impact substantial adverse physical Significant Significant Significant impacts associated with the I m pact with I m pact provision of new or physically Mitigation altered governmental facilities, need Incorporat for new or physically altered ed 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: i. Fire protection? ❑ ❑ ❑ ii. Police protection? ❑ ❑ ❑ iii. Schools? ❑ ❑ ❑ FI iv. Parks? ❑ ❑ ❑ v. Other public facilities? ❑ ❑ ❑ a (i-v). No Impact. The Tustin HEU provides a plan to accommodate the City's fair share of affordable housing and identify and improve existing affordable housing. To accommodate the RHNA allocation, the HEU proposes 20 sites to accommodate RHNA. The City Zoning Code and map would be amended to accommodate two of the sites proposed, Enderle Center and The Market Place, to provide a housing overlay for the provision of residential development. Future development within the 20 designated RHNA sites would add new housing in the City which would increase the demand on the City's public services including fire and police protection, schools, parks, and libraries. However, potential impacts to public services would be assessed on a project-by-project basis at the time development was proposed and all development fees required by Section 9331 of the Tustin City Code would ensure that public services would increase at the same rate as development. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential projects proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential public service impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Measures that are required by underlying Page 161 INITIAL STUDY City of Tustin Specific Plan EIRs will be implemented. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to reduce impacts to public services. Therefore, the project would result in no impact. Page 162 INITIAL STUDY City of Tustin 4.20 RECREATION Would the project: Potentially Less Than Less Than No Impact Significant Significant Significant Impact with Impact Mitigation Incorporat ed 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? 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? a — b. No Impact. In 2011 , the City had 113 acres of existing local and community parks, but needed an additional 114 acres to serve its population based on a standard of three acres per 1 ,000 persons based on January 2011 City population of 75,781 . 12 As discussed previously, the project would not directly result in development; however, implementation of the housing programs could facilitate additional housing development in fulfillment of the City's RHNA allocation. Typically, residential development increases the need for new parks and increases the use of existing citywide park facilities. Potential impacts on the availability of open space land and park and recreational facilities and recreation impacts would be evaluated through a project-by-project basis and developers would be required to pay applicable development fees required by Section 9331 of the Tustin City Code, which would ensure a balanced system of public and private parks, recreation facilities, and open spaces that serves the needs of existing and future residents. 12 City of Tustin General Plan Conservation/Open Space/Recreation Element, available at https://www.tustinca.org/Docum entCenter/View/713/City-of-Tustin-General-Plan- PDF?bidld= ----------------------------------------------------------------------------------------------------------------- Page 163 INITIAL STUDY City of Tustin The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential projects proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential recreation impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations. Therefore, the project would result in no impact. Page 164 INITIAL STUDY City of Tustin 4.21 TRANSPORTATION Would the project: Potentially Less Than Less Than No Impact Significant Significant Significant Impact with Impact Mitigation Incorporat ed a) Conflict with a program, plan, ❑ ❑ ❑ ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities? b) Conflict or be inconsistent with ❑ ❑ ❑ CEQA Guidelines § 15064.3, subdivision (b)? c) Substantially increase hazards ❑ ❑ ❑ due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? d) Result in inadequate emergency ❑ ❑ ❑ access? a — d. No Impact. The Circulation Element of the City's General Plan identifies goals and policies intended to improve overall circulation in the City and address circulation issues. New residential development would be expected to result in vehicular trips that would increase use of streets for transportation purposes. Future development within the RHNA sites would occur on underutilized properties within an urbanized area and would be consistent with the City's Circulation Element. Potential traffic impacts related to increased transportation associated with the HEU would be analyzed through a project-by-project basis. The City's Traffic Engineer would require project-specific transportation analysis, if required. In addition, the Orange County Fire Authority would ensure adequate emergency access is provided during plan checks for future development within the 20 sites. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential project proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. The City's Zoning Code would be updated following adoption of the HEU to include a housing overlay over The Market Place and Page 165 INITIAL STUDY City of Tustin Enderle Center RHNA housing sites, which would allow for the development of residential in these areas. Potential impacts that could result from proposed Zoning Code changes would be evaluated under a separate CEQA review process. The HEU would not directly result in changes to land use or zoning designations that would generate additional demand on the regional and local circulation systems; conflict with a program, plan, ordinance, or policy addressing the circulation system; conflict with CEQA Guidelines section 15064.3; increase hazards; or result in inadequate emergency access. Potential transportation impacts under future development within proposed RHNA sites would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Measures that are required by underlying Specific Plan EIRs will be implemented. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to reduce transportation impacts. Therefore, the project would result in no impact. Page 166 INITIAL STUDY City of Tustin 4.22 TRIBAL CULTURAL RESOURCES a) Would the project cause a substantial Potentiall Less Than Less No adverse change in the significance of a y Significant Than Impact tribal cultural resource, defined in Public Significa with Signific Resources Code Section 21074 as either a nt Impact Mitigation ant site, feature, place, cultural landscape that Incorporat Impact is geographically defined in terms of the ed size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is: i) Listed or eligible for listing in the ❑ ❑ ❑ California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k)? ii) A resource determined by the lead ❑ ❑ ❑ agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1 . In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe? a (i-ii). No Impact. The City currently has a local register of historic resources included in the Tustin Historic Resources Survey which identifies over 400 sites of possible distinction and notable recognition.13 The RHNA sites identified do not include sites listed in the Tustin Historic Resources Survey. In addition, potential significant historic and cultural properties that could be historic as defined in Public Resources Code section 5020.1 (k) would be evaluated on a project-by-project basis. However, there is potential for resources to be unearthed or discovered that are eligible for listing. Development proposed as a result of the HEU would be required to obtain City approval on a project-by-project basis for any 13 Tustin Historic Resources Survey available at: https://www.tustinca.org/1039/Resources Page 167 _ INITIAL STUDY City of Tustin discretionary action, such as approval of a grading permit, and undergo a separate CEQA review process to assess potential environmental impacts. Under CEQA, consultation with tribes would be conducted under AB 52. Additionally, a Sacred Lands search request would be obtained from the Native American Heritage Commission (NAHC) as part of the tribal consultation process. Appropriate measures would be put in place to protect or relocate any identified resources. Tribal cultural resources are sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are either eligible or listed in the California Register of Historical Resources or local register of historical resources (Public Resources Code § 21074). As discussed above, development proposed as a result of the HEU would be required to obtain City approval on a project- by-project basis for any discretionary action, such as approval of a grading permit, and undergo a separate CEQA review process to assess potential environmental impacts. In order to determine whether any tribal cultural resources could be impacted by the proposed project, California Native American tribes that are traditionally and culturally affiliated with the project area would be contacted early in the CEQA process (Public Resources Code § 21080.3.1), and consultation undertaken with those Native American tribes that express an interest in engaging in consultation for this project. Appropriate measures would be identified during consultation and put in place to protect or relocate any identified resources. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential projects proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential tribal cultural resource impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Measures that are required by underlying Specific Plan EIRs will be implemented. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to protect tribal cultural resources. Therefore, the project would result in no impact. Page 168 INITIAL STUDY City of Tustin 4.23 UTILITIES AND SERVICE SYSTEMS Would the project: Potentially Less Than Less Than No Impact Significant Significant Significant Impact with Impact Mitigation Incorporat ed a) Require or result in the relocation or ❑ ❑ ❑ construction of new or expanded water, wastewater treatment, stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? b) Have sufficient water supplies ❑ ❑ ❑ available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? c) Result in a determination by the ❑ ❑ ❑ Fq 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? d) Generate solid waste in excess of ❑ ❑ ❑ state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? e) Comply with federal, state, and ❑ ❑ ❑ local management and reduction statutes and regulations related to solid waste? Page 169 INITIAL STUDY City of Tustin a — e. No Impact. Implementation of the housing programs would facilitate housing development to meet the City's RHNA allocation. The proposed RHNA sites identified for future housing development are primarily infill locations surrounded by roadways that contain utility infrastructure adjacent to existing development that is served by these utilities service systems and have been planned for urban uses. Implementation of the housing programs would facilitate housing development to meet the City's RHNA allocation of 6,782 housing units. Development of housing would require additional potable water resources to operate. The City of Tustin UWMP projects a demand of 9,898-acre feet (AF) by 2045 and a supply of 9,898 AF.14 Additionally, the UWMP includes a contingency plan and supply assessment for dry year(s). The proposed 16 of the 20 proposed RHNA sites have been previously analyzed under adopted Specific Plans which are included in the City's UWMP projections. The East Orange County Water District and Irvine Ranch Water District would provide wastewater collection to the proposed RHNA sites. The City contracts for residential refuse collection and solid waste materials are transported to a Materials Recovery Facility where it is sorted for recyclables. The County of Orange owns and operates the Frank R. Bowerman Sanitary Landfill, located at 11002 Bee Canyon Access Road in Irvine, which serves Tustin. The Resource Conservation and Recovery Act of 1976 (United States Code Title 42, Section 6901 et seq.) governs the creation, storage, transport, and disposal of hazardous wastes and operators of hazardous waste disposal sites. AB 939, the Integrated Waste Management Act of 1989 (California Public Resources Code Section 40000 et seq.) requires all local governments to develop source reduction, reuse, recycling, and composting programs to reduce tonnage of solid waste going to landfills. Cities must divert at least 50 percent of their solid waste generation into recycling. Compliance with AB 939 is measured for each jurisdiction, in part, as actual disposal amounts compared to target disposal amounts. Actual disposal amounts at or below target amounts comply with AB 939. The City must comply with State law to reduce solid waste generation, promote reuse and require solid waste collection for recycling and composting. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential projects proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential utilities impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established related to utilities. Therefore, the project would result in no impact. 14 Available at ittps://www.tustinca.org/DocumentCenter/View/5138/Tustin-2020-UWMP Page 170 INITIAL STUDY City of Tustin 4.24 WILDFIRE Potentially Less Than Less Than No Impact Significant Significant Significant I mpact with I mpact If located in or near state responsibility areas or Mitigation lands classified as very high fire hazard severity Incorporat zones, would the project: ed a) Substantially impair an adopted emergency ❑ ❑ ❑ response plan or emergency evacuation plan? b) Due to slope, prevailing winds, and other factors, ❑ ❑ ❑ exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire? c) Require the installation or maintenance of ❑ ❑ ❑ associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? d) Expose people or structures to significant risks, ❑ ❑ ❑ including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? a — d. No Impact. According to the CalFire Fire Hazard Severity Zone Map, the City of Tustin contains very high fire severity zones in the northeast portion of the City15. The proposed RHNA sites are not located within a fire hazard zone. In addition, the sites and areas adjacent to the sites are urbanized and do not contain hillsides or other factors that could exacerbate wildfire risks. As discussed previously, the City of Tustin General Plan Conservation/Open Space/Recreation Element identifies several geologic hazards that could impact the community. Figure COSR-1 of the Conservation/Open Space/Recreation Element depicts the areas in the community which require special planning considerations to avoid potential hazards. Areas in southeast Tustin along Peters Canyon Wash/Channel are identified as being in a 100-year flood plain. The western portion of Tustin, surrounding the DCCSP area, is identified as 500-year flood plain. Several of the proposed RHNA housing sites overlap identified hazard areas. Current Federal Emergency Management Agency (FEMA) Federal Insurance Rate Maps (FIRM) maps that cover the city (panel 15 Cal Fire Hazard Severity Zone Viewer ,ittps://egis.fire.ca.gov/FHSZ/ Page 171 _ INITIAL STUDY City of Tustin 06059C0164J and 06059CO277J) identify majority of the city as within Zone X, areas of 0.2 percent annual chance flood; areas of 1 percent chance flood with average depths of less than 1 foot or with drainage areas less than 1 square mile, and areas protected by levees from 1 percent annual chance flood.16 As previously mentioned, the City adopted an Emergency Operations Plan. The plan outlines operational duties and procedures for various positions. Additionally, the City's Safety Element, as contained within the City of Tustin General Plan, includes policies and procedures to be administered in the event of a disaster.17 The Safety Plan seeks interdepartmental and inter-jurisdictional coordination and collaboration to be prepared for, respond to and recover from every day and disaster emergencies. All projects in the city would be require to be consistent with both emergency planning documents. Additionally, new residential uses in the city are required to include all fire related safety features pursuant to the California Fire Code, which is included in the Tustin City Code as Section 8104. The City's Building Department and the Fire Department would review the building plans prior to approval to ensure that all applicable fire safety features are included in each development project. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential projects proposed to achieve the City's RHNA, and associated infrastructure improvements, would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. Potential wildfire impacts would be evaluated on a site-by-site basis and mitigation measures, if necessary, would be implemented to reduce significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established related to wildfire hazards. Therefore, the project would result in no impact. 16 Federal Emergency Management Agency (2009), Federal Insurance Rate Maps (Panels 06059C0164J and 06059CO277J ), available at: https://msc.fema.gov/portal/home 17 General Plan Safety Element (2017) available at: https://www.tustinca.org/DocumentCenter/View/713/City-of-Tustin-General-Plan- PDF?bidld= Page 172 INITIAL STUDY City of Tustin 4.25 MANDATORY FINDINGS OF SIGNIFICANCE Potentially Less Than Less Than No Impact Significant Significant Significant I mpact with I mpact Mitigation Incorporat ed a) Does the project have the potential to ❑ ❑ ❑ substantially 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, substantially 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? a. Does the project have the potential to substantially 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, substantially 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? No Impact. As discussed in Section 4.8, the City's Conservation/Open Space/Recreation Element of the General Plan Identifies areas as "important natural resources" within Figure COSR-2. Since the natural resource areas have been designated, new development has occurred throughout the city. Areas identified as important natural resources are located at the northern and southern ends of the city. Natural resources to the north include open space areas, Lower Peters Canyon Retarding Basin, Eucalyptus Windrow, and Redwood Grove. This area also includes Coastal Sage Scrub habitat. The natural habitats to the north support sensitive or endangered species such as the California Black-tailed Gnatcatcher, the San Diego Cactus Wren, and the San Diego Coast Horned Lizard. Within southern Tustin, agricultural land is identified as an important natural resource based on the CDOC's previous designation of the land as important Page 173 INITIAL STUDY City of Tustin farmland. However, the area has since been adopted into a specific plan (TLSP) and is no longer utilized for agricultural purposes. Additionally, Peters Canyon is a predominant riparian feature within the city. Several mitigation measures were adopted for Peters Canyon as part of the ETSP. These mitigation measures continue to reflect City policy. For several years, the Lower Peters Canyon Retarding Basin contained a small riparian habitat.'$ This habitat has severely deteriorated in recent years. The City works with the County of Orange, which recently constructed a replacement dam, to preserve the riparian area and implement active measures to increase water supply to restore the habitat area. As discussed in Section 4.9, the City of Tustin contains several designated historic resources and resources of historic age that could be eligible for designation. Tustin's historic preservation program was established by Tustin City Code Section 9252 "Cultural Resources District," and is supported by Residential Design Guidelines and Commercial Design Guidelines established by the City. It is also supported by the Secretary of Interior's Standards for the Treatment of Historical Properties.19 Together, these documents establish criteria and procedures for the designation, preservation and maintenance of cultural resources throughout the City of Tustin. The City's Conservation/Open Space/Recreation Element of the General Plan Figure COSR-2 identifies areas sensitive to cultural resources. The City has very detailed standards and requirements for grading that are designed to protect sensitive topographic, soil, paleontologic, and archaeologic resources. The Tustin Grading Manual prescribes appropriate measures to protect the earth by controlling erosion, sedimentation, and storm damage. Proper grading, soil management, and open space standards will work to preserve these resources. Sensitive locations are identified, and their preservation is a high priority for the City during any project review. As new resources are identified in the City, they will be documented as features or resources the City desires to preserve. As per the City's General Plan, a records search will be performed prior to any development. If no record of resources exists, a field survey will be performed. Any proposed project which is located within a sensitive area as defined by Figure COSR-2, The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. Future residential projects proposed to achieve the City's RHNA goals would be located on developed, underutilized sites or on vacant parcels proposed and zoned for mixed use development. One RHNA site is located in the ETSP; however, the site is currently developed and is outside of areas containing sensitive biological habitat. Potential biological and cultural resource impacts would be evaluated on a site- by-site basis and mitigation measures, if necessary, would be implemented to reduce 18 City of Tustin General Plan Conservation/Open Space/Recreation Element, available at https://www.tustinca.org/DocumentCenter/View/713/City-of-Tustin-General-Plan- PDF?bidld= 19 Tustin Residential Design Guidelines and Commercial Design Guidelines available at https://www.tustinca.org/1039/Resources Page 174 INITIAL STUDY City of Tustin significant impacts. Additionally, all future projects would be required to comply with applicable Federal, State, and local policies and regulations established to protect biological species and cultural resources. Therefore, the project would result in no impact. 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)? Less Than Significant Impact. Cumulative impacts are defined as two or more individual effects that, when considered together, are considerable or that compound or increase other environmental impacts. The cumulative impact from several projects is the change in the environment that results from the incremental impact of the development when added to the impacts of other closely related past, present, and reasonably foreseeable or probable future developments. Cumulative impacts can result from individually minor, but collectively significant, developments taking place over a period. The CEQA Guidelines, Section 15130 (a) and (b), states: a. Cumulative impacts shall be discussed when the project's incremental effect is cumulatively considerable. b. The discussion of cumulative impacts shall reflect the severity of the impacts and their likelihood of occurrence, but the discussion need not provide as great detail as is provided of the effects attributable to the project. The discussion should be guided by the standards of practicality and reasonableness. The HEU proposes several program changes to comply with State law, as well as proposed housing sites to accommodate RHNA's quantified objective administered to the City for the 2021-2029 planning cycle. The HEU also provides for the continuation of the preexisting policies and programs that were adopted in the 2014-2021 Housing Element. The HEU would not directly result in changes to land use or zoning designations that would place housing within an area of potential exposure to hazardous materials. The City's Zoning Code would be updated following adoption of the HEU to include a housing overlay over The Market Place and Enderle Center RHNA housing sites, which would allow for the development of residential in these areas. Potential impacts that could result from proposed Zoning Code changes would be evaluated under a separate CEQA review process. Furthermore, mitigation measures that are required by underlying Specific Plan EIRs would be implemented as development is proposed. Therefore, the project would have no impact. c. Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly? Less Than Significant Impact. The HEU is a policy document, and its adoption would not, in itself, produce environmental impacts. No actual development or rezoning is proposed as part of the HEU. The HEU would not directly result in changes to land use or zoning designations that would place housing within an area of potential exposure to hazardous materials. The City's Zoning Code would be updated following adoption of the HEU to include a housing overlay over The Market Place and Enderle Center RHNA housing sites, which would allow for the development of residential in these areas. Page 175 INITIAL STUDY City of Tustin Potential impacts that could result from proposed Zoning Code changes would be evaluated under a separate CEQA review process. Development proposed as a result of the HEU would also be required to obtain City approval on a project-by-project basis for any discretionary action, such as approval of a grading permit, and undergo a separate environmental process to assess potential environmental impacts. Furthermore, mitigation measures that are required by underlying Specific Plan EIRs would be implemented as development is proposed. Therefore, the project would have no impact. Page 176 INITIAL STUDY City of Tustin End of document. Page 177 ATTACHMENT F PLANNING COMMISSION RESOLUTION 4440 RESOLUTION NO. 4440 A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF TUSTIN RECOMMENDING THAT THE CITY COUNCIL APPROVE GENERAL PLAN AMENDMENT 2021- 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 Housing Element is required to be updated every eight (8) years to reflect new statutory requirements and accommodation its share of Reginal Housing Needs Assessment Allocation. C. That housing is an important issue with the State of California and as such, each city and county must identify and analyze existing and projected housing needs within their jurisdiction and prepare goals, policies, programs, and quantified objectives to further the development, improvement, and preservation of housing. D. That in accordance with State Law, the City of Tustin has prepared a Draft Housing Element for the 2021-2029 period in accordance with California Government Code Sections 65580-65589.8. E. That the City conducted extensive community outreach efforts through an online community survey, social media ads and posts, newspaper advertisements, mailings to stakeholders and memorialized all outreach efforts in the 2021-2029 Housing Element Community Engagement Plan. F. That on November 11 , 2020, the Planning Commission held a public meeting to review the 2021-2029 Housing Element requirements and the City's strategy for enhancing and preserving the community's character, and strategies for expanding housing opportunities and services for all household types and income groups. G. That a joint public workshop was held on May 11, 2021 , to inform the general public, the Planning Commission, and the City Council with the purpose and intent of the Housing Element Update. Resolution No. 4440 Page 2 H. That HCD has reviewed the Draft Housing Element and provided verbal comments to the City on August 12, 2021 followed by formal written comments on August 27, 2021. I. That on August 17, 2021, the City Council amended the Draft Housing Element with the inclusion of two (2) additional sites (The Market Place and Enderle Center) to the City's Site Inventory in response to the public input. J. That on September 7, 2021, the City Council further amended the redistribution of the housing units based upon the California Department of Housing and Community Development (HCD) review of the Draft Housing Element related to preservation of at-risk units and accessory dwelling units (ADUs). Specifically, the revision redistributes 582 units (517 Preservation of At-risk units and 65 ADUs) to the Tustin Market Place and the Enderle Center. K. That the Draft Housing Element has been revised to address public input and HCD's comments. L. That a public hearing was duly called, noticed, and held on General Plan Amendment (GPA) 2021-002 on September 14, 2021, 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. M. 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 GP A 2021- 002, and a Negative Declaration was prepared for the project. II. The Planning Commission hereby recommends that the City Council approve GPA 2021-002, attached hereto as Exhibit A, for the 6th Cycle Housing Element. PASSED AND ADOPTED by the Planning Commission of the City of Tustin, at a regular meeting on the 14th day of September, 2021. AMY MASON Chairperson JUSTINA L. WILLKOM Planning Commission Secretary Attachment: 1. Exhibit A: 2021-2029 Final Draft Housing Element Resolution No. 4440 Page 3 STATE OF CALIFORNIA ) COUNTY OF ORANGE ) CITY OF TUSTIN ) I, JUSTINA L. WILLKOM, the undersigned, hereby certify that I am the Planning Commission Secretary of the City of Tustin, California; that Resolution No. 4440 was duly passed and adopted at a regular meeting of the Tustin Planning Commission, held on the 14th day of September, 2021. PLANNING COMMISSIONER AYES: PLANNING COMMISSIONER NOES: PLANNING COMMISSIONER ABSTAINED: PLANNING COMMISSIONER ABSENT: JUSTINA L. WILLKOM Planning Commission Secretary Attachment F - Exhibit A Final Draft General Plan Housing Element and Appendices Also available electronically by going to : www.tusti nca .org/housi ngelement >>Click on September 2021 Draft Housing Element 1 a , , v �.� a _ _ +4 � 41 +' ,'mss ;x.�,,•.� n •.. _� _ 4 1. :�°a moi. .1 j'. s-r City of Tustin Draft Housing Element 2021 =2029 September 2021 .r 1 w Old "Town "' TUSTTNT ��A ✓T'd 1. �"' '�'�:.�� + ��. � � � � EB ED IE t IQ STMIT 7 1 - . Draft Housing Element TUSTIN GENERAL PLAN SEPTEMBER 2021 This page intentionally left blank. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 i TABLE OF CONTENTS Section Page I. INTRODUCTION TO THE HOUSING ELEMENT I-1 Purpose Of The Housing Element I-1 Scope And Content Of Element I-2 Consistency With State Planning Law I-2 General Plan Consistency I-3 Public Participation I-4 11. SUMMARY OF ISSUES,NEEDS,CONSTRAINTS AND OPPORTUNITIES I1-1 Summary Of Housing Needs 11-1 Preservation Of Units At Risk Of Conversion 11-16 Summary Of Housing Issues 11-18 Housing Constraints 11-19 Housing Opportunities 11-51 111. HOUSING ELEMENT GOALS AND POLICIES 111-1 Housing Supply/Housing Opportunities 111-1 Maintenance And Conservation 111-3 Environmental Sensitivity 111-4 IV. HOUSING ELEMENT IMPLEMENTATION PROGRAM IV-1 Housing Programs VI-1 APPENDICES A- Review of Past Performance B- Sites Inventory C- Affordable Housing Resources D- Affirmatively Furthering Fair Housing E- Public Participation F References CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN JUNE, 2021 ii LIST OF TABLES Tables Page TABLE H-I-1: STATE HOUSING ELEMENT REQUIREMENTS I-3 TABLE H-II-1: POPULATION GROWTH 2010-2018 II-2 TABLE H-II-2: POPULATION PROJECTIONS 2025-2045 II-2 TABLE H-II-3:EMPLOYMENT PROJECTIONS II-3 TABLE H- II-4: EMPLOYMENT BY OCCUPATION II-4 TABLE H-II-5: LIST OF MAJOR EMPLOYERS II-4 TABLE H-II-6:JOBS-HOUSING BALANCE II-5 TABLE H-II-7:TUSTIN HOUSEHOLD INCOME DISTRIBUTION OVERVIEW 2017 II-7 TABLE H-II-8: NUMBER OF HOUSEHOLDS WITH COST BURDEN II-8 TABLE H-II-9: NUMBER OF HOUSEHOLDS WITH COST BURDEN II-9 TABLE H-II-10: TENURE OF HOUSEHOLDS WITH HEAD OF HOUSEHOLD AGED 65 YEARS OR OLDER II-10 TALBE H-II-11: ESTIMATED HOUSEHOLD INCOME DISTRIBUTION-HOUSEHOLDS WITH HEAD OF HOUSEHOLD AGED 65 YEARS OR OLDER II-11 TABLE H-11-12: SENIOR HOUSEHOLDS BY TENURE II-12 TABLE H-11-13 RACE AND ETHNICITY II-12 TABLE H-II-14 TUSTIN EMPLOYMENT IN AGRICULTURE II-14 TABLE H-II-15 ORANGE COUNTY FAIR MARKET RENT II-17 TABLE H-II-16 NEW AND RESALE PRICE OF HOMES AND CONDOMINUMSII-21 TABLE H-II-17 AVERAGE RENTAL RATES 2021 II-22 TABLE H-II-18 SUMMARY OF RESIDENTIAL ZONING REGULATIONS II-26 TABLE H-II-19A DEVELOPMENT FEES II-37 TABLE H-II-19B DEVELOPMENT FEES II-38 TABLE H-IV-1 HOUSING ELEMENTS PROGRAMS 2021-2029 IV-1 LIST OF FIGURES Figures Page FIGURE H-11-1: IMPACT FEE ZONES II-33 FIGURE H-II-2: PLANNING FEES II-40 CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN JUNE, 2021 iii 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. Of the mandated General Plan Elements,the Housing Element is the only one that is required to be updated on a specific schedule. The Housing Element is also subject to review by the State Department of Housing and Community Development(HCD). In order to address a community's changing housing needs,Housing Elements are to be updated every four to eight years. State Planning Law mandates that jurisdictions within the Southern California Association of Governments (SCAG) region adopt revisions to their Housing Elements by October 15, 2021. There are two relevant Housing Element time periods: • 2013-2021: The previous planning period began on October 15,2013,and ends on October 15,2021 • 2021 -2029: The current Housing Element planning period begins on October 15, 2021 and ends in October 15,2029. The planning period for the 6th Cycle Regional Housing Needs Assessment (RHNA) as prepared by SCAG,is from June 30,2021 to October 15,2029,an eight-year period. The Housing Element includes the following sections: Section I- Introduction Section II -Summary of Issues, Needs, Constraints and Opportunities Section III-Goals and Policies Section IV- Housing Programs Appendix A- Review of Past Performance Appendix B - Housing Sites Inventory Assessment Appendix C-Affordable Housing Resources Appendix D-Affirmatively Furthering Fair Housing Appendix E - Public Participation (Community Engagement Plan) Appendix F-References PURPOSE OF THE HOUSING ELEMENT The purpose of the Housing Element is to achieve an adequate supply of safe, affordable housing for all economic segments of the community, including individuals with special housing needs. An effective housing element provides the necessary conditions for conserving, preserving and producing an adequate supply CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 I-1 of housing affordable at a variety of income levels and provides a vehicle for establishing and updating housing and land-use strategies to reflect changing needs, resources,and conditions. The Land Use Element of the City's General Plan 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 goals, policies, 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. Section II and Appendix D for additional information on the City's demographic profile. 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 emphasizes the promotion of and affirmatively furthering fair housing opportunities throughout the State, regional and local levels of government and for all economic segments of a community. The Legislature's major concerns with regard to the preparation of Housing Elements are: o Recognition by local governments of their responsibility to consider economic, environmental and fiscal factors and community goals set forth in the General Plan in contributing to the attainment of State housing goals; o Recognition of responsibility by the State and local governments to utilize vested powers to facilitate, improve and ensure the provision adequate housing for all economic segments within a community; o Cooperative efforts by all levels of government to provide housing to low- and moderate-income households; o Cooperative participation of government and the private sector in an effort to expand housing opportunities and accommodate housing needs; and o Designating and maintaining a supply of land and adequate suitable sites suitable,feasible and available for housing development. 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 I-2 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. This Housing Element complies with statutory requirements of Government Code Sections 65580- 65588. GENERAL PLAN CONSISTENCY According to State planning law,the Housing Element must be internally consistent with the other General Plan elements. Certain goals and policies of each element may also address issues that are primary subjects of other elements. This integration of issues throughout the General Plan creates a strong base for the execution of plans and programs and ultimate attainment of community goals. The Housing Element is most closely tied to the Land Use Element as residential development capacities established in the Land Use Element are incorporated into the Housing Element. The Tustin General Plan includes the following elements: • Land Use • Housing • Circulation • Conservation/Open Space/Recreation • Public Safety • Noise • Growth Management 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. 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 I-3 The Public Safety Element relates to the Housing Element by designating areas that are unsafe for development such as high fire severity zones, Alquist-Priolo Zones, floodplains,etcetera. Similar to the Public 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 Tustin Housing Element is consistent with the goals and policies set forth in the adopted General Plan, but also incorporates new development opportunities presented by the Red Hill Avenue Specific Plan and the Downtown Commercial Core Specific Plan. Pursuant to new State law, the City is updating the Public Safety Element,Land Use Element and Circulation Element following the Housing Element update as part of an overall Citywide General Plan update. This update is anticipated to be completed by January 2024. If additional elements in the General Plan are amended in the future, the Housing Element will be reviewed and modified if necessary to ensure consistency among the various elements. The City will ensure that updates to these Elements achieve consistency with the Housing Element. PUBLIC PARTICIPATION The California Government Code section 65583, subdivision(c)(8) requires that local governments make diligent efforts to solicit public participation from all segments of the community in the development of the Housing Element. The City's comprehensive public participation plan in included in Appendix E - Community Engagement Plan. Public Engagement The City of Tustin recognizes the importance of public participation and consultation during the preparation of the 2021 - 2029 Housing Element Update, and, therefore, developed a comprehensive Community Engagement Plan (Appendix E) to solicit input from residents,community members and stakeholders throughout the update process. The following provides a summary of the City's Community Engagement Plan outreach efforts: CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 I-4 • Public Meetings - Multiple public workshops and public hearings held providing opportunities for community and public participation and input, including with residents, stakeholders, Planning Commission and City Council, and options for virtual community participation. • Online Community Survey-Two separate releases of an online community survey in English and Spanish to gather feedback related to local housing needs; • Mailings - Direct mailing and email notifications delivered to Tustin residents, businesses, apartment owners, service providers, and other agencies in English and Spanish; • Stakeholders - Individual stakeholder meetings held with multiple organizations as part of the consultation process; • Website - Creation of a focused webpage on the City's website dedicated to the Housing Element Update which was routinely maintained and updated with pertinent information; • Social Media and Multi-Media News Releases - Specific information, provisions and updates advertised in English and Spanish through the City's website, social media posts, paid advertising via social media and in newspaper and magazine publications, press releases, video features, flyers, postcards,and posters;and • On-going public input-Continuous opportunities for review and comment of the Draft Housing Element update using all the community outreach methods and media listed above. Details of the City's outreach efforts are described in the Community Engagement Plan (Appendix E). Summary of Public Comments Received The City received fifteen(15)public comments during the first round of review of the Draft Housing Element (between June 30, 2021 and July 30, 2021) and one (1) comment since the August 17,2021 City Council meeting where an amendment was made to the draft Housing Element. The comments received during the initial review (prior to the amendment) are summarized below. More than half of the comments expressed concern over the number of units planned, particularly the low-income distribution, being concentrated in one major area (Tustin Legacy) rather than distributed throughout the City. In response to these comments, the draft Housing Element was subsequently revised on August 17 and September 7,2021. • Concern over the apportionment, density and geographic placement of additional low-income housing primarily identified to occur within the Tustin Legacy area. Respondents encouraged the City to consider the overall housing increase, and, particularly the lower-income housing to be more CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 I-5 equally apportioned/distributed throughout the City and be available to all rather than concentrated within the Tustin Legacy area. • Affordable housing should be dispersed equitably throughout the community. • Resident within current Tustin Legacy neighborhood expressed displeasure of current high taxes in addition to the Tustin Legacy identified to being the recipient of the majority of homeless and low-income housing allocations. • Concern that they did not physically receive or receive communication about the available survey. • Concern that the City is not providing enough site capacity for very low- income housing. RHNA requires 1,724 very low-income units and the Draft Element provides a capacity for 1,699; a deficiency. Their suggestion is to provide a fifteen (15) to thirty (30) percent capacity buffer at each level of income to avoid violating the No New Loss requirement. • Concern regarding specific Site 6 being held by one (1) owner and unknown willingness by said owner to sell property to pursue housing which would result in a site inventory deficiency. • Concern that the plan will not realize attainable housing options for residents and workers of Tustin. • Encourage the City to adopt a compliant housing element update by the required due date of October 15,2021. • Inquiry regarding whether the City plans to build condominiums and small houses for young adults just starting their careers and want to live in the City of Tustin. • Request for information regarding rental assistance programs. • Request update regarding housing developments in Tustin. • Request for the Housing Element Technical Memorandum. • Concerns regarding the identification of zone or zones where emergency shelters are allowed without discretionary review and/or permit, assessing the need and capacity for emergency shelters, emergency shelter standards; analysis for special needs; analysis of governmental and nongovernmental constraints;site inventory analysis and capacity,including ADUs;assessment of fair housing issues related to AFFH; programs within the Draft Housing Element including preserving assisted housing developments, and public engagement and outreach efforts undertaken by the during the update process. As of September 1, 2021, one (1) public comment has been received on the proposed Negative Declaration. The comment questioned whether the adequacy of the environmental analysis conducted based on the City's RHNA allocation and the CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 I-6 number of units that could be potentially constructed within the City. A response was provided to this question along with other questions to the City's website for information and assist the public in the Housing Element update process. In response to this comment and other related-comments,it is important to note that the Housing Element is a planning and policy document that does not approve, permit or entitle any residential development projects. The sites inventory and housing unit distribution has been modified several times since it was originally presented at the City Council and Planning Commission Housing Element Workshop held on May 11, 2021. In order for those properties identified in the Sites Inventory to accommodate additional housing units to the meet the City RHNA allocation, it will require the creation of overlay zones and/or an amendment to Specific Plan and are therefore only considered candidate sites. Additional evaluation and a separate environmental assessment will be completed concurrently with the adoption of an overlay/rezone and/or amendment to the City's General Plan, and is required to take place with three years of the City's adoption of the 2021-2029 Housing Element. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 I-7 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 considerations 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 from when households are paying more than they can afford for housing; • Housing needs resulting from the presence of"special needs groups" such as the seniors, large families, female-headed households, persons with disabilities (including physical and mental disability), and persons experiencing homelessness;and • Housing needs resulting from the conversion of assisted housing developments to market rate housing. Population Growth As shown in Table H-II-1,between 2010 and 2014 the City's population grew steadily from 75,540 to 80,617, an increase of 5.6 percent. Between 2014 and 2018, Tustin's population growth decreased by approximately 1.0 percent, with a decrease from 80,617 to 79,787. The population growth in Tustin is comparable to the countywide growth rate. However, Tustin's 5.6 percent population growth rate within the 2010- CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-1 SEPTEMBER 2021 2018, eight-year period is greater than the nearby cities of Anaheim, Garden Grove, Orange and Santa Ana.These other cities experienced growth rates in the range of 1.0 percent to 4.7 percent,compared to Tustin s 5.6 percent population increase.The City of Irvine experienced the largest population increase,with an increase of 33.1 percent within the same eight-year period. TABLE H-II-1 POPULATION GROWTH 2010-2018,CITY OF TUSTIN,NEARBY JURISDICTIONS AND ORANGE COUNTY Percent Growth Jurisdiction 20101 20142 20183 2014-2018 2010-2018 Tustin 75,540 80,617 79,787 -1.0% 5.6% Anaheim 336,265 346,961 352,018 1.5% 4.7% Garden -1.4% 1.0% Grove 170,883 175,085 172,652 Irvine 212,375 248,521 282,584 13.7% 33.1% Orange 324,528 139,826 139,502 -0.2% 2.0% Santa Ana 325,483 334,924 1 332,727 -0.1% 2.2% Orange 1.3% 5.5% County 3,018,963 3,145,515 3,185,968 Sources:12010 U.S.Census 2 2014 U.S.Census 3 American Community Survey(5-Year Estimate)2018 Population projections are shown in Table H-II-2. According to Orange County Projections(OCP)2020 Modified data,the population in the City of Tustin is expected to increase by approximately 6.3 percent within a 20-year period (2025-2045), from 84,265 persons in 2025 to 92,564 persons by the year 2045. TABLE H-II-2 POPULATION PROJECTIONS 2025-2045 2025 2030 2035 2040 2045 Percent Change (2025-2045) Tustin 84,265 85,239 87,932 90,576 92,564 6.30% Source:OCP 2020 Modified,Prepared by Center for Demographic Research. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-2 SEPTEMBER 2021 Employment An assessment of the needs of the community must take into consideration the type of employment held by City residents. Incomes associated with different jobs and the number of workers in a household determines the type and size of housing a household can afford. The American Community Survey (ACS) provides information about employment, specifically the number of City residents by industry type, who are employed by businesses either outside or within their community. As of 2018, the largest occupational category in the City was the service occupation in which a total of 17,418 residents (41.10 percent) were employed. The second largest category was the sales and office occupations, employing 9,585 residents (22.60 percent). Both of these categories and respective percentages are very similar to the previous housing cycle and have not changed significantly. Table H-I1-4 shows the breakdown of employment by occupation. Table H-11-3 provides employment projections between the years 2016 and 2040. According to OCP-2018 Modified data,employment in the City of Tustin is expected to increase by approximately 42 percent between 2016 and 2040. The largest percentage of employment by occupation includes service occupations(41.1 percent). However, given the changes in retail shopping trends and more customers making purchases online, there is and will likely continue to be less demand for retail space in the future,which could potentially impact retail employment as well. TABLE H-II-3 EMPLOYMENT PROJECTION Percent Change 2016 2020 2025 2030 2035 2040 (2016-2040) Tustin 49,200 53,029 54,831 61,752 66,579 69,752 41.77% Source:Center for Demographic Research at Cal State Fullerton-OCP,7t CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-3 SEPTEMBER 2021 TABLE H-II-4 EMPLOYMENT BY OCCUPATION,2018 CITY OF TUSTIN Occupational Category Number Management,business,science,and arts occu ations 8,293 19.5% Service occupations 17,418 41.10% Sales and office occupations 9,585 22.60% Natural resources,construction,and maintenance occupations 2,581 6.1% Production,transportation,and material moving occupations 4,571 10.8% Total 42,448 100.0% Source:U.S.Census:2014-2018 American Community Survey Table H-II-5 provides a list of the largest employers in Tustin in 2020.The list includes a variety of industries, including education, financial, government, manufacturing, health care and wholesale trade. There are fewer major retail employers within the City than in the past planning period. TABLE H-II-5 LIST OF MAJOR EMPLOYERS IN TUSTIN,CA 2020 Company/Address No. Emp. Product/Service Tustin Unified School District 2,850 Education 300 South C St. -Tustin 92780 SchoolsFirst 983 Financial Services 14171 Red Hill Avenue,Tustin, CA Young's Market Co LLC 681 Distributor 14402 Franklin Ave Tustin, CA 92780 Costco Wholesale 658 Wholesale Trade 2700 Park Ave. - Tustin 92780; 2655 El Camino Real,Tustin, CA City of Tustin 409 Government 300 Centennial Way-Tustin 92780 Avid Bioservices, Inc. 230 Manufacturing 2642 Michelle Dr# 200,Tustin 92780 Vita Best Nutrition 215 Manufacturing 2802 Dow Ave,Tustin,92780 Kaiser Permanente 200 Medical 2521 Michelle Dr.Tustin 92780;1745217th St,Tustin 92780 Logomark, Inc. 196 Wholesale Trade 1201 Bell Ave. -Tustin 92780 Source City of Tustin Comprehensive Annual Financial Report for the Year Ended,2020 Jobs-Housing Balance CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-4 SEPTEMBER 2021 The jobs-housing ratio in a jurisdiction is a general measure of the total number of employment opportunities and housing units within the geographic area. The jobs- to-housing balance is a planning tool to review whether a community has a healthy balance between jobs and the housing supply available to potentially house workers for those jobs. This balance may be impacted by the match between wage levels and housing costs;whether all workers in a house have employment in the community in which they live; whether preferences are met within the community for either housing or employment;and whether options are available nearby for either housing or employment. A desired target is a jobs-to-housing-units ration of 1:1,indicating a jurisdiction has reached an equilibrium between employment and housing opportunities. Table H-II-6 shows the 2018 jobs-housing balance for Tustin,Orange County and the Southern California (SCAG) region. Recent data indicate that Tustin had a jobs- housing ratio of 1.78 in 2018,indicating that the City is jobs-rich in comparison to the countywide ratio of 1.57 and the SCAG region ratio of 1.28. TABLE H-II-6 JOBS-HOUSING BALANCE CITY/COUNTY/REGION 2019 Tustin Orange County SCAG Region Total Jobs 50,169 1,726,003 8,465,304 Housing Units 28,118 1,094,169 6,629,879 Jobs-Housing Ratio 1.78 1.57 1.28 Sources:SCAG Local Profile City of Tustin 2019 Overcrowding "Overcrowding" is generally defined as a housing unit occupied by more than one person per room in housing unit (including living room and dining rooms, but excluding hallways, kitchen, and bathrooms). An overcrowding can be caused by lack of affordable housing (which forces more than one household to live together) and/or a lack of available, adequately sized housing units. Overcrowding is an indicator of inadequate supply of affordable housing, especially for large families. Overcrowded and severely overcrowded households contribute to faster rates of deterioration due to more intensive use of individual housing units. The faster rates of deterioration are caused by excessive wear and tear, and the potential cumulative effect of overburdening infrastructure systems and exceeding service capacities. Furthermore,overcrowding in neighborhoods contributes to overall declines in social cohesion and environmental quality. Such decline can often spread geographically CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-5 SEPTEMBER 2021 from housing units to neighborhoods and impact the overall quality of life and the economic vitality of a community." According to the 2019 American Community Survey,447 owner-occupied and 2,769 renter-occupied households in Tustin had more than 1.0 occupant per room.This data shows that overcrowding disproportionately affects renters, with 25 percent of renter-occupied units overcrowded compared to three percent of owner-occupied units. Substandard Units -Type,Age and Condition of Housing Stock Age is one measure of housing stock conditions and a factor for determining the need for rehabilitation. Without proper maintenance, housing units deteriorate over time. Thus, units that are older are more likely to be in need of major repairs (e.g., a new roof or plumbing). As a general rule of thumb, houses 30 years old or older are considered aged and are more likely to require major repairs. According to the ACS of 2019, Tustin offers a mix of housing choices. Of the 25,315 housing units in the City, 54.5 percent (13,815) are comprised of one-unit (either attached or detached) structures, 20 percent (5,093) are comprised of 2-9 units structures, approximately 24 percent (6,041) are comprised of 10 or more units structures,and 2 percent(524) are mobile homes. As of 2020, approximately 64 percent (17,816) of the City's existing housing stock is over 30 years old,the age at which housing tends to require significant repairs. The ACS of 2019 quantifies"Selected Conditions'which is a measure of substandard housing. The selected conditions are: incomplete plumbing or kitchens, overcrowding and 30 percent of the household income spent on rent or monthly owner costs. Of the 12,453 owner-occupied housing units, only 245 (less than two percent) housing units were indicated to have two or more"selected conditions". Of the 12,862 renter occupied housing units,1,901 (14.77 percent)were indicated to have two or more "selected conditions". At this time the City's Building Division (Code Enforcement) estimates that approximately ten percent of the City's housing stock is in need of varying degrees of repairs,which is generally consistent with the"selected conditions" data. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-6 SEPTEMBER 2021 Single Room Occupancy (SRO): Single Room Occupancy ("SRO") units are one-room units intended for occupancy by a single individual and typically range in size from 250-500 square feet. SROs are typically more affordable than other housing and can be a source of housing for low- and moderate-income households. They are distinct from a studio or efficiency unit, in that a studio is a one-room units that must contain a kitchen and a bathroom. Although SRO units are not required to have a kitchen or a bathroom, many SROs have one or the other and could be equivalent to an efficiency unit. SRO units are allowed within the City's Multiple Family Residential districts and Planning Area 3 of the Tustin Legacy Specific Plan area. SRO units such as rest homes are also conditionally-permitted within Commercial Districts in the city.The City will review the Zoning Code and Tustin Legacy Specific Plan to determine if other zones or planning areas are appropriate for inclusion of SROs. Affordability Gap Analysis The purpose of the affordability gap analysis is to illustrate the"gap"between the cost of what households pay toward their housing expenses in relation to their incomes. State and federal guidelines indicate that a household paying more than 30 percent of its income for housing is overpaying.Those who pay an excessing amount of their income on housing are referred to as "cost-burdened." Overpayment for housing can create an imbalance in a household's overall budget. Evaluating incidents of overpayment can influence the supply and demand of housing. Federal and State agencies use cost burden indicators to determine the extent and level of funding and support that should be allocated towards a community. The cost burden is the ratio of housing costs to household income.For renters,housing cost is gross rent(contract rent plus utilities). For owners, housing cost is "select monthly owner costs," including mortgage payment, utilities, association fees, insurance, and real estate taxes. TABLE H-II-7 TUSTIN HOUSEHOLD INCOME DISTRIBUTION OVERVIEW 2017 Income Owner Owner Renter Renter Total N M Household Income less-than or= 30% 1,155 31.8 2,470 68.1 3,625 AMI Household Income >30% to less-than 1,075 27.5 2,840 72.5% 3,915 or=50% AMI Household Income >50% to less-than 1,820 36.7 3,135 63.3% 4,955 or=80% AMI Household Income >80% to less-than 1,450 47.3% 1,610 52.6% 3,060 or=100% AMI CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-7 SEPTEMBER 2021 TABLE H-II-7 TUSTIN HOUSEHOLD INCOME DISTRIBUTION OVERVIEW 2017 Household Income>100% AMI 7,085 - 3,540 - 10,625 Total Households 12,590 - 13,595 - 26,185 Source:Comprehensive Housing Affordability Strategy(CHAS),2013-2017 estimates. The state and federal standard for housing cost burden is based on the income-to- housing cost ratio of 30 percent and above. According to the most recent Comprehensive Housing Affordability Strategy (CHAS) data published by the U.S. Department of Housing and Urban Development (HUD), 43.44 percent of Tustin households overpaid for housing in 2017. However, the total cost-burdened households have decreased by 5.82 percentage points, from the 49.26 percent reported in 2012. In addition,the number of households that pay 50 percent or more of their gross income toward housing has decreased by 16 percent within five years, from 21.95 percent in 2012 to 18.48 percent in 2017. TABLE H-II-8 NUMBER OF HOUSEHOLDS WITH COST BURDEN(2012 AND 2017 COMPARISON) Cost burden Cost burden Total Income >30% >50% 2012 2017 2012 2017 2012 2017 Household Income less-than or=30% AMI 2,980 2,845 2,685 2,300 3,455 3,625 Household Income >30% to less-than or= 2,870 3,345 1,540 1,715 3,340 3,915 50% AMI Household Income >50% to less-than or= 2,875 2,710 640 590 4,840 4,955 80% AMI Household Income >80% to less-than or= 1,125 1,120 190 125 2,420 3,060 100% AMI Household Income >100% AMI 2,325 1,355 365 110 10,665 10,625 Total 12,175 11,375 5,424 4,840 24,715 26,185 Source:Comprehensive Housing Affordability Strategy(CHAS),2008-2012 estimates and 2013-2017 estimates. As exhibited in Table H-11-9 below,both owner and renter households in Tustin may be cost burdened. Overall, there is a higher rate of cost burden, among renters with CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-8 SEPTEMBER 2021 26.85 percent experiencing a cost burden whereas16.61 percent of owners experience cost burden. TABLE H-II-9 NUMBER OF HOUSEHOLDS WITH COST BURDEN (2012 AND 2017 COMPARISON) Cost Burden Owner Renter Total Cost Burden less-than or=30% 8,150 6,415 14,565 Cost Burden>30% to less-than or= 2,870 3,670 6,540 50% Cost Burden>50% 1,480 31360 4,840 Cost Burden not available 90 150 240 Total 11,375 13,595 26,185 Source:Comprehensive Housing Affordability Strategy(CHAS),2013-2017 estimates. Special Needs Groups State law identifies certain households that historically have more difficulty in finding adequate and affordable housing due to special needs. Special needs populations include seniors, persons with disabilities, female-headed households, large households,and farmworkers.Many persons within these special needs groups often have lower than average incomes because of their special needs. Special needs may be related to a person's employment and income, family characteristics, disability and household characteristics, or other factors. Consequently, certain residents in Orange may experience higher incidences of housing overpayment(cost burden),overcrowding,or other housing problems.Special needs groups required to be analyzed in the Housing Element include seniors, persons with physical and developmental disabilities,persons experiencing homelessness, single parents,large households,and farmworkers Demographics regarding special needs groups are presented in Appendix D. Appendix D discussion incorporates planning and analysis, which is collectively referred to as an assessment of fair housing(AFH),and generally includes: • A summary of fair housing issues in the City of Tustin and an assessment of the jurisdiction's fair housing enforcement and outreach capacity; and • An analysis and summary of fair housing issues and identification of trends and patterns within the City of Tustin in comparison to surrounding cities and the larger Orange County region,including the topics of: o Integration and segregation; o Racially or ethnically concentrated areas of poverty; o Disparities in access to opportunity, including for persons with disabilities;and CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-9 SEPTEMBER 2021 o Disproportionate housing needs (such as overpayment, overcrowding, housing conditions disproportionately affecting protected classes), and displacement risk. where the City's. Discussion below includes a brief overview of these topics. Seniors (65+) The needs of many senior households are a result of their low and fixed incomes, physical disabilities/limitations,and need for assistance. The four main concerns for the 65+age population are: • Housing: considering that many seniors live alone, they may have difficulty maintaining their home • Income: this population is typically retired and live on a limited income • Healthcare: due to health conditions, they are likely to spend high amounts on health care • Transportation:a decline in strength,vision,reaction times,and short- term memory may make it unsafe for a senior to drive thus may rely on public transportation Table H-II-10 shows the tenure of households with the head of household aged 65 years or older in the City in 2018. The City had 1,596 renter households and 2,913 owner households with a head of household aged 65 years or older.Households with a senior householder represented 17.3 percent of all households in the City. This is a 1.6 percent increase since 2011. TABLE H-11-10 TENURE OF HOUSEHOLDS WITH HEAD OF HOUSEHOLD AGED 65 YEARS OR OLDER(2018) Head of Household 65 Years or Older Tenure # Households % Households Renters 1,596 6.1%1 Owners 2,913 11.2%2 Total Households 4,509 17.3%3 1 As a percentage of 13,600 renter households. 2 As a percentage of 12,532 owner households. 3 As a percentage of 26,132 total households. Source:U.S.Census,2014-2018 American Community Survey Table H-II-11 shows the estimated householder income distribution for householders aged 65 years or older in 2018. Approximately 18.2 percent of elderly senior CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-10 SEPTEMBER 2021 households in Tustin earned less than$25,000 annually or about 25.3 percent of AMI for a household of two persons in 2018. TABLE H-II-11 ESTIMATED HOUSEHOLD INCOME DISTRIBUTION HOUSEHOLDS WITH HEAD OF HOUSEHOLD AGED 65 YEARS OR OLDER,2018 Income Range Number Percent Cumulative % Less Than$10,000 318 7.05% 7.05% $10,000-$24,999 821 18.2% 25.3% $25,000-$34,999 400 8.8% 34.1% $35,000-$49,999 543 12.0% 46.2% $50,000-$74,999 725 16.1% 62.3% $75,000-$99,999 413 9.16% 71.4% $100,000 or More 1,289 28.6% 100.0% Total Households 4,509 100.0% Source:U.S.Census Bureau:20014-2018 American Communities Survey.Table B19037 According to the American Community Survey 2014-2018 5-year estimates, Tustin's seniors (65 and older) makeup 9.88 percent of the population, which is 4 percentage points lower than the regional share of 13.9 percent. As illustrated in Table H-II-12 below, in the City of Tustin, 64.6 percent, or 2,913, of all senior (65 years or older) headed households were owners. In comparison, 35.4 percent, or 1,596, of all senior- headed households were renters. However, countywide 75.7 percent of senior- headed households are owners, and 24.3 percent of senior-Headed Households are renters. However,both owners and renters are cost-burdened at a higher percentage in Tustin than in the County overall,despite having a lesser percentage of the elderly population. TABLE H-11-12 SENIOR HOUSEHOLDS BY TENURE,2018 Jurisdiction Total Senior- Owner Renter Owner costs as a Gross rent Elderly Headed percentage of as a Population Households household percentage income of 30% > household income CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-11 SEPTEMBER 2021 TABLE H-11-12 SENIOR HOUSEHOLDS BY TENURE,2018 30% > Tustin 7,914 4,509 2,913 1,596 37.1% 73.2% Orange 440,488 246,942 186,944 59,998 33.0% 63.4% County Source:American Community Survey,5-Year Estimates,2014-2018 City demographics for senior households are further discussed in Appendix D. Minority Populations The City of Tustin racial demographic data is provided in Table H-II-13. The most common race/ethnicity amongst the city's population is persons of Hispanic ethnicity (41.22 percent). The second largest population included persons White, Non-Hispanic (30.36 percent) followed by Asian/Pacific Island, Non- Hispanic (21.93. percent). Minority populations (non-White) are considered special needs population.Additional data and analysis is provided in Appendix D regarding racial and ethnic patterns within Tustin. TABLE H-11-13 RACE AND ETHNICITY (Tustin,CA CDBG)Jurisdiction Race/Ethnicity Count Percent White,Non-Hispanic 24,289 30.36% Black,Non-Hispanic 1,926 2.41% Hispanic 32,982 41.22% Asian/Pacific Island, Non- 17,542 21.93% Hispanic Native American, Non- 418 0.52% Hispanic Two+Races,Non-Hispanic 1,949 2.62% Other,Non-Hispanic 169 0.23% Source:County of Orange,Analysis of Impediments,2020 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-12 SEPTEMBER 2021 Persons With Disabilities Physical and developmental disabilities can hinder access to housing units of traditional design and potentially limit the ability to earn an adequate income. According to the 2013-2018 ACS, 6.89 percent or 5,525 persons in Tustin between 18 and 65 years of age reported a disability in 2018. While 6.12 percent or 4,905 total persons over age 65 reported a disability in 2018. 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 1.1 and 2.5). The City's process and policies to provide reasonable accommodation to populations with disability are discussed within Housing Constraints,below. Additional information is also provided in Appendix D. Large Households The U.S. Census Bureau considers a household containing five or more persons is a large family. According to the County Al, the city contains 3,775 large family households. 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 lower-income, frequently resulting in the overcrowding of smaller dwelling units and accelerating unit deterioration. Data shows that the large families experience greater proportions of housing problems than other family types in the city (see Appendix D). Special needs of large family households in the city and policies to address identified needs are further discussed in Appendix D. Female-Headed Households Female-headed households require special consideration and assistance because of their greater need for daycare, health care, and other supportive services. Female- headed households with children, in particular, tend to have lower-incomes, thus limiting housing availability to this group. According to 2014-2019 ACS, there are 3,684 female householders and 1,799 female householders with children in the city. As identified in Appendix D, one census tract, 755.14, contained a substantial population of female-headed households. Additionally, 75 to 100 percent of households in this census tract were also identified as low to moderate income. Special needs of female-parent households in the city and policies to address identified needs are further discussed in Appendix D. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-13 SEPTEMBER 2021 Farmworkers Farmworkers are traditionally defined as persons whose primary incomes are earned through seasonal agricultural work. Farm workers have special housing needs because they earn lower incomes than many other workers and move throughout the season from one harvest to the next. Statewide, farmworker housing is of unique concern and of unique importance. While only a small share of SCAG region jurisdictions have farmworkers living in them, they are essential to the region's economy and food supply. According to the 2014-2018 ACS, 415 residents of Tustin's residents were employed in agriculture,forestry,or fishing,and hunting occupations,with 258 being employed full-time, year-round. Tustin is an urbanized community with no undeveloped parcels zoned for agriculture as a principal use; however, some residential zones allow a range of agriculture and related uses. However, some farmworkers may commute to nearby farming operations outside of the city. TABLE H-II-14 TUSTIN EMPLOYMENT IN AGRICULTURE INDUSTRY,2018 Total Percent Employment 415 0.98% Total in agriculture,forestry,fishing,and hunting 258 0.86% Full-time, year-round in agriculture, forestry, fishing, and hunting Source:American Community Survey 2014-2018 5-year estimates. Persons Experiencing Homelessness 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 challenging 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. State law (Section 65583 (1) (6)) mandates that municipalities address the special needs of homeless individuals within their jurisdictional boundaries. The U.S. Department of Housing and Urban Development (HUD) defines homelessness as: (1) Individuals and families who lack a fixed, regular, and adequate nighttime residence and includes a subset for an individual who is exiting an institution where he or she resided for 90 days or less and who resided in an emergency shelter or a place not meant for human habitation immediately before entering that institution; CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-14 SEPTEMBER 2021 (2) Individuals and families who will imminently lose their primary nighttime residence; (3) Unaccompanied youth and families with children and youth who are defined as homeless under other federal statutes who do not otherwise qualify as homeless under this definition; or (4) Individuals and families who are fleeing, or are attempting to flee, domestic violence, dating violence, sexual assault, stalking, or other dangerous or life- threatening conditions that relate to violence against the individual or a family member. a) In accordance with HUD's Continuum of Care (CoC) Program, Orange County's 2019 Sheltered Point In Time Count, Everyone Counts,is a biennial unsheltered count and an annual sheltered count of all individuals experiencing homelessness in the community on a single point in time, took place the night of Tuesday, January 22, 2019. The count revealed that 6,860 individuals in the County were experiencing homelessness. Although some individuals may identify with more than one subpopulation of the individuals counted, 52.02 percent were chronically homeless, 33.73 percent had substance use issues, 31.17 percent had a physical disability, 26.82 percent had mental health issues, 14.03 percent has a developmental disability,9.50 percent experienced domestic violence,and 1.80 percent were HIV/AIDS positive. The City of Tustin had 359 individuals total, 95 unsheltered and 264 sheltered. 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 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. Homelessness is further discussed in Appendix D. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-15 SEPTEMBER 2021 PRESERVATION OF UNITS AT RISK OF CONVERSION State Housing Element law requires an analysis of the potential for currently rent- restricted low-income housing units to convert to market rate housing, and to propose programs to preserve or replace any units "at-risk" of conversion. This section presents an inventory of all assisted rental housing in Tustin, and evaluates those units at risk of conversion during the ten-year,2021-2031 planning period. At-Risk Units Inventory Tustin Gardens is a 99-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 31,2022 and the City has recently been notified that the existing contract has been extended for a new 20-year period which would mean the contract would expire on July 31, 2041. As a result, these housing units are no longer considered at risk for this housing cycle. Westchester Park (150-units), Flanders Pointe (49-units) and Chatam Village (210-units) are other at-risk communities within Tustin that could also be converted towards the end of the planning period. Various restrictions and incentives affect the likelihood that at-risk units will convert to other uses. Depending on the circumstances, different options may be used to preserve or replace the units. Preservation options typically include: (1) transfer of units to non-profit ownership; (2)provision of rental assistance to tenants using other funding sources; and (3) purchase of affordability covenants. Transfer of Ownership Transferring ownership of an at-risk project to a non-profit housing provider is generally one of the least costly ways to ensure that the at-risk units remain affordable over an extended period of time. By transferring property ownership to a non-profit organization, low income restrictions can be secured and the project would potentially become qualified for additional governmental assistance. This may be an option for Westchester Park,Flanders Pointe and Chatam Village developments and City staff will explore this option and others as a program to maintain the at-risk units. Rent Subsidy Tenant-based rent subsidies could also be used to preserve the affordability of housing. Similar to Section 8 vouchers, the City, through a variety of potential funding sources,could provide rent subsidies to tenants of at-risk units. The level of the subsidy required to preserve the at-risk units is estimated to equal the Fair Market Rent ("FMR") for a unit minus the housing costs affordable by a lower income CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-16 SEPTEMBER 2021 household. The FMR for Orange County for Fiscal Year (FY) 2020 and 2021 is identified below. TABLE H-II-15 ORANGE COUNTY FAIR MARKET RENT,2020-2021 Year Efficiency One- Two- Three- Four- Bedroom Bedroom Bedroom Bedroom FY 2021 $1,678 $1,888 $2,331 $3,227 $3,716 FY 2020 $1,563 $1,785 $2,216 $3,098 $3,578 Source:HUD User FY 2021 Fair Market Rent Documentation System Purchase of Affordability Covenant Another option to preserve the affordability of at-risk units is to provide an incentive package to the owner(s) to maintain the project as affordable housing. Incentives could include writing down the interest rate on the remaining loan balance, providing a lump-sum payment, and/or supplementing the rents to market levels. The feasibility and cost of this option depends on whether the units are too highly leveraged and interest on the owner's behalf to utilize the incentives found in this option. Table 23 of Appendix B 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. Programs for Preservation of At-Risk Units The City will make efforts to preserve units "at risk" at, Westchester Park, Flanders Pointe and Chatam Village. The cost of acquiring and preserving each of the at-risk developments is less than replacing the units with new construction. The actual amount required to preserve each project 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 DRAFT HOUSING ELEMENT GENERAL PLAN II-17 SEPTEMBER 2021 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. Housing trends and data, specifically regarding special needs groups, are discussed in Appendix D. Section C.2.5 identifies disproportionate housing needs of various groups within the City of Tustin. Disproportionate Housing Needs generally refers to a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing need when compared to the proportion of members of any other relevant groups, or the total population experiencing that category of housing need in the applicable geographic area. For purposes of this definition, categories of housing need are based on such factors as cost burden and severe cost burden, overcrowding,homelessness,and substandard housing conditions. The following conclusions were identified upon analysis of available data and documentation available regarding housing trends and characteristics within the City of Tustin: • A higher percent of non-White households experienced housing problems than White households in Tustin. • Non-White households that experienced the greatest proportion of housing problems include Hispanic (71.19 percent),Black(62.40 percent),and Native American(50.00 percent). • The same trend occurred for the county population. • A higher proportion of households are considered overcrowded in southern Tustin,which overlaps with census tracts that contain greater proportions of minority population and low-income households. • According to the Orange County's 2020 Analysis of Impediments to Fair Housing Choice (AI), displacement of residents due to economic pressures may be a significant contributing factor to fair housing issues in Orange County and,in particular,in parts of Orange County that have historically had concentrations of low-income Hispanic and Vietnamese residents. Additional data and analysis of housing issues can be found in Appendix D. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-18 SEPTEMBER 2021 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 High cost of renting or buying adequate housing is a primary ongoing constraint. High construction costs, rising land costs, labor shortages, market financing constraints and neighborhood opposition make it expensive for developers to build housing. Construction Costs: Construction costs can vary depending on the type of development with multi-unit housing typically less costly to construct than single-unit homes. Such costs are also dependent on materials used and building height, as well as regulations set by the City's adopted Building Code. The International Code Council (ICC) compiles an indicator of construction costs at six(6)month intervals which is referred to as'Building Valuation Data".The ICC was established in 1994 with the goal of developing a single set of national model construction codes, known as the International Codes, or I-Codes. These estimates provide the average cost of labor and materials for typical Type VA wood frame housing construction and are based on "good quality" construction, providing for materials and fixtures well above the minimum required state and local building codes. In February 2021,the ICC estimates that the average per square foot for good quality housing was approximately $125.18 for multi-unit housing and $138.79 for single- unit homes. A reduction in amenities and quality of building materials (above a minimum acceptability for health, safety, and adequate performance) could lower costs and associated rents and 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 DRAFT HOUSING ELEMENT GENERAL PLAN II-19 SEPTEMBER 2021 According to an Orange County Register article published on March 12, 2021, California contractors are continuing to be confronted with a higher cost for materials, problems with the supply chain and project delays or cancellations due to COVID-19 - one year after the worldwide pandemic began. As a result, the overall cost of the housing unit is affected and this cost is a considerable factor during this particular planning period. Another key component of construction cost is labor. Depending on the availability of construction worker and their respective wages can also affect the overall cost of the housing.The State of California does not have sufficient numbers of construction workers to meet Governor Newson's stated housing goals. According to a study for Smart Cities Prevail,the State of California has a shortage of over 200,000 construction workers. The study concludes that California has lost about 200,000 construction workers since 2006 as a result of the economic recession and/or workers finding work in other industries. This,in turn,has impacted housing costs. Overall, although construction costs are a significant portion of the overall development costs,they are consistent throughout the region and,especially in light of land costs,are not considered a major constraint to housing production in Tustin. Land: Raw land and improvement costs comprise approximately 40-50 percent of the total development costs of a residential unit. Prices for land in Tustin have risen significantly in recent years. As referenced previously, basic construction costs including labor and materials for residential projects have increased rapidly, and together with land costs,have increased the cost of housing making homeownership unattainable for many households. These costs are fairly consistent throughout the region as the main components of labor and materials do not fluctuate much be area. Preparation of a site can be a substantial cost,but the variations and factors are more a function of the site,than of the jurisdiction. Financing: The availability of financing affects a person's ability to purchase or improve a home. Interest rates can have an impact on housing costs. Some mortgage financing is variable rate, which offers an initial lower 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. Even if Tustin homebuyers are able to provide a 3 percent down-payment and obtain a 3.2 percent 30-year loan(average loan rate for FHA or VA guaranteed loans for May CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-20 SEPTEMBER 2021 2021), 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 H-II-16 and H-II-17). TABLE H-11-16 NEW AND RESALE PRICE OF HOMES AND CONDOMINIUMS TUSTIN AND NEIGHBORING JURISDICTIONS 2020 Median Home Median Home %Change from city Zip Code Price-Q2 2020 1 Price-Q2 2019 1 2019 Tustin 92780 $702,000 $648,500 +8.2% Tustin 92782 $779,000 $805,000 -3.2% 92801 $495,000 $525,000 -5.7% 92802 $520,000 $557,500 -6.7% 92804 $565,500 $573,000 -1.3% Anaheim 92805 $582,500 $550,000 +5.9% 92806 $631,000 $635,000 -0.6% 92807 $721,500 $703,000 +2.6% 92808 $703,000 $688,000 +2.2% 92840 $682,000 $552,500 +23.4% 92841 $715,000 $615,000 +16.3% Garden Grove 92843 $431,000 $560,000 -22.9% 92844 $425,000 $485,000 -12.4% 92845 $749,000 $659,000 +13.7% 92602 $1,300,000 $1,243,500 +4.5% 92603 $970,000 $1,087,500 -10.8% 92604 $811,500 $750,000 +8.2% 92606 $815,000 $799,500 +1.9% Irvine 92612 $686,500 $663,500 +3.5% 92614 $820,500 $730,000 +12.4% 92618 $920,000 $966,750 -4.8% 92620 $954,500 $1,030,000 -7.3% 92865 $755,000 $640,000 +18.0% 92866 $735,000 $738,500 -0.5% Orange 92867 $737,500 $737,000 +0.1% 92868 $550,000 $472,500 +16.4% 92869 $655,250 $670,000 -2.2% 92701 $300,000 $380,000 -21.1% 92703 $575,000 $493,000 +16.6% Santa Ana 92704 $550,000 $510,000 +7.8% 92705 $1,060,000 2 $930,0002 +17.2% 92706 $730,000 $650,000 +12.3% 92707 $497,500 $500,000 -0.5% 1 Data include all home sales,new and resale,and condominiums. 2 Includes Lemon/Cowan Heights(outside Tustin) Source:Orange County Register,August 12,2020,August 21,2019,August 18,2019,August 15,2019,August 14,2019 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-21 SEPTEMBER 2021 The greatest impediment to homeownership, however, is credit worthiness. According to the Federal Housing Authority, lenders consider a person's 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. TABLE H-11-17 AVERAGE RENTAL RATES 2021-1ST QUARTER CITY OF TUSTIN Number of Bedrooms Number of Average Square Average Units Footage Rent Studio 834 425 SF $1,678 1 bedroom 3,727 516 SF $1,888 2 bedroom 6,325 720 SF $2,331 3 bedroom 2,044 1,087 SF $3,227 4 bedroom 576 N/A $3,716 5 or more bedroom 94 N/A $N/A Total 13,600 687 SF $2,568 Source:OCACS 2018 Housing Characteristics for Cities Places(2020),HUD FY 2021 Fair Market Rent(2021),Rent Cafe(2021) "2021 Fair Market Rent indicates 92780 zip code. 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-22 SEPTEMBER 2021 Governmental Constraints In addition to market factors, housing affordability is also affected by factors in the public sector. Local policies and land use regulations can impact the price and availability of housing,and the provision of affordable housing. 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. Residential Land Use Designations 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 E-4 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 H-II-18). Residential projects, regardless of the number of units or density (even if density proposed is below anticipated level of density or development standard for that zone), can submit a preliminary review application for City Staff review and obtain City comments prior to submitting a formal application for review. This review process takes 30-days, requires a deposit and is facilitated by the Planning Division with written comments provided from the Building, Planning and Public Works Divisions or any other applicable divisions or agencies to the developer or applicant. This process facilitates a more streamlined review of a project prior to submitting for a formal review and provides certain project assurances to the developer or applicant. Other processes were presented as Programs in the Housing Element to support in streamlining development applications, including 1.11 Development and Permit Streamlining and 1.5 Zoning Code Streamlining Program.When a formal application CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-23 SEPTEMBER 2021 is submitted for a new construction project in the R-2 or R-3 zones formal Design Review is required and approval by the Planning Commission. Approximate application processing time can range from 3 months, for smaller projects, to 9 months, for larger projects depending on if there is a subdivision included with the application and the level of environmental review. Parking requirements could be a potential constraint for single-family and multi- family residential development. Required parking for multi-family projects is two covered spaces, in either a garage or carport, for each dwelling unit, plus one unassigned guest space for every four units. For Tustin,this is not considered overly excessive given the older age of many of the existing multiple family residential units and the fact that many units or complexes have non-conforming parking. Parking requirements for single-family residential includes two-car garage per dwelling, or three-car garage per dwelling with five or more bedrooms. Parking is a significant area of concern within several areas of the City, especially in the higher-density residential areas. At the time of this update, the City is currently reviewing the City's permit parking requirements and overall process.A new program has been included in this Housing Element, Program 1.2a., that commits to adopting new objective design standards that facilitate high-quality residential development; while ensuring the provision of adequate parking. Additionally, Program 1.14 a. commits to promoting adaptive reuse of historic resources for affordable housing and evaluate the use of alternate parking strategies.As existing multi-family parcels are recycled to conform to current parking requirements, the parking provided is more reflective of the actual occupancy and potential demand within the unit. A decrease in the number of required residential off-street parking spaces is allowed and limited to a maximum reduction of one (1) parking space through approval of a Minor Adjustment. Minor Adjustments are reviewed administratively by the Zoning Administrator and can take approximately 1 to 3 months to process the application. Within the Multi-Family Residential District (R-3), a 35-foot height limitation and 65 percent coverage preclude the development of housing projects with building height above the 35-foot height limitation. While these height limits may place some restrictions on housing development, these limits are designed to maintain compat- ibility of land use intensity. They ensure proper and effective transportation within the community and are commonly used by local governments as a development tool. 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 for such development projects have been granted. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-24 SEPTEMBER 2021 The Land Use Element indicates that residential development that supports commercial uses may also be permitted in the City's Old Town commercial area and along a portion of Red Hill Avenue just north and south of the Interstate-5 freeway. 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 the respective specific plans for each area. New multi-family residential development continues to be an important supporting use for the City's mixed-use commercial/retail development areas. Specific Plans In 2018, the City of Tustin has adopted two specific plans, which offer a range and mix of uses and housing types.The City anticipates that while much of the residential growth will continue to be focused within the Tustin Legacy Specific Plan as the City owns and controls this land, the two specific plan areas will also accommodate additional residential units. These plans include: CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-25 SEPTEMBER 2021 H � m O m O m m O w o bD b0 4J t� b0 4J t� b0 4J N to to to ci5 �_ � � C) W ^C O C _ H z LO LO 00 I � x a F o w w w N � w H W m a a a w x � d v C) C) C) � U u1 V CA O M m w U C CG H In y � CA to m ( \ to ± 4 $ _ to ± 4 $ _ .ƒ/ / ƒ \ e .2 / % / \ $/ / $ / $ / \ $/ / $ / $ E \ § E \ / \ \ / N § / \ / \ k _ ƒ ƒ ƒ \ % O ƒ ƒ ƒ , ƒ ƒ ƒ ƒ LO r r r ƒ ƒ ƒ ƒ ^ 9 \ ƒ ƒ ƒ \ ƒ / $ $ / $ \ \ / \ \ / \ Lf) \ % / \ % E E E o f o f o f o f o f /ƒ cn cn 2 ƒ Z ƒ Zz \ \ \ \ \ \ Pw CN ( / \ // E ( k \ /$ [ j = o m $ � & z = § $ m u = o ± / \ \ \ � ± § \ e / / \ � ± § [ e / � ± m 0 9 } / / � ± [ \ [ � / \ E / � m \ \ � ° / to / # \ e ./ _ = f g \ \ ƒ ( \ r / § / \R / / ( R 2 � � \ \ ƒ3 / \ 2e • Downtown Commercial Core Specific Plan(adopted July 3,2018) • Red Hill Avenue Specific Plan(adopted November 6,2018) The Downtown Commercial Core Specific Plan (DCCSP) introduced mixed-use and infused the potential for 887 units into the area through a Residential Allocation Reservation (RAR) review process. To date, 140 new non-mixed-use units were constructed. While this development entailed all market rate units, the developer participated in the in-lieu fee option regarding affordable housing provisions. The Red Hill Avenue Specific Plan (RHASP) introduced mixed-use to the area and similarly identified the potential for 500 new units in conjunction with the RAR review process.No units have been constructed in this area to date;however,there is an application pending for a development project currently under consideration within this area. East Tustin Specific Plan 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. Tustin Legacy Specific Plan (formally MCAS Tustin) 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 MCAS Tustin Specific Plan that allowed for additional renter-occupied units, including affordable rental units. 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-29 SEPTEMBER 2021 Within Neighborhood G of the Specific Plan,there is a completed 225-unit affordable housing community with a 375-unit single-family neighborhood. This area is intended to include a range of housing types for single-family and multi-family residential (i.e., detached homes,carriage way units,courtyard housing,townhomes and flats. Similar to Neighborhood D, this area allows for up to six (6) stories in building height for multi-family,commercial and non-residential and up to three (3) stories in height for single-family units, thereby providing opportunities for the development of higher density residential products. Tustin Legacy has been undergoing development since the early 2000's. Ultimate buildout is expected by 2035. There are two primary factors that influence the timing of development at Tustin Legacy: 1) market demand for the uses planned;and 2) the complexity and timing of environmental clean-up efforts. Where adequate infrastructure is in place and supports new development, this Phasing Plan would enable earlier response to positive market conditions and result in more rapid buildout of the Specific Plan area. Where a proposed development project is not supported by existing infrastructure, conditions of approval shall be established to ensure that appropriate infrastructure is constructed in accordance with this Phasing Plan and mitigation adopted in the supporting environmental documentation. Appendix B includes discussion of available housing opportunity within the MCAS Tustin Specific Plan area. 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. 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, CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-30 SEPTEMBER 2021 although assistance may be required for units offered at prices affordable to lower income households. Overlay Zones and Other Districts Planned Development (PC) Zone 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. Cultural Resource District The Cultural Resource District is an overlay district that applies to those properties, structures and sites that are designated within the City. Currently there are 397 total residential structures (365 single-family and 32 multi-family), 73 commercial structures, 13 mixed use and 12 institutional structures designated as historic within the City. All of the residentially-zoned sites within this district can accommodate ADUs. Density Bonus and Workforce Housing Ordinance Government Code Section 65915 requires a jurisdiction to provide density bonus or other incentives or concessions for the production of lower income housing units or for the donation of land within the development if the developer agrees to construct a specified percentage of units for very low, low, and/or moderate-income households. Density bonus is a California state requirement and as a result, is not subject to discretionary review of local agencies or jurisdictions. Current state law requires that jurisdictions must provide density bonuses and development incentives to all developers who propose to construct affordable housing on a sliding scale, whereby the amount of density bonus and number of incentives vary according to the number of affordable housing units to be provided. AB2345 passed in September 2020, amended the Density Bonus Law to increase the maximum density bonus from 35 percent to 50 percent.For a developer to obtain the maximum density ,a project must set aside a higher percentage of total units at a certain income level.Similarly,levels of density bonus between 35 and 50 percent are granted on the sliding scale. The State's Density Bonus Law and City's Workforce Housing Ordinance (adopted in 2018)encourages development of housing for lower income households within the CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-31 SEPTEMBER 2021 Red Hill Avenue and Downtown Commercial Core Specific Plan areas. The City's density bonus program is incompliance with current State law. Housing or 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. Facilities serving more than six (6) persons are conditionally permitted within Planned Development District (P-D),Multiple Family Residential District (R- 3),Suburban Residential District(R4),and Retail Commercial District(C-1). It is the policy of the City of Tustin to comply with the federal Fair Housing Amendments Act of 1988 and the California Fair Employment and Housing Act to provide individuals with disabilities reasonable accommodation in regulations and procedures to ensure equal access to housing and to facilitate the development of housing for individuals with disabilities.Tustin City Code Section 9278,Reasonable Accommodation, addresses this and establishes a process for individuals with disabilities to make requests for reasonable accommodation when reasonable accommodation is warranted based upon sufficient evidence. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-32 SEPTEMBER 2021 A completed development application form is required providing specific information as identified in TCC Section 9278d1.A filing fee in the amount required for a Minor Amendment application pursuant to the City's current adopted fee schedule is required to accompany the completed application. The property for which the reasonable accommodation is being requested must be in compliance with the codes and regulations existing at the time of application submittal. Reasonable accommodation requests are considered without a public hearing by the Community Development Director. The Director may either grant, grant with conditions,or deny a request for reasonable accommodation in accordance with the required findings set forth in TCC Section 9278f. If additional entitlement(s) are requested in addition to the request for reasonable accommodation, then, the approval body for the entire application, including the request for reasonable accommodation,is the same body that acts on both.Other provisions,as applicable, are identified in Section 9278 of the TCC. The City's Community Development Department may inspect annually or more often. A deed restriction is recorded against the property to ensure compliance with conditions of approval, potential removal of the accommodation, and use restrictions. Homeless Accommodation Recent legislation (AB 101 and AB 139) require revisions to local zoning regulations regarding the provision of Low Barrier Navigation Centers (LBNC) and emergency shelters.Specifically,AB 139 requires the assessment of shelter needs be based on the most recent Point-in-Time Count and the parking standards for shelters be based on staffing levels. Homelessness within the City is further discussed in Appendix D. Emergency Shelters,Transitional Housing,and Supportive Housing To address the regional needs of homeless individuals and families,the City of Tustin participates in the Continuum of Care(CoC)program sponsored through the County of Orange. The purpose of the Continuum of Care Homeless Assistance Programs is to fund projects that will fill gaps in locally developed Continuum of Care systems to assist homeless persons to move to self-sufficiency and permanent housing. An important element of meeting this objective is to fund projects that will meet the goal of ending chronic homelessness. The Orange County Continuum of Care system consists of six basic components: Advocacy on behalf of those who are homeless or at-risk of becoming homeless; A system of outreach, assessment, and prevention for determining the needs and conditions of an individual or family who is homeless; Emergency shelters with appropriate supportive services to help ensure that homeless individuals and families receive adequate emergency shelter and referrals; Transitional housing to CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-33 SEPTEMBER 2021 help homeless individuals and families who are not prepared to make the transition to permanent housing and independent living; Permanent housing, or permanent supportive housing, to help meet the long term needs of homeless individuals and families; Reducing chronic homeless in Orange County & addressing the needs of homeless families&individuals using motels to meet their housing needs. As part of the City of Tustin's participation in the CoC program, and in partnership with 2-1-1 Orange County, on January 22,2019,a Point-In-Time Homelessness count was conducted in Tustin.The count provided data which indicated that 73 percent of Tustin's homeless population lives in Transitional Housing or Emergency Shelters, while 26 percent reside in places not meant for human habitation. The data collected from the Point-In-Time Count will provide direction to the City of Tustin's overall efforts to address homelessness within the City. In March 2019, the City of Tustin opened a new low-barrier temporary homeless shelter in the Tustin Legacy Specific Plan area, with 57 emergency shelter beds for men, women, and families with children. Recently, in response to the Covid-19 pandemic,additional facilities have been installed and the capacity of this shelter has been increased to 84 beds. This facility is operated by Temporary Shelter, Inc., and will include a variety of wrap-around and other supportive services to be administered at the site. This is a legally-compliant shelter which does not have any religious component. This site is being established to ensure that unsheltered homeless individuals with ties to Tustin have the opportunity to be provided with a bed and shelter. The site also has potential to expand in the future, should the need arise. In addition to the City's participation in the County of Orange Continuum of Care, the City of Tustin will continue to provide funding to homeless service providers who provide emergency and transitional shelter resources,along with additional support services for homeless and at-risk homeless individuals. In the Tustin Legacy Specific Plan, Planning Area 3 is a designated transitional/emergency housing site currently operated by the Orange County Rescue Mission. This site includes the reuse of two existing barracks (Building Numbers 553 and 554) and accompanying parking areas for an emergency homeless shelter or transitional housing for homeless persons. Supporting social services and food services are also allowed within this Planning Area. Transitional Housing The City of Tustin currently supports transitional housing facilities,including Village of Hope and House of Ruth. The House of Ruth is within the City's R4 zone and Village of Hope is within the Tustin Legacy Specific Plan as permitted in the zones. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-34 SEPTEMBER 2021 The House of Ruth is a seven (7) unit multi-family residential facility and family resource center to provide transitional housing and related support to families with children who are experiencing homeless or are at-risk. The Village of Hope is a 387 transitional housing program for homeless men, women and children. Transitional Housing is allowed in zones where multi-family housing is permitted. Supportive Housing Supportive Housing - 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. Recent changes to State law under AB 2162 and AB 2988 would expand the provision of supportive housing to be permitted by right where multi-family and mixed uses are permitted. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-35 SEPTEMBER 2021 Residential Care Facilities: In 1969,the Lanterman Developmental Disabilities Services Act(aka Lanterman Act) was adopted by the California state legislature which stipulates that small State- licensed residential care facilities for six or fewer persons must be treated as regular residential uses and permitted in all residential districts; the City of Tustin is compliant with the Lanterman Act. State-licensed residential care facilities for more than six persons are similar to "rest homes, extended care facilities, convalescent hospitals and sanitariums" as defined in the Tustin City Code and are conditionally permitted in the R-3 and R-4 zones.The Land Use Element and Tustin Zoning Code provide for the development of multifamily housing in the R-2, R-3 and R-4 zones. Traditional multifamily housing for persons with special needs, such as apartments for seniors and the disabled, are considered regular residential uses permitted in these zones. The City's land use policies and zoning provisions do not constrain the development of such housing. State-licensed residential care facilities for more than six persons are also conditionally permitted within the City's Tustin Legacy Specific Plan, Red Hill Avenue Specific Plan and Downtown Commercial Core Specific Plan areas.Potential conditions for approval for these uses may include hours of operation, security measures, loading requirements, and management. Conditions would be similar to those for other similar uses in the same zones and would not serve to unduly constrain the development of residential care facilities for more than six persons. Occupancy standards for residential care facilities are the same as occupancy standards for all other residential uses. The City has not adopted a spacing requirement for residential care facilities. 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. Additionally, planning fees cover the cost of City resources in reviewing and assisting in processing of proposed ministerial and discretionary planning actions. 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-36 SEPTEMBER 2021 detail required site improvements and provides a list of fees associated with development(Table H-II-19a,H-II-19b,and Figure H-II-1). Planning and Permitting fees are charged on an at-cost basis to cover staff services and administrative expenses for processing development applications.Development impact fees are required to provide essential services and infrastructure to serve new residents. Impact fees are governed by State law to demonstrate a nexus between development and potential impacts. The City permitted a condominium project of 140 units in the Red Hill Avenue Specific Plan Area. The project fees for this project were $496,780.25. Fee costs respective to overall development costs and anticipated cost of units are considered insignificant. 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 price. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-37 SEPTEMBER 2021 H � Z N W O N w � ca m n m L _ a h U) � a � � x 9 LU ° J-- 04.1 N 3 a Q c a a yy N U C LL p Y1m N jQ C L v v m G P W t4 fi'O 3 77 O Q [4 t0 [0 R! V a m o Y N ^a � rtS G c G Q 7 y u7 oli m w1 N L M N A Fy c7 a s am n dcm ` � a � aa - a " a s a s 0 0 0 o `? o w ' o m N � m aai to co (c �. LO LO LO nel) G `aa y e a o o GJ 4a ua 4% 4 4% � 4A � � a Q t O � v �� � 4 � a4 � u3 41; N y tL D U4,4 — W — O 4? Ul N a G � n c 3 � x rn a a 00 G p N t7 N 7 y It co ad Q Q K 3 .12 a Na y o oLy m � a � m o N y � Lyac a _• G w o V] it Z O L '' •O c = W N N F- J � § mom aIL c c 4 — ¢ m n ior si3 0 m `° U a � m � 4 on U m m m i° (PCP c w o a C a p v ti. c c •.r - N a o` ca � 'cL al aN t 0 0 LU d. U C W W O LL W Unil 0 U y LL Z (/] 0 Z Z Ua Ow Hz � w U c� \ § m \ / o \ m / \ / \ � 2 / % D W /D § ] § & 2 / q \ ® uj /\ \ f/ - f \ \ � j / / \ 04 o / / } N \ f LL_ \/ W \ LLI LL 7 § } / \ f § \ $ \ [{ ) /} k C \ @ kE \ E ] _ Et > 7 &{ § ° -0 \ \ 2 / _ ° / } \/ E \/ § S \ 58f 6 CL E \ / \ / / \ / E /\ � k / \ ° ` - — S m N 2 _ 2@ e $ ( 2 g R f r % 9 > _ m - G $ Q $ \ D $ Q } [ & ( W - } ƒ f / E �2gE $ E k TO >, m � k + k � ± 0 \ 7 \ \ E § ) Jf } $ co Q LL m 2 � , 2 ¢ w k \ ) k $ ƒ \\/\\ \ E § E o CO z z 2 > \ \ cN c = = o _ \ g \ � § � / 777£ § gclj - \ 72 a) \ a) % 0 0 © } Q = E� � ~ ~ % kk \ \ / ) ZD = k » m E = o u \ c a. cLU ) / m I % § L) I ■ o ± . i ( 2 � W r- 0 f � LL / �LL \ o z2 % < \ \ P / 4 0 \ � U / Figure H-II-1. Impact Fee Zones ® MAJOR THOROUGHFARE AND BRIDGE FEE PROGRAM "T Ta MALE FOOTHILDEASTERN TRANSPORTATION CORRIDOR AGENCY r'Y i t jZONE 8! r` ftt J` ZONE 6Al i j wan IT. ZONE J ZONE Bwr icMim i h4, 7 ! r }' ZONE B . 1VSTIN LEGACY rk TU TI pp�� � `� Tusny$;May p 4, rr,, � rr u: i 7]bi my d Lean upanp��n-QYp14Mq Jin 72,&10-9dTm CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-40 SEPTEMBER 2021 Figure H-II-2. Planning Fees PLANNING DIVISION AND REDEVELOPMENT FEES TYPE OF CHARGE (See "Criteria for Determining FY 08-09 Fees Plannina Fees"below) 77f(35 Appeals '/2 Application Fee Certificate of Compliance $95.00 City Attorney/Special Counsel/City and Agency Staff/ Actual Costs(2) Outside Consultants Code Amendment (2)(10) $950.00 Concept Plan Review(2)(10) $3,000 Deposit(s) Conditional Use Permits and Amendments(2)1'0J Major $3,000 Deposit(9) Minor(new development) $665.00 Minor(existing development) $350.00 Amendment to Conditions of Approval $350.00 ABC License $255.00 Time Extensions $250.00 Design Reviews and Amendments(2)(10) Major New $3,000 Deposit(9) Major Remodel $635.00 Minor New $510.00 Minor Remodel $350.00 Sign $65.00 Amendment to Conditions of Approval $350.00 Time Extensions $250.00 Development Agreements(2)(10) $2,000(2)(11)(12) Miscellaneous Research / Legal opinions for Extraordinary Actual Costs Research (City Attorney; Special Counsel Fees; City and/or Agency staff;and outside consultant costs) Environmental EIR Major (Deposit) $4,000(2)(4) EIR Minor(Deposit) $2,500(2)(4) Supplemental EIR Actual Cost(2) Addendum EIR Actual Cost(2) Initial Study $95.00 Negative Declaration $125.00(4) Resolution No.08-60 Page 8 of 57 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-41 SEPTEMBER 2021 Figure H-II-2. Planning Fees(cont.) PLANNING DIVISION AND REDEVELOPMENT FEES TYPE OF CHARGE (See "Criteria for Determining FY 08-09 Fees Planning Fees"below) 77f(35 Notice of Completion $50.00 Notice of Determination $25.00 Notice of Exemption $25.00(4) General Plan Amendments Land Use Map $985.00 Major Text Amendment $2,000(2) Minor Text Amendment $750.00 Large Family Day Care Review $350.00 Lot Line Adjustment $255.00 Lot Merger $190.00 Miscellaneous Documents $190.00(3) Newsrack Permit (per permit location $125.00 (4+permit locations) $500.00 deposit Temporary Use Permit(TUP) $95.00 Time extension on TUPs $50.00 Subdivisions and Amendments(2)(10) Tentative Tract Map $3,000 Deposit(9) Tentative Parcel Map $3,000 Deposit(9) Tentative Tract Map(ET Project) $2,730 Tentative Tract Map(ET Sector) $5,715 Final Tract Map $1,335 Final Parcel Map $1,110 Amendment to Conditions of Approval $350.00 Reversion to Acreage Map Fee+$65.00 Time Extension $250.00 Master Association Documents,CC&R review Actual Cost(2) Use Interpretations $125.00 Variances and Amendments(z)(10) Major $3,000 Deposit(9) Minor $380.00 Resolution No.08-60 Page 9 of 57 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-42 SEPTEMBER 2021 Figure H-II-2. Planning Fees (cont.) PLANNING DIVISION AND REDEVELOPMENT FEES TYPE OF CHARGE (See "Criteria for Determining FY 08-09 Fees Planning Fees"below) 777 Amendments to Conditions of Approval $350.00 Time Extensions $250.00 Zone Change $950.00 Zoning Administrator Action Administrative Adjustment/Minor Adjustments $95.00 Soil Remediation $95.00 Minor Conditional Use permits(existing development) (5) Time Extensions (6) Amendment to Conditions of Approval m Design Review(RDA) (8) Written zoning confirmation/non-conforming status letter $50.00 (Hourly) Planning review of plan check submittals 20%of Building Division Plan Check or Permit Fee CRITERIA FOR DETERMINING PLANNING FEES CONDITIONAL USE PERMITS MAJOR CUP: New uses in combination with new construction or existing development in excess of 5,000 square feet of floor area,new auto services or repair related uses, and new apartment or condominium projects in excess of 3 dwelling units, condominium conversions. MINOR CUP: New uses in combination with new construction or existing development with 5,000 square feet or less of floor area, new uses within existing structures,expanded or modified existing uses, signs, new apartment or condominium project with 3 dwelling units or less,second single family dwellings. Resolution No.08-60 Page 10 of 57 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-43 SEPTEMBER 2021 Figure H-II-2. Planning Fees (cont.) CRITERIA FOR DETERMINING PLANNING FEES DESIGN REVIEW MAJOR NEW. New development in excess of 5,000 square feet of floor area or building relocations. MINOR NEW: New development with less than 5,000 square feet of floor area. MAJOR REMODEL: Modifications to existing structures or site which include an increase in existing floor area in excess of 50%, and/or existing fagade or site modifications which constitute a change in 3 or more major design elements on a building elevation or site which result in a complete fagade upgrade. Definition of an element includes windows, doors, colors, materials, parking lot changes,etc. MINOR REMODEL: Modifications to existing structures which include an increase in existing floor area of 50%or less, and/or existing fagade or site modifications which constitute a change in 3 or less major design elements which do not result in a complete facade upgrade, single family homes not part of a subdivision, residential room additions, and new or modified accessory structures associated with existing development. VARIANCES MAJOR VARIANCE: New development that deviates from a specific development standard, all existing development which deviates from a standard by more than 10%. MINOR VARIANCE: Existing development that deviates from a specific development standard by less than 10%, new single family homes not part of a subdivision,or projects where the site will contain less than 3 new apartments or new condominiums. NOTE:Where there is a question as to what category a project should be classified.the Director reserves the right to determine the applicable category a project should fall within. Footnotes: (1) Includes cursory review of applications by building staff. (2) City Attorney;Special Counsel;City and Agency staff;and outside consultant fees to be reimbursed at the actual cost incurred to City. (3) Examples:Parking Agreements,Access Agreements,Deed Restrictions. Resolution No.08-60 Page 11 of 57 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-44 SEPTEMBER 2021 Figure H-II-2. Planning Fees (cont.) Footnotes: (4) The applicant will be required to provide the City with a cashier's check for$43,payable to the Orange County Clerk-Recorder within 48 hours of project approval, for filing of environmental documents. Substantial additional fees may be required by the Orange County Clerk-Recorder when the City files the Notice of Determination, in accordance with A8 3158, as established by the California State Department of Fish and Game.If additional fees are required,the applicant will be required to provide the City with a cashier's check for the additional fees,payable to the Orange County Clerk-Recorder within 48 hours of project approval. (5) See fee for Minor CUP(existing development). (6) See fee for Time Extensions(CUP,Design Review,Variance and Subdivision) (7) See fee for Amendment to Conditions of Approval(CUP,Design Review,Variance,and Subdivision) (8) See fees for Design Reviews. (9) Initial deposit fees are required at the time of application submittal for large developments.Actual staff costs will be subtracted from the deposit and any additional staff costs incurred above the initial deposit will be due to the City. (10) Fees are intended to cover the cost of processing a standard application typically including but not more than two (2) meetings with the applicant. Requests or requirements for additional staff meetings, responses to correspondence/e-mails,the need for the City to engage outside consultants are to be reimbursed at actual staff and City Attorney/Special Counsel costs. (11) This fee is for a Development Agreement as provided for under Government Code Section 65864 and does not apply to an Agency or City"Disposition and Development Agreement'. A deposit of S2,000 shall be required and actual costs reimbursed based on the same parameters as established in footnote 2,unless an agreement is reached with the developer to modify this requirement. (12) Initial and any on-going deposits and costs to reimburse the City or Agency for actual city attorney, special counsel or actual staff or outside consultant costs unless an agreement is reached with developer to modify this requirement. Resolution No.08-60 Page 12 of 57 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-45 SEPTEMBER 2021 Building Codes and Enforcement: Building and safety codes regulate new construction, alteration, and reconstruction of buildings, and are intended to protect occupants from unnecessary risk of fire, structural collapse, unsanitary conditions, and injury or loss of life. While building and safety codes are adopted for the purposes of preserving public health and safety, and ensuring the construction of safe and decent housing, they have the potential to increase the cost of housing construction and/or maintenance. The City of Tustin's building codes are based on regulations necessary to protect the public health,safety, and welfare of its residents. The City has adopted into its Codes and Ordinances the 2019 California Building Code, based on the 2018 International Building Code, as published by the International Code Council,which establish construction standards for all residential buildings. The City has adopted minor amendments to the CBC, none of which are expected to pose a constraint to development. Compliance with the CBC should not significantly add to the cost of construction since the Code is mandated to be enforced statewide and costs should be relatively uniform across the State of California. Any costs associated with Building Code standards are necessary to protect the health safety and welfare of the citizens. Compliance ensures that all new or renovated buildings are structurally sound,have proper exiting and are equipped with necessary fire protection features. 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 City of Tustin encourages the simultaneous processing of related applications for a single project and the Community Development Department serves as the coordinating agency to facilitate reviews with other in-house departments such as Police,Public Works/Engineering,and Parks and Recreation. Larger-scale discretionary residential projects within the Tustin Legacy area of the City include design review,conditional use permit(s),development/housing and/or reimbursement agreements, tentative tract map, and sometimes minor adjustments or modifications (i.e. minor deviations). For these projects, the environmental analysis has already been completed under the Final Program EIS/EIR for MCAS Tustin and supplemental addendums and other analyses that have been prepared so future projects tier off of the Final Program EIS/EIR for MCAS Tustin which helps to streamline the review. Processing time for these projects may take approximately 6- CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-46 SEPTEMBER 2021 10 months and depends upon the various agreements that may be required between the applicant and the City. For Tustin Legacy, developments under the former Master Developer footprint (approximately 800 acres) are also 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 Tustin Legacy 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 Tustin City 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 in this area. Smaller discretionary residential projects outside of the Tustin Legacy area may include design review, conditional use permit(s), tentative parcel maps and minor adjustments or modifications as well as necessary CEQA analysis. Depending on the project details,additional CEQA review time may or may not be necessary as part of the entitlement application and these projects may take approximately 3-5 months to process. The time to process either large or small-scale residential development applications depends on the completeness of the application at the time of submittal and the team that the applicant has assembled to process their project with City staff. 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 (if the project requires discretionary review) and plan checking departments (if the project does not require a discretionary review) simultaneously review the plans.The Design Review application does not necessarily 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. Project applications which comply 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. As part of Program 1.2,the City will provide and adopt objective design standards to further ensure that the City CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-47 SEPTEMBER 2021 can provide local guidance on design standards to facilitate high-quality,streamlined residential development. These standards would further increase certainty and reduce inefficiencies related to project's design review and approval. As discussed above, when a formal application is submitted for a new construction project in the R-2 or R-3 zones formal Design Review is required and approval by the Planning Commission. Approximate application processing time can range from 3 months, for smaller projects,to 9 months, for larger projects depending on if there is a subdivision included with the application and the level of environmental review. For development proposed that constitutes as a new use in combination with new construction or existing development in excess of 5, 000 square feet of floor area and new apartment or condominium projects in excess of 3 dwelling units or condominium conversions, a Major Conditional Use Permit would be required in addition to Design Review by the City. For new uses with new construction or existing development including 5,000 square feet or less, a Minor Conditional Use Permit would be required in addition to Design Review. Depending upon the parking provided versus that which is required in the Tustin City Code, respective Specific Plan or other planned community,an additional Conditional Use Permit may be required for shared or joint use parking. All projects that trigger a Conditional Use Permit for parking, must be reviewed and approved by the Planning Commission. The number and/or type discretionary applications does not infer that additional time is needed or required to process them. The review of all development is considered and reviewed in a timely manner by City staff. A thorough review and complete review of proposed development is in the interest of public welfare and safety to ensure development would be compatible with existing and future land uses, so as not to induce environmental or health risk as a result of project operation. Therefore, the discretionary or non-discretionary development approval process would be considered reasonable and beneficial, and would not be considered a constraint on housing supply and affordability. For projects of significant benefit to the low-income community,costs can be waived by the City Council. In 2020, City staff developed a streamlined application and implemented a complimentary streamlined review system (i.e., Residential Allocation Reservation or "RAR process") for projects located in the DCCSP and the RHASP. The RAR process, which is an integral part of each plan, is a preliminary review of the project prior to formal submittal for entitlements whereby residential units are potentially allocated to a project based on certain findings. An application with project CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-48 SEPTEMBER 2021 description, parking management plan, scaled and dimensioned site plan and architectural elevations are required for the submittal.The allocation is not final until the formal application for the project is submitted, reviewed and approved by the City following required hearings before the Planning Commission and City Council. Additionally,City staff is currently developing citywide ADU design guidelines and updating the Zoning Code to streamline the ability to construct ADUs as an affordable housing option(see Program 1.8 of Section IV). 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. Cumulative In 2018, with the adoption of the Red Hill Avenue Specific Plan (RHASP) and Downtown Commercial Specific Plan (DCCSP), new mixed-use housing opportunities were created along Red Hill Avenue and in certain segments in the City's downtown area. A Voluntary Workforce Housing Incentive Ordinance was also adopted during this same timeframe and is applicable to both Specific Plan areas to encourage development of affordable housing. The Ordinance mirrors the State Density Bonus Law and allows for concession and/or incentives under State Law.At the time of this update, the first mixed use project along Red Hill Avenue within the RHASP is under City review. This is the first project to comply with this Ordinance and includes the provision of 20 percent affordable housing with a concession and incentive request for a reduction in open space and a waiver for park fees for the affordable units provided.The waiver of park fees is an option subject to approval by the City Council. The project will be using the State parking ratios for affordable housing. Since adoption of either plan, the City has not received any requests for projects below the City's allowable densities. New construction in the city has continued primarily within the Tustin Legacy area with recycling of older single- family units into new single-family homes or smaller multi-family complexes. Remodeling and rehabilitation of existing residential structures is also significant. Other than the Tustin Legacy area and some vacant parcels within the DCCSP, the City is primarily built out. The cumulative effect of the City's residential development standards does not constrain the expansion of the housing opportunities. Density standards contained with the City's Zoning Ordinance are consistent with densities established in the General Plan.With the establishment of mixed-use zones in the Red Hill Avenue and CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-49 SEPTEMBER 2021 Downtown Commercial Core Specific Plan areas the City has established increased height limits, eliminated setbacks and included provisions to allow a reduction in parking and/or modifications to the parking standards. The City closely monitors its development standards and land use controls and their impact on development.The City does not currently have locally adopted ordinances such as inclusionary ordinances or short-term rental ordinances that could directly impact the cost and supply of residential development. Amendments are made as necessary to the Tustin City Code to ensure development responds to housing market trends. During this monitoring process,the City will also continue to look at ways to further reduce governmental constraints. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-50 SEPTEMBER 2021 HOUSING OPPORTUNITIES During the past several years,a number of changes to Statutes resulting from new or amended laws have occurred which focus on housing and, particularly housing opportunities and site identifications and associated required assessments. The changes to the law are a result of Chapter 375, Statutes of 2017 (AB 1397), Chapter 958, Statues of 2018 (AB 686), Chapter 664, Statutes of 2019 (AB 1486), and Chapter 667,Statutes of 2019 (SB 6). Appendix B, Housing Sites Inventory Assessment, with associated Attachments provides the analysis. The purpose of the Housing Element's site inventory is to identify and analyze specific land (sites) that is available and suitable for residential development in order to determine the City's capacity to accommodate residential development and reconcile that capacity with the City's RHNA. The intent of the required site inventory is to ensure the City determines whether there are sufficient adequate sites to accommodate the RHNA by income category. The site inventory and analysis help to determine whether program actions must be adopted to "make sites available" with appropriate zoning, development standards, and infrastructure capacity to accommodate the new development need. As identified in Appendix B, the City has adequate opportunity sites to develop for anticipated growth and RHNA allocation. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-51 SEPTEMBER 2021 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 five 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) promote fair housing opportunities; 3) preserve and improve existing extremely low-, low- and moderate-income housing; Preserve and improve the existing supply of low- and moderate- income housing 4) conserve and improve the condition of the existing housing;and 5) ensure that 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:Provision of 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 commensurate with the City's identified housing needs in the RHNA allocation. Policy 1.1:VARIETY OF HOUSING CHOICES -Provide site opportunities inventory of vacant and underutilized land for development of housing that responds to diverse community needs in terms of housing type, cost and location,emphasizing locations near services and transit. Policy 1.2: ACCESSORY DWELLING UNITS - Facilitate the development of accessory dwelling units and junior accessory dwelling units as a means of dispersing affordable units throughout the community. Policy 1.3: REGULATORY INCENTIVES - Support the use of regulatory incentives,such as density bonuses and deferment of impact fees,to offset the CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN III-1 SEPTEMBER 2021 costs of affordable housing while ensuring that potential impacts are addressed. Policy 1.4: DEVELOPMENT STREAMLINING - Initiate development permit and zoning code streamlining strategies to encourage and expedite residential development (i.e. accessory dwelling units, affordable housing units, and investments in existing buildings) to reduce and eliminate regulatory barriers. Policy 1.5: SMART GROWTH PRINCIPLES-Encourage infill development or site redevelopment within feasible development sites for homeownership and rental units through the implementation of smart growth principles, allowing for 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 employment opportunities, community facilities and services, and amenities. Policy 1.6: FINANCIAL RESOURCES - Pursue grants and other funding opportunities that support the affordable homeownership and rental housing construction and housing rehabilitation for all segments of the population. Policy 1.7: PARTNERSHIPS - Continue to implement best practices for developer selection,project underwriting and due diligence and partnerships for affordable housing developments that receive financial and other assistance to ensure long term viability of affordable housing and to ensure the maximized leverage of local resources. GOAL 2: Promote fair housing opportunities for all people regardless of their special characteristics as protected under state and federal fair housing laws. Policy 2.1: FAIR HOUSING - Affirmatively further fair housing by taking meaningful actions to combat discrimination, help overcome patterns of segregation, and foster equal housing opportunities for all within the Tustin community. Policy 2.2:HOMELESS HOUSING AND SERVICES -Support and expand housing and services that address the needs of the City's homeless population. Policy 2.3:HOUSING OPTIONS-Promote the dispersion and integration of housing for low- and very-low income families throughout the community. Policy 2.4:SENIOR HOUSING-Support the development and maintenance of affordable senior rental and ownership housing and supportive services to facilitate maximum independence and the ability of seniors to remain in their homes and/or in the community. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN III-2 SEPTEMBER 2021 Policy 2.5: SPECIAL NEEDS HOUSING - Encourage the availability of affordable housing for special needs households, including large, extremely- low and low-income families. Special needs households include the seniors, large families, female-headed households with children, households with persons with disabilities,and persons experiencing homelessness. Policy 2.6 FAIR HOUSING PROTECTIONS - Promote fair housing opportunities by supporting the continuation of policies that require relocation assistance, and/or to provide incentives and assistance for purchase of the units by low-and moderate-income households GOAL 3: Preserve and improve the existing housing supply and prevent displacement of existing tenants. Policy 3.1:AFFORDABLE RENTAL HOUSING-Support efforts to conserve assisted rental units by work with property owners, tenants, and non-profits to facilitate the preservation of assisted rental housing at risk of conversion to market rate and promote rental assistance programs. Policy 3.2: FINANCIAL RESOURCES - Pursue grants and other funding opportunities that support the preservation and expansion of affordable housing. 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 4: Conserve and improve the condition of the existing housing stock. Policy 4.1: SUBSTANDARD HOUSING PREVENTION - Periodically evaluate housing conditions and, when appropriate, adjust the City's community preservation programs to prevent and address any increase in deteriorated housing conditions. Policy 4.2: COMMUNITY PRESERVATION - Continue the City's community preservation efforts to enforce health,safety,and zoning codes to prevent and eliminate substandard housing conditions and address deferred maintenance, detrimental to the health, safety and welfare of residents. Policy 4.3: HISTORIC RESOURCES - Promote the continued maintenance and preservation of City's historically and architecturally significant residential resources. Policy 4.4: ADAPTIVE REUSE - Encourage the adaptive reuse of historic resources to support affordable housing. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN III-3 SEPTEMBER 2021 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 5: Ensure that new housing is sensitive to the existing natural and built environment. Policy 5.1:SUSTAINABLE DEVELOPMENT-Prioritize sustainable housing developments in proximity to services and employment centers thereby enabling the use of public transit, walking or bicycling and promoting an active lifestyle. Policy 5.2: ENERGY CONSERVATION - Promote green building practices for more sustainable energy conservation measures in the construction of new housing or rehabilitated units,including Policy 5.4: FEDERAL AVIATION REGULATIONS - Provide development community with information to ensure that development proposals meet the criteria of the Federal Aviation Regulation (FAR) Part 77 Imaginary Obstruction Surfaces for John Wayne Airport in coordination with review procedures by the Airport Land Use Commission(ALUC). CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN III-4 SEPTEMBER 2021 HOUSING IMPLEMENTATION PROGRAMS The Housing Element Implementation Program provides for specific actions the City intends to undertake to achieve the goals and policies of the Element. The Housing Element Programs describes the specific programs that will be implemented during the planning period. Housing programs include those which are currently in operation and can be further enhanced or refined to meet future housing needs as well as new programs to reflect the many changes resulting from the adoption of new housing-related legislation that is specifically part of the 6th cycle Housing Element update. A review of the City's past performance on housing element implementation programs is contained in Appendix A of the Housing Element. The following table (Table H-20) identifies existing and new housing programs to be implemented during the 2021-2029 period. The programs are organized according to the goals described in Section III (Housing Element Goals and Policies) along with a listing of the responsible agenc(ies),funding source,quantified objective and timeframe. 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P4 wQS wQS wQS N N rl V o 0 N O w N a H > � W � H wLn2:,C 27,C 27,E C) r, w NOo o o o z ° > o > o > o Unn Unn Unn Unn p C) ,t tcr, -p � —C C O O ami C) Q a ri � •� cC ry Q .r' O .° w w Vl m p'" p f-T, cC cC C) sr O d ,ui O �" � � •� sem. � � .� � Q' .� � � a) � ,� •`� 'm ° 3 C) w U u ro a ':) a -CU a s axQ y w ZZ ro a o > 0 bn '- � ¢ Ln ro � U') ro m ° ow CJ C7 Ln C u Lf) C v � wo � � N OU) x v � W Q O N N rl V O N O cn "5 � w a H W � w °� NO o unn 0 0 0 o z � U O o � W This page has been intentionally left blank. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-27 SEPTEMBER 2021 APPENDIX A REVIEW OF PAST PERFORMANCE State law establishes an eight-year cycle regulating housing element updates. In compliance with the 5th SCAG RHNA cycle, the Tustin Housing Element was updated in 2013 and was certified by The State's Housing and Community Development Department in compliance with State's Law. The following section evaluates the effectiveness of the goals, policies and programs of the last adopted Housing Element(2013-2021). Review of Past Housing Element Objectives (2013-2021) State law (California Government Code Section 65588(a)) requires each jurisdiction to review its housing element as frequently as appropriate and evaluate: • The appropriateness of the housing goals, objectives, and policies in contributing to the attainment of the state housing goal; • The effectiveness of the housing element in attainment of the community's housing goals and objectives;and • The progress in implementation of the housing element. The evaluation provides valuable information on the extent to which programs have been successful in achieving stated objectives and addressing local needs, and to which these programs continue to be relevant to addressing current and future housing needs in Tustin. The evaluation provides the basis for recommended modifications to policies and programs and the establishment of new housing objectives. The following highlights the housing activities and programs from the past Housing Element: Goal 1: Adequate Housing Supply 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. While unit count was undefined, the program has seen development of over 1,549 units over the 8-year period. Development in the Tustin Legacy Specific Plan area accounted for 1,351 units (Greenwood, Amalfi, Anton Legacy, Levity developments. Of these units, 262 units were affordable. Two new specific plan areas allowing residential development (generally mixed-use residential),where not previously zoned to allow residential,were created in the City CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 A-1 in 2018; the Downtown Commercial Core Specific Plan (DCCSP) area and the Red Hill Avenue Specific Plan (RHASP) area. Both of these new Specific Plan areas require all future development to participate in the City's Workforce Housing Ordinance (Ordinance No. 1491 adopted in 2018) options contributing to affordable housing mostly through mixed-use. To date,140 units have been built in the DCCSP area during this planning period. New construction/Additions and Alterations 1,549 new residential units were issued permits for constructions during the 2013- 2021 planning period, above the assigned RHNA of 1,227 units, though partially meeting the City's estimated objective of 2,900 new constructed units for said period. Most estimated new construction (2,295) was anticipated to occur in the Tustin Legacy. While sites were available, the market/development community did not respond to the estimated objective during the planning period with probable effects due to the economy, other factors and the Covid-19 Pandemic occurring within said cycle. Expectations were exceeded relative to Accessory Dwelling Units (second units). While ten (10) second units (ADU's) were estimated, actually new ADU's accounted for twenty-seven (27) new units are deemed approved/under construction/in the plan check process. This result is assumed attributed to new State laws, economics and generational characteristics and desires of the population. Additionally, a total of 5,307 residential additions and alterations were processed during this planning period. Accessory Dwelling Unit (Second Residential Units) As noted above, expectations were exceeded relative to Accessory Dwelling Units (second units) resulting in almost three times the 10-unit objective referenced. In 2017, the City Council adopted Ordinance No. 1479 related to accessory dwelling units (ADUs), formerly known as second residential units. With such, the City was deemed in compliance with State law. Most activity resulted after this 2017 timeframe. 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 2013-2021,328 restricted units were established. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 A-2 Special Needs Housing The City was effective in addressing housing needs for our special needs population; the disabled (including developmentally disabled), elderly (seniors), homeless, female head of household and large families. Specific results were capturable for the disabled,seniors and homeless categories but less so for the female headed household and large family categories as the metrics were not present. Disabled: Ongoing efforts have continued during this planning cycle regarding the program objective to ensure accommodations for the disabled. Some of the efforts included update of the City's website Housing Section, participation in an adjacent city's task force relative to housing needs of developmentally disabled, and, meeting with Tustin Legacy affordable housing developers to discuss specific needs for this population. Further, implementation requirements and associated program objectives relative to SB 520 were met and continues. The City also ensured that development of multi-family housing to set aside portion of the units to be accessible in compliance with Chapter 11 of the California Building Code. Homeless: The City of Tustin is directly assisting the unsheltered homeless population within Tustin through the collaboration between the Tustin Police Department, CityNet,Orange County Health Care Agency (PERT Mental Health Services),Orange County Rescue Mission,and the Tustin-based nonprofit Operation Warm Wishes,to provide resources and services to the transient homeless in Tustin. In March 2019, the City of Tustin opened a new low-barrier temporary homeless shelter with 57 emergency shelter beds for men,women,and families with children. This facility is operated by Temporary Shelter, Inc., and includes a variety of wrap- around and other supportive services which are administered at the site. This site is being established to ensure that unsheltered homeless individuals with ties to Tustin have the opportunity to be provided with a bed and shelter. The City will continue to develop a strategy that will continue to address homeless needs in the community. Transitional and Supportive Housing: The City of Tustin and Orange County Rescue Mission executed a ground lease to support the Rescue Mission's construction/rehabilitation of a 5.1 acre site to establish a 192-unit transitional housing project (Village of Hope) at the former MCAS Tustin. This site was created by converting former military barracks equipped with private bathroom and kitchenette.The Village of Hope has also increased their transitional housing capacity to up to 387 units, an increase of 195 units . This transitional housing facility is currently in operation. The City also conveyed two four-plexus to the Orange County Rescues Mission to provide transitional housing to homeless veterans to serve 26 homeless veterans and their families, the Tustin Veterans Outpost was completed. The conversion of CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 A-3 fourteen(14)units from transitional to permanent supportive housing for low income families also took place and resulted with an amended Homeless Assistance Agreement with Families Forward. The City also entered into an Agreement with Family Promise in partnership with Home Aid Orange County for the construction of a new seven(7) housing unit facility and family resource center (House of Ruth) to provide affordable housing and related support to extremely-low-income families with children who are experiencing homelessness or are at-risk of being homeless. In addition, the City allocates CDBG funds annually to non-profit groups such as Families Forward Transitional Housing Program;Human Options Third Step Transitional Housing Program; and,Mercy House Family Care Center. Zoning Studies The City was to undertake zoning studies to include the creation of zoning provisions which would accommodate mixed-uses in portions of the city,particularly in the Old Town Commercial Area and study the relaxation of certain development standards and incentives for projects which include affordable housing units particularly units for extremely low income if directed by the City Council. In 2018, the Tustin City Council adopted a new specific plan document, the Downtown Commercial Core Specific Plan(DCCSP). This Orange County American Planning Association award winning Plan introduced mixed-use and infused the potential for 887 units into the area. To date, 140 new residential units were constructed (all within the Vintage Development). While this development entailed all market rate units, the developer participated in the in-lieu fee option regarding affordable housing provisions. Also in 2018,the Red Hill Avenue Specific Plan(RHASP) was adopted by the Tustin City Council. The RHASP introduced mixed-use to the area and similarly identified the potential for 500 new residential units to the area. Additionally,a Workforce Housing Ordinance was prepared and adopted by the City Council in 2018 which currently affects both the DCCSP and RHASP areas of the City. All future projects in these two areas of the City are required to participate. In 2020, City staff prepared for both the DCCSP and the RHASP areas streamlined application and review systems. Currently in process, City staff is working on citywide ADU design guidelines with examples as well as an ADU zoning update. Additionally, staff is working on residential related mixed-use parking strategies for the DCCSP area. 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, two apartment developments that were granted density bonuses by the City in November 2012 were completed. The Amalfi development is a 533-unit complex CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 A-4 with 37 moderate income units. Anton Legacy Apartments is a 100% affordable development with 225 rental units: 88 very low income; 73 low income; and 64 moderate income. A total of 190 density bonus units were realized. Goal 2: Equal Housing Opportunity Fair Housing This objective was to provide housing counseling services to assure equal housing opportunities by assisting approximately 400 residents annually and 3,000 residents by 2021. Between 2013 and 2021, it was estimated by the Fair Housing Foundation that 1,333 Tustin residents requested assistance and were provided with housing counseling services. Additionally, yearly educational outreach activities occurred. The City responds to any general housing and discrimination complaints. The objective was met. Goal 3: Ownership Housing The City continues to encourage new housing construction for home-ownership in a mixture of price ranges particularly in the Tustin Legacy area. The City's goal is to provide a job/housing balance within the Community by encouraging and requiring the developer to construct workforce housing units within the City's owned sites at Tustin Legacy. The City also partnered with Habitat for Humanity in creating two(2)new affordable ownership housing units for families. Goal 4: Affordable Housing Preservation 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. The 100 at-risk units at Tustin Gardens were preserved throughout the review period. Goal 5:Neighborhood Conservation Enforcement of Building and Housing Codes The objective of this program is to continue to enforce building and housing codes to ensure health and safety, rectify Code violations and thereby improve the overall character of the community. The quantified objective was to investigate 30 substandard housing cases annually and 240 cases by 2021. The City's Code Enforcement Staff estimated that over 2,300 property maintenance and housing code CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 A-5 related inspections were conducted between 2013 and 2020. The City has been successful in getting property owners to abate code violations. Preservation of Historic Resources 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 2013 and 2021, the Community Development Department issued 163 Certificates of Appropriateness certifying building changes were consistent with design guidelines and appropriate within the District context. Further, the City is in the process of an update to the City's Historical Resources Survey and Report which is to be completed in 2021. Goal 6: Environmental Sensitivity Energy Conservation/Rebate Program 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. All new units were required by the City to meet these standards. In addition, since 2013, all properties within the City have the opportunity to benefit from inclusion in the California HERO Program to finance distributed generation renewable energy sources,energy and water efficiency improvements and electric vehicle charging infrastructure. Availability of grants are continuously explored. Water Efficiency In response to Assembly Bill 1881,the City in coordination with the League of Cities Orange County Division and the Orange County Water District prepared and adopted the Water Efficiency Landscape Ordinance. The City's website has been updated with information and guidelines to achieve water efficiency. The City adopted an ordinance addressing synthetic turf landscaping, including material, installation and maintenance, to promote reduced irrigation needs and quality landscaping. In December 2015, the City Council adopted Ordinance 1465 which calls for additional water efficiency and was found to be in conformance with both State law and Governor Brown's Executive Order. The City issued 12 residential permits and 24 permits for landscape rehabilitation, subject to the Water Efficient Landscape Ordinance: In 2013, the City also participated in the SoCal Water Smart program where rebates were provided for eligible water saving projects. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 A-6 In 2018, the City partnered with other Orange County Cities to prepare a helpful video guide for the public to use regarding water efficient landscaping. Said video received an Orange County American Planning Association award. Progress in Meeting 2013-2021 Housing Element Quantified Objectives The SCAG Regional Housing Needs Assessment(for the 2014-2021 cycle) indicated a new construction need in Tustin by 2021 of 1,227 units, of which 283 units were for very low-income households, 195 for low income, 224 for moderate income and 525 for above moderate income. Table AA-1 summarizes the quantified objectives and compares the City's progress in meeting these objectives. TABLE AA-1 SUMMARY TABLE EFFECTIVENESS OF HOUSING ELEMENT, 2013-2021 New Construction Preservation Income Group Goal Actual' Goa12 Actual Very-Low 283 103 100 100 Low 195 74 Moderate 224 114 Above Moderate 525 1 1,258 Total 1,227 1 1,549 1 100 100 'Numbers include total,actual number of units with permits issued and completed. zwhile the numbers represent units,it does not account for the funding and other support activities provided. Source:The City of Tustin,Housing Element,2013 Table HTM-25,2014-2021 Housing Needs;City of Tustin Annual Reports 2013-2020-Implementation Status-Housing Programs Progress Report-Government Code Section 65583 Tables(Tables C or D depending on the year) CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 A-7 APPENDIX A - ATTACHMENTS REVIEW OF PAST PERFORMANCE CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 A-8 SUMMARY OF PREVIOUS 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 2013 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 2013 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. 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, 2009 and 2013, the City updated its Housing Element and was certified by the State's Housing and Community Development Department in compliance with State's Law. The time period covered in this analysis is generally 2013 - 2020, and, 2021, where information is available. REVIEW AND PROGRESS IN IMPLEMENTING THE 2013 GOALS AND OBJECTIVES Table A-1 summarizes the performance and presents a comparison of the quantified objectives of the previous 2013 Element and the actual achievements since 2013. The 2012 SCAG Regional Housing Need Assessment (for the 2013-2021 cycle) indicated a new construction need in Tustin by 2021 of 1,227 units,of which 283 units were for very low-income households, 195 for low income, 224 for moderate income and 525 for above moderate income. Table A-1 conveys the actual results for new construction as well as goals and actual results regarding rehabilitation/preservation APPENDIX A CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN JUNE 30,2021 9 and housing assistance, where information was available. Of note, any extremely low-income units are captured in the very-low income category. TABLE A-1 SUMMARY TABLE EFFECTIVENESS OF HOUSING ELEMENT,2013-2021 New Construction Rehab/Preservation Housing Assistance Income Group Goal Actual Goal' Actual Goal' Actual Very-Low 283 94 171 253 242 243 Low 195 74 49 132 74 74 Moderate 224 114 Above Moderate 525 1,240 Total 1,227 1,522 220 385 316 317 1 While the numbers represent units,it does not account for the funding and other support activities provided. Data not available for those not presented with numbers. Source:The City of Tustin,Housing Element,2013 Table HTM-25,2014-2021 Housing Needs;Table A-2, Effectiveness of Housing Element Programs;Table H-20,Housing Element Programs 2013-2021;City of Tustin Annual Reports 2013-2020-Implementation Status-Housing Programs Progress Report-Government Code Section 65583 Tables(Tables C or D depending on the year) Table A-2 provides program by program review of the previous Housing Element (identified in Table H-20 from the 2013 Housing Element),containing a discussion on the effectiveness and continued appropriateness of each program. It includes an identification of units achieved or status thereof, where applicable. Of note, any extremely low-income units are captured in the very-low income category. Table A-3, Progress Towards Objectives 2013-2021, following Table A-2 provides a summary table identifying focused areas with quantified objectives, associated accomplishments and, where known, the distribution of units by income category. The focused areas include new construction, rehabilitation, preservation, and other focused affordable housing programs. The detail is articulated in Table A-2. Of note, any extremely low-income units are captured in the very-low income category. 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O W bA v w w v w � o to UQQCTU ro ° by ro m Z a O m O r4 75 U N W U � N W U s G Ln •� w .A tc P— U f1 f1 f1 s� m f1 �7 f1 x C m ^m H z w N W eq U" C LO �l C= O N x o 0 w U U O wbt w U w o > o w � ad � v o Q. to o o U Q Q U Q B bA w o . o o Atz g Tl o ILI tc � . tc 3 tc Q) ILI r4 Ur4 .4 2 \ \ f 4 ® ¥ 7 q '/ .§ &/ \ \ \ A \ \ � � § j \ \ \ \ ( \ 0 \ /\ o ) & \ $ 2 z J ` 6 LF) < R $ R f $ ¥ e , w # m a # m z ( 6 g t < z y = = a < ! \ u w / 7 a K ¥ a 5 w / 7 a K ¥ a 5 G 2 / / & m m m m m m m m /\ G5 m m m m m m m m � \ � \ U 2 ± e3 § U '/ / o a \ ( 0 ±\ e / \ i � § Q � } m / \ } \ � / • \ « � ( / '; 3 8 3 0 \•c ® b % § \ g ; o @ Q « Q c _ S U o 3 W � N .r s. m O Q p 75 U U � w o ) ::5 o V/ n/ �1 z W N W �b-0'u W Z N O O � 7� O w bt 0 w v w v � w � � v Q bn o U Q Q +r 0 •+'• � � � `�' a ,� W 3 5 o� " O � .� U � � � •O cn � 1 v O > m (� O o4: a m -5 x c § 2 75 U � � § \ / \ ) . � / / 3 f 2 � Q � O � � w � e 6 ® ® § & 2 n / / 0 A Q / & q : \ 2 \ \ \ \ \\ \ 00 / /CD ® � ~ \ \ 0 3 ��\ \ \ � O $ 73 �Tlbt � § B / S ( * c � bID ` $ / J [ > / / / i f \ ( ƒ \ \ ,L) G / § ( $ / m45ul t .) » 4 \ / } ( 2 = o / \ \ { \0 \\ § } § \ ± « / » 2 m 7 \ / e e e Q 2 m§ § $ $ » a ( U') ce eq » e e•- ± 8 f § § ± ) 7� \ \ f k / 0 0 \ \ / � N o o 75 U t--� •�' oN W � �, m (f) Op 3 ° m ro m m N � • .° CO 2 ca r-O 7� Com.uU 7� O Ufa 8 C) 0 O by xU, o o o 'er o cn a o ° cn U ° o o o o C o r cc o o bn m o m C) c o oN 30 � ° 0 3 0 0 000 Cg > cv0 ucv cv ¢ x ¢ w o � 4 o C u a) o �" '7 ° o U, o ma :" C.7 > �U :J tp t Z ro s ' N m r w 8 U Q ° GG a-+ tc a tc 9 s c ' m C Eb ul b-07� m '� a C� t � O W U Q rd a`Ai .� C ani O bD m U b�D O O s p m m p r4 � N o C7� x75 _ a� U W � � � 1�•Lr V1 0 U U 7 7 � o ° 3A o rUW � Lf) m oU o ¢ o �x � N U d U f 0 7J C.7 U') Q 6 bre ro 0 2:' UUC1C1 m w m m 4 ; W m P4 by o cn x C) O w rx ° mC� C) 0 N Q 75 N � cn U O > cV O > °n° to o °� 3 O o ° o x o o U U m G G W s O u a m O U O z u C U U o ff O O H z tc _ a � � o 'er o N W N r. •7 tcU, u ° d [~ O N ° O ° ° O U N O O U') U �o W • O W bt W � V � O H W-4 w v W y w � � v �. to +r � W un bn H � U Q o 0 N Q 75 N ul cn v w w y cC ,O Q O O H W v x C) m r, O s. 0 .) m m O 0 O m O m s. N W r-1 p f O m W Z N �• v bD O O s a m � m N en o U U w O w bA W � V � O w v w v w � � v �. to +r a' W by � � O w P ow � Q U � 75 � § �ƒ U � � � � k \ \ q / /r. / G \ \ ` \ { \ \ «« w , ® e> , c@mr, \ ] � $\ ( 2 \ \ \ \ \ \ / 0 0 0 0 w / Q 2 / \ % q > ± k Q ® § ■ 7 � ° C / / ¥ $ zo w O 7 7 � � 7J / � S ( � / * k ( ( k © i § 2 « § '\ ¢ E ± « q � 75 � § �ƒ U � � � � k \ \ q 0 e = o m \ 6 / . 2 3 g \ / ( \ /� \ \ Gj ® ( � \ ( § m » \ ) ® ` \ \ / \ § ® ƒ % 5 = \ � \ / / \ / \ \ � \ \ \ / / \ / \ & \ / @ o / Q 2 / \ u / QA Q / & t : 7 \ / \ �� ¥ @ / C4 w O 7 7 � � 7J / � S ( � / * k ( ( k © i § 2 « ) § •\ / % ± § q » / / - .r o o o o 75 y Q x Fro �a x C) U Z V Q t--� .� N � V Q t--� •� N � U w U w Ln cn 0 2 •m O � Z Z � x m LO H w � o 0 x o � O cn 7� 7� W bt r P4 U) uC) o � xU o Uw w � bID bn. u C)C) v +, •+�- N �, CEJ'p O �O CL � � c o ;° a w � o �� � o � � w � � ,� U ��° •0 0 3 w � Q r4a a a x r4 x it GJ 75 45 tc O O u � � X Q O p-, �7 � ° u � O •O O u � U cv W � UCO �W roa f�1 tc U ¢ bD b-0 s. N ~ •.yr [� ON z„ � O •u z N Wtc O C W z Np m C a -- i eCi �^ _ p N Ey O C4 ) O x s (J m O bt U �W-4 x � Em � ° C° Ucn o U w � bt m bD O C by ul .� m 7-' �° Id by ,� O x O m O �N r4 U ro m rl, ro ro x r4 Q W � N .r Q bn o 75 N CL 45 tc U w U . w o •� "D 00m co N 110 cr) ce) all N CN f� �U o � o � o � o � o � o � o � o H tc z W av N W � Q) a M N OCA w W � O cn � H w � � v o U Q Q +r a� L a� � l W o pp I 7 .§ 2 / \ \ \ \ \ � � ¥ � Ln t \ \ Ln \ = z f 2 � Q � O � � w / Q ® Q \ u k q00 = \ / \ $ a ® o / Q2UU 7 e �Tl © / \ r ±\ Q ( * ( \ ( -:J ) \ c � bID ` $ J \ > / / / i § � / 6 & E \ { ƒ / @ / \ � § \ / / ul \ � •E _ / @ �\ 2 ( § 2 \ ( / � / � \ On \ -C ( -cj q ® blo 7 ® � u � � ° ® z © /u 0 J O — J \ \ / \ J / ) $ ) [ ) \ : / \ / ) \ / 0 3 3 3 2 3 m g $ _ % , U \ § % k % Q i v HQ a x 75 CZ U U N W U W O ax +�+ OJ •--� •--� N Ci -� a s0-i U oc T e. cC Ci m p � O M •,_,� W U U f •� U U f 7C U O G O m N p X PE, ro UC, � U m U cn s+ m U ul > bD z 1-4 w W a N N � O eq to O � m � I rd en O O wbt U w a wv > c�nwUW w � Q bn o U Q Q � C U) m Q Q C) O r. 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M N X O 75 N r rm G •� ° m o w O o o cv Cf)-zj �, � �, �,�1 � .� �o •� ;� � � � s. �, civ � � o o .� � `� 3 3 � •� ,� .� c .� W H x W 0 U W � N .r s. m O Q O 75 C! � � O ° 3 W � .� � � arCs o � •� C7 by °�' P'-" 75 H 75 tc w � ¢ N v ax G O 75 s� bD tc O N U O W bD m 7� O C/7 C/7 w bA 7� 0 w v w v � w � Go ON bt U Q Q cn U) a� cr bA ;z W " � a o b�O + v O d v bn U C� ro o v o it °; o TABLE A-3 PROGRESS TOWARDS OBJECTIVES 2013-2021 CITY OF TUSTIN Quantified Extremely Very Unit Type/Description Objectives Accomplishments t Low Low Low Moderate Upper NEW CONSTRUCTION (See Table H-17 and Table H-18;2013 Housing Element for Income Objectives) MCAS Tustin Housing Units(Tustin Legacy) Neighborhood D 1,048 533 37 496 Neighborhood G 1,247 818 88 73 64 593 Units Approved/Under 12 ADU's Construction(2020 Undefined (undefined income) Annual Progress Report)) Preservation 100 100 100 New Ownership and Rental Housing(all 587 172 6 1 14 151 outside of Tustin Legacy) 10(note 5 Second Unit units 15 indicated in (Undefined income) Table H-20) Recycling of SFD to MFD 8 Undeterminable in R-3 district Subtotal 3,000 514 303 348 1,835 RHNA 1,227 283 195 224 525 Difference L773 231 108 124 1,310 1,534 (includes 1,522 units+ 12 ADU's approved RHNA and under ACTUAL TOTAL UNITS Required construction) 194 74 115 1,240 CONSTRUCTED 1,227 Note: Statistics show 1,562 new residential projects completed in planning period REHABILITATION Single and Multi-Family Undefined Undeterminable Rehab Single Family Undefined Undeterminable Multi-Family Undefined Undeterminable Multi-Family Rental Acquisition/Rehab/Conv ersion/Resale Undefined Undeterminable APPENDIX A CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 A-61 TABLE A-3 PROGRESS TOWARDS OBJECTIVES 2013-2021 CITY OF TUSTIN Quantified Extremely Very Unit Type/Description Objectives Accomplishments t Low Low Low Moderate Upper Ut Note-5,307 8 residential additions Total Rehabilitation Undefined and alterations realized during the planning period PRESERVATION Tustin Gardens 100 1 100 100 Total Preservation 100 100 100 OTHER FOCUSED AFFORDABLE HOUSING PROGRAMS Homeless Assistance& Variety ofA variety of support Supportive Services Programs- Undefined services provided Tustin Legacy New Construction Inclusionary 452 230 Housing Requirement Other Administrative Support(Housing Authority;Density Variety of Bonus';Affordable Programs- A variety of support Housing Assistance services provided Programs(associated Undefined with HOME funds; CDBG),etc. Section 8 Rental Voucher 1,600 4,268 Assistance Vouchers Vouchers Shared Housing Referrals Undefined A variety of support services provided See Above Total Other Programs Due to See Above Due to Various Various Metrics Metrics Number of Units unless otherwise noted. Sources: Tables H-17&H-18;Housing Element Implementation Program Section;Table HTM-35(2013 Housing Element) APPENDIX A CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 A-62 APPENDIX B HOUSING SITES INVENTORY ASSESSMENT The focus of the site inventory assessment is to identify sites that,in total,can achieve Tustin's assigned 2021 Regional Housing Needs Allocation (RHNA) by income level for the planning period (2021 -2029). Housing Units Approved/Entitled/Pending and Permitted As conveyed in Table B-1, Summary of RHNA Credits and Remaining Need, there are a total of 658 housing units that are captured from approved/entitled, pending and permitted (projects under construction). In addition, 35 ADUs or JADUs are projected to be constructed during the 2021-2029 planning period. A total of 6,089 additional housing units are therefore needed to achieve the total assigned RHNA of 6,782 housing units. Approved/Entitled There are 532 units in three projects with a total of 132 extremely-low-income transitional housing units and 400 above-moderate income housing units that were approved/entitled at the time of the preparation of this housing element and are being included in the RHNA count. They are as follows: House of Ruth: This entitled project will consist of a 7-unit short-term transitional housing facility on at 1941 El Camino Real, a 0.38-acre vacant parcel, to serve extremely low income homeless families (2 to 7 persons per unit). It includes 2 density bonus units. It will provide support services to avoid long-term homelessness.The project is anticipated to begin construction in 2021/2022. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 B-1 TABLE B-1 SUMMARY OF RHNA CREDITS AND REMAINING NEED [QUANTIFIED RHNA OBJECTIVES] CITY OF TUSTIN 2021-2029 Net Units ADUs Units Projected RHNA Income Group RHNA Approved Permitted In Review ADU** Need Very Low 862 0 1 6 4 851 Extremely Low 8621 132 2 0 728 Low 1,046 0 4 18 1,024 Moderate 1,132 0 4 12 1,116 Above Moderate 2,880 400 1 131 1 2,334 Total 6,782 532 12*/** 137 35 6,053 1 Pursuant to Government Code Section 65583(a)(1), City's share of extremely-low-income units is 862 (50 percent of the total Very-Low Income new construction objective). 12 ADUs currently permitted and under construction. ""Income categories distributed per SCAG Regional Accessory Dwelling Unit Affordability Analysis(2020). Source:2021 RHNA,SCAG Village of Hope (OCRM): This entitled project will consist of an expansion of 125 units to the existing Village of Hope,a 262-unit transitional housing facility operated by the Orange County Rescue Mission (OCRM). When completed, the facility will provide 387 units. The facility and entitled new expansion are located at 1 Hope Drive in Tustin Legacy Neighborhood A.Village of Hope serves homeless individuals;therefore,these units will serve extremely low-income residents. The overall site is approximately 5 acres. Currently no indication has been provided to the City regarding the commencement of these expansion units. They are assumed to be built in the next two-three years of this planning period. Brookfield Development. This is an entitled 400-unit above-moderate-income development planned in the Tustin Legacy Specific Plan area within Neighborhood D South. The project is currently under construction. Pendit There is one pending mixed-use project with a total of 137 housing units(6 very-low- income and 131 above-moderate-income). This project is currently under review and anticipates public hearings in summer 2021. Permitted There are currently 12 accessory dwelling units(ADUs) that are permitted and under construction. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 B-2 Projected ADU and JADU Development Throughout the City, an estimated 35ADUs and JADUs are projected to be realized during this planning period. This is based on the recent past performance as well as the new legislation and the City's efforts to allow and encourage such units.A current SB2 grant funded project will result in the preparation of citywide accessory dwelling unit design guidelines with accompanying examples. Suitable Sites Identification and Assessment The City analyzed and assessed a number of sites and areas throughout the community based on these above-mentioned parameters as well as other considerations.While many sites were considered,18 sites,two facilities,and one site category have been identified for Tustin's qualifying sites to accommodate RHNA. Attachments accompany this is Appendix B. Attachment B-1, Sites Identification to meet RHNA, provides a detailed listing of the RHNA related sites. Figure B-2, Site Identification to Meet RHNA,provides a map of the site locations.Additionally,area site aerials and individual site APN maps with summaries are provided for reference organized by each of the three respective specific plan areas as well as an "other' category in Attachment B-2. The total capacity that can be realized from the identified sites is 7,513 units, exceeding by 1,460 units the net RHNA need of 6,053 units. Tustin Legacy Specific Plan (TLSP)Area Tustin Legacy contains two Neighborhoods where residential housing sites will be concentrated for this planning period: Neighborhood D and Neighborhood G. The land is vacant.The zoning for Tustin Legacy is SP 1 and the General Plan designation is TLSP. A total remaining capacity of 3,325 units are allocated throughout the Specific Plan. Neighborhood D has a total of 84.73 acres and is divided into two areas:South(44.86 acres) and North (39.87 acres). Sites within Tustin Legacy do not have a density prescribed to the planning area per the TLSP; however, there is a development cap placed on several of the planning areas. Therefore, a default density of 30 units per acre was applied for the RHASP areas within the cap limit. Site 1B-Neighborhood D South This area includes a recently entitled 400-unit market-rate development(identified as The Landing by Brookfield Residential) on 25.44 acres within one Tract(Tract 18197) which has seven lots. The lots range in size from 2.57 acres to 5.28 acres. Grading activities are currently taking place. The first building permits are planned to be CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 B-3 requested in 2021. Construction is in phases and is estimated to be completed during this 2021-2029 planning period. The remainder of this area,19.42 acres,is identified for multifamily type development within the same Tract (Tract 18197) which has three lots. The lots range in size from 5.45 acres to 7.04 acres.A total of 896 units have been allocated to this area. A total of 1,296 housing units are currently allocated in Neighborhood D South to meet RHNA. The City is planning a rezone (Specific Plan Amendment) within three years (by 2024) to accommodate a minimum of 100 additional housing units within this area,to bring the total number of housing units to meet RHNA to 1,396.Assessor parcel numbers have not yet been established as this area is part of the base closure land conveyance from the Department of Navy to the City of Tustin. Neighborhood D South was identified in the past two planning cycles as vacant land available for housing to meet RHNA. A portion of the area has housing that resulted in the past housing cycle (2014-2021). The remaining allocated units, as described above, is expected to be built within this 2021-2029 planning period. Site 1A- Neighborhood D North This portion of Neighborhood D does not currently have any residential planned (no residential units allocated).The City is planning a rezone (Specific Plan Amendment) within three years (by 2024) to accommodate a minimum of 430 additional housing units within this area, bringing the total number of housing units to meet RHNA to 1,396. The focused vacant land is 39.87 acres. It is currently situated within four parcels. The rezone is included in the City's identified programs (see Table H-20, Housing Element Programs 2021-2029).Neighborhood D North was not identified in either of the past two planning cycles as vacant land available for housing to meet RHNA. The 430 housing units are expected to be constructed during the planning period. Site 2-Neighborhood G Neighborhood G currently has housing within the area built over the past two planning cycles. Fifty acres are currently planned and available for future housing developments.A total of 2,029 housing units are currently allocated in Neighborhood G to meet RHNA. The City is planning a rezone (Specific Plan Amendment) within three years (by 2024) to accommodate a minimum of 200 additional housing units within this area, to bring the total number of housing units to meet RHNA to 2,229. Neighborhood G was not identified in the past two planning cycles as needed to meet RHNA. The remaining entitled units, as described above, are expected to be built within this 2021-2029 planning period. There are 13 identified parcels designated for residential development with one parcel at 10 acres and the rest at smaller acreages. Red Hill Avenue Specific Plan (RHASP)Area CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 B-4 The Red Hill Avenue Specific Plan was adopted in 2018. The Specific Plan area consists of approximately 52 acres centrally located within the City. It is primarily a commercial and retail corridor that is prime for revitalization.With the Specific Plan, mixed-use residential is now permitted in this area, with a total of 500 residential units allocated through the Specific Plan, 395 units to the north of the freeway and 105 units to the south of the freeway. The RHASP provides a unique Residential Allocation Reservation (RAR) which is approved either by the Community Development Director or the Planning Commission/City Council,as applicable.The RAR is the mechanism with an associated process and timeline that allocates units to a requested development. The units are drawn from a residential allocation bank which assigns units by area and allows for transferability between areas. The maximum density on an individual parcel may exceed 25 dwelling units per acre(the General Plan's maximum density) as long as the total dwelling units allocated to the Specific Planning Area is not exceeded. Therefore, a default density of 30 units per acre is achievable in the RHASP area. This Specific Plan was accompanied by a City prepared Program Environmental Impact Report which affords future developers time and significant costs savings yielding building of homes in a more expedient manner. The Zoning is SP 13 and the General Plan designation is RHASP. The maximum allowable building height for residential mixed-use development in the RHASP is 4 stories/50 feet. Four sites within the RHASP area have been identified as relevant sites to meet RHNA: Site 3 -13751 -13841 Red Hill Avenue (Pending Project) This site has a pending mixed-use project under review.The pending project includes 137 units (114 base density units plus 20% density bonus), of which 131 are market- rate and six are designated affordable to very low-income households. The site is made up of two parcels on 3.37 acres. The project was approved by the City Council in August 2021. The project is expected to be completed within the first few years of the planning period. This site is under one ownership and is vacant. The project is located in the Planning Area north of the I-5 freeway. This site was not identified in either of the past two planning cycles as vacant land available for housing to meet RHNA. Site 4-13822-13852 Red Hill Avenue (Red Hill Plaza) This non-vacant site consists of four parcels on 5.48 acres, all under one ownership. The current land use is a shopping center with commercial, retail and restaurants. Past development interest discussions have ensued with the owners, interested developers and the City regarding this property.165 units have been assigned to this site. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 B-5 Site 5 -1571 El Camino Real (Denny's Restaurant) This non-vacant site adjacent to and under the same ownership as site 4. It is possible that the two sites could merge for one development.The site is 0.90 acre and currently has a restaurant use. 32 units have been assigned to this site. Site 6- 14081 -14231 Red Hill Avenue (Stater Bros. Shopping Center) This non-vacant site consists of six parcels on 5.95 acres under three owners. The holdings are all within the same family, yielding a more favorable redevelopment potential. The current land use is a shopping center with commercial, retail, restaurants and service stations(only one active).166 units have been assigned to this site. Downtown Commercial Core Specific Plan (DCCSP)Area The Downtown Commercial Core Specific Plan was adopted in 2018 and is centered around the intersection of Main Street and EI Camino Real in Old Town.The DCCSP consists of approximately 220 acres located in the northern and western portion of the City. This area was not previously zoned to accommodate residential development. With the adoption of a Specific Plan, it is now an option to allow residential (primarily mixed-use residential)in this area.A total of 887 residential units have been allocated through the Specific Plan within six Development Areas. Since Specific Plan adoption, 140 residential units have been developed,and 747 allocated units remain. The DCCSP also provides the unique Residential Allocation Reservation (RAR) which is approved either by the Community Development Director or the Planning Commission/City Council,as applicable. The RAR is the mechanism and associated process with a specified timeline from approval to under construction that allocates units to requested developments. The units are drawn from a residential allocation bank which assigns units by Development Area and allows for transferability between areas. Current housing bank allocations include 45 units to Development Area 1, 92 units to Development Area 2, 200 units to Development Area 3, 150-units to Development Area 4 and,260 units to Development Area 6. The maximum density on an individual parcel may exceed 25 dwelling units per acre (the General Plan's maximum density) as long as the total dwelling units allocated to the Specific Plan area is not exceeded.Therefore,a default density of 30 units per acre is achievable in the DCCSP area. This Specific Plan was accompanied by a City prepared Program Environmental Impact Report which affords future developers time and significant costs savings. The Zoning is SP 12 and the General Plan designation is DCCSP. The maximum allowable building height ranges from two to five stories, depending on Development Area and adjacent land uses. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 B-6 None of the DCCSP sites were identified in either of the past two planning cycles as vacant land available for housing to meet RHNA. A total of 10 sites are within this Specific Plan area: Site 7-Development Area 1 This non-vacant site consisting of two parcels, under separate ownership, is located at 365 W. First Street (Think Physical Therapy) and a vacant portion of a property shared with the existing Villa Viento Apartments. The two parcels are 1.1 acres. The Housing Allocation Bank's 45 units for this Development Area is assumed on this site. Sites 8 and 9- Development Area 2 Both sites in Development Area 2 are non-vacant sites. Site 8 (Bel Air Motor Hotel located at 140 W. First Street) is 1.0 acre on one parcel under one ownership. Site 9 includes two parcels:Tustin War Memorial,a City-owned parcel located at 150 E. First Street, and the adjacent Wienerschnitzel restaurant at 105 El Camino Real under one ownership (donated to the City). The Tustin War Memorial building is a multi-war memorial with four plaques along the north wall of the building. The building itself is currently vacant and is permanently closed. At one time, this building was shared with the Tustin War Memorial and The Learning Village Preschool. The school closed in 2018 as did the War Memorial. Together, the site is 0.88 acre. The Housing Allocation Bank's 92 units for this Development Area are assumed between these two sites. Site 10- Development Area 3 The non-vacant site 10(Larwin Square),located at the southwest corner of First Street and Newport Avenue,is approximately 16.47 acres and within one parcel under one owner. It is a multi-building shopping center serving retail, restaurants, commercial and office uses. A major building tenant was a grocery store which vacated in the 2015-2016 timeframe. That tenant space remains vacant. Mixed-use residential development interest has been expressed by the owner's representatives. The Housing Allocation Bank's 200 units for this Development Area is assumed on this site. Conceivably, the site, due to its size, could possibly handle more units if a transfer of units from another development area was requested and approved. Sites 11, 12, 13, and 14- Development Area 4 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 B-7 All four sites in this Development Area are available vacant land with no buildings on the sites. As this Development Area is part of the City's original Downtown Core, the sites are small and appropriate for infill residential development.All 150 units for this Development Area, identified in the Housing Allocation Bank, are assumed captured within these four sites. Site 11 consists of six small vacant parcels under one owner totaling 1.02 acres. The site is located at 225-255 El Camino Real and 250 Prospect Avenue. Site 12 consists of three vacant parcels totaling approximately 2.29 acres arranged in an L-shaped configuration. All three parcels are held by one owner. Site 13 is a vacant 0.25-acre parcel located at 125 W. Main Street. Site 14 is a vacant 0.44-acre parcel located at 420 El Camino Real.The site is L-shaped and wraps around a building. Sites 15 and 16- Development Area 6 One site (site 15) in this Development Area is vacant and the other (site 16) is non- vacant.All 260 units for this Development Area,identified in the Housing Allocation Bank, are assumed captured between these two sites. Site 15 consists of 2.73 acres on three parcels under one owner along with a portion of an estimated 0.77-acre Caltrans parcel adjacent to the freeway. At the time of writing of this update document, City staff have been working with an applicant for a residential related project for this site. Site 16 is referred to as the El Camino Plaza located at 620 El Camino Real situated at the southwest corner of El Camino Real and Sixth Street. It is 7.81 acres and under one owner on three parcels. The current land uses include retail, restaurants, commercial, and office. Significant owner and developer interests exists on this site with a recent preliminary residential mixed-use project submitted to the City in 2019 as well as a separate recent inquiry for a mixed-use project containing senior housing. Site 17- Enderle Center The non-vacant site 17 (Enderle Center) consists of 11.62 acres, under the ownership of a single family. Currently a commercial center, with redevelopment it is expected to accommodate 413 units. Site 18 -The Market Place CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 B-8 The non-vacant site 18 (The Market Place) consists of 48.65 acres, under single ownership. Currently a commercial center, with redevelopment it is expected to accommodate 900 units. Sites to Accommodate Low and Very Low Income RHNA The Housing Element Update is required to calculate if lower income RHNA distribution has more than 50 percent on non-vacant sites. The only sites that would contain true non-vacant sites are in the RHASP and DCCSP areas. It is estimated that between these two areas,a total of 311 of the 1,724 very-low income units,and 196 of the 1,046 low-income units would result in these two areas.That results in 18 percent, significantly lower than the stipulated 50 percent. Further, not all the sites are non- vacant resulting in an even lower percentage expected on non-vacant sites. Table B- 2, Sites to Meet RHNA Estimated Income Distribution Reference, above provides more detail. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 B-9 u \ \ k \ k � k / m 7 / \ \ \ f 5 u m LO z / 00 00 00 2 - O \ � \ / k @ w w 2 3 § q % m ® m / .2 \ \ # kad 2 # # Ln L R © ® © 00 k / o u 75 w cq k 2 / ¥ ° 0.4 \ � jLO\ / 006 6 2 2 2 ƒ d 0� 2 2 m o \ & \ \ \ \ \ 6 \ \ 5 5 2 § 6 \ t t t u o _ _ _ = u o § ° % % %% /% & 9 9 9 � / % » » » m » & # 2 » k ° 7 75 2 Cd e e -4- $ m fl, ± 4 ± co \ u o .§ o o m » @ e / ' 2 ' 2 ' 2p / 2 / a % _ \ % .bC blo 7 c o N e 3 Q e v ± U ^ R 2 H � v zo w y •+-' GJ N � W v O � GJN O O O Ln c- d1 N O m N H N m H H m \.n LO v P-4 00 0N LO 00 Ln °O OZ O m G, CD N n •,� r-•7 � r-i r-+ CA N .� Cq Ln � 0 0 00 N 0 0 0 Cn O Lr) N pp et et et ON et c- m (Z:)ed U GJ as O O O O O O O L O O O U U75 Cd w O c- cv m et+ Ln "o 75 -05 75� O tD 00 H � v zo w N ad ZF � a � W v O � .� a x ad o 3 ad a00 o 0 v N v � i W 'y m eV C� LO CIO r� V, U � �i V v 0.4 O a� G V �i ° Y � o a v u o bc Zoning Appropriate to Accommodate Very Low and Low Income RHNA All 16 identified sites to meet RHNA have appropriate zoning to allow residential development,at densities to achieve the estimated capacities and,without inhibitors, such as stringent standards, that inhibit residential development. There are no provisions that would deter accommodating very low-or low-income housing. Table B-3, RHNA Sites Assessment - Zoning / Size / Lot Consolidation Potential / Available Infrastructure,below,is a snapshot of sites appropriateness regarding these respective factors. Each factor is discussed further following the table. Table B-3 RHNA Sites Assessment Zoning/ Size/ Lot Consolidation Potential/ Available Infrastructure Site Site Reference Appropriate Site Lot Available # Zoning Size Consolidation Infrastructure Acres Potential Tustin Legacy Specific Plan Area 1 Neighborhood D Yes* Varies Yes Some Planned as part of Master Planned Community 2 Neighborhood G Yes Varies Yes Some Planned as part of Master Planned Community Red Hill Avenue Specific Plan Area 3 13751-13842 Red Hill Yes 3.37 Pending Project Yes Avenue (pending Handled project) 4 13822-13852 Red Hill Yes 5.48 Yes Yes Avenue 5 1571 El Camino Real Yes 0.90 No -One Yes Parcel/Yes with Adjacent Site 4 6 14081-14231 Red Hill Yes 5.95 Yes Yes Avenue Downtown Commercial Core S gecific Plan Area 7 365 W.First St. & Yes 1.1 Yes Yes Vacant Frontage of CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 B-13 Villa Viento Apartments 8 Bel Air Motor Hotel Yes 1.0 No -One Parcel Yes at 140 W. First Street 9 Tustin War Yes 0.88 Yes Yes Memorial& Wienerschnitzel at 150 E. First Street& 105 El Camino Real 10 Larwin Square at Yes 16.47 Yes,Though Yes SWC First Street& Same Newport Avenue Ownership 11 Farmer's Market Yes 1.02 Yes,Though Yes Related Properties at Same 225-255 El Camino Ownership Real&250 Prospect Avenue 12 NEC of El Camino Yes 2.29 Yes,Though Yes Real&Sixth Street at Same generally 542 El Ownership Camino Real 13 125 W. Main Street Yes 0.25 No -One Parcel Yes (adjacent to Arvida Book Store, previously Mrs. B's) 14 420 EI Camino Real Yes 0.44 No-One Parcel Yes 15 Vacant Lot Adjacent Yes 2.73 Yes-3 of 4 Yes to I-5 Freeway& Parcels Under East of Jack in the Same Box Restaurant at Ownership 14042 Newport&El Camino Real 16 El Camino Plaza at Yes 7.81 Yes,Though Yes SWC of El Camino Under Same Real&6th Street I Ownership * Site 113 (TLSP Neighborhood D - South) has appropriate zoning, but a rezone (Specific Plan Amendment)to accommodate residential development is proposed to occur within three years for Site 1A(TLSP Neighborhood D-North). As Tustin is in a metropolitan county,HCD allows the use of a defined default density of 30 dwelling units per acre. Sites 1 through 16 are within Specific Plan areas which do not have any density limits and,the General Plan for these areas also do not have density limits. Rather, these Specific Plans offer developers flexibility for innovative CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 B-14 design by imposing limits on overall unit counts within the Specific Plan area, without specific density restrictions for individual sites. Therefore, these sites have appropriate density to accommodate lower income units. As such, zoning would be considered appropriate to consider the RHNA for lower income households where the zone allows for a range of 24-35 units per acre which would be the case in these three Specific Plan areas. Several sites have high density development assumptions, exceeding 40 units per acre. Such assumptions are consistent with the current real estate development market in Tustin and surrounding areas. An analysis of realistic capacity finds: 1. Land use controls are not a limiting factor as the sites are within Specific Plans that do not have density restrictions for individual development sites. 2. Required site improvements are feasible due to the relatively large acreages available for master-planned development. 3. Utility systems for the requisite number of units were analyzed and planned for in the preparation of the Specific Plans. Higher-density residential development is now common in recent developments within one to two miles of the Specific Plan areas. For example: • The Bowery, 1,150 apartments and 80,000 sq. ft. of commercial space on 14.6 acres located immediately west of the Tustin Legacy Specific Plan, was approved in 2020. This project's density is 79 units per acre. • Broadstone Arden, 1,221 apartments on 18.8 acres located immediately southwest of the Tustin Legacy Specific Plan,is currently under construction. This project's density is 65 units per acre. • Anton Legacy,225 affordable apartments on 7 acres within the Tustin Legacy Specific Plan,was completed in 2015.This project's density is 32 units per acre. Mixed-use development is permitted and encouraged in Specific Plan areas. However, this is not anticipated to reduce residential development capacity for several reasons: • In addition to the permitted number of residential units,a substantial amount of non-residential development (in excess of 9.5 million square feet in the Tustin Legacy Specific Plan alone) is planned for and accommodated.Most of this nonresidential development capacity has remained unutilized for the past 20 years,and there is no expectation that the demand for nonresidential uses will both utilize the available capacity and displace potential residential development. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 B-15 • Development standards allow building heights up to 150 feet,minimizing the impact of such restrictions on density. Lot coverage and floor area ratio restrictions are not imposed in the Tustin Legacy Specific Plan. The Tustin Legacy Specific Plan, adopted in 2003 and amended regularly since, includes plans for water, wastewater, electrical, and other utility services. The availability and capacity of utility services were evaluated in technical studies prepared in support of an environmental impact report (State Clearinghouse No. 1994071005) prepared in compliance with the California Environmental Quality Act. The EIR determined the utility plan identified in the Specific Plan would be adequate for the proposed residential and nonresidential development and would not put the citywide system over capacity. The presence of sites over 10 acres does not limit the ability to provide housing for lower-income households. Within the Tustin Legacy Specific Plan,the Anton Legacy project is an example of a large site (7 acres) that was developed with a significant, 225-unit affordable housing project, including 88 very-low-income and 73 low- income units. Similar and larger affordable projects have been developed in the adjacent city of Irvine. No lower-income units are proposed on sites less than one- half acre in size except where lot consolidation is considered feasible due adjacency of parcels and the presence of a single landowner or landowning family. The Tustin Legacy Specific Plan encompasses the former Marine Corps Air Station Tustin, which closed in 1999. Since that time, hazardous waste remediation has been occurring across the site under the authority of the Naval Facilities Engineering Systems Command. Currently, over 85 percent of the Specific Plan area has been conveyed to the City of Tustin and other agencies for redevelopment.The majority of the areas not yet conveyed are planned for development as part of a regional park and community college campus. Therefore, the presence of continued remediation activities on the Tustin Legacy site will not significantly impair the site's ability to support the number of residential units anticipated. Emergency shelters and transitional/supportive housing are permitted,and are presently in operation,in parts of the Tustin Legacy Specific Plan. There are no agricultural activities in Tustin or surrounding areas and it is therefore concluded that no farmworker housing is required. Manufactured housing is permitted in residential districts and is not distinguished from site-built housing. 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More specific information including details regarding eligible projects and activities and funding availability can be found in this section of the housing element update.The following is a summary of this information along with updates to reflect new state and federal programs. • Senate Bill (SB) 2 Grants In 2017, Governor Brown signed a 15-bill housing package aimed at addressing the state's housing shortage and high housing costs. Specifically, it included the Building Homes and Jobs Act (SB 2,2017),which established a $75 recording fee on real estate documents to increase the supply of affordable homes in California.Due to the various number of real estate transactions that may take place within the county,the annual revenues will also fluctuate. The first year of SB 2 funds were available as planning grants to local jurisdictions. On May 20, 2020, HCD approved $310,000 of funding to the City. Through five projects, the City participates in goals of the Planning Grants Program including, accelerated housing production, streamlined approvals,expedited processing,promotion of development,objective design and development standards, promotion of ADU development, preservation and rehabilitation, as well as assisting in this state mandated Housing Element Updated. The Local Early Action Planning(LEAP)grants was another source of funding intended to aid local jurisdictions in the preparation and adoption of planning documents and process improvements that accelerate housing production and facilitation compliance to implement the sixth cycle of the RHNA. On December 28, 2020, the City was awarded $300,000 in LEAP funding for two projects;facilitating compliance in implementing the sixth cycle of the RHNA and funding assistance with preparation of the 61h Cycle Housing Element Update and, secondly, an implementation tool associated with the Housing Element Update. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 C-1 For the second year and onward, 70% of SB 2 funding under the Permanent Local Housing Allocation(PLHA)component of SB 2 will be allocated to local governments for purposes of affordable housing. The City does intend to participate in the PLHA grants to the degree possible. • Partnerships In March 2019, the City of Tustin in partnership with Temporary Shelter, Inc (TSI) opened the Tustin Temporary Emergency Shelter, a 57-bed, low barrier emergency shelter. 100% of Tustin's Permanent Local Housing Allocation (PLHA) will partially fund TSI's operation of the shelter. The City will use other funding sources to fully fund the shelter's operation. In establishing the Tustin Temporary Emergency Shelter, the City Council declared a shelter emergency.Under the urgency of a declared shelter emergency and a Federal court order to open a shelter within 120 days,the City asked two(2)nonprofits with experience operating shelters to submit proposals. One nonprofit declined and the City chose Temporary Shelter Inc, a secular affiliate of the Orange County Rescue Mission,to operate the shelter. The Tustin Temporary Emergency Shelter is a safe, clean and dignified low barrier emergency shelter. The shelter is built on a human scale not an industrial scale, with semiprivate living spaces, integrated health care, 24- Hour/seven-day-a-week intake&orientation,and 24-Hour Access to Orange County Behavioral Health staff. The shelter serves as a first-step opportunity with a focus on moving guests forward towards self-sufficiency and healing by providing strategic pathways and interventions that lead to ending their homelessness. PLHA funding (SB 2) will only be allocated to homeless services and,as such,serving the homeless meets the requirement to prioritize investments that increase the supply of housing for households with incomes at or below 60% AMI. 100% of PHLA funds between 2019-2023 will be allocated towards operation of the emergency shelter. SB 2/PHLA funding will continue to assist persons within the City who are experiencing or are at-risk of homelessness, including, but not limited to, providing rapid rehousing, rental assistance, supportive/case management services that allow people to obtain and retain housing, operating and capital costs for navigation centers and emergency shelters, and the new construction, rehabilitation, and preservation of permanent and transitional housing. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 C-2 • Preservation At-Risk Housing Rental Units The City shall register as a Qualified Preservation Entity with HCD to ensure that the City will receive notices from all owners intending to opt out of their Section 8 contracts. The City has a total of 417 at-risks units that could be converted to market rate during this planning period. The City will consult with the property owners and continue the affordability levels of the at-risk units through establishment of a program that utilizes California Debt Limit Allocation Committee (CDLAC) Tax Exempt Bonds to finance affordable housing developments for low-income Californians. • Single-and Multi-Family Home Rehabilitation Program The City has identified funding options such as grants and other funds to extend the life of existing, older housing in the community which may be more affordable to those currently residing in the units. The City will identify and allocate available resources to finance the rehabilitation of residential units in target areas to assist seniors, disabled and lower-income households to ensure safety and habitability of housing units and the quality of residential neighborhoods. The City will also explore a partnership with a non-profit organization, such as Habitat for Humanity of Orange County, to administer the program. • First-Time Homebuyer and/or Foreclosure Negotiated Purchase The City's First-Time Homebuyer Program will be re-established which will provide down payment and second mortgage assistance to low- and moderate-income buyers to assist them to purchase an existing home in the City. 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$59,400 in 2021-22 CDBG funds to continue its financial support of homeless assistance and supportive services in the City. The City's goal for this program is to assist 150 homeless individuals, per year over the projection period. 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 C-3 • Tustin Legacy New Construction During the next planning period, it is anticipated that additional market-rate residential units will be constructed in both Neighborhood D South and Neighborhood G and that additional affordable residential units will be constructed within Neighborhood D North through an amendment to the Tustin Legacy Specific Plan for this specific area. There are currently no inclusionary housing requirements contained within the Tustin Legacy Specific Plan area. • Administrative Support The City and the Tustin Housing Authority will provide administrative support to implement its affordable housing activities. Additional staffing may be needed to provide a level of administrative support anticipated for the next planning period. Staff will evaluate this in conjunction with a review of streamlining measures and other methods of facilitating the approval of housing projects within the City. During the 2014-2021 housing element update, the City initiated the development of additional very low, low- and moderate-income housing in the Tustin Legacy Specific Plan area(formally MCAS Tustin)and these efforts were furthered with the adoption of two (2) specific plans; the Red Hill Avenue Specific Plan and Downtown Commercial Core Specific Plan. through the incentives offered through the State's housing bonus density law. City Staff will look at expanding this to other areas of the City. The City is not an entitlement jurisdiction for HOME funds but may apply to the State for HOME funds. The City is an entitlement jurisdiction for Community Development Block Grant (CDBG) funds. For FY 2020-2021, the City of Tustin was allocated $847,890 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-19,the City will utilize State and Federal resources to leverage local resources as these funding sources match the City's programmatic objectives. This table is a summary of affordable housing resources. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 C-4 This page intentionally left blank. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN JUNE 2021 C-5 H � Z N bD W O CN o� v o °' � u •G � a � � � � � o � � p � O bA..7r O fl 00 U �O .r, U m ul \ O O w bD a a`ci O O m 3 m x ark ark C 0 O o s 7� 0 ° o W ° U) (J en bn ro 7� � 7� N o ° o o CJ uz o 7� 7� Q ° 7� 0 U x W)tu z z a a H tu y U v O bA U tu v o v O0 O v o o V) W)C� o o ^o 3 3tu N U w cFn a a cF°n H � � wo N ul O O _ O � u � � u � •� O H O +� O •� � � � a V O p"7� 3 0 O G �1 U R U ro ro s° cn R x • Ul • • • • • • • • • • • • • u O 7� O s� 7� m O O O 7� O am am s 7� U O O 7� � -� � •oma � � -� � o � � � � .. o 7� m o .cn w o m a) •� O O '� � � O m � � w ms's w u m 9 O O o 7� o • o _ tu v J N o o ° o o ° � o � �° � 3 ° o w � o� •� H x m Z Z tu tu d o 9 m W � O m xoy i E• W v V V Wtu U a U V V) O �- � O O > m t x W Q tu w � a a v o 0 0 3 p O 3 Q p P4 ; w4 > c� xx a w UV H � zo W N W W W Z C7 '� Z tc 5 u Wtc ¢ o ¢ o O U • • • • • • • • • • • aa J Q t.0 ° > .� 00 ^C O O CIO bD, OO 7� 7� '> O J tu w ,� �, � .� �,U° o C7 C7 •3 ro w � � z z U W w w U � a o u U v o o p wtu tu �" W .�"i � .�' Cir �. Cir•.+ v W c! W) cn Q bi) m ontu w o o o Q o W ccw cn R� H .q zo W N W W W Z C7 '� Z O x a Q 91 c� c, N O N Z �D x Q c� cW7 H o w U O m � v v U � v V � a O Appendix D: Affirmatively Furthering Fair Housing D-i Executive Summary Existing federal law requires departments and agencies to administer programs relating to housing in a way that affirmatively furthers fair housing. These obligations extend to state and local governments that receive funds or contract with the federal government. For example,a local government receiving Community Development Block Grant(CDBG) dollars directly from the federal government is obligated to affirmatively further fair housing;under federal law this included completing an assessment of fair housing to inform the consolidated plan.As of January 1,2019,AB 686 extends the obligation to affirmatively further fair housing to all public agencies in the State of California.AB 686 makes changes to Housing Element Law to ensure the long-standing duty to affirmatively further fair housing is part of the housing element of the general plan. Every jurisdiction is responsible for self-identifying internal constraints to furthering fair housing,as well as developing goals and programs that will be implemented to remove identified barriers and improve access to p. This discussion incorporates planning and analysis,which is collectively referred to as an assessment of fair housing (AFH), generally includes: • A summary of fair housing issues in the City of Tustin and an assessment of the jurisdiction's fair housing enforcement and outreach capacity;and • An analysis and summary of fair housing issues and identification of trends and patterns within the City of Tustin in comparison to surrounding cities and the larger Orange County region,including the topics of: o Integration and segregation; o Racially or ethnically concentrated areas of poverty; o Disparities in access to opportunity,including for persons with disabilities;and o Disproportionate housing needs (such as overpayment, overcrowding,housing conditions disproportionately affecting protected classes),and displacement risk. This analysis utilized available federal, state,and local data and knowledge to identify trends and patterns in fair housing issues and identification of trends and patterns within the City of Tustin. Orange County's Analysis of Impediments to Fair Housing Choice (AI) was prepared in May 2020 and contains a thorough examination of structural barriers to fair housing choice and access to opportunity for members of historically marginalized groups protected from discrimination by the federal Fair Housing Act (FHA) within Orange County. The Al also outlines fair housing priorities and goals to overcome fair housing issues. In addition,the Al lays out meaningful strategies that can be implemented to achieve progress towards the County's obligation to affirmatively furthering fair housing. The Al was prepared in consultation with Orange County jurisdictions,including the City of Tustin,and with input from a wide range of stakeholders through a community participation process. Barriers to fair housing choice specific to the City of Tustin that were identified in the County Al and the commitments of the City to address identified barriers were incorporated into this AFH regarding. Supplemental data analysis was conducted to further understand potential fair housing issues within the context of AFH topics at the city-level. D-2 The following table provides a summary of the results regarding each topic required to be analyzed as part of this AFH assessment. AFH Topic Area Summary Fair Housing Enforcement The Fair Housing Foundation provides fair housing services and Outreach Capacity for Tustin, along with various other cities in Orange and Los Angeles Counties. During the 2018-2019 Fiscal Year,the Fair Housing Foundation successfully assisted the City with combatting housing discrimination through managing twelve allegation cases and one discrimination case for Tustin residents. Monthly fair housing workshops that cover a variety of topics continue to be held for both residents and landlords. Cases are handled as presented in a timely fashion. Integration and Segregation . There were no areas of high segregation and poverty identified within the city. Highest resource areas are within the northern portion of the city and the lowest resource areas are to the south. • Minority populations are concentrated predominately within the central portion of the city. • Dissimilarity index scores identified high segregation between Black/White and Hispanic/White populations. Similarly,isolation index scores indicated high isolation of White and Hispanic populations. • City population has relatively low percentages of persons with disability. • Tustin has a slightly higher proportion of families with children(52.64 percent) than Orange County (47.84 percent). • The lowest percentages of low or moderate income (LMI) population are within the northern portion of the city and the highest percentages of LMI populations are to the south. Racially and Ethnically Tustin does not include racially/ethnically-concentrated areas Concentrated Areas of poverty (RECAPs);however,the southern portion of the city,near Irvine and Santa Ana,are higher in percentages of population considered poverty status. The City of Tustin has a lower median income than Orange County,but overall percentage of the White population is almost identical. Both income and White populations tend to be concentrated within the northern portion of the city. Access to Opportunities According to State opportunity maps,highest resource areas were identified within census tracts 0524.19, 0756.06, and 0756.07. Seven census tracts were D-3 considered"low resource". High resource census tracts were identified predominately within the northern portion of the city,while the low resource census tracts were predominately within the southern portion of the city. • According to opportunity map scores,Non-Hispanic Whites and Asians have much higher access than do Blacks and Hispanics. • Low resource areas and populations tended to have low education and environment scores. Disproportionate Housing . A higher percent of non-White households experienced Needs housing problems than White households in Tustin. • Non-White households that experienced the greatest proportion of housing problems include Hispanic (71.19 percent),Black(62.40 percent),and Native American(50.00 percent). • The same trend occurred for the county population. • A higher proportion of households are considered overcrowded in southern Tustin,which overlaps with census tracts that contain greater proportions of minority population and low-income households. • According to the 2020 Al, displacement of residents due to economic pressures may be a significant contributing factor to fair housing issues in Orange County and,in particular,in parts of Orange County that have historically had concentrations of low-income Hispanic and Vietnamese residents. Other Contributions • According to 2015-2019 American Community Survey (ACS) data,50.3 percent of households are owner- occupied,compared to 49.7 percent of renter-occupied. Both city and county trends from 2010 to 2019 show that rentals are becoming increasingly more popular. • Within Orange County,Black loan-applicants were the only racial or ethnic category whose majority of applications (less than 50 percent) did not result in an originated loan for the purposes of refinancing and home improvement. Sites Inventory . Housing units in the sites inventory are concentrated in the southwestern half of the city in tracts considered lower resource (tracts 744.06, 744.07, 744.08, 755.12, 755.13, 755.14, 755.15). Several sites are located within tract 755.07,which is identified as a moderate resource area. D-4 • Despite the lack of new affordable housing units being introduced in northeastern,more affluent areas of the City, online survey results indicated that 65% of respondents chose the Tustin Legacy Specific Plan (TLSP) Area as an area that is most appropriate to develop more housing. • The City's strategy to preserve affordable housing in addition to developing other housing options within identified sites will encourage a diverse housing market that will attract people from all races and income levels in these areas. • Goals identified within Section D.5 below would be implemented citywide and support in furthering fair housing within identified housing sites. • Tustin Legacy (Tract 744.15) is a Master Planned Community that is currently being developed. Although the tract has been identified as low resource, it has been substantially enhanced with new resources within recent years. Improvements include schools, parks,community resources,employment centers, transportation,and a variety of housing. With recent improvements,the Tustin Legacy area surpasses other areas in the City for livability and well-rounded services for households with various income levels. As identified in Section D.3,the following concerns have been identified regarding fair housing issues: • Disparity in access to opportunity between the northeast (higher resources),where there are predominate populations of White residents,and southwest (lower resources) of the city,where there are predominate populations of Hispanic residents; • High segregation and severe housing issues for the city's Black residents; • Concentrated female-headed households and LMI population within Census tract 755.14; • Lack of affordable housing opportunities for Hispanic residents;and • Disproportionate housing problems faced by large family households. Factors that may contribute to these concerns include the following: • Lack of supply of affordable housing in high opportunity areas; • Inequal access to affordable housing for persons with protected characteristics; • Concentrated access to opportunity within high resource areas;and • Lack of education and enforcement, specifically to educate property owners/landlords about State law prohibiting discrimination. The City and County established goals to address fair housing concerns(Section D.5.1) which were included in the 2020 County Al. Several goals are cross-jurisdictional goals;Orange D-5 County and all participating jurisdictions have a role to play in implementing those goals. In addition,the City of Tustin committed to individual,which respond to city-specific challenges. Additionally,the City General Plan includes several goals that support in furthering fair housing. If implemented,the goals and strategies identified will serve as an effective basis for affirmatively furthering fair housing by reducing patterns of segregation,mitigating displacement,addressing disproportionate housing needs,and increasing access to opportunity for members of protected classes. D.I. Overview of AB 686 In 2018,the California State Legislature passed AB 686 to expand upon the fair housing requirements and protections outlined in the Fair Employment and Housing Act(FEHA). The law: • requires all state and local public agencies to facilitate deliberate action to explicitly address,combat,and relieve disparities resulting from past patterns of segregation to foster more inclusive communities;and • creates new requirements that apply to all housing elements due for revision on or after January 1,2021. The passage of AB 686 protects the requirement to affirmatively further fair housing within California state law,regardless of future federal actions. It also preserves the strong policy in the U.S. Department of Housing and Community Development's (HUD) Affirmatively Furthering Fair Housing(AFFH) Rule as published in the Federal Register in 2015. As of January 1,2019,AB 686 proactively applies the obligation to affirmatively further fair housing to all public agencies in California. Public agencies must now examine existing and future policies,plans,programs,rules,practices,and related activities and make proactive changes to promote more inclusive communities. AB 686 also creates new requirements for all housing elements revised on or after January 1, 2021. These requirements ensure that the obligation to affirmatively further fair housing is a part of a jurisdiction's planning process and guiding documents for community development. D.2. Assessment of Fair Housing Issues A fair housing issue is a condition in a geographic area of analysis that restricts fair housing choice or access to opportunity and includes such conditions as ongoing local or regional segregation or lack of integration,racially or ethnically concentrated areas of poverty and affluence, significant disparities in access to opportunity, disproportionate housing needs,and evidence of discrimination or violations of civil rights law or regulations related to housing. This assessment of fair housing considers the elements and factors that cause,increase, contribute to,maintain, or perpetuate segregation,racially or ethnically concentrated areas of poverty, significant disparities in access to opportunity,and disproportionate housing needs. Data and determinations below include findings from Orange County's 2020 Analysis of Impediments to Fair Housing Choice (2020 Al). The 2020 Al includes a thorough D-6 examination of structural barriers to fair housing choice and access to opportunity for members of historically marginalized groups throughout Orange County protected from discrimination by the federal Fair Housing Act (FHA). The 2020 Al also outlines fair housing priorities and goals and meaningful strategies that can be implemented at the county and city level to achieve progress towards affirmatively furthering fair housing. The California Department of Housing and Community Development(HCD) has developed a statewide AFFH Data Viewer,which assembles various data sources and provides options for addressing each of the components within the full scope of the assessment of fair housing. The AFFH Data Viewer was utilized to address the data components of new requirements to affirmatively furthering fair housing in combination with other data such as local or regionally available data. Other data sources used in this assessment include the 2010 U.S. Census, American Community Survey (ACS) 5-Year Estimates,and other sources as referenced below. Patterns were compared from the 2019 ACS 5-Year and the 2010 ACS 5-Year Census data to identify trends within the jurisdiction. Census tracts included the city of Tustin study area for this analysis include the following: • 524.19 (overlaps North Tustin) • 755.12 • 525.02 • 755.13 • 525.24 • 755.14 • 744.07(overlaps Santa Ana) • 755.15 (overlaps a small portion of • 744.08 Santa Ana and a large portion of • 755.04 (overlaps Santa Ana) Irvine) • 755.05 • 756.06 (overlaps North Tustin) • 755.06 (overlaps Santa Ana) • 756.07 • 755.07 • 757.01 (overlaps North Tustin) Several census tracts overlap the city boundary but were excluded from the study area since a substantial majority of the census tract falls within a neighboring jurisdiction as seen in Figure 1. Census tracts excluded from the study area include the following: • 754.03 • 756.03 • 757.02 • 744.06 • 756.05 D.2.1. Fair Housing Enforcement and Outreach Capacity The Fair Housing Foundation provides fair housing services for Tustin,along with various other cities in Orange and Los Angeles Counties. The Foundation provides landlord-tenant counseling and mediation,rental housing counseling,and community outreach and education. In addition,the Foundation screens fair housing complaints,investigates through testing, engages in conciliation or mediation efforts,and refer complaints to the appropriate administrative agencies where appropriate. D-7 During the 2015-19 reporting period the County of Orange Urban County Jurisdiction took the following actions(on its own or in cooperation with regional partners and the Fair Housing Council of Orange County (FHCOC)) to overcome impediments to fair housing choice identified in the 2020 Al: • Fair Housing Community Education- During 2015-19, the FHCOC regionally conducted or participated in 467 education and/or outreach activities. Regionally, over 9,550 people were served by these activities. Through its various regional outreach efforts FHCOC distributed over 82,130 pieces of literature on fair housing,its services and other housing-related topics.Additionally,throughout Orange County FHCOC held 32 training sessions for rental property owners/managers. FHCOC presented 16 fair housing seminars, 70 general fair housing workshops. • Fair Housing Enforcement- On a regional basis,FHCOC staff received 363 allegations of housing discrimination and opened 179 cases where the allegations seemed sufficiently meritorious to warrant further investigation and/or action. FHCOC also conducted 362 systemic onsite tests,either paired or'sandwich', 51 tests occurring in the jurisdiction and 215 other testing activities. • Housing Dispute Evaluation& Resolution- On a regional basis, activities provided by FHCOC included assisting 7,664 unduplicated households addressing 24,766 issues, disputes and/or inquires. According to the AFFH Data Viewer database,the United States Department of Housing and Urban Development Office of Fair Housing and Equal Opportunity(FHEO) inquiries for the city totaled 33 cases between 2013 and 2021,including 3 disability-,10 race-,1 familial status-, and 19 unclassified-related accounts. Of the 33 inquiries,18 resulted in failure to respond,2 resulted in no valid basis, 7 resulted in no valid issue,and 5 resulted in other disposition. During the 2018-2019 Fiscal Year,the Fair Housing Foundation assisted the City with combatting housing discrimination through managing twelve allegation cases and one discrimination case for Tustin residents,providing services to those individuals throughout the case management process. They also provided ample fair housing education and outreach to further prevent discrimination,assisting 127 Tustin landlords/tenants who were provided with either landlord/tenant counseling,mediation,UD assistance,and/or referral services during the last fiscal year. Overall,the Fair Housing Foundation's outreach efforts assisted 672 residents during the 2018-2019 Fiscal Year. Fair Housing Foundation provides a comprehensive,extensive and viable education and outreach program. The purpose of the program is to educate tenants,landlords,owners,real estate agents and property management companies on fair housing laws;to promote media and consumer interest;and to secure grass roots involvement within communities which includes: • Fair Housing Workshops • Certificate Management Training • Walk-In Clinics • Rental Housing Counseling Workshops • Community presentations, staff training, and workshops D-8 • Community events,booths,networking,etc. The following Fair Housing Foundation(now virtual) educational workshops are offered free of charge for Tustin residents every month: • Fair Housing Workshops • Rental Counseling Workshops • Fair Housing Workshops in Spanish • Fair Housing and the Housing Industry During COVID-19 Virtual Workshops (Landlord-focused) • Rental Counseling During COVID-19 Virtual Workshops The City advertises these workshops on their website's Fair Housing Services webpage. In addition,the City regularly updates its municipal and zoning codes in accordance with State and federal laws and requirements regarding fair housing. With each housing element cycle, local nonprofits,agencies,advocacy groups,and other fair housing stakeholders are invited to take part in the development and review of the City's housing element(see Section D.2.6). D.2.2. Integration and Segregation Integration generally means a condition in which there is not a high concentration of persons of a particular race,color,religion, sex,familial status,national origin, or having a disability or a particular type of disability when compared to a broader geographic area.Segregation generally means a condition in which there is a high concentration of persons of a particular race,color,religion, sex,familial status,national origin, or having a disability or a type of disability in a particular geographic area when compared to a broader geographic area. Race and Ethnicity The ethnic and racial composition of a region is useful in analyzing housing demand and any related fair housing concerns as it tends to demonstrate a relationship with other characteristics such as household size,locational preferences,and mobility. A full breakdown of city demographic data is provided in Table 2. In February 2017,the Department of Housing and Community Development (HCD) and the California Tax Credit Allocation Committee (TCAC) convened a group of independent organizations and research centers that would become the California Fair Housing Task Force ("Task Force"). TCAC and HCD charged the Task Force with creating an opportunity map to identify areas in every region of the state whose characteristics have been shown by research to support positive economic,educational,and health outcomes for low-income families—particularly long-term outcomes for children. These opportunity maps are made from composite scores of three different domains made up of a set of indicators. Table 1 shows the full list of indicators.The opportunity maps include a measure or"filter" to identify areas with poverty and racial segregation. To identify these areas, Census tracts were first filtered by poverty and then by a measure of racial segregation. The criteria for these filters were: • Poverty: Tracts with at least 30 percent of population under federal poverty line D-9 • Racial Segregation: Tracts with location quotient higher than 1.25 for Blacks,Hispanics, Asians, or all people of color in comparison to the County Figures 2 and 3 illustrate city and county opportunity ratings by Census tract. Figure 4 identifies concentrations of minority population by Census block group. Table 1:Domains and List of Indicators for Opportunity Maps Domain Indicator Indicator Economic Poverty Adult education Employment Job proximity Median home value Environmental CalEnviroScreen 3.0 pollution indicators and values Education Math proficiency Reading proficiency High school graduation rates Student poverty rates Source: California Fair Housing Task Force,Methodology for the 2020 TCAC/HCD Opportunity Maps,December 2020 Table 2: Race and Ethnicity (Tustin,CA CDBG) (Los Angeles-Long Beach- jurisdiction Anaheim,CA) Region Race/Ethnicity Count Percent Count Percent White,Non- 24,289 30.36% 4,056,820 31.62% Hispanic Black,Non- 1,926 2.41% 859,086 Hispanic 859,086 6.70/° Hispanic 32,982 41.22% 5,700,860 44.44% D-10 Asian/Pacific Island,Non- 17,542 21.93% 1,888,969 14.72% Hispanic Native American, 418 0.52% 25,102 0.20% Non-Hispanic Two+Races, 1,949 2.62% 267,038 2.08% Non-Hispanic Other,Non- 169 0.23% 30,960 0.24% Hispanic #1 country of Mexico 11,270 14.09% Mexico 1,735,902 14.34% origin #2 country of Vietnam 2,115 2.64% Philippines 288,529 2.38% origin #3 country of India 2,048 2.56% El Salvador 279,381 2.31% origin #4 country of Philippines 1,677 2.10% Vietnam 234,251 1.93% origin #5 country of Korea 1,446 1.81% Korea 224,370 1.85% origin China excl. Hong Kong 1,250 1.56% Guatemala 188,854 1.56% #6 country of origin &Taiwan #7 country of China excl. origin Taiwan 1,040 1.30% Hong Kong& 174,424 1.44% Taiwan #8 country of Iran 507 0.63% Iran 133,596 1.10% origin #9 country of Guatemala 405 0.51% Taiwan 87,643 0.72% origin D-11 #10 country of Canada 339 0.42% India 79,608 0.66% origin #1 LEP Language Spanish 10,333 14.60% Spanish 2,033,088 16.79% #2 LEP Language Vietnamese 1,665 2.35% Chinese 239,576 1.98% #3 LEP Language Korean 844 1.19% Korean 156,343 1.29% #4 LEP Language Chinese 816 1.15% Vietnamese 147,472 1.22% #5 LEP Language Tagalog 400 0.57% Armenian 87,201 0.72% #6 LEP Language Other Indic 285 0.40% Tagalog 86,691 0.72% Language #7 LEP Language Hindi 218 0.31% Persian 41,051 0.34% #8 LEP Language Persian 216 0.31% Japanese 32,457 0.27% #9 LEP Language Other Asian 183 0.26% Russian 28,358 0.23% Language #10 LEP Arabic 165 0.23% Arabic 23,275 0.19% Language Hearing difficulty 1,749 2.19% 303,390 2.52% Vision difficulty 1,216 1.52% 227,927 1.90% Cognitive 2,308 2.89% 445,175 3.70% difficulty Ambulatory 2,894 3.63% 641,347 5.34/a° difficulty Self-care 1,162 1.46% 312,961 2.60/a° difficulty Independent 2,353 2.95% 496,105 4.13% living difficulty Total 6,477 8.1% 158,784 5% D-12 (Tustin,CA CDBG) (Los Angeles-Long Beach- jurisdiction Anaheim,CA) Region Male 36,263 48.83% 6,328,434 49.33% Female 37,995 51.17% 6,500,403 50.67% Under 18 19,341 26.05% 3,138,867 24.47% 18-64 48,704 65.59% 8,274,594 64.50% 65+ 6,213 8.37% 1,415,376 11.03% Families with 9,226 52.64/° children 1,388,564 47.84% Note: LEP stands for Limited English Proficiency Source: County of Orange,Analysis of Impediments,2020 D-13 Figure 1: Census Tracts in the City of Tustin TM0 7� TOM 1NMeb 7�/.A 7tidt 7 LU v ' City of Tustin - Census Tracts City Boundary Q Cencus Tracts Not Analyzed 0 Tustin Cencus Tracts N 0 0.5 1 Miles p City of Irvine,County of Los Angeles,Bureau of Land Management,Esri,HERE, Garmin,INCREMENT P,USGS,EPA Source:AFFW Data Viewer D-14 Figure 2:2020 TCAC/HCD Opportunity Areas (Tustin) o na Im - — - lig I�r, r,m,n Ave orange F, I, ,,,I,r r kl J. Vi AI I IIJId AVCUL ' e 'q 0S Ma Ga�,yen Gru�Prw; -@m 1 1 rn U c Fairhaven N Memorial r � z f o I rllstin , c e syr,.,.; 't;.t>•Jv 1e A19�A1L-RS '> Santa All , 3ra51 402 p , I. ". alGA5lS rrezuey:� - � +51 Air' Hicks Ca Ian 4 a� 0 1� I`9! !1 � Srinlln vlEl A•iC -'� uth CitCit of Tustin /irvinea�" y 9 r Ranch TCAC Opportunity Areas 2021 f P'r` 1310Piii 'yam Oak Highest Resource c3;0ourse y - cIt `� High Resource $�'tiy y� _ M Q Moderate Resource(Rapidly Changing) �^ Moderate Resource Low Resource P . High Segregation&Poverty Cit Boundary y 4'.°,Illam Sand Ganyory iya5h l!rn•:f'" �133 INA 0 0.5 1 Miles - Mason "4 r,Rgyr nal City of Irvine,County of Los Angeles,Bureau of Land"Management E�ri,HERE, I I I PaIA Garmin,INCREMENT P,USGS,METI/NASA,,N..GA EPA USDA Source:AFFH Data Viewer - - French HidJ n .v '.... a D-15 Figure 3:2021 HCD/TCAC Opportunity Areas (County) . � �'", --• ... Mlra Loma" Whittler -`-- _ ) -. � .cn„, Eastvale Jurupa Vall — v, CHINO 4'ALLEY H«klen Valey, W rYt11N Area 'U LV -H N©1 HILLS Norco / ` Norwalk L(�.fL'YJ LyW�t:J 3rizn C,Ilik s.r Corona--"� Rom i u rti _ 55I—'-'__ _ ��, ,.. 7 EJ'CAL VALLEY u,a ,x 14i�.f1Y Irltr /) U:AlLT31r°.W� �. k AN v Orange County TCAC Opportunity Areas 2021 ° SANTA IWARG MOUNTAi • .. Slate Highest Resource 0 High Resource Q Moderate Resource(Rapidly Changing) Moderate Resource ~ 0 Low Resource 0 High Segregation&Poverty ~ 0 Missing/Insufficient Data Q County Boundary 'r4 N 0 2.5 5 Miles A I t ! t I A,N Garmin,USGS,NGA,EPA,USD Source r.AFFH Data Viewer D-16 Figure 4: Areas of Minority Concentration in Tustin o ne elm V) �- ' Regional Z cr''' z Park. z z tiC �PmanAve Orange �A--E-Chapman-Ave LanycnV,o,a I?- J. 'Vv Al in.nl Ave 4y � Peters r i.anyo �.. F La'Je L3 ARe ro v ve f Par r w o Fairhave n ttA■Pamok?ml Foothill H> sr XI,, C L _— i'rr }P North Tustin v` rol h.j; r �A' fTit hSt A fi n lege g D zz z I [� e. a r r••. C.r. P Rel ° Santa Ana L 4t ' Joe m v ;3rasl C c a % L .^. O` .. r ht m L? 2 r Vd.KY,LO Y th m .. Y.Y3 fiy,Y1 yv� iq rfj Lt, nU f I''r+3 F Ea,rger Ave cam "I"ti SI Ar1y,'eW E'I u, I .,w. Hicks C V P m U, r, 3 I yv F Pyer Rd . Fr. 5 y `S R R + 5 I qy a Strnflo Vier Ae-e o �''+u. `�• Oji �Se� j�� ast Anton eN eta 4,,, NSXz;ti �y y� eh 6GL SansDiegortF' SF/r: oeo Irvine v s t ^�/.. Ram In City of Tustin Park Gr ' t p titan is Nrir y Oak t �y E C reek Golf or Racial Demographics 2018 (Block Group) ya° �y c Cour <20% S% a N 21-40% y '� r 41-60% �^ ® 61-80% F' N, Q City Boundary 5inc!CanYonaLasB` �13a IN A 0 0.5 1 Miles City of Irvine,County of Los Angeles,Bureau of Lan 44nagement E HERE, I I I Garmin,INCREMENT P,USGS,ME'T lf4fal �A,USDA Source:AFFH Oat.Viewer �� Freni;4 HY _ �j3`�` ro D-17 Two quantitative metrics can be used to analyze the relative extent of racial and ethnic segregation in entitlement jurisdictions for federal housing programs. These are known as the dissimilarity index and the isolation index. The dissimilarity index is a primary quantitative metric used for identifying patterns of geographic segregation. The isolation index,another quantitative metric for identifying patterns of geographic segregation, compares a group's share of the overall population to the average share within a given sub-area (such as census tract). Table 3 provides thresholds for dissimilarity quantitative analysis.Values for the Isolation Index range from 0 to 100. A larger value means that the average group member lives in a census tract with a higher percentage of people from another group.Table 4 indicates dissimilarity index scores,and Table 5 indicates isolation index scores. Table 3:Dissimilarity Index Thresholds Value Level of Segregation Dissimilarity Index Value (0- 0-40 Low 100) 41-54 Medium 55-100 High Table 4:Dissimilarity Index Scores Racial/Ethnic Dissimilarity1990 2000 2010 Index 2020 Trend Trend Trend Tustin Non-White/White 26.33 36.73 32.93 48.19 Black/White 42.49 35.11 29.03 66.02 Hispanic/White 31.14 48.19 42.55 57.43 Asian or Pacific Islander/White 19.20 17.74 19.76 28.73 Orange County Non-White/White 30.38 34.71 33.58 44.71 Black/White 32.60 33.63 32.27 46.98 Hispanic/White 36.13 41.08 38.18 52.82 Asian or Pacific Islander/White 32.58 34.31 34.82 43.19 Source: County of Orange,Analysis of Impediments, 2020 D-18 Table 5: Tustin Isolation Index Scores 2020 Isolation Index 1980 1990 2000 2010 2020 (Orange County) White/White 83.7 66.3 54.3 43.2 52.44 55.16 Black/Black 6.1 9.9 3.6 2.7 4.84 3.32 Hispanic/Hispanic 10.2 27 51.3 51.9 56.10 52.81 Asian/Asian 4.4 12.1 19.6 26.7 19.86 31.84 Source: County of Orange,Analysis of Impediments,2020 As shown in Figure 2, the city's highest resource areas are to the northeast and the low resource areas are to the south and southwest. The city did not include any areas categorized as high segregation and poverty. The city's resource trend is consistent with the county's overall trend. The county's highest resources were generally located along the coast and within the hillside areas,while low resource areas were clustered near the center of the county along Interstate 5 (1- 5) (see Figure 3).Areas that were indicated as rapidly changing were located along the perimeter between low resource and high resource areas,particularly on the southern coastal side. The City of Tustin is not classified as a rapidly changing area. This pattern indicates a rapidly expanding trend of high resources from the coast,inward towards central Orange County located near I-5. Overall,Orange County experiences moderate levels of segregation,with significant variances in some individual jurisdictions. The Non-White/White value is 44.71,Black/White 46.98, Hispanic/White 52.82,and Asian or Pacific Islander/White 43.19. These values have all increased sharply since 2010,though values had remained consistent from 2000 and 2010. Jurisdictional values tend to indicate low levels of segregation in comparison to the county as a whole,but this is due to the spatial distribution of populations across different jurisdictions rather than within different jurisdictions. Tustin experiences a range in levels of segregation between different racial groups. The Asian or Pacific Islander/White Dissimilarity Index current value was 28.73,indicating a low level of segregation. Non-White/White Dissimilarity Index value was 48.19,indicating a medium level of segregation. Black/White and Hispanic/White Dissimilarity Index values were 66.02 and 57.43,respectively,indicating a high level of segregation.All races experienced an increase in segregation from 2010 to present. Black residents faced an especially large increase in segregation from 2010 to present and is one of the highest Dissimilarity Index values amongst all jurisdictions within Orange County. Overall, Tustin s current Dissimilarity Index values were higher than most other jurisdictions within the county. Isolation values for different populations vary widely across the county and individual jurisdictions.Values for White residents are generally higher than for other residents,likely due D-19 to the larger number of White residents overall. In Orange County,White residents have a current Isolation Index value of 55.16,Black residents 3.32,Hispanic residents 52.81,and Asian residents 31.84. Values for the county are higher than values in Tustin for White and Asian residents,again likely due to higher segregation across jurisdictions rather than within them. County Isolation Index values have generally decreased for White residents over time, increased for Hispanic and Asian residents,and remained low for Black residents. City Isolation Index values were slightly higher for Black(4.84) and Hispanic (56.10) residents. City data from 1980 to today shows that, similar to the county trend,Isolation Index values have generally decreased for White residents over time,increased for Hispanic and Asian residents,and remained low for Black residents.The group with the highest level of isolation as of 2000 is the Hispanic population. Before 2000,the White population historically experienced the greatest level of isolation. Persons with Disabilities As shown in Table 2,the city population has relatively low percentages of persons with disability. The city's percentages for hearing,vision,cognitive,ambulatory, self-care,and independent living difficulties were all lower than the county's. Figures 5 and 6 illustrate the population percentage with disability within the county and city. The county includes several clusters of population with disability,including areas near Westminster,Fullerton,Huntington Beach, Lake Forest/Mission Viejo,and Laguna Beach/Dana Point. In the City of Tustin,there are only a handful of census tracts containing 20 percent or greater populations with a disability. As indicated by Table 2, Tustin s population also tends to be slightly younger than the greater Orange County population. Data provided in Table 6 shows to what extent people with different disabilities are able to access and live in the different categories of publicly supported housing within the city. As shown in Table 2, the city's population of persons with disability is 6,477, or 8.1 percent of the population. The City of Tustin includes two types of publicly supported housing,Project-Based Section 8 Housing and Housing Choice Vouchers (HCV). The proportion of people with disabilities that qualify for Section 8 Housing and HCV, exceeds the overall population concentration of people with disabilities. According to FHEO statistics,3 of 33 total inquires within the city of Tustin filed between 2013 and 2021 were disability-related. Tustin allows for reasonable accommodations in the land use and zoning process for developers of housing for persons with disabilities. Table 6:Disability by Publicly Supported Housing Program Category,Tustin People with a Disability Count Percent Public Housing n/a n/a Project-Based Section 8 11 10.68 D-20 Other Multifamily n/a n/a HCV Program 108 19.82 Source: County of Orange,Analysis of Impediments,2020 Familial Status In order for families to have protected choice they need to access housing options without discrimination. In a 2016 housing discrimination study,researchers found that compared to households without children,households with children were shown slightly fewer units and were commonly told about units that were slightly larger,and as a result, slightly more expensive to rent(California Department of Housing and Community Development,2021). This differential treatment is considered discrimination and a type of steering,which occurs on a racial basis as well. Familial status refers to the presence of children under the age of 18,whether the child is biologically related to the head of household,and the martial status of the head of households. According to the HCD AB686/AFFH data tool maps (see Figure 7),all Census tracts in the city identified persons 18 years and over in households living alone as making up less than 20 percent of the overall population across all census tracts.Percentage of persons 18 years and over in households living with a spouse ranged across the city. As shown in Figure 8, percentages of persons 18 years and over in households living with a spouse increased from the southwest to the northeast. Census tracts in south and southwest portion of the city(tracts: 744.06, 744.07, 744.08, 755.12, 755.13, 755.14, 755.15) contained approximately 20 to 40 percent persons 18 years and over in households living with a spouse,while northeast census tracts identified 60 to 80 percent of persons 18 years and over in households living with a spouse. As shown in Figure 9,majority of children in the city are living in married couple households. Throughout Tustin, almost all census tracts indicated 60 percent or greater of children living in married couple households. Conversely, one census tract, 755.14,appears as an outlier with 40 to 60 percent of children living in female-headed households (see Figure 10). Additionally, 75 to 100 percent of households in this census tract were identified as low to moderate income in Figure 11. Overall,the city of Tustin has a slightly higher proportion of families with children (52.64 percent) than the larger region(47.84 percent) (see Table 2). D-21 Figure 5: Percent Population with Disabilities in Orange County Chino Hills Mlra lana :rtlutl-r cnrrw Eastvale Jurupa Vail „'I S CHINI Witllid VALLEY Wgkjlin va . I eY•r..e .F CHIkd HELLS -_...__. ?� - CnrnoHdts ,I hluns rMl �.�•! Corona— TE 4ESCA4 VALLEY Th. Q Retreat Y I I it • Y �, II 73 -Al° - .t W - 7 g. v L C.C-UJ'l•9- - X00,. :;a fv'�P �l/Y14n"' Sxare Orange County Population with a Disability(Tract)-ACS(2015-2019) C 10% 1-:- IN4u we 10%-20% 20%-30% 0 14 % % >40 county Boundary s AN 0 2.5 5 Miles I I I I Esri,HERE,Garmin,USGS,NGA,EPA,USDA,NRS Source:AFFH Data Viewer D—LL Figure 6: Percent Population with Disabilities in Tustin o na im - - - 1Y Ch roman Ave Orange � ,` E-ChapmamAva {� U 'v.Almant Ave y y�G � r aq E La Veta Aye v. e - Garyery Gro`4e'Fw1'` rn 0 r air ven moral I z North T tot ?t/o t*a 'A' 1 7th 5tiAm lege =z b •,,,. _._ - . 1 U�CI.�B(l�i 'AJ q Santa Ana .. _ 3rd 51 q o E6.6.d - 1 h * - � y UT...lt21LY/ 0 7 2 N - s 1: l m` L r;t m _ y n rc IAA:.I`773 P.CY�.ELSi7 v`6i Orifi j� a 'SI Ani,,,v Pi vjmalv� kicks Ca 1 W vj hyo M t i V Q .. c g F (lyet fa€1 �p 43 � � h a� 0 .... _..� a`� r, I`9! Snnfin vrer A,� rr�• uth dy An '-n Die rVlnr3 err Raw h City of Tustin E, Oak �P Creak Golf Cr Population with a Disability (Tract) - ACS (2015-2019) ¢ course 0 <10% 10%-20% r- 20%-30% >40% 1 A 4 Q City Boundary h Unlvf",+'4 ItasJ A 0 0.5 1 Miles Irvine,County of Los Angeles,Bureau of Lan nagement,E I,HERE, t I I Garmin,INCREMENT P,USGS, A,USDA ch Hit Source:AFFH Data Viewer r`v D-23 Figure 7: Percent Population of Adults Living Alone -Tustin ,fa z z cil `Po hapman Ave ;r E-ChapmomAve Oarl� �d Ahimid Ave y m ~� c �G`(�- -•-T� E La;'elzi Ave — 22 harden•Gro'4 e'f Fantu._, H Memo"" I Park F FuuihdrFr z = North Tu in sml - tpn S'^i 17th 5t Z y La An r0 Ikge o cC , Z D.'A' - VhIQt � •;�ntaAik,BI-A �•aiitd e, v 1. • 0 m a L r;n. m ,I Ary,7r.. U"� Nfeks Cany arner-Ave—,7,----- j 8�yy '^ U� L D,er R,1 Ln R 1' 4, r Culver Al Plem '�o., 1. titinllov;er Aie ,N V6 th K rY St m ov Unrvine C Ranch Geek " F Park QQi Oak b Jahn a�av q k'' f_ Creek Goff Course eb AitFori.�>rany. _ -- v� P,4ithelscl0 �,v City of Tustin Percent of Population 18 Years and Over in Households Living Alone (2019) 0 City Boundary !wash C N A 0 0.5 1 Miles ity of Irvine,County of Los Angeles,�IW.@nzi I,HERE, t i I Garmin,INCRE.,N�IE'�1T P,USGS,M .3 A,USDA 4 y Source:AFFH Data Viewer PeAylt Hr# •� `�` c-" D-24 Figure 8: Percent Population of Adults Living with their Spouse -Tustin o ne im i z h�Ch man Ave F Orange `�P•Chapman Ave 's dd Ahnand Ave 2 -'-- ° Garyery Gro�BF��� — in c Fauh„ �. m tWlemarui� a, Park. Foo°I. m 4 E N orth T -A' 17th St iAm s� !e 0 m z Mrd st � .I Santa Ana 3 r .+.. ca B , t'+ L hlu' f �� m m y n JI Dom' F t�,,x7er Ave 51 Anjj,,v Pi �&m Hicks c' w, VE! c rfl o � yl: E Dyer Ra V) Vi �1 Al $untlI Ave ulh • �1'r• �, 4 4R�f f�i, ami AntontN6 `W 4,;, y. San�DiegotFwy � �,�^ IfVln@ o �'lx" o��`6rw mfr Ranch 1ti� S, Park r,. Oak yP'' C-1,Golf or ~ Course City of Tustin Percent of Population 18 Years and Over in Households Living with Spouse * n 4 rf4f lY. Q 40%-60% .� m 60% 80% ���� ti a Q City BoundaryIN h' llnlyE.t50�'` 1133 A0 0.5 1 Miles Irvine,.County of Los Angeles,Bureau of Lan nagement,E i,HERE, I I I I Garmin,INCREMENT P,USGS,METI/N " A,USDA Source:AFFH Data Viewer - f•P��J - �4 D-25 Figure 9: Percent of Children in Married Couple Households -Tustin o ne im - r n z // hr Cfk Aman Ave Orange ,�-E•Chapman•Ave-•` t,nion V,e,y 1, dd Ahnaid Avc 9Qk� c t C f•* ` e' F La Veta AvF he __ m 2 G aryery GroveF�"� Faiift m tWtemarui� a, ParR ` ] Foothillf„ m 4 1_- ll. SFr i` z - North T col `'in u -A' 17th St a - A n a� .�,1 rl f I All, lr:",t& r . 3rd st CL 5�c� Gam' e E VJDA 0 v, 1 ca 4 t''+ L hlu9903 n y n JI t� rn � ��t v.gry fa fa '.S'51 Anj1,.t f H+CFS C❑ 1 94 °• VQ E Oyer fid r U) 0�' �. Sunflower Ave '�Y 1s°F Tim uth ast 20 AntorN 6 4„ San�DiegolFwy � rVln@ a yx'P_L0�;��'w Ranch 11; Park City of Tustin f>, Oak �y � Creak Goll oC Course Percent of Children in Married-Couple Households 20%-40% w 40%-60% �`'-- �u 4% - 60%-80% s C` �• - >80% c" Q City Boundary 1 Univf",+'4IN IrasJ 0 0.5 1 Miles Irvine,.County of Los Angeles,Bureau of Lannagement,E i,HERE, A I r i I Garmin,INCREMENT P,USG. A,USDA A Source:AFFH Data Viewer - r40 - r`v D-26 Figure 10: Percent of Children in Single Female-Headed Households -Tustin rij 1, hleglOn.�t h�Ch F,man Ave Orange �—E•Chapnnan-Ave niCn V,e,y.N dd Ahnaid Ave i m n FLaVeL3Aye 2 Gar aeh•Grove'f.Y` Fairhaven m klemorial a, Fuoi h i I m 4 Patlt E z = North T 'Plo° -A' 17th St VJ iAm 9e M . 0 Z o` e Z ( O Santa Ana rd st t. dl CLE 1. + C ca 71 L m 13 `n f�17 4Y1 y n in (4 GT! C IIULI`iti CK`Y.hC3:7 ��'t •�o%3�a t EO,ikBer Ave '.S'51 Anj1,,v Pi �&M Hicks C❑ 6, V e c E Dye Fct r V) 0�' �. Sunflov;er Aid uth Antun�ty� � Fti SJan-iDieg,o1F. �rVln2 4 yn ✓o�� Ranch PIII Park G`epJc F , .,. e,�u fiir ' Oak Creek Golf oC City of Tustin C°urme - Percent of Children in Female-Headed Households 0 <20% 0 209/.-40% 40%-60% Q City Boundary �. 0 0.5 1 Miles Irvine,.County of Los Angeles,Bureau of LanA nagement,E i,HERE,Garmin,INCREMENT P,USGS A,USDA Source:AFFH Data Viewer - �40 - D-2 Income Level Identifying low or moderate income (LMI) geographies and individuals is important to overcome patterns of segregation. Figure 11 and Figure 12 show the Lower and Moderate Income (LMI) areas in the city and county by census tract,respectively.HUD defines a LMI area as a Census tract or block group where over 51 percent of the population is LMI (based on HUD income definition of up to 80 percent of the AMI). Similar to trends of high and low resource shown in Figure 1, the city's lowest percentages of LMI population are to the northeast and the highest percentages of LMI populations are to the southwest (tracts: 744.06, 744.07, 744.08, 755.12, 755.13, 755.14, 755.15). LMI populations within the county also followed trends of high and low resource shown in Figure 2. Density of LMI populations tend to increase within inland areas, specifically cities located adjacent to or intersected by the I-5 Santa Ana freeway, State Route 55 freeway,or the 261 Toll Road. The highest percentages of LMI population are located near Fullerton and Santa Ana. Smaller LMI populations are located near Lake Forest, Laguna Niguel,and Dana Point. Within the county,the coastal and hillside communities tend to have lower percentages of LMI populations. D.2.3. Racially and Ethnically Concentrated Areas Racially/Ethnically Concentrated Areas of Poverty In an effort to identify racially/ethnically-concentrated areas of poverty(RECAPs),HUD has identified Census tracts with a majority non-White population(greater than 50 percent) and a poverty rate that exceeds 40 percent or is three times the average tract poverty rate for the metro/micro area,whichever threshold is lower. Orange County includes two RECAP area clusters scattered throughout the jurisdiction as shown in Figure 13. RECAP areas include southern Irvine (University of California, Irvine campus) and three small census tracts surrounding Santa Ana.Areas that include high percentages of persons who are considered poverty status are dispersed throughout the northcentral Orange County.The southern portion of Orange County does not include RECAP areas and has low percentages of persons considered poverty status. As shown in Figure 14,the city of Tustin does not include RECAP areas;however,the southern portion of the city,near Irvine and Santa Ana where RECAP areas were identified,are higher in percentages of population considered poverty status. Racially Concentrated Areas of Affluence In response to the RECAPs utilized by HUD in its 2015 AFFH rule, scholars at the University of Minnesota Humphrey School of Public Affairs have created the Racially Concentrated Areas of Affluence (RCAAs) metric to more fully tell the story of segregation in the United States. Based on their research,RCAAs are defined as Census tracts where 1) 80 percent or more of the population is white,and 2) the median household income is$125,000 or greater (slightly more than double the national the median household income in 2016). While this is a useful measure nationwide, HCD has adjusted the RCAA methodology to better reflect California's relative diversity. D-28 Figure 11: Low and Moderate Income (LMI) areas in Orange County Hills� Chino i; Aura Lima Whittier- _ �j ,;h„�, _Eastvale Jurupa Va61 re�rl _ HieJd�n 4 Y4sv � f'U f'�NTE' H'I I � CHVNiiJ VAL LFY y�„mlure ar.a-i ,,/ m y \ ^S Chino Hills - -_ N-- 'Norwalk SeaW NA MI .-,moi _,,,.✓. Be • •• ••. _ �ucnn I IH ower COrOna—”" La be G e; 55 7 ES CAL VAtLEw The lln.nl aM��i old t m I iii • 73 7 a o L L IS i ,3rdl� D Orange County Low to Moderate Income Population(Tract)-(HUD) <25% kb,,-cc 25%-50% 50%-15% -75%-100% 0 County Boundary N A 0 2.5 5 Miles City of Irvine,County of Los Angeles,Bureau of Land Management,Esri, RE, I I I I I Esri,HERE,GarUSGS,NGA,EPA,US DA^ Source:AFFH Data Viewer min, D-29 Figure 12: Low and Moderate Income (LMI) areas in Tustin o na im - — - 1Y Ch rdman Ave Orange � �r F;Ilr oy,rr,-r�,✓.ve 111, h U 'v.Almanul A'de y r y�G � aq E La:re 4i Ave 2 E Garyery Gro�e'F��y �� � . rn v C Fdirli9:rir N Memorial u Park Foolhil-i, e z = North T ani t*a Al t 7tte W t A J) 1 z I 1, S.1f1t:1 AlI.i r , �3rd51 0 o \ gw N - � ca M - UULI'i'u CXSCACSJ � �'t/1. 'SI Ai Hicks c VY c ffl q y r' yQ: a: r9! SI,In11nv;Fr AVe =i UIII matin F all An to r. star,Diego,f wy rvin ;+ Raw 9 ..eek City of Tustin E>, f Oak �y � Creak Goll Cr Course Low to Moderate Income Population (Tract) - (HUD) <25% r L J25%-50% r- N' _] 50%-75% 75%-100% City Bounder Y 1* Urn et5,+.` �Ib3J A 0 0.5 1 Miles Irvine,County of Los Angeles,Bureau of LanSWanagennent,E I,HERE, I I I Garmin,INCREMENT P,USGS, A,USDA ch Hit Source:AFFH Data Viewer r`v D-30 Figure 13: Racially Concentrated Areas of Poverty (RECAPs) in Orange County Mira Uma y`Jl E2SIV .Ie Joupa Vall �1�hltti er _- -- un�n� P m N, HILLS fink r•1 j.�✓ ri nc�„I _ r Corona--�--1' �r ss T ESCAt VALLEY The - 0 Retreat Ca I 73 e o U L I d 1 r� Orange County ter. SANTA MARL, Racially or Ethnically Concentrated Areas of Poverty(R/ECAPs) ® 0-Not a R/ECAP Beach 7J�1-R/ECAP Area Poverty Status(Tract)-ACS(2015-2019) COUNTY <10% tamp r<- SO%- 20%-30% \\\ 30%-40% 1.,. -I 4 County Boundary S, N 0 2.5 5 Miles h City of Irvine,County of Los Angeles,Bureau of Land Management,Esri,HE 'l1V I i i i I Esri,HERE,Garmin,USGS,NGA,EPA,USDA,NR� Source:AFFH Data Viewer D-31 Figure 14: Racially Concentrated Areas of Poverty (RECAPs) in Tustin I�etOronal Park. Orange - ,n—E-Ehapman'Ave nYon'Jie,t t< Z r m, ay F La Veto Ave % 2 0 _' Garycn=Gro�e'fwY""" —� N 'o Fairhaven w Memorial '— Park 63 Li i Z - North T lir rot 'pkat '^; 17th St a lege z z 1 Santa Ana a, "r _ 3rd 51Msiffi o E-1St St a n E(_ &.6.6 Yen 1. 0 7 = yw c 010 o L', L hlr: _ m m J J JI�0.311-110 F td-rx7er Ave SI ArYJ!,,v Pf uaa�lmm Hicks ca VQ C rrl o v�' J • 5�-�.�!y���r� N U� (I1 U�C.1.`.1..�U2� E I!'j t'r Lil! a� 0 �e a` r9! •r. r S jn1Inv;er Ave uth zu h' City of Tustin �"t, Ranch - Park .:- �• Racially or Ethnically Concentrated Areas of Poverty(R/ECAPs) ss Oak �0-Not a R/ECAP Creek Golf Cr 1-R/ECAP Area !¢ �., Course Poverty Status(Tract)-ACS(2015-2019) f n 10%-20% o c i 30%-40% ->40% �/ ®city Boundary h�as�" L�nn.etsktiv`.+ ItasJ IN 0 0.5 1 Mlles ity of Irvine,.County of Los Angeles,BA�of nagement E i,HERE, r I I Garmin,INCREMENT P,USGS,M" _ " A,USDA Source:AFFH Data Viewer FTr,,Gh HJiJ _ 'y D-32 RCAAs have not been studied extensively nor has a standard definition been published by HCD or HUD,this fair housing assessment uses the percent White population and median household income as proxies to identify potential areas of affluence. Table 7 shows percentage of White (alone) population and median income by jurisdiction for the city of Tustin,Orange County,and several surrounding jurisdictions. The percentage of White population in Tustin (59.01 percent) is comparable to the county's (59.25 percent). The city and county median household incomes are also similar with annual incomes of 84,697 and 90,234 dollars, respectively. Santa Ana (28.87 percent) and Irvine (47.80 percent) both have lower percentages of White population,while the city of Orange has a very high percentage (74.03 percent). Generally,the rank of jurisdictions from low to high percentage of White population is also consistent when ranked from low to high income,except for one outlier. The city of Irvine had the highest reported median household income ($105,126) and has a predominately non-White population.According to the 2020 Al,Tustin isolation index for White population was 52.44, which is moderate compared to other jurisdictions within Orange County and is lower than the county's calculated overall value (55.16). Table 7:White Household Income and Percent Population (2019) Tustin e Oran (city) Santa Ana Irvine Orange Orange County Median Household 84,697 91,793 66,145 105,126 90,234 Income All 931304 95,827 70,084 111,574 95,934 Households White alone' 101,658 95,702 79,000 113,779 100,723 White 59.01% 74.03% 28 47.80/° 59.25/°87% ° Population Notes: 1.White Alone refers to people who reported White and did not report any other race category. Source: 2015-2019 American Community Survey 5-Year Estimates The City of Tustin has a lower median income than Orange County,but overall percentage of the White population is almost identical.As shown in Figure 15,both income and White populations tend to be concentrated within the northern portion of the city. Although census tracts of high income and predominately White populations do not exactly overlap,there appears to be an area of lower income and non-White majority near census tract 755.14. D-33 w- w G3 Q� u F- ..3 - t q o_ O p o � � w 0 z p Q V c - p Y ❑ p q�..r1' d � �� W /'� rr q rx• V �I ,GO w O _ Q� W W p Q a GJ p a © _ H�r O iN _• p Q \ o .0 0 0 CO _ o N o -XN pIi �t ,I aaa ti LH � o Q o w V a 00 O O - - I n o � m O Ill C O o � O ttl a C.1 0 D.2.4. Access to Opportunities Access to opportunity is a concept to approximate place-based characteristics linked to critical life outcomes. Access to opportunity oftentimes means both improving the quality of life for residents of low-income communities,as well as supporting mobility and access to'high resource'neighborhoods. The following section describes locational differences and disparities experienced by different groups in accessing key features of opportunity: educational quality, economic factors,transportation,and environmental health. TCAC/HCD Opportunity Maps The 2021 TCAC/HCD Opportunity Maps are made from composite index scores of three different divisions (economic,environmental,and education) to categorize tracts as low, moderate, or high resource (Table 1 shows the full list of indicators). Categorization is based on percentile rankings for Census tracts within Orange County.Higher composite scores correlate to higher resources. Three opportunity indices (economic,educational,and environmental) use data assembled by the California Fair Housing Task Force on behalf of the Department of Housing and Community Development (HCD) and California Tax Credit Allocation Committee (TCAC) for the 2020 TCAC/HCD Opportunity Map. The Economic Opportunity Index is a composite of four indicators depicting elements of neighborhood socio-economic character. The Environmental Opportunity Index reflects indicators from the exposures and environmental effects subcomponents of the"pollution burden" domain of CalEnviroScreen 3.0. The Educational Opportunity Index is a composite of four educational indicators capturing information on student proficiency, graduation rates,and student poverty.All indices range from 0 to 100,reflecting percentiles scaled to census tracts in Orange County,and with higher values indicating higher levels of opportunity. The two transportation indicators (transit trips and low transportation cost) analyzed below employ data from version 3.0 of the Location Affordability Index (LAI) 9.The transit trips index measures how often low-income families in a neighborhood use public transportation. The index ranges from 0 to 100,with higher values indicating a higher likelihood that residents in a neighborhood utilize public transit. The low transportation cost index measures cost of transportation and proximity to public transportation by neighborhood. It too varies from 0 to 100, and higher scores point to lower transportation costs in that neighborhood. At the County level,high and highest resource areas are located along the coast in cities such as Huntington Beach,Newport Beach,and Laguna Beach(see Figure 3). Whereas a greater concentration of low resource areas are concentrated in north-central Orange County in cities like Anaheim,Santa Ana,and Orange. Locally,northern and central Census tracts (407.03 and 408.12) scored lower,indicating lower resources than other tracts within the City,although overall scores still indicated"High Resource." Table 2 shows the scores by domain. Tables 8 and 9 provide index scores by race and tract. D-35 Table 8 : Opportunity Map Scores -City Environment Low Economic Educational Tustin Opportunity al Opportunity TransportatiTransit Index Index Opportunity Index on Cost Index Index Tustin total Population White,Non- 77.38 55.53 57.98 37.04 41.62 Hispanic Black,Non- 49.56 33.87 33.27 54.51 60.02 Hispanic Hispanic 42.96 28.64 27.42 56.88 63.88 Asian or Pacific 67.05 46.94 49.79 44.90 48.62 Islander,Non- Hispanic Native American, 63.12 43.93 47.46 43.06 49.65 Non-Hispanic Tustin population below federal poverty line White,Non- 57.39 42.89 38.78 47.97 52.79 Hispanic Black,Non- 36.90 22.50 25.10 55.19 64.45 Hispanic Hispanic 32.15 17.72 18.62 65.68 74.10 Asian or Pacific 42.37 30.60 25.82 55.88 61.08 Islander,Non- Hispanic Native American, 26.20 13.70 14.20 65.00 66.80 Non-Hispanic Orange County total population D-36 White,Non- 59.36 53.88 58.61 33.84 27.43 Hispanic Black,Non- 45.85 45.21 45.63 39.68 36.21 Hispanic Hispanic 31.86 41.02 30.86 41.80 41.28 Asian or Pacific 49.36 46.78 52.50 37.48 36.11 Islander,Non- Hispanic Native American, 46.39 48.79 45.07 37.47 33.02 Non-Hispanic Orange County population below federal poverty line White,Non- 51.70 51.01 52.13 39.18 32.26 Hispanic Black,Non- 36.25 40.42 37.29 40.77 35.60 Hispanic Hispanic 22.65 39.02 23.81 45.65 46.55 Asian or Pacific 38.94 46.38 48.32 41.97 39.51 Islander,Non- Hispanic Native American, 35.89 38.62 40.92 40.15 40.17 Non-Hispanic Source: County of Orange, Analysis of Impediments,2020 D-37 Table 9: Opportunity Map Scores- Census Tracts Economic Environmental Education Census tract Domain Domain Domain Composite Final Index Score Category Scores Scores Score 0524.19 0.962 0.574 0.863 0.638 Highest Resource 0525.02 0.896 0.166 0.199 -0.217 Moderate Resource 0525.24 0.912 0.376 0.541 0.272 High Resource 0744.07 0.12 0.024 0.055 -0.94 Low Resource 0744.08 0.179 0.047 0.054 -0.839 Low Resource 0755.04 0.702 0.199 0.35 -0.136 Moderate Resource 0755.05 0.622 0.22 0.068 -0.462 Low Resource 0755.06 0.614 0.619 0.529 0.189 Moderate Resource 0755.07 0.626 0.27 0.208 -0.269 Moderate Resource 0755.12 0.27 0.218 0.106 -0.575 Low Resource 0755.13 0.386 0.185 0.199 -0.426 Low Resource 0755.14 0.187 0.092 0.078 -0.753 Low Resource 0755.15 0.452 0.005 0.236 -0.839 Low Resource 0756.06 0.986 0.534 0.927 0.766 Highest Resource D-38 0756.07 0.948 0.709 0.683 0.517 Highest Resource 0757.01 0.776 0.156 0.43 -0.028 Moderate Resource Source: California Fair Housing Task Force,TCAC/HCD Opportunity Maps,2021 Statewide Summary Table,December 2020 Education Countywide,there are disparities across racial/ethnic groups in access to educational opportunities as measured by the index.Across all tracts in Orange County,non-Hispanic Whites exhibit the highest exposure to educational opportunity (index score of about 59) and non-Hispanic Asians second highest(53).Hispanics have the lowest access to these opportunities (31),with non-Hispanic Blacks in between (46) as seen in Table 8. Several jurisdictions score highly(index values at or above 60) on educational opportunity across all racial categories. These cities include Aliso Viejo,Huntington Beach, Irvine,Laguna Niguel,La Palma,Mission Viejo,and Rancho Santa Margarita. Other jurisdictions obtain low scores on the index. San Juan Capistrano has low educational opportunity,scoring below 10 on the index for all races/ethnicities. San Clemente,Anaheim, and Santa Ana fare similarly poorly,although non-Hispanic Whites score higher (39) than other race/ethnic groups in these cities. Buena Park, Costa Mesa,Garden Grove,Orange,La Habra and Westminster are other cities that struggle with educational opportunity,all with scores in the 30s to 40s on the composite education index. Finally,a few cities have educational opportunity patterns that mirror those of Orange County overall. Non-Hispanic Whites in Fountain Valley have high exposure to educational opportunity(scores of about 60),whereas Hispanics in the city do not(30). In both Fullerton and Tustin,Non-Hispanic Whites and Asians have much higher access than do Blacks and Hispanics. The location of proficient schools and school assignment policies may be significant contributing factors to fair housing issues in Orange County. The schools with the highest proficiency in Orange County are generally located in coastal areas and hillside areas rather than in the center of the county,though Irvine is an exception. This distribution of proficient schools maps on to patterns of residential racial and ethnic segregation,with disproportionately White population in areas with high performing schools and relatively low Hispanic population in those areas. Public education in Orange County is highly fragmented with 27 school districts serving the county's students. District boundaries frequently map onto municipal boundaries, which in turn correlate to patterns of segregation. Inter-district transfers are only available for extremely limited circumstances. This Analysis did not reveal school assignment policies that contribute to segregation within individual school districts. D-39 According to the 2015-2019 American Community Survey 5-Year Estimate,Tustin has a high percentage of Title I schools (52.6 percent) compared to the County overall(2.22 percent) as seen in Table 10. Title I schools are intended to help meet the educational needs of students by using federal, state,and local funds to support effective,evidence-based educational strategies that close the achievement gap and enable the students to meet the state's challenging academic standards. Schools in which children from low-income families make up at least 40 percent of enrollment are eligible to use Title I funds to operate schoolwide programs that serve all children in the school in order to raise the achievement of the lowest-achieving students. In the City of Tustin,Title I schools are concentrated in tracts 525.02, 744.07,and 755.04,which also consist of a population with higher percentages of lower to moderate income households and a greater total Non-White population when compared to the rest of the city.The City of Tustin has a lack of policies and practices that promote access to more proficient schools for protected groups as these groups experience this disparity both at the local and county level. Employment The Economic Opportunity Index is a composite of four indicators depicting elements of neighborhood socio-economic character. In Orange County,there are significant disparities in access to economic opportunity as Non-Hispanic White residents have the greatest access to economic opportunity.As seen in Table 8,Asian and Pacific Islander residents (49),Native Americans (46),and Black Residents (46) have lower index scores in the high to mid-40s,while Hispanics have the lowest access to economic opportunity of all racial and ethnic groups in Orange County. Tustin's scores similarly reflect this trend as the City has very high scores for non-Hispanic White residents(77) as well has Asian residents(67),but Black and Hispanic residents have significantly lower scores (in the 40s). Despite this trend,job proximity is not a factor that is heavily weighted in these scores as the City has an overall high percentage (66.4 percent) of employment opportunities being located within 29 miles. Compared to the County's job proximity average of 57.6 percent as seen in Table 10,residents from the City of Tustin are generally in closer proximity to jobs when compared to the rest of the County. Transportation The two transportation indicators (transit trips and low transportation cost) analyzed data from version 3.0 of the Location Affordability Indexed (LAI). The transit trips index measures how often low-income families in a neighborhood use public transportation. The index ranges from 0 to 100,with higher values indicating a higher likelihood that residents in a neighborhood utilize public transportation. The transportation cost index measures cost of transportation and proximity to public transportation by neighborhood. It too varies from 0 to 100, and higher scores point to lower transportation costs in that neighborhood. When analyzing Orange County as a whole,non-Hispanic Whites have the lowest score (34), while Asian and Pacific Islanders as well as Native Americans have a score of 38 as referenced in Table 8. Black residents have a score of 39 while Hispanics have the highest score of 42. There are no significant disparities between racial/ethnic groups in the low transportation cost index in most jurisdictions in Orange County. However,in Tustin and Rancho Santa Margarita,White and Asian residents have significantly lower scores on the low transportation cost index D-40 compared to Black and Hispanic residents. In specific,Hispanics in Tustin have the highest transit index score (64) followed closely by Blacks(60),while Asian and White residents have significantly lower scores (49 and 42) respectively. This trend is similar to the overall County scores as Hispanics have the highest transit index score,while non-Hispanic Whites have a significantly lower score than other racial and ethnic groups. Environmental The California Office of Environmental Health Hazard Assessment(OEHHA) developed a screening methodology to help identify California communities disproportionately burdened by multiple sources of pollution called the California Communities Environmental Health Screening Tool (CalEnviroScreen). This tool uses Census tracts as the unit of analysis where high-scoring Census tracts tend to be more burdened by pollution from multiple sources and are most vulnerable to its effects,considering their socioeconomic characteristics and underlying health status. Pollution Burden scores for each Census tract are derived from the average percentiles of the seven Exposures Indicators (ozone and PM2.5 concentrations, diesel PM emissions, drinking water contaminants,pesticide use,toxic releases from facilities,and traffic density) and the five Environmental Effects indicators(cleanup sites,impaired water bodies, groundwater threats, hazardous waste facilities and generators,and solid waste sites and facilities). Indicators from the Environmental Effects component were given half the weight of the indicators from the Exposures component. The calculated average pollution burden score (average of the indicators) was divided by 10 and rounded to one decimal place for a Pollution Burden(0.1 -10). Population Characteristics scores for each Census tract are derived from the average percentiles for the three Sensitive Populations indicators(asthma,cardiovascular disease, and low birth weight,) and the five Socioeconomic Factors indicators (educational attainment,housing burdened low-income households,linguistic isolation,poverty,and unemployment). The calculated average percentile is divided by 10 for a Population Characteristic score ranging from 0.1 -10. After the components are scored within Pollution Burden and Population Characteristics,the scores are multiplied to calculate the overall CalEnviroScreen Score ranging from 1-100%. CalEnviroScreen reports scores as percentiles to compare tracts across the county. The City of Tustin had an average overall percentile of 43.49 percent as seen in Table 10. Protected groups in the City of Tustin suffer from less access to environmentally healthy neighborhoods as these populations are concentrated in tracts that have the highest scores in the City.Tracts with percentiles over 61 percent are concentrated in the southwest(tracts 744.06, 744.07, 744.08, 755.12, 755.13, 755.14, 755.15),while tracts scoring lower than 43 percent make up the northeastern half of the City,as seen in Figure 16. The tracts with scores over 61 percent also experience other disparities such as a high percentage of low to moderate income households, overcrowding,higher poverty rates,and a higher concentration of protected groups like Hispanics. Census tract 755.15 is one of the highest scoring tracts in the City with a score of 71.48 percent. This tract scored high due to high exposures to toxic releases,traffic,and contaminated drinking water. Figure 16 and Table 10 show that while Tustin had a relatively low score, overall Orange County had a similar average score of 50.01 percent. 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Ir..:l L�fld R ..ILII i:i:-I Corona-- E1f11!,1A1.�1JUtAAI Fn t VJp L.,hf nvon�ns __ ij EcCAL Vl - t C_L41YJ 1�.1.1.CJ gle:�i_ WLl1Aly . Jill„ ; LA A I,'.r1.,'v r i H 1115 � m nl au.3n r,o Orange County CalEnviroScreen Percentiles r, _ 1-10%(Lowest Score) Rom 11-20% t �� 21-30% 31-40% Cir 41-50% _ 51-60% 61-70% 71-80% 81-90% 91-100%(Highest Score) 0 County Boundary IN 0 3 6 Miles 1 i 1 1 I City of Irvine,County of Los Angeles, Bureau of Lard Management,Esri,HERE, Source:CalEnviroScreen 4,0-Feb.2021 Update Garmin,USGS,EPA,MPS D-48 Countywide,there are disparities across racial/ ethnic groups in access to environmental opportunities,measured as lower exposure to and effects from pollutions. Across all tracts in Orange County,non-Hispanic Whites exhibit the highest access to environmentally healthy neighborhoods (index score of about 54). All other racial/ ethnic groups obtain lower index scores in the 40s: Hispanics score lowest at 41,followed by non-Hispanic Blacks(45),non- Hispanic Asian/Pacific Islander (47),and non-Hispanic Native American(48). As seen in Figure 16,higher percentiles are concentrated in northcentral Orange County,with neighboring cities like Santa Ana and Orange having generally higher scores compared to Tustin.As a result,the tracts to the southwest that abut Santa Ana experience higher percentages(tracts 744.06, 744.07, 744.08, 755.12, 755.13, 755.14, 755.15). Extensive use of motorized transportation modes and large particulate generating uses in these tracts contribute to poor air quality. New regulations must be implemented to fulfill Air Quality Management Plan requirements. These regulations must be managed to increase the public health,safety,and welfare in order to lower the scores of these tracts and to increase access to environmentally healthy neighborhoods for protected classes. D.2.5. Disproportionate Housing Needs Disproportionate Housing Needs generally refers to a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing need when compared to the proportion of members of any other relevant groups, or the total population experiencing that category of housing need in the applicable geographic area.For purposes of this definition,categories of housing need are based on such factors as cost burden and severe cost burden, overcrowding,homelessness,and substandard housing conditions. As shown in Table 11,a higher percent of non-White households experienced housing problems than White households in Tustin. Non-White households that experienced the greatest proportion of housing problems include Hispanic (71.19 percent),Black(62.40 percent),and Native American (50.00 percent). The same trend occurred for the county population. Of the family types,family households that included five or more people experienced the greatest burden of housing problems,with a substantial percentage of 75.23 of the city demographic. Of the county population,large families also had the highest percentage of housing problems;however,the gap in percentages amongst the various family types was less pronounced. D-49 Table 11: Any Housing Problem by Tenure and Race,Tustin Demographics of Households with Disproportionate Housing Needs Households experiencing any of 4 #with problems #households % with housing problems problems Race/Ethnicity White,Non-Hispanic 4,465 10,495 42.54% Black,Non-Hispanic 380 609 62.40% Hispanic 5,485 7,705 71.19% Asian or Pacific Islander,Non- 2,644 6,089 43.42% Hispanic Native American,Non-Hispanic 60 120 50.00% Total 13,034 25,018 52.10% Household Type and Size Family households, <5 people 6,690 14,315 46.73% Family households,5+people 2,840 3,775 75.23% Non-family households 3,825 7,465 51.24% Households experiencing any of 4 #with severe #households % with severe Severe Housing Problems problems problems Race/Ethnicity White,Non-Hispanic 2,085 10,495 19.87% Black,Non-Hispanic 205 609 33.66% Hispanic 3,915 7,705 50.81% Asian or Pacific Islander,Non- 1,519 6,089 24.95% Hispanic Native American,Non-Hispanic 10 120 8.33% Total 7,734 25,018 30.91% Source: County of Orange, Analysis of Impediments,2020 D-50 Table 12:Any Housing Problem by Tenure and Race,County Demographics of Households with Disproportionate Housing Needs Disproportionate Housing Jurisdiction Needs Households experiencing any of 4# with problems #households % with problems housing problems Race/Ethnicity White,Non-Hispanic 206,658 540,773 38.22% Black,Non-Hispanic 8,074 16,719 48.29% Hispanic 152,740 241,841 63.16% Asian or Pacific Islander,Non- 84,193 186,038 45.26% Hispanic Native American, Non-Hispanic 1063 2,179 48.78% Total 452,728 987,550 45.84% Household Type and Size Family households, <5 people 228,740 576,690 39.66% Family households,5+ people 95,050 145,028 65.54% Non-family households 138,270 273,662 50.53% Households experiencing any of 4 # with severe #households % with severe Severe Housing Problems problems problems ace/Ethnicity White,Non-Hispanic 104,324 540,773 19.29% Black,Non-Hispanic 4,816 16,719 28.81% Hispanic 107,752 241,841 44.55% Asian or Pacific Islander,Non- 50,205 186,038 26.99% Hispanic D-51 Native American,Non-Hispanic 544 2,179 24.97% Total 267,641 987,550 27.10% Source: County of Orange,Analysis of Impediments,2020 D-52 Cost Burden Cost burden is the fraction of a household's total gross income spent on housing costs. There are two levels of cost burden: (1) "Cost Burden' refers to the number of households for which housing cost burden is greater than 30 percent of their income; and (2) "Severe Cost Burden" refers to the number of households paying 50 percent or more of their income for housing. This analysis must address the burdens on both owners and renters (tenure). According to HUD CHAS Databook using data from 2013-2017 ACS,the race and ethnicities that experience the greatest severe cost burden in Tustin are Other and Hispanic,as shown in Table 11. The race and ethnicities that experience the greatest severe cost burden in Orange County are Hispanics and Blacks. Compared to the county,Tustin had similar cost burden percentages across most races. As shown in Tables 11 and 12,non-family households experienced the greatest percentage of severe cost burden within Tustin and Orange County. The percentage of more than five people households was higher than non-family households. A non-family household consists of a householder living alone (a one-person household) or where the householder shares the home exclusively with people to whom he/she is not related. As identified above,the 2020 A.I. compared County of Orange households by household type for 2000,2010,and 2016. The analysis found the number of family households married without children, other families,and non-families are generally increasing,while families married with children are generally decreasing. This could indicate that there is a lack of housing affordable for non-families and single persons that do not rely on two incomes for living expenses. Affordability could be a barrier to housing for persons with disabilities or special needs populations who rely on Supplemental Security Income as their primary source of income, which ranges from$954 to$1,776 per month, depending on their qualifications.Households may experience cost burden when SSI incomes are not adequate to pay for rent and not increasing at rates comparable to rent increases. Majority of renters within City's census tracts had over 40 percent cost burdened households,while majority of homeowners within census tracts had less than 40 percent cost burden(see Figure 17). Due to lack of rental options available in the City,renters could experience lack of affordable options. Overcrowding Households having more than 1.01 to 1.5 persons per room are considered overcrowded and those having more than 1.51 persons per room are considered severely overcrowded. The person per room analysis excludes bathrooms,porches,foyers,halls, or half-rooms. This analysis of Tustin addresses the overcrowding on both owners and renters. D-53 � rh B' a d j m a �w Q .O rCp 77 a ate, o al o J LO j N O LLJ fs+ ) _ c - H e C O Q a o 0 C7�►��"� nJ 0 u o VJ According to the 2020 Al, overcrowding in Orange County is very high,at 9.51% overall, expanding to 15.97% for renters. The relative majority of Housing Choice Vouchers is also limited to 0-1-bedroom units (43.97%). 5,561 households or 26.20% of Housing Choice Voucher occupants are also households with children,the highest of any category of publicly supported housing(followed by Project-Based Section 8,with 9.62%). Furthermore,according to the 2018 five-year ACS estimates,the majority of tracts in the City have a low percentage of households that are living in overcrowded conditions,with tracts bordering Santa Ana towards the southwest having higher percentages (tracts 744.06, 744.07,744.08, 755.12,755.13, 755.14, 755.15).Regionally,census tracts with overcrowded households are concentrated in the northcentral Orange County,particularly in the City of Anaheim and Santa Ana.As a result, within Tustin,all tracts besides the few bordering Santa Ana,have a low percentage of overcrowding ranging between 1 and 8 percent. The tract with the highest percentage of overcrowded living conditions is tract 444.08 (22.68 percent) which is located in the westernmost part of the city and borders Santa Ana (see Figure 18). These southwestern tracts also experience a concentration of minorities,a larger percentage of lower to moderate income households, and other housing problems. The higher average of overcrowded living condition in south and southwestern Tustin suggests that there are could be disparities in the proportion of members of protected classes and housing problems,as populations of minorities and lower income levels experience overcrowding in these parts of the city. Substandard Housing Housing age is frequently used as an indicator of housing condition. In general,residential structures over 30 years of age require minor repairs and modernization improvements,while units over 50 years of age are likely to require major rehabilitation such as roofing, plumbing, and electrical system repairs. A small percentage of units are at risk of improvement due to age as only 31.3 percent of housing is older than 50 years old in all tracts of the city (Table 13).As shown in Table 14,13,034 units, or 52.10 percent of total housing units within the city,were identified as having one or more housing problems (which includes cost burden). Approximately 22.1 percent of households experience one or more of the four severe housing problems. Compared to the county's population,where 45.84 percent of the population has one or more housing problems and 27.1 percent of the population has a severe housing problem,the city of Tustin population experiences slightly more housing problems than the county population;however,the problems experienced are less severe. There are four housing problems in the CHAS data: 1)housing unit lacks complete kitchen facilities;2) housing unit lacks complete plumbing facilities;3)household is overcrowded;and 4) household is cost burdened.A household is said to have a housing problem if they have any 1 or more of these 4 problems. D-55 Figure 18:Distribution of Overcrowded Households I CRINOHiLIS y � r Cine HiHv , _ " Norwalk lfl owe eiw" '� .L I. hlnl.'c�t fw GOrOnd'' -'� Artcs 8 \ TM T r 4 e rit i i rti.I "ti . II L Nl I I. I'.i 11 L '*a^ SANTA MARGARItA \�•' '�" MOUNTAIMS cR Orange County mm— Overcrowded Households 0 <_8.2(Statewide Average) 0 515 <_20 <. L <_70 0 County Boundary N 0 3 6 Miles City of Irvine,County of Eos Angeles, Bureau of Land Management,Esri,HERE, Source:CHHS Data-Tract Garmin,INCREMENT P,USGS,EPA D-56 As shown in Table 11,the race/ethnicity that experiences the highest percentage of housing problems is Hispanic (71.19 percent). The race/ethnicity that experiences the second highest percentage of housing problems is Black(62.30 percent).Similarly,the Hispanic population had the greatest percentage of severe housing problems (50.81 percent). The percentage of Hispanic households that experience severe housing problems was substantially greater than all other races and ethnicities. Native American households had the smallest percentage of households that experiences severe housing problems(7.69 percent).These results may be skewed due to the low number of households identified as Native American,Non-Hispanic. Table 13:Age Housing Built Year Built Number of Units Percent of Units Built 2014 or later 1,086 4.0 Built 2010 to 2013 387 1.4 Built 2000 to 2009 2,802 10.3 Built 1990 to 1999 5,994 22.1 Built 1980 to 1989 2,952 10.9 Built 1970 to 1979 5,462 20.1 Built 1960 to 1969 6,735 24.8 Built 1950 to 1959 1,222 4.5 Built 1940 to 1949 154 0.6 Built 1939 or earlier 386 1.4 Total 27,180 Source: 2015-2019 American Community Survey 5-Year Estimates According to the 2020 Al, deteriorated and abandoned properties are not a significant contributing factor to fair housing issues in Orange County. Although there was a surge in deteriorated and abandoned properties in the wake of the foreclosure crisis,particularly in heavily Hispanic areas and with significant harmful consequences for communities,that issue has gradually abated over the ensuring years. Table 14 identifies the number and overall percent of vacant housing units categorized as "Other Vacant" in the American Community Survey within Tustin and nearby jurisdictions. Irvine and Tustin contained the lowest number and second lowest percentage of vacancy relative to other nearby cities. D-57 Table 14:Vacant Properties City Count Percent of Total Properties Tustin 162 13.8% Orange 548 33.7% Irvine 628 11.4% Santa Ana 599 30.3% Source: County of Orange,Analysis of Impediments, 2020 Homelessness Persons who are classified as homeless include individuals or families who lack or are perceived to lack a fixed,regular,and adequate nighttime residence, or who have a primary nighttime residence in a shelter, on the street,in a vehicle, or in an enclosure or structure that is not authorized or fit for human habitation. People experiencing homelessness are vulnerable to violence and criminalization due to their unhoused status. Orange County's 2019 Sheltered Point In Time Count took place the night of Tuesday,January 22,2019. Emergency Shelters and Transitional Housing Programs collected client-level demographic information from individuals and families staying the night in each program. The 2019 Unsheltered Count process took place over two days,Wednesday,January 23 and Thursday,January 24,to ensure the 800 square mile County jurisdiction was canvassed effectively. Within Orange County 3,961 unsheltered homeless persons and 2,899 sheltered homeless persons counted. During the same point-in-time count,95 unsheltered homeless persons and 264 sheltered homeless persons were counted,for a total of 359 homeless persons identified in Tustin. According to the 2020 Al, displacement of residents due to economic pressures may be a significant contributing factor to fair housing issues in Orange County and,in particular,in parts of Orange County that have historically had concentrations of low-income Hispanic and Vietnamese residents. The Urban Displacement Project at the University of California Berkeley identified census tracts in Orange County that experienced gentrification over various time periods from 1990 to present. Several areas that have undergone gentrification at some point since 1990 were identified in Anaheim, Costa Mesa,Dana Point,Fountain Valley,Fullerton, Garden Grove,Huntington Beach, Irvine,Orange,San Clemente,and Villa Park. The city of Tustin was not identified as an area of gentrification. Though the Urban Displacement Project does not map the risk of future gentrification in displacement in Southern California as it does in the Bay Area,the areas most vulnerable to gentrification and displacement in Orange County - going forward- are disadvantaged areas located near areas that have already gentrified and disadvantaged areas located near major transit assets as well as anchor institutions like universities and hospitals. Because the southern and coastal portions of Orange County have relatively few disadvantaged areas, displacement risk is therefore concentrated in inland D-58 portions of central and northern Orange County.These areas also tend to have higher Hispanic and Asian population concentrations than the county,illustrating the fair housing implications of displacement. Two key factors in predicting displacement for an area are the loss of low-income households and increases in rent.Median household income of residents in the city of Tustin experienced approximately$15,000 increase from 2010 to 2019,as shown in Table 15. Residents throughout the county experienced a very similar increase within the same timeframe.The mean income for both city and county also increased similar amounts (approximately$20,000). Conversely,the percentage of households that earn$15,000 or less simultaneously increased from 2010 to 2019 and percentages of households earning more than$15,000 annual decreased. Although low- income households are generally increasing,this phenomenon suggests polarizing income, where low-income households in the city are losing income and high earning households are earning greater income. Table 15:Household Income Income City (2010) City (2019) County(2010) County(2019) Total 71,680 104,524 984,503 1,044,280 Less than 6.6% 8.5/° 3.9 4.1 ° ° ° $10,000 /°/° $10,000 to 2.5% 3 8% 3.2 2.6 ° ° $14,999 /°/° $15,000 to 2.6% 1 3% 3.3 2.2 ° ° $24,999 /°/° $25,000 to 2.2% 1 8% 3.7 2.7 ° ° $34,999 /°/° $35,000 to 2.1% 1.9% 3.8/° 2.5/°° $49,999 $50,000 to 2.5% 1 9% 3.7 2.9 ° ° $74,999 /°/° $75,000 to 2.6% 2 2% 3.6 2.7 ° ° $99,999 /°/° $100,000 to 2.7% 1.5% 4.1/° 2.8/°° $149,999 $150,000 to 2.1% 1.5% 3.6 2.8 ° ° $199,999 /°/° D-59 $200,000 or more 5.4% 4.3% 7.2% 5 8% Median income 901939 105,126 74,344 90,234 (dollars) Mean income 113,185 135,877 99,719 122,488 (dollars) Source: 2015-2019 American Community Survey 5-Year Estimates;2006-2010 American Community Survey 5-Year Estimates As previously discussed above and shown in Figure 17,renters experience the greatest level of cost burden in the city of Tustin. Throughout most of Tustin,40 percent or greater of renters experience overpayment(cost burden),whereas the majority of homeowners do not experience cost burden(less than 40 percent) throughout most of the city. High percent of cost burden for renters is an indicator of displacement risk,in combination with polarizing income trends. The city of Tustin supports a number of publicly supported housing projects with low-income units. Table 16 includes a breakdown of publicly supported housing residents by race along with the corresponding census tract percentage of population by race. Table 16 shows that the percentage of White residents and Black residents within the housing projects was greater than their proportion of population identified for their corresponding census tract (the census tract that the housing project was located in) population within four of the six City housing projects. Although Hispanic residents made up a large majority of population residing within the housing projects,their percent of population within the project was lower than the corresponding census percentage in almost every instance.Tustin Gardens had an abnormally high percent of Asian population residing within the housing(59.0 percent) compared to the overall Asian population percentage of the census tract(9.2 percent). Overall,the proportion of White and Black residents living in publicly supported housing indicates these populations may be overserved representative of their total percent of the population,while Hispanic residents may be underserved. 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. D-60 ; \ / a r e w r m t ( \ / \ f e o a 2 % 00 m $ % \ \ \ b z75 a cn \ / m ± 3 g ± g w e r e e r W � t / { R f e ± @ ± ± ) » g / \ \ / / ; R / / ® Lf) \ \ \ \ \ 2 q mt '§ // R R g f m \ & \ \ / ± ± ±/ \ & ® ± ® a � •� /� � § OC Ln c f c e e + r © � % a ad ° \ m « � ^ e ® t \ / ƒ r — / / \ \ \ / / / un un� \ \ \ \ \ / \ & b,O w ) / / / / / � ® $ Q 4 4 Q Q ± W \ t \ _ . � \ f J § ma Additional programs have been provided at the Tustin Legacy site. A Homeless Assistance Plan has been established for TLSP (formally 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 TLSP: • 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 operate 48 family units. The Orange County Rescue Mission operates a 192-unit transitional/emergency shelter (Village of Hope). The Orange County Social Services Agency operates a 90-bed facility for abused and neglected children and their families. During the 2021-2029 planning period,the Orange County Rescue Mission will be expanding their facility to include an additional 125 units. Numerous other agencies provide shelter and other services to the homeless in the nearby cities of Santa Ana, Irvine, and Orange. Table 17 is a list of organizations in Tustin that provide homeless services. Table 17. Emergency Shelter/Transitional Housing Facilities 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 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 organizations involved in providing homeless services. Aldergate Refers interested persons to Ecumenical Services Alliance in Santa Ana. Village of Hope Operates a food service program and 262 units transitional home at the Village of Hope operated by the Orange County Rescue Mission D-62 Tustin Family Campus 90-bed intermediate care shelter for abused children and their parents operated by the Orange County Social Services Agency. Family Solutions Collaborative Provides referrals to families for emergency shelters, transitional housing and affordable housing Families Together of Orange Operates a food pantry and Farmers' Market for needy County populations Salvation Army Six (6) transitional units at Tustin Field I operated by Salvation Army. Salvation Army 16 transitional units in Buena Park were initially acquired by the Salvation Army. The Buena Park complex is being sold and the obligation for 16 transitional units is being transferred to a Salvation Army development in Santa Ana. The City assisted in acquisition and contributed grant funds to acquire the units,hence why the requirement to provide transitional units is being transferred to another location. Human Options 1 Six (6) transitional units at Columbus Grove operated by Human Options Orange Coast Gateway to Six (6) transitional units at Columbus Grove operated by Housing Orange Coast Interfaith Shelter. (NOTE for CD Staff: An official request to convert to affordable housing is anticipated.) Tustin Family and Youth Center Distributes food supplies to needy populations. 1 Although these units are located in the City of Irvine,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,2021 Other Data Tenure Tustin's population includes a balance of renters and homeowners. According to 2015-2019 ACS data,50.3 percent of households are owner-occupied,compared to 49.7 percent of renter- occupied (see Table 18). Households in the county are predominately owner-occupied (57.4 percent). Both city and county trends from 2010 to 2019 show that rentals are becoming D-63 increasingly more popular. The city experienced growth,numerically,in both owner-and renter-occupied housing from 2010 to 2019;however, the growth in the renter-occupied housing outgrew the homeowner population,causing a shift in majority to renter-occupied housing. County households were predominately owner-occupied in 2010,but there was a much larger difference between owner-and renter-occupied housing. Table 18:Housing by Tenure City of Tustin Orange County Tenure Estimate Percentage Estimate Percentage 2010 Owner- 13,109 52.8 599,032 60.8 occupied Renter-occupied 11,730 47.2 385,471 39.2 Total 24,839 984,503 2019 Owner- 12,759 49.7 595,272 57.4 occupied Renter-occupied 12,938 50.3 442,220 42.6 Total 25,697 1,037,492 Source: 2015-2019 American Community Survey 5-Year Estimates;2006-2010 American Community Survey 5-Year Estimates Mortgage Lending Initially in mortgage lending,buyers must locate a lender who will qualify them for a loan. This part of the process entails an application,credit check,ability to repay, amount eligible for, choosing the type and terms of the loan,etc. Applicants are requested to provide sensitive information including their gender,ethnicity,income level,age,and familial status. This information is required to be gathered by the Community Reinvestment Act and the Home Mortgage Disclosure Act;however,it does not guarantee that individual loan officers or underwriters will not misuse the information. A report on mortgage lending discrimination by the Urban Land Institute describes four basic stages in which discrimination can occur: • Advertising/outreach stage. Lenders may not have branches in certain locations,not advertise to certain segments of the population, or violate advertising rules with respect to fair housing. D-64 • Pre-application stage. Lenders may not provide applicants of different racial and ethnic backgrounds the same types of information as other preferred groups or may urge some to seek another lender. • Lending stage. Lenders may treat equally qualified individuals in a different manner, giving different loan terms,preferred rates, or denying a loan based on a factor not related to ability to pay and risk. • Loan administration. Lenders may treat minorities in harsher terms, such as initiating foreclosure proceedings if any payment is late, or by making loans at terms that encourage defaults. Table 19 and Table 20 include percentages of applications that resulted in originated loans and denial by loan purpose within Orange County from 2014 to 2017. Table 21 shows loan application actions by race in the city of Tustin for 2019 as provided by the Federal Financial Institutions Examination Council(FFIEC) Home Mortgage Disclosure Act(HMDA) Dataset. Table 22 further identifies loan denial percentages by race in Tustin for 2019. Comparing the proportion each race makes up of the applicant pool to the percentage denied can provide indication as to whether mortgage lending discrimination is occurring. According to Table 19,White applicants had the highest approval rate across all loan purposes. Further,White applicants had the lowest denial rate across all loan purposes. Black applicants were the only racial or ethnic category whose majority of applications did not result in an originated loan (less than 50 percent) for the purposes of refinancing and home improvement. Black applicants also had the highest loan denial rate for the purposes of refinancing and home improvement and the second highest for home purchase. Table 19:Percentage of Loan Applications Resulting in Originated Loans by Race or Ethnicity and Loan Purpose in Orange County,2014-2017 Home Mortgage Disclosure Act Data Race or Ethnicity Home Purchase Refinancing Home Improvement White,Not Hispanic 66.56% 59.12% 61.96% Black,Not Hispanic 61.93% 49.62% 49.49% Asian,Not Hispanic 63.95% 55.35% 51.26% Hispanic/Latino 59.54% 50.57% 51.60% Source: County of Orange,Analysis of Impediments, 2020 Table 20: Percentage of Loan Applications Denied by Race or Ethnicity and Loan Purpose in Orange County,2014-2017 Home Mortgage Disclosure Act Data Race or Ethnicity Home Purchase Refinancing Home Improvement D-65 White,Not Hispanic 9.09 16.30 17.60 Black,Not Hispanic 12.03 22.04 31.74 Asian,Not Hispanic 9.75 16.65 23.21 Hispanic/Latino 12.38 20.75 28.12 Source: County of Orange,Analysis of Impediments, 2020 D-66 75 0 J c c Q ® q m o ? \ > \ = 2 U \ 75 \ § § 0 0 � J § \ � / � $ 2 � 2 � § 0 ® \ w $ w / 6 k 2 \ \ cq v m o 75 Q q $E, / . � \ @ w ¥ � \ R m CD q u75 ) LO 7 / 75 § � c 2 LO q 2 R 2 w ƒ / ( .§ u c o c .0 a e = % ± $ � ./ @ § @ .§ 2 E \ u •_ % m % ¥ 0 44 \ \ ƒ ON 0 N Q Q x 0 U 0 u U 000 x W � w .o w U = � o � x � w � � X 00 O w a� a� u w N '5 w � U O � � U � O w Table 22:Tustin Loan Applications and Denial by Race Race and Population Applicant Pool Denial Ethnicity Population (proportion of (proportion of (proportion of total population) total applicants) total denials) White alone 46,823 59.0 47.1 52.2 Black or African 1,508 1.9 0.8 1.4 American alone American Indian and Alaska 588 0.7 23.6 22.0 Native alone Asian alone 16,861 21.2 0.5 0.6 Native Hawaiian and 0 - 0.2 19.9 Other Pacific Islander alone Hispanic or 31,902 40.2 10.9 14.4 Latino Total Population 79,346 - - - Source: Federal Financial Institutions Examination Council(FFIEC) Home Mortgage Disclosure Act(HMDA) Dataset,2019;2015-2019 American Community Survey 5-Year Estimates Note: The sum of percentages for a given category may not equal 100 percent due to overlap between Hispanic and other races identified. Additionally,not all applicants identified their racial/ethnic backgrounds, or multiple categories were selected. The majority of loan applications within the city of Tustin originated from White applicants (59.0 percent) in 2019.However,the proportion of White applicants was lower than the proportion of the city population that identified as White. The second largest proportion of total applicants originated from American Indian and Alaska Native applicants,and the third largest proportion originated from Hispanic or Latino applicants.The proportion of American Indian and Alaska Native applicants was substantially greater (23.6 percent) than the proportion of the city population that identified as American Indian and Alaska Native applicants(0.7 percent). Denial percentages by race were mostly consistent and similar to applicant percentages by race. One outlier was a relatively large denial percentage identified for Native Hawaiian and Other Pacific Islander alone applicants.Approximately 19.9 percent of Native Hawaiian and Other Pacific Islander alone applicants experienced denial,while they only accounted for 0.2 percent of the applicant pool. D-69 D.2.6. Outreach The preparation,adoption,and implementation of a housing element requires a diligent effort to include all economic segments of the community. AB 686 reinforces and builds on this requirement.Under AB 686 and changes to Housing Element Law,the housing element must also include a summary of fair housing outreach and capacity. Public participation is summarized in Appendix E of the Housing Element. Several stakeholder groups were invited to participate in the planning process,including Fair Housing Council of Orange County,Fair Housing Foundation and Family Promise of Orange County. A total of two (2) public workshops were held during the housing element process;the first was held on November 11,2020 with the Planning Commission and the second workshop was held on May 11,2021 and was a joint workshop with the Planning Commission and City Council. Outreach efforts made and public participation opportunities provided included the following: • Housing Element Webpage update • Social media posts(Facebook,Twitter and NextDoor) • Workshop information featured on City's"spotlight" webpage and email blast sent to City news subscriber list • Workshop featured in City and Department website calendars • Public notification posted City's e-notice board (under CC and CPC),at the Tustin Library,and Senior Center • Workshop information posted Tustin News-April 29 (Full Color/ Main Page),reaches approximately 7,000 residents • Workshop information posted Irvine Weekly-May 7(Full Color),reaches approximately 8,200 residents with anticipated readership of 33,000 • Direct mail postcards (Housing Element Update Workshop included with Strategic Plan Workshop Postcard) o Mailed to 29,885 Tustin residents and 3,457 Tustin businesses • Direct mail postcards focused on Housing Element Update to Interested Parties List • Email blasts with Housing Element Workshop Postcards and Meeting Information- April 21,May 3 and May 10;and • Housing Element Update Workshop held via Zoom at 5 p.m. Due to the Covid Pandemic,public gatherings and meetings were not permitted and therefor all public workshops were online and made available to attend via livestream or by telephone. Remote accommodations provided opportunities to those with geographic barriers to participation. The public workshops and public hearings were held outside of work hours, during the evening,to facilitate participation. Drafts of the housing element will be made available to the public for review and comment. Comments will be reviewed,considered and incorporated, as appropriate,into the document before incorporated into the document and before submission to the Department of HCD for review. D-70 D.2.7. Local Data and Knowledge Based on data from Nextdoor,a free social media platform for neighbors within the same geographical area to share information and communicate information,including neighborhood updates,polls,events,ask for recommendations,as well as list items for sale. Residents on Nextdoor identified over 60 distinct neighborhoods within Tustin. Some common characteristics that Nextdoor users identified as favorable about their community were"quiet", "family friendly", "safe","walkability', "clean", and several commercial factors such as "restaurants", "shopping", and"food". During the first virtual public workshop held on November 10, 2020, City staff provided a briefing to the Planning Commission regarding the pending housing element update that would be needed and the anticipated process and timing. The public was able to provide questions and comments relative to housing is Tustin either before or after the meeting. Five(5) written public comments were provided via email prior to the virtual meeting and included the need for more affordable housing for low-income residents, housing equity with the community, need for additional supportive housing and the shortage of available below-market housing. During the virtual public workshop held on May 11,2021,the public was able to provide questions and comments regarding the housing element process,as well as general information to consider while developing the analysis and policies for the housing element. Leading up to this meeting,an online housing element survey was conducted to learn and understand the housing concerns within the City. Of the 192 individuals that responded to the online survey, 52 percent of respondents live in Tustin and 26 percent both live and work in Tustin. The survey also revealed that 67 percent of attendees believe affordability is the most urgent issue for city housing. Additionally,65 percent of respondents believe the best way to help people who are experiencing homelessness is to better connect people to assistance and services. Approximately 65 percent of respondents also chose the TLSP area as most appropriate to add more housing units. Comments were not provided regarding impediments to fair housing on the basis of race or ethnicity during public outreach;however,indicators suggest that the Tustin Hispanic population may experience inequality resource access compared to the city's White population. As shown in Figure 19,the northeastern portion of the city that experiences high resources(see Figure 1) and greater incomes,contains a sizable gap of predominately White residents. The southwestern portion of the city that experiences low resources and lower incomes,contains a sizable gap of predominately Hispanic residents in tracts 744.06, 744.07, 744.08, 755.12, 755.13, 755.14,755.15. D.2.8. Other Contributions Other contributions that affect the accumulation of wealth and access to resources include historically disinvestment,lack of infrastructure improvements,and presence of older affordable housing units that may be at risk of conversion to market-rate housing. The City of Tustin invests in its infrastructure through its Capital Improvement Program(CIP), a seven-year program that identifies future projects and cost estimates that allow City staff to D-71 properly plan for future capital improvements throughout the City.Major capital improvement projects completed during fiscal year 2017-2018 include: • Annual Major Building Maintenance (Accessibility Improvements,Replace HVAC Units,Repair Tile Roofs) • Eastbound El Camino Real at Jamboree Road Improvement Project • Transit Circulator Feasibility Study • 17th Street Treatment Plan Membrane Replacement As reported in the City's Annual Comprehensive Financial Report 2017-2018, the City's capital projects for the 2018-2019 fiscal year were budgeted at$99.4 million. Budgeted projects include 15 Tustin Legacy Facility improvements, seven public facility improvements,two water projects,four transportation facility improvements,two traffic control facility improvements, three park facility improvements,and one flood control facility improvement. D-72 OF a :Z w- m Q� 7z O c n CO N N d U ad aye c, a= O pq h .A lM1 .z L jPt`lj� l�� p Cn X Q m o n o y w o o c z The Capital Projects Funds are used to account for financial resources to be used for the acquisition or construction of major capital facilities. Using various funding sources (revenues generated from ratepayers and user fees, grants,and bonds),the City acquires,repairs, or replaces the major assets needed to deliver its services (water, sewer, streets,trails, streetlights, traffic signals and storm drains) to the City's residents and businesses. The City of Tustin received an annual allocation of$726,651 from HUD under the Community Development Block Grant(CDBG) program for the Program Year 2017-18. Currently,the City is in the process of completing the design and construction of various capital improvement projects approved and budgeted by City Council for fiscal year 2020-2021. The City lists its current projects and provides project status on the City website. Additionally,various City housing projects are currently under covenants per AB 987. Table 23 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. Tustin Gardens is a 223(a) (7)/221(D) (4) project with a Section 8 contract for 99 units and is extended on an annual basis. Their current contract is due to expire on July 31,2022;however, the City has also recently received correspondence indicating that the existing contract could be extended for a new 20-year period which would mean the contract would expire on July 31, 2041. As of the writing of this update,the details of the potential new contract are being confirmed by City staff. There are also Westchester Park(149 all low-income units),Flanders Pointe (32 very-low income, 16 low income; plus 9 moderate income-totaling 57) and Chatham Village (212,all low-income units) all of which could also be converted towards the end of the planning period. Various restrictions and incentives affect the likelihood that at-risk units will convert to other uses. Depending on the circumstances, different options may be used to preserve or replace the units. Preservation options typically include: (1) transfer of units to non-profit ownership; (2) provision of rental assistance to tenants using other funding sources;and (3) purchase of affordability covenants. D-74 U " U C7 C7 C7 LLJ m Fq o O Lr)o o oo � v o x V o o LO v w m m 0 oA o 0 0 0 y+ .. r v +�� S-i O w N N H U v n x NU� x U Q U U Q U O a 9 O u p p U U d1 Q LN O U O u odE x Q U iii � _RCn � 1 o 6-0 ul n U s m m U O U s w f- W f 6 N N f d Cn N f 6 w N f d m \ \ \ \ \ \ \ \ \ \ / \ 2 2 7 2 2 2 2 � \ \ \ \ ) G ) G / ; k k ON ./ � ( ( \ \ Lr) � � .\ \ � � .- � § § • \ \ \ / \ \ / \ \ \ U \ / \ \ j \ \ \ ` t t U \ U §c / e .§ c / ® ® © ® ® ® ° ° ® 'cam ® 222 \ ] \ 5 ® = = G c \ � _ � � _ / j / \ / CN 3a, / / j / \ U) r, S, / \ / / j / / j / / j \ \ \ \ 7 7 7 7 \ \ \ \ \ \ \ \ \ \ \ C? \ \ \ \ C? \ \ j \ Q R \ Q 2 2 2 2 e e e e \ G \ G \ G \ G Q Q Q Q \\ 5 \\ 5 \\ 5 \\ 5 w Q .§ 7g .§ 7 g .§ 7 g .§ 7 ® / cc cc \ \ \ \ \ \ \ \ r k \ \ k \ \ k \ \ k \ \ ® \ 2 2 2 2 § > ! y ! y e w ! y ktc ktc ktc ktc ƒj tc \ � 2 . . . . \ .\ \ \ \ \ ƒ ( ( c § e / \ \ \ / / Q / \ / 0 \ j m % � \ \ ( ( \ \ ( m \ \ 2 6 \ } Bo" u o" UEeoURoR ƒ� z D.3. Summary of Fair Housing Issues As discussed in the previous sections of this analysis,the following conclusions were determined regarding potential fair housing concerns and indicators of certain disadvantaged populations: • The highest resource areas (environment,education,income,minority concentrations, etc.) are in the northeastern portion of the city and the lowest resource areas are in the southwest(tracts 744.06, 744.07, 744.08, 755.12, 755.13, 755.14, 755.15). The city's high and low resource areas are consistent with the county's overall trend,where the highest resource areas are located along the coastal and hillside areas,while low resource areas were clustered near I-5 in northcentral Orange County. Areas of low resource within the city were also identified as having higher percentages of LMI population. • Black residents faced an especially large increase in segregation from 2010 to present and has one of the highest Dissimilarity Index values amongst all jurisdictions within Orange County. • Census tract 755.14 had a larger percentage (40 to 60 percent) of children living in female-headed households than all other census tracts within the city (see Figure 10). Additionally,a particularly large percentage (75 to 100 percent) of households in this census tract were also identified as LMI in Figure 11. • Overall,the proportion of White and Black residents living in publicly supported housing indicates these populations may be overserved representative of their total percent of the population,while Hispanic residents may be underserved and in need of additional affordable housing opportunities. Additionally,Hispanic households experience a disproportionately high percent of housing problems when compared to all other races/ethnicities within the city. • Further,the northeastern portion of the city that experiences high resources and greater incomes,contains a sizable gap of predominately White residents. The southwestern portion of the city that experiences low resources and lower incomes,contains a sizable gap of predominately Hispanic residents in tracts 744.06, 744.07, 744.08, 755.12, 755.13, 755.14, 755.15. • Large families experience a disproportionate percentage of housing problems compared to other family types within the city. DA Sites Inventory The Tustin Land Use Element and Zoning Code provide residential development opportunities to accommodate the City's 2021-2029 Regional Housing Needs Allocation (RHNA). Tustin's Regional Housing Allocation for the 2021-2029 planning period is a total of 6,782 housing units, including 1,724 units for very-low-income households,1,046 units for low-income households, 1,132 units for moderate-income households,and 2,880 units for above moderate-income households. Figure 20 and 21 detail the designations of vacant and non-vacant land identified to meet the RHNA in the City of Tustin. The vacant and non-vacant land inventory includes land that is currently zoned as specific plan,medium-and high-density residential,and land that can D-78 potentially be designated as high-density residential. Realistic capacity of sites has been 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 City Council, maximum zoning and general plan densities,and eligible incentives to developers for provisions of affordable housing. 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 new construction, preservation, rehabilitation, and other housing program objectives. As shown in Figure 20, sites to accommodate the City's RHNA allocation are located near the Interstate-5 (I-5) and in south Tustin,with a majority of the units being allocated in tracts 755.05, 755.07, 755.12, 755.13 and 755.15.The impacts on patterns of socioeconomic and racial concentrations are further discussed below: • Improved Conditions:A variety of suitable sites to meet the City's RHNA allocation have been identified in the 2021-2029 Housing Element Update. These sites consist of remaining units in three specific plans,ADUs/JADUs, and transitional housing. Spatial analysis of the data available on the Affirmatively Furthering Fair Housing Data Viewer showed that the tracts with low to moderate income households,concentrated minorities,and housing problems were located in the south and southwestern tracts of the City (744.06, 744.07, 744.08, 755.12, 755.13, 755.14, 755.15).As seen in Figure 20,a majority of identified sites are located within these tracts that experience socioeconomic or racial disparities in the City of Tustin. The selected sites combined with the City's Comprehensive Housing Affordability Strategy,would be able to accommodate residential development of all income levels to further fair housing in the City of Tustin. • Exacerbated Conditions:Factors used in calculating realistic capacity included the size of site parcels,the location and site layout,the potential for lot consolidations where appropriate,the number of owners,the already available and/or additional infrastructure improvements needed were among the many protocols in assessing the realistic capacity of the identified sites. In that the City's General Plan densities are not caps for these three Specific Plan areas,allowed increased densities was also a positive merit towards realistic capacity. Site improvement requirements may only be prevalent in the Tustin Legacy area in that it is vacant land though with significant base infrastructure already prevalent. The identified sites can accommodate a variety of income levels since these parcels are intended to build all types of housing as prescribed by their respective specific plans. The City's current site inventory and approach to accommodate future growth through comprehensive plans is an effective strategy to meet the City's 2021-2029 RHNA allocation. D.4.1. Integration and Segregation: Race and Income Census tracts with the highest concentration of minority races,in this case,a Hispanic majority, are located west of I-5 and border Santa Ana (tracts 744.07, 744.08,and 755.15). Similarly,low- and moderate-income populations are concentrated to the southwest in tracts 755.15, 755.13, D-79 and 755.12. The site inventory identified most sites within these tracts and are zoned as part of a specific plan or have been identified as at-risk units that are intended to be preserved. The City's strategy to preserve affordable housing in addition to developing other housing options in these areas will encourage a diverse housing market that will attract people from all races and income levels in these areas. Additionally, goals identified within Section D.5 below would be implemented citywide and support in furthering fair housing within identified housing sites. Listed in Table 24 below,the sites identified for RHNA contain variety of income levels. Of the census tracts that RHNA sites are allocated to,three include populations that have less than 50 percent of population that fall within the low to moderate income category,and five include populations that have greater than 50 percent. The majority of RHNA sites are allocated to the TLSP area,which has 60.14 percent population within the low to moderate income category. However,as previously stated,the TLSP area is rapidly developing and changing in accordance with the City's plans for the area. Although the tract has been identified as predominately low to moderate income,it has been substantially enhanced with new resources within recent years. Improvements include schools,parks,community resources,employment centers, transportation,and a variety of housing,which are likely to increase potential for higher wage earning. With recent improvements,the Tustin Legacy area surpasses other areas in the City for livability and well-rounded services for households with various income levels. Therefore,the selected RHNA sites would result in improved conditions. The racial makeup of the census block groups where selected RHNA sites are located include predominately non-White populations(less than 50 percent White).Only one site,Enderle Center,included population with less than 50 percent non-White population. The City's housing strategy is to implement a variety of evenly distributed housing types and affordability levels within each of the housing sites. By doing so,the selected sites would improve diversity and would not concentrate affordable housing within areas of minority populations. In addition to a variety of housing opportunity,new resources and amenities, such as those implemented in the TLSP area,would be improvements to these areas and provide a benefit to the community. Therefore, selected RHNA sites would result in improved conditions. Table 24. Sites Demographics Area Non-White Population Low to Moderate Income (Percent) (Percent) 525.24 (Tustin Market Place) - 33.59 Block Group 1 61.10 - Block Group 2 62.99 - Block Group 3 54.78 - Block Group 4 62.71 - D-80 Block Group 5 61.52 - 755.04 (Enderle Center) - 37.43 Block Group 1 46.60 - Block Group 2 44.58 - 755.05 (DCCSP) - 61.37 Block Group 1 74.38 - Block Group 2 53.66 - 755.06 (DCCSP) - 34.00 Block Group 1 55.69 - Block Group 2 47.58 - 755.07 (DCCSP/RHASP) - 61.99 Block Group 1 71.27 - Block Group 2 79.55 - Block Group 3 76.70 - 755.12 (RHASP) - 72.46 Block Group 1 85.60 - Block Group 2 81.40 - 755.13 (RHSP) - 64.70 Block Group 1 83.51 - Block Group 2 73.32 - 755.15 (TLSP) - 60.14 Block Group 1 60.86 - Block Group 2 84.37 - Block Group 3 92.23 - D-81 Block Group 4 74.63 - Source:AFFH Data Viewer D.4.2. Racially/Ethnically Concentrated Areas of Poverty and Affluence While no racially/ethically concentrated areas of poverty (per HUD's definition)were found in Tustin, some tracts with a high concentration of minorities and LMI populations were found in the southwestern parts of the city(tracts 744.06, 744.07, 744.08, 755.12, 755.13, 755.14, 755.15). In contrast,census tract 755.05 can be considered a concentrated area of affluence as it has a majority White population and a higher range in median income compared to its adjacent tracts. The Downtown Commercial Core Specific Plan(DCCSP) ,Enderle Center,and The Market Place a few sites in this tract that would support affordable housing in more affluent areas. Despite the lack of new affordable housing units being introduced in northeastern and more affluent areas in the City, online survey results indicated that 65% of respondents chose the TLSP Area as an area that is most appropriate to develop more housing.Additionally, goals identified within Section D.5 below would be implemented citywide and support in furthering fair housing within identified housing sites. As identified in Table 25 below,the sites selected for RHNA allocation include a range of percent of population considered poverty status. The sites include relatively low percentages of population considered poverty status, overall. The City's housing strategy is to implement a variety of evenly distributed housing types and affordability levels within each of the housing sites. By doing so,the selected sites would improve diversity and would not concentrate affordable housing within areas of high poverty.Therefore, selected RHNA sites would result in improved conditions. Table 25. Areas of Poverty Area Percent 525.24 (Tustin Market Place) 19.10 755.04 (Enderle Center) 4.90 755.05 (DCCSP) 6.70 755.06 (DCCSP) 5.40 755.07 (DCCSP/RHASP) 16.70 755.12 (RHASP) 14.30 755.13 (RHSP) 8.80 755.15 (TLSP) 12.00 Source: AFFH Data Viewer D-82 D.4.3. Access to Opportunity Tustin consists of 21 tracts,with an even distribution of opportunity areas. The City's south and southwestern tracts are of low resource,while the northeastern half of the City is considered high and highest resource. Housing units in the sites inventory are concentrated in the southwestern half of the city in tracts considered lower resource (tracts 744.06, 744.07, 744.08, 755.12, 755.13, 755.14, 755.15). Several sites are located within tract 755.07,which is identified as a moderate resource area. Section 2.4 details access to opportunities in these areas and analyzes factors like education,employment,transportation,and access to environmentally healthy neighborhoods. The City's site inventory,which would include a variety of housing affordability,being located primarily in low resource areas can potentially improve the quality of life for residents in these areas and support the mobility of these tracts in attaining higher resources as seen in Figure 22. Tustin Legacy (Tract 744.15) is a Master Planned Community that is currently being developed. Although the area comprises 1,500 acres,there are 800 acres remaining for potential future development with a diverse housing stock,community amenities,and resources. In recent years,the Tustin Legacy area has been enhanced with new resources to serve current and future residents,which will improve opportunities for the area. Based upon the resources listed below,the Tustin Legacy area surpasses other areas in the City for livability and well-rounded services for households with various income levels. These resources include,but not limited to: • Education o Heritage Elementary School o Legacy Magnet Academy (Grades 6-12) o Advance Technology and Education Park(ATEP) community college by South Orange County Community College District • Parks o A total of 91 acres of public and private parks have been completed or are under construction,including Veterans Sports Park,Tustin Legacy Linear Park,Victory Park and another 79 acres of potential parkland are remaining. • Community Resources o Orange County Social Services facility for Abused and Neglected Children and their parents as well as emancipated youth(includes many women headed households and their children) o Rancho Santiago sheriffs training facility o Orange County Animal Shelter o Fire Station o Army Reserve Center o Village of Hope transitional homes for individuals and families with children • Employment o Flight at Tustin Legacy office complex o Hoag medical center and Health South acute care facility o Stater Bros. grocery store and other retail and neighborhood services at the Village at Tustin Legacy D-83 o The District at Tustin Legacy shopping center that offers a variety of retail, restaurants,entertainment, groceries and other neighborhood services such as banks, gyms, dance/art studios,barbers and salon services,etc. • Transportation o Metrolink transit facility • Diverse Housing Stock-Residential developments at various income levels including: o Columbus Square (1,075 residential units consisting of single-family homes, duplexes and multi-family homes) o Columbus Grove (465 detached homes) o Field I (376 attached units) o Field I1(189 detached units) o Amalfi Apartments (533 apartment units) o Greenwood (375 detached single-family units) o Anton Legacy (225 affordable housing units) o Levity (218 attached units) o The Landing(400 attached and detached homes-under construction) Negative TCAC Opportunity index scores generally indicate that the census tract has lower resource indicator scores than the region. Majority of the sites that RHNA has been allocated to contain negative index scores. The TLSP area includes majority of the City's RHNA allocation. However,as previously stated,the TLSP area is rapidly developing and changing in accordance with the City's plans for the area. Although the tract has been identified as low resource, it has been substantially enhanced with new resources within recent years. Improvements include schools,parks,community resources,employment centers,transportation,and a variety of housing,which will increase opportunity within the area. Therefore, selected RHNA sites would result in improved conditions. Table 26.TCAC Opportunity Areas Area Index Score 525.24 (Tustin Market Place) 0.27 755.04(Enderle Center) -0.14 755.05 (DCCSP) -0.46 755.06 (DCCSP) 0.19 755.07(DCCSP/RHASP) -0.27 755.12 (RHASP) -0.58 755.13 (RHSP) -0.43 755.15 (TLSP) -0.84 Source:AFFH Data Viewer D-84 D.4.4. Disproportionate Housing Needs A few trends are immediately clear in housing needs in Orange County. The housing problems include houses that have 1 of 4 housing problems by race/ ethnicity and family type. Overall, across the County,Black and Hispanic residents are more likely to face all of these housing problems,at varying rates across different jurisdictions. Housing problems occur more frequently in more populated areas of the County,including Anaheim and Santa Ana in particular. There are some more obvious discrepancies in rates of housing problems across different demographic groups. Black residents in Aliso Viejo experience hosing problems at a rate of 61.84% ,in Orange (city) at 68.87%,in Tustin at 62.40%, and in Buena Park at 54.49%. Hispanic residents experience rates of housing problems that are high overall,but significantly higher in central and southern Orange County. Asian residents generally experience average or lower rates of housing problems,with exceptions in Garden Grove and Santa Ana,where they experience housing problems at rates of 55.94% and 54.62% respectively. All identified sites to meet RHNA have appropriate zoning to allow residential development,at densities to achieve the estimated capacities and,without inhibitors, such as stringent standards, that don't align appropriately for residential development. There are no provisions that would deter accommodating very low- or low-income housing in the City to aid in lowering the percent of disproportionate housing needs experienced by protected classes. D-85 Figure 20: Location of Sites to Meet RHNA Suitable Sites for Additional Residential Development ■� _jf I� I °°� Suitable Site Locations Downtown Commercial Core Specific Plan l / w. Red Hill Avenue Specific Plan Tustin Legacy Specific Plan p7j�yy Enderle Center -Tustin Marketplace ® Municipal Boundaries N Mile D-86 �Z r U — ro a aC 0 w \ro � c .N F z � / wLi o v O 0.7 q� z (z m � � C Ip a 7 N 0 a � CL t z C A 117m Figure 22:Location of Sites in Opportunity Zones . o �► 'i: New City of Tustin TCAC Opportunity Areas 2021 Highest Resource High Resource Moderate Resource Low Resource High Segregation&Poverty - site Inventory Q City Boundary N 0 0.5 1 Miles City of Irvine,County of Los Angeles,Bureau of Land Management,Esri,HERE, Garmin,INCREMENT P,USGS,EPA Sour- AFFH Data Viewer D-88 D.S. Identification and Prioritization of Contributing Factors As identified in Section D.3,the following concerns have been identified regarding fair housing issues: • Disparity in access to opportunity between the northeast(higher resources),where there are predominate populations of White residents,and southwest(lower resources) of the city,where there are predominate populations of Hispanic residents; • High segregation and severe housing issues for the city's Black residents; • Concentrated female-headed households and LMI population within Census tract 755.14; • Lack of affordable housing opportunities for Hispanic residents;and • Disproportionate housing problems faced by large family households. Factors that may contribute to these concerns include the following: • Lack of supply of affordable housing in high opportunity areas; • Inequal access to affordable housing for persons with protected characteristics; • Concentrated access to opportunity within high resource areas;and • Lack of education and enforcement, specifically to educate property owners/landlords about State law prohibiting discrimination. D.5.1. Goals for Affirmatively Furthering Fair Housing In response to the identified factors above,the City and County established goals to address fair housing concerns,which were included in the County Al.The first six overarching goals below, multiple of which have several strategies listed for implementation,are cross-jurisdictional goals. Orange County and the participating jurisdictions all have a role to play in implementing those goals. Following those goals,individual goals for Tustin are outlined,which respond to local circumstances. 1) Goal 1: Increase the supply of affordable housing in high opportunity areas. a) Explore the creation of a new countywide sources of affordable housing. b) Using best practices from other jurisdictions,explore policies and programs that increase the supply affordable housing, such as linkage fees,housing bonds, inclusionary housing,public land set-aside,community land trusts,transit-oriented development, and expedited permitting and review. c) Explore providing low-interest loans to single-family homeowners and grants to homeowners with household incomes of up to 80% of the Area Median Income to develop accessory dwelling units with affordability restriction on their property. d) Review existing zoning policies and explore zoning changes to facilitate the development of affordable housing. e) Align zoning codes to conform to recent California affordable housing legislation. 2) Goal 2: Prevent displacement of low-and moderate-income residents with protected characteristics,including Hispanic residents,Vietnamese residents, seniors,and people with disabilities. D-89 a) Explore piloting a Right to Counsel Program to ensure legal representation for tenants in landlord-tenant proceedings,including those involving the application of new laws like AB 1482. 3) Goal 3: Increase community integration for persons with disabilities a) Conduct targeted outreach and provide tenant application assistance and support to persons with disabilities,including individuals transitioning from institutional settings and individuals who are at risk of institutionalization. As part of that assistance, maintain a database of housing that is accessible to persons with disabilities. b) Consider adopting the accessibility standards adopted by the City of Los Angeles,which require 15 percent of all new units in city-supported Low-Income Housing Tax Credit (LIHTC) projects to be ADA-accessible with at least 4 percent of total units to be accessible for persons with hearing and/or vision disabilities. 4) Goal 4: Ensure equal access to housing for persons with protected characteristics,who are disproportionately likely to be lower-income and to experience homelessness. a) Reduce barriers to accessing rental housing by exploring eliminating application fees for voucher holders and encouraging landlords to follow HUD's guidance on the use of criminal backgrounds in screening tenants. b) Consider incorporating a fair housing equity analysis into the review of significant rezoning proposals and specific plans. 5) Goal 5: Expand access to opportunity for protected classes. a) Explore the voluntary adoption of Small Area Fair Market Rents or exception payment standards in order to increase access to higher opportunity areas for Housing Choice Voucher holders. b) Continue implementing a mobility counseling program that informs Housing Choice Voucher holders about their residential options in higher opportunity areas and provides holistic supports to voucher holders seeking to move to higher opportunity areas. c) Study and make recommendations to improve and expand Orange County's public transportation to ensure that members of protected classes can access jobs in employment centers in Anaheim,Santa Ana,and Irvine. d) Increase support for fair housing enforcement,education,and outreach. As identified in the 2020 Al,the following goals were established for the City of Tustin in effort to address factors outlined above: 1) In collaboration with the Orange County Housing Authority(OCHA): a) Attend quarterly OCHA Housing Advisory Committee to enhance the exchange of information regarding the availability,procedures,and policies related to the Housing Assistance Voucher program and regional housing issues. b) Support OCHA's affirmative fair marketing plan and de-concentration policies by providing five-year and annual Public Housing Authority (PHA) plan certifications. c) In coordination with OCHA and fair housing services provider,conduct landlord education campaign to educate property owners about State law prohibiting discrimination based on household income. 2) Through the Fair Housing Foundation: D-90 a) Provide fair housing education and information to apartment managers and homeowner associations on why denial of reasonable modifications/accommodations is unlawful. b) Conduct multi-faceted fair housing outreach to tenants,landlords,property owners, realtors,and property management companies. Methods of outreach may include workshops,informational booths,presentations to community groups,and distribution of multi-lingual fair housing literature. c) Provide general fair housing counseling and referrals services to address tenant- landlord issues and investigate allegations of fair housing discrimination and take appropriate actions to conciliate cases or refer to appropriate authorities. d) Periodically monitor local newspapers and online media outlets to identify potentially discriminatory housing advertisements. e) Include testing/audits within the scope of work with fair housing provider. 3) Prepare a new Housing Element that is compliant with all current State laws and is certified by the California Department of Housing and Community Development. 4) Utilize funding through State programs (SB2) to support affordable housing and/or homeless prevention services. 5) Update zoning ordinance to comply with current State law. As part of this Housing Element, the City has established several programs that address the constraints of this AFH analysis, as well as support the goals that were previously established during development of the County Al. The City's General Plan Housing Element (2021-2029) includes several goals that will support in furthering fair housing within the city. • 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. • 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. • Goal 3: Increase the percentage of ownership housing to ensure a reasonable balance of rental and owner-occupied housing within the City. • Goal 4:Preserve the existing supply of affordable housing in the City. To facilitate these goals, several programs will be implemented over the planning period to ensure the City's goals are met.Several of the City's programs were modified in response to create measurable actions that will be monitored to progress is made towards AFH constraints identified as part of this analysis. The following table provides the programs that will be implemented over the planning period to address. Supporting programs would facilitate development of new affordable housing opportunities, provide housing and/or housing services for persons with protected characteristics, protect existing low-income housing from conversion to market rate housing, promote high-quality housing/housing rehabilitation throughout the City, and Promote and educate the public/landlords on fair housing practices. Through these actions, the City will be able to take meaningful action towards creating affordable housing opportunities in high resource areas, provide access to affordable housing for persons with protected characteristics, distribute access D-91 to opportunity outside of high resource areas, and provide education and enforcement to implement State law prohibiting discrimination. 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O O (3) by O cin x w0 cn bo +~+ U O O O "" It It ^ w In O O O O 30 p ° s it 0 by 3 u by •�' � w � a, � � � � w w � � Z � xuw � � '� z � � Z •� N Lc) rN- O r- L� O p� ( ir) O r- u u O O O O O p by 0 (n `p •� � 3 Q a� (t u t U a O Cd bA �i X O � Cd Cd O Cd R-a � Q N I I r w l r „ 0 . . .w yy ti JI Iwo JI MW • • - - • • • Tustin s. 2021-2029 Housing Element Contents Background .........................................................................................................................................3 ProjectPurpose...................................................................................................................................3 Goals & Objectives...........................................................................................................................3 TargetedStakeholders .....................................................................................................................4 Outreach & Engagement Strategies...............................................................................................7 Education & Awareness Strategies...................................................................9 City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan P a g e 1 2 Purpose This COMMUNITY ENGAGEMENT PLAN is for the City of Tustin's 6r"Cycle Housing Element(2021-2029). This Plan describes strategies for engaging with residents and stakeholders through an online survey, education and awareness campaigns, and public meetings. Due to COVID-19 restrictions on in-person meetings,this outreach plan focused on alternatives such as virtual meetings, targeted email blasts, mailings to stakeholders, unpaid and paid social media postings, posters at community facilities, distribution of flyers, dedicated project website, and newspaper advertisements. Background The City of Tustin is preparing the 2021 — 2029 HOUSING ELEMENT UPDATE to evaluate current and future housing conditions, and identify housing sites and programs to meet the community's needs. While updating the housing element is a State requirement, it is also an opportunity to assess its accomplishments and progress toward meeting housing goals put forth in the previous Housing Element in 2013. The 2021- 2029 Housing Element will outline the goals, policies and programs needed to promote the development and preservation of safe, accessible, and diverse housing in the City. Goals and Objectives The GOAL of the COMMUNITY ENGAGEMENT PLAN for the 2021 — 2029 Housing Element Update is to guide the City's community and stakeholder engagement efforts and to provide information about the importance in participating in the Housing Element Update. The OBJECTIVES of the Community Engagement Plan include: Building public awareness of the Housing Element Update, its requirements, and the City's vision and goals to adequately plan to meet housing needs to all of its residents; Educating the Tustin community on the requirements of the Housing Element Update, and progress since the previous Housing Element; Engaging community members and key stakeholder groups to provide input on potential policies and programs that will align with Tustin resident's housing needs; Facilitating discussions with community members and decision makers to identify how and where additional housing could be located within the City; and, Providing a concise document to the Tustin City Council and Planning Commission for adoption, with input and updates from public outreach and engagement activities during the Housing Element Update. Al �t City of Tustin 2021 — 2029 Housing Element Update Community Engagement Plan P a g e 3 Targeted Stakeholders To meet the OBJECTIVES of the City of Tustin's COMMUNITY ENGAGEMENT PLAN, the City requested feedback from a diverse set of stakeholders within the community who represent multiple interests and experiences related to housing.This section of the Community Engagement Plan includes the various organizations and agencies that were included in the City's outreach efforts. A database was maintained and updated with stakeholder contact information throughout the outreach process. The various stakeholders include, but are not limited to: RESIDENTS, APARTMENT OWNERS, SERVICE PROVIDERS, ORGANIZATIONS, and AGENGIES. Isoli Affordable Housing Advocates ASIS Organizations and agencies that advocate for safe and affordable housing opportunities for residents of all ages and abilities within the City of Tustin. This includes but is not limited to: - Kennedy Commission - University of Irvine - Tustin Planning - Habitat for Humanity Partnership - Jamboree Housing - OC Community - Linc Housing Corp. Housing Corp. Apartment/HOA Managers and Owners The TEAM (Tustin Effective Apartment Managers) group, which is a problem-solving community organization comprised of apartment managers, apartment owners, police, school officials, and service providers, and additionally outreached to 99 Home Owner Association property management groups throughout the Tustin area. Community Service Groups Community-based organizations that provide services to historically under-represented community members as well as youth and seniors. This includes but is not limited to: - St. Joseph Hospital - Alzheimer's of OC -Community Health - Lestonnac Free Clinic Initiative of OC - Meals on Wheels -Neighborworks OC -Tustin Community - Tustin Public Schools OC Foundation Foundation Disability Advocates Organizations and agencies that advocate or provide assistance to people with disabilities who rely on safe and accessible housing opportunities. This includes but is not limited to: - Assistance League of - Dayle McIntosh - Learning Disabilities - The Blind Children's Tustin Center Assoc. of Southern Learning Center CA - Regional Center of OC City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan P a g e 4 Economic Development Organizations that represent or advocate for business and employers in Tustin. This includes but is not limited to: - Tustin Chamber of Commerce - Tustin Economic - BIA Orange County - Orange County Development Division Chapter Business Council Environmental Advocates Commissions, agencies, or organizations that advocate for sustainable land use and environmental protection in the Tustin or Orange County area. This includes but is not limited to: - Southern California - Southern California - Southern California Air -OC Fire Authority Gas Edison Quality Management - Regional Water - OC Environmental - Airport Land Use -East Orange Quality Control Health Commission County Water Board District Low-Income Communities Organizations or agencies that represent low-income communities in Tustin. This includes but is not limited to: - Boys & Girls Clubs of - Big Brothers and Big - Goodwill of OC - Legal Aid Society of Tustin Sisters of OC OC - MOMS OC - OC Food Access - Patriots & Paws - Second Harvest Food Coalition Bank of OC - Veterans Legal - YMCA of OC - Community Action - Public Law Center Institute Partnership of OC - Orange County Finance Trust People Experiencing Homelessness Organizations, groups, or agencies that provide services to people experiencing homelessness in Tustin. This includes but is not limited to: - Housing and Homeless - City Net - Families Forward - Family Promise of OC Prevention Unit - Human Options - Olive Crest - OC Gateway to - Second Chance OC Housing - The Eli Home - American Family - OC Social Services - OC Rescue Mission Housing Tustin Family Campus -Orange County Housing Finance Trust Real Estate Affiliated Businesses or agencies that are affiliated with real estate transactions in Tustin. This includes but is not limited to: - Affordable Housing - Consumer Credit -Orange County Clearinghouse Counseling Realtors Association of Professionals City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan P a g e 1 5 Residential Developers Residential or property developers that develop housing sites in Tustin, including affordable housing developers. This includes but is not limited to: - Intracorp Homes -City Ventures -Greystar -Curt Pringle & Assoc. - Century Housing - Civic Center Barrio - William Lyon Homes, -HomeAid Orange County Housing Corp. Inc. - Lennar Corp. - Taylor Morrison - Brookfield Residential - Shea Homes Southern CA Senior Housing and Advocates Agencies or organizations that provide senior housing in Tustin, and agencies that advocate for safe, affordable, and accessible housing options for senior residents living in Tustin. This includes but is not limited to: - Council on Aging - OC Office on -Tustin Housing -Senior Rental OC Aging Authority Properties in Tustin -Community Action -Orange County -County of Orange Partnership of Health Care Agency Senior Services Orange County Religious Institutions Faith-based organizations who provide supportive services to residents living in Tustin. This includes but is not limited to: - St. Paul's Episcopal - Grace Harbor - The Salvation Army -Orange County Church Church & School Rescue Mission Underrepresented Groups Cultural organizations or groups who advocate for the traditionally underrepresented groups in the Tustin area. The City has reached out to these organizations to encourage feedback. This includes but is not limited to: - AIDS Services - Fair Housing - Fair Housing Council of - Tustin Unified Foundation Foundation OC School District City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan P a g e 1 6 Outreach & Engagement Strategies The chart below provides a summary of the scheduled activities, community outreach and engagement strategies that the City implemented to obtain input and build awareness throughout the Housing Element Update. Each strategy encourages participation, facilitates meaningful dialogue with the community, and builds awareness of the challenges and opportunities of implementing housing strategies that meet the State's requirements. Schedule of Activities ► Housing Element Update Community ► Joint Community Workshop with Workshop with the Planning Commission the City Council and Planning ► Draft Document- Public Hearing with the Commission Planning Commission \\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\O O\\\\\\\\\\\\\\\\\\\\\\\\\\\\\ � )UI IUIIA�II �0IM0II \ November ' • September 1 2021 Ar 'A October 2020 2021 A'PF' May 2021 rr ► Community Survey open ► June 30-Reopened the ► Finalize Document- for 30 days Community Survey for 30 days Public Hearing with the ► Draft Housing Element City Council Document available for public review(30 days) and HCD review(60 days) Online Community Survey An online community survey was made available from January 21, 2021 through February 28, 2021, in English and Spanish, to help city staff better understand the communities housing needs and priorities. In total, there were 193 survey respondents, with a majority of the respondents being Tustin residents. The online survey re-opened for another 30 days from June 30, 2021 through July 30, 2021. Planning Commission and Council Meetings and Workshops A total of four community/public meetings are planned with the Planning Commission and City Council as part of the Housing Element preparation process. These virtual workshops and in-person hearings, serve as a method for community members to provide input on the progress of the Housing Element update as well as a venue to inform the Council and Commission on the state requirements, discuss housing needs, and to provide a progress update. November 10, 2020 — Planning Commission Workshop (Via Zoom) - City staff provided an overview of the housing element preparation process, including plans for community outreach. May 11, 2021- City Council and Planning Commission Workshop (via Zoom) - City staff presented its findings from the community outreach and engagement activities, and solicited input on future housing needs. Key topics covered at the meetings included: A Survey results A Reviewed existing housing policies A Potential new housing programs A Opportunity sites for meeting housing requirements ® Project timeline City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan P a g e 1 7 Public Review Period The City is available to the public for a 30-day public review period, from June 30, 2021 through July 30, 2021. During this time, stakeholders and the general public are provided with the opportunity to review and comment on the Draft Housing Element document before it is finalized. The document has also been transmitted to the Department of Housing and Community Development (HCD) on June 30, 2021 for a 60-day review period. The HCD review period concludes on August 30, 2021. Planning Commission and Council Adoption Public Hearings After the final Draft Housing Element is developed, and reviewed by HCD,the City will hold public hearings with the Planning Commission and City Council before submitting the final draft to HCD for certification. Tentative — Planning Commission Hearing on September 14, 2021 Tentative — City Council Hearing on October 5, 2021 City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan P a g e 1 8 Education & Awareness Strategies The City is using many strategies to build education and awareness of the Housing Element Update, and increase participation among community members. The following strategies were implemented to ensure public awareness and to solicit feedback from residents and stakeholders. -CITY WEBSITE SPOTLIGHT FEATURE - Outreach and project information was (.SOCIAL MEDIA POSTS- UNPAID posted as a spotlight feature on the City's website and sent to the web's AND PAID -Social media posts subscriber list in English and in Spanish were made containing information -POSTED FLYERS - Notifications in English and in Spanish were posted on the on public participation City's e-notice board, Library, Senior Center,Tustin Family Youth Center (TFYC), opportunities regarding the and Boys & Girls Club. Additional bundles of flyers were distributed at the Housing Element Update survey, Senior Center (200 flyers),TFYC (200 flyers), and Boys & Girls Club (100 and multiple workshops/meetings, flyers). Additional flyer distribution was offered to individual apartment on all of the City's social meda locations part of the TEAM (Tustin Effective Apartment Managers) group platforms -CITY CALENDAR - Meeting information was posted on the City's Calendar -PRESS RELEASE - A press release •TUSTIN CHAMBER - Tustin Chamber of Commerce advertised meeting dates on was distributed in English and their website. Flyer graphics shared were in English and in Spanish. Spanish, inviting the public to review the Draft Housing Element -EMAIL BLASTS - Multiple email notifications were sent to 268 stakeholders and Update (97 subscribers) interested parties. The City Manager's Office utilized their Community Outreach -VIDEO OUTREACH - Mayor ListSery to e-mail notifications to over 10,000 subsribers. Graphics included and Clark's Corner video advertised attached to email blasts were in English and in Spanish. review of the Draft HEU. Video -POSTCARD MAILINGS - Postcards containing workshop and public participation was posted on all Social Media information in English and in Spanish were mailed to 396 interested parties outlets including YouTube including residents, businesses, property managers, housing advocacy groups, -The Tustin Chamber of Commerce non-profits, religious institutions and others. Information regarding workshop shared workshop/meeting participation was included within the City of Tustin's Strategic Plan postcards information on each of their social which were distributed to 29,885 Tustin residents and 3,457 Tustin businesses. media platforms Notification Methods i Media Posts o *WEBSITE- City developed a -NEWSPAPER ADVERTISEMENTS-To build widespread awareness of the dedicated Housing Element Update Housing Element Update,the City has made publications in local and regional webpage, hosted on the City's news resources in both printed and digital formats website *Website includes a project *Tustin News - distributed to over 7,000 Tustin residents overview, schedule of activities, *Irvine Weekly - distributed to over 8,200 Tustin residents, including a digital and information on how the public distribution, reaching over 33,000 individuals can get involved -PAID SOCIA MEDIA ADS - Paid advertisements on the City's social media *Website updated regularly with platfroms which enabled notification to a larger population than traditional timeline, meeting updates and postings survey information • - • - • • ❑_ • • • • - CCC .... City of Tustin 2021 — 2029 Housing Element Update I Community Engagement Plan P a g e 9 Appendix B Index of Interested Parties Index of Interested Parties Housing Element Survey Respondents r' O CF) an r, O O O O O O N O N O O N N N O O O O N O N 0110 O Q ri O O O N nQ n n n N N N N N N N N N N N N N N N N N N N N N N 0) N LN N N 0) 0) 0) 0) 0) 0) 0) 0) 0) 01 01 an an an an an an an an an 0) 0) Q 01 co U 0) 0) 0) Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q u Q Q Q Q U U U U U U U U U U U U U U U U U U U U U U U Q U U U C C C C C C C C C C C C C C C C C C C C C C w C O (B C C C vn vn vn vn vn vn Ln v vn Ln v vn vn vn vn vn vn vn vn Ln v v M vn M C vn vn vn H H H H H H H H H H H H H H H H H H H H H H 0 H D Ln H H H O > co N O L N— O a) a) � N N O Q L >Q N L U •� M L L L Z � O Ov u O Ln n > N aJ 7 4 L -0 O UCC cO a) M m 'L Ln _ C aJ O dA N C� In x (0 7 G Oo 4. = (n Z J M = Z L� O C Z -a L c a) Q Zu (B J _ U cc Ln GJ (0 C N aJ z (0 c l0 CC� 47 (0 47 C C V •� � c' z Q >> 0 —M w a z m 0 � 2 — � � z =; Q •m L o � Lj- 0 L c7 Q u m H 0 N Q U O O O O O N N N N N N N N O O O O O n n n n n n n n n n n n n n n n n n u N N N N N N N N N N N N N N N N N N m N Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q m U U U U U U U U U U U U U U U U U U i C C C C C C C C C C C C C C C C C C O L V7 V7 V7 V7 V7 V7 V7 V7 V7 V7 V7 V7 V7 V7 V7 V7 V7 V7 O co C v — O m n O Co co co M O LC N c L , co O O co U a) co c O aJ N >Q --,e _ L O � � 5 •L Q J Q L �` L � Q (O i LS a7 a7 J C = cocc = °J a7 a7 +J C 'F, = O a) O O co E co aJ co M O p Q - CCI W co d' W Q Q U C J V1 J 0 Index of Interested Parties Community Development Block Grant Interested Parties List 00 mm -1 0000 0 0000 qt o 0 0 o 0 0 -11 o ONO 0 0 -1 o Nn 0 0 0000 0 0rl' 0rl' 0rl' o p o �D �D r` r` r` 00 r` 00 00 00 r` 00 r` �D �D w r` r` w �D w �D r` r` r` r` �D �D �D w �D r- C14 N N N N N N N N O N N N N N N N N N O N N N N N N N N N N O N N dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q U U U U U U U U U U U U U U U U U U U U U U U U U U U U U U U U U > > U N tV L mL m m m U QJ tV tV tV U l6 c l7 c E u l7 c E c E c E m c c c U c O Q c Qc Q Q Q co Q Q Q Q co > > co m O O M M c m '> '> C M O > c m m m tco •> '> '> c •� c Lnf— U' LnQ J U' LnQ (n L L Q f— LnJ i Q J v) Ln f— v) L L L L N O r` v O O 0 N N N N L O vI v vI m v) v N Ln } Ln vI O U j � a � 0 4J m > � 4J 0 to : L 4J >' (p L U > 0' � Y 4J U L Q U 3 L 7 0 L tV L L L U> III III III Q L O L O' ° ti4 }' L U L v) N L L +-+ v N O U C v L O O In C �n .+-+ c6 L O L U I.f) Y v U> m m Ln rIjW W n' T r` r, m tV T ° co ° o > Ln °o U 0 t t 3 mn mn mn 0 {A W v) U U a-' c Y a-+ m O ° m X i i Z a-+ X X X tV U l6 LJ rl N w w > (� w Q Q O w Z w U XO > w J E m O O 000 000 000 W W tD 00 In c-I > c-I In 00 r, In O c-I Z O > Z Z omo r- In qt 000 000 N r-Ao0 O O 00 O O N W O O � O tDD O 0 0 00 O O O O � o N Q N c-I N c-I In r- c-I In qt —i —i —i —i N D- Lr) —i N m 00 M d 4 —1 N d d d lD —i —i C � 7 � O C U :3 v O pO U c v > ti4 N O 0 o c O O > > U p O U L n c c v U -C O ate-+ � -C ° E 7 0 ° v +>,+ ° C 4J Fo L > U L U L U +�+ +�+ U 0 0 D N U U o 'o o v 0 0 ao O a 4J C ° L b4 L C �"� U O (n •O •� L L U C O tV C U U U ++ 0 tLo v ao ° a0' c�0 ° .0 O v c ago ago a0o C -0 > J 0 O C C � c6 - m 7 v >, v U v v L C L -C O O O L v }+ tV tV U E N Ll6 L 0) 4J N M 43 L L C C C N 0 0 p Co03 v - •> � Q = J- N ao 0 0 >- U W 3 N - O O L o_ o_ O_ J y U L v v L �n N +-+ +-+ > +-+ O > C v C C O O _a O O - Q Q Q 0 O ^I c c +� c c c c o : " v , , N a � _ _ co O O O = v b4 c N 1° 0 0o Q U v v o .� vI 3 0 o o •c f0 L vI v m �n z c O E CLc > 0 i0 NO L L L }' O O cc� O O E co co co m O O E O Q Q Q Q m m U U U U U U G U U U 0 W W W W W U- 0 O N -0 (6 C N E UO v O •L OC7 -0 Lco UO C OO c �G Q O O O O vL c W cn N CO MMO 6 N7 i _ C uo N tV u U L W QJ U Q C 2 M M m M O C L l6 C -O U 4J M 4J m C N O i0 >, b00 > .V cp C 4J In Q to U L mu C C L �[ CO L m aO ° L L lO uo m -0 C 0 Y 4J C 'L +.+ ° L 4J f0 v m U v E M N UO v O tV N +� •N v L O -0 U L m - v Z m �° �° vI GD u U 2 a w C7 vI 00 U U —M 0 a U 3C(f Ln M �t Lf) I- N M M Ln I- O Ln Ln Ln Ln Ln O Ln lD M 00 N lD 00 lD O Lf) Ln 00 rl lD r-A O O O 0 0 0 0 0 0 0 M O O O O O iD rl � Ln O o0 N rl N 00 O O ri O N o0 00 00 n w o0 � n n n n n n w a0 � n n n n n � � � � n n � � � a0 n 00 t.0 n t.0 n n n N N N N N N N N N N N N N N N N N N N N N N N N N O N N N N N N N N dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl dl Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q Q U U U U U U U U U U U U U U U U U U U U U U U U U U U U U U U U U U L L U U U 41 41 (6 00 00 O ON l6 l6 L l6 (6 (6 (6 (6 (6 (6 (6 (6 (6 (6 (6 (6 m O O = C U O C C C C C C C C L C C C C C Q OJ Q Q Q Q Q Q OJ O Q Q Q Q Q 00 CCO •� m Q Q (6 L > (6 (6 (6 (6 (6 (6 L (6 (6 (6 (6 (6 (64J � � (0 O 7 O > O p (6 C > (6 O 7 7 7 (n O L (n (n (n (n (n (n O J (n (n (n (n Ln J L. 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Q O +-+ + CL + + O c c L - L N N N > (n _ O (0 U Y c v ,n L - L Li >, c N M t0 t0 +-' OJ O L L L 0 L O Ln }' O c •i C OJ +-' 'n L7 t0 L ~ U w ~ r-A ro x x + coo E p O L L O U Z w �O Z O > > w w w w w w w m O Q n O Y LL w Z E z Q m w O rl Ln NC) rlJ rl m 00rNI 00rNI O tD O O O rl rl O m r-A O N O O Ln Ln v rl rn Ln M A r-IN 00 O -1 -1 00 N M -1 -1 -1 N M OM N M 00 O 0) O Ln to Ln r-A I- O� r-A O M n N r-A r-A r-A rl D_ rl rl rl rl N N N N r-A r-A r-A D_ M N r-A rl N 00 r-A r-A rl rl N Dl M D- M r-A C O 7 o }0 E >- U - :3 CL c uo u L C N 0) UO O O C t U N N o ~ c ° Q >, O U C02 02 U c :> _ ° c c o L p Q u O uo O O v `� v v (LO U c v v c — O ao Q v m - c O L Ln E c c C c = '� 'C LU ,n :3 :3tL6 O :3 (0 :3 U � C tp0 p � � U � OJ - � U O C p p O = O ° O D_ 7 L p z O ate-+ '� 'O >. U O N l0 U U 4J U U 2 N 3 E O - O N m C 7 i 0 L v OJ H OJ OJ c Y °J T n O T c0 •E E T u Ln •Q +� U Q u v +, t 0) o U o O E ° v a v v c *' U > "' (6 (6 - > +� +� +� D U c>0 D LL U L m i O E E •C (0 (0 E (n OJ +-+ > : L L Q > L O Q O C OJ Q L M OJ >' U ° D_ o = O O o ° 0) 0) 0) U U N c0o0 o c U = o p v = f0 o L L L Q p N N c -c U U U O U v - b4 Q Q U z UO T Q 0U0 00c u_ u O E t0 •+� C C c t0 C w (n > c c c ao o c0 c0 v v O O °p U > > > M U U M +� b4 p >0 m O O v v v v L z z O O O O O O O O a a a (n (n (n (n CL -C -C -C D D D D C O ° +-' C O C L m m OJ c Y Q uo J ° OJ C C C OJ (0 4J E C 4J L >` m L L C O c O U C 3 C (0 QJ N _ v Ln c O f6 a°0 d N C OJ v N �_ c m m Y m UO O U- - - E U 0 J ° 'm c0 •L i J J ° U c t c0 c0 (n cL0 v v �_ o c o v v ° ao E v (0 (0 O U > M O N > C Y 7 l0 +.+ U 7 7 � C -0 N L O C L 4J L l0 E (6 = O - > C (0 U O t (0 (0 (6 (6 (6 (0 L - L N L M Lu M � M Q M Q Z - M U U d' J J W D_ 00 � > L p - p n (0 O CD J J (n m \ 0 0 o m / o 0 / / / / / / / / @ \ \ \ \ \ \ \ \ 9 \ \ K \ \ { _ { \ \ . < 0 < ® E ± » \ a \ / x \ } e % u 7 f 0 / 2 / / / z z co o m z @ @ \ \ \ \ \ \ \ \ _ 2 \ % _ 3 0 u (3)0 » » a § E § § >- \ § / / / \ \ \ \ / S S E 2 G E E % % \ \ E \ L k / / U = 0 § _ = 0 0 § § M: » / E / / \ Ln \\ \ \ \ 7 7 _ g / @ E \ \ \ \ 2 a> 3 \ >< / \ / \ \ ƒ / \ \ Index of Interested Parties Outside Agencies and Developers List `o 0 E o v $ 0 E v a v 0 a a v 9 w E ° `o p E E `0 a 0 E ° a v q p l 3 o Q o 0 < 9 E 3 w o :0 `0 _ - u u t J W " O O O O O - O O O O O O r o m m o0 0 0o ui o o m m v o m m o0 o m o � �n o m m o0 o m o o 00 00 0 0 00 � n n m o m o n v o 00 m n n v m �n o m in m n m m o m y o o0 m r r �n in o moo ui o r m v oo v m in v o0 oyo m o v m n �n m m v m �n m v m m m m m m m y r Z � � � v v oo O v m v v v v m v m o v v v v v v m m v v v m y o v v v v 00 v N � m 0o m v m .. m o g � 55 � 5g � g � `° gm m' < u ° " ' 5ga5 � � � � g � � 55 H V V ru QmQ m m j mQ Y mQ m o o m " m m Q m m �' V �Q' '� a a V V ru ra U U ra ra V ni ni n, G m V ni V V n, 4 o V n, iJ n, U n, n, n, v V V v n, a a - a s a a a �-' a ai a �-' m a > o a a a a ai ai a -°omo -°omo U ¢ V H H H .n .n u = V H H l7 vi l7 vi `J° H vi H O vi - 2 H LL H V O O V 0 0 •' o N m N UI Vl > UI vi ai v v v ai -° v a a> v r v a> a > m° N a <> 0 0 0 > ° .r". r ° -c oLvo a r� y r o N v c n m o `°° 3 "' o y°o 0 n --vo o -°0� '° o w o ,°, " 3 > n, E x N > vii m = v E E O t7 LD r 0 1O o t7 m ¢ - .n .�Y. m 3 v 1O -0 O Z 3 Z z m �° v 3 Z m° 3 0 ^ o m° o z Z m° a 3 m w a w m Y o �n N �" n W m o o ":' m o 0 0 "' T > V O c Q o C 00 U E UO v=Oi i V O u o r o 0 0n o V v o v . ° L 071 - „ o r 0. v m r m v v v Y O - O wO O " O V - v� >. o m o > W V v - c 0 O c m o Y o v " 3 w " '" o v LL v c w o u c 0 2 a 0 = a V o .L V ,� u c v D v v u v - o u E o o - o N 3 c o 071 c m �° 2 v o v o z �i u r v o > L V ",� m 2 2 c � -" o m Y c > a e v v V V c ._ o v v > E ,� v '" ¢ o u a V v v .0 a i o J 2 vi Q '" - V m ¢ 071 "o_ E _ -O o N E - V ra N = v oo Q v r v `° o > 0 0 0 ° r > vri " - 3 ,0 �_ -0 c V V O v v oo LL 2 U E ., v c v >' c r 2 °- 4 0 V V o v �' v L a s O a v a v o a s c v E a a v r`a o o L o a v L �° c° _ - - E :a -o ,°., c° v ._ u '^ E m E - c° > a° a v > ro Yn E 0 c ro V Yn � v v E o0 0 v = Yn ro v E v V E >'J - v J v o > D O a H �i a tw 0 0 H D J 2w u m 3 LL v, = H O H O J O a J 0 m° �v, - v, V O V UI W � J — N v F— a v 3 a a o o E N ° ° c m v o E c v J ° v v m N v ° r a > E v U r V V v a _ j '° _ ° _ > v "' o ami w E z m - LD v v _ > m v v v 3 w om = ¢ o a x° u �i 3 w o ° ° ° o o w v `o a o 0 0 0 E a o o a -E o a o a 0 3 0 o v E o E 0 E u E a o v o t °' _ _ u u a w o t o E v o ° @ E 9 c o - E o 0 w w 2 0 r r m o 00 0 0 � m r m m Q m o umi r Q U � o v `T No o r r g ° ggVmEo � a ° g55 � � � g � � � 5 � g � � 55 � 5 tg = u m V v m m m m m m m m m m tg m m o v a ai pv gai gai .m g u<_ .m vo o E Vaai VLLLL sai Ev mvoo a gai gai V- a_ rmvoo v o ° c c c o .L .L c .L .� .L o .L c .L .L c c c .L .L c o c .L .L c o a _ zv a ^ _ ^ _ _ _ _ a _ _ 0 m a o ov o oto 0 Yo N N o Y V v z ._ Y m 'y m > U > ' a m > Y m a m V > a r -° c o n N > v ip O0 0 N ~ Q V >' m = a > g Q m a 3 v 3 r t r > Uj > v o0 `E l7 m l7 w 0 _ m ry w Y in - a ui z m N = o z Y n ? o E o V wo V y z° o �' 3 a a w ° o >° ° u = V `° o .`n. l m m m v m m m m n o O m O m m � m m o o m n m o0 o ui ui "' O v o m o- E V T T E> V EO m T UI O u O 1 O V v J m ` 0 0 ° o Q v o ov°o m n, - ., - , U,- x G°o >te "O o° L V ooo o oo UU3a OE . Vc l7 ?N pV O L - V N m mix �w m O O Eo f EV � m u v v o o °° J mo V ° ° o00 ° v ° = zovuoo' v - aE ot ° V o V c o � L vv co oo- ° V o V JV ° V V x > > V V O E v v E E o o vV avo V o E x° o EE ` ow° � � bu z 65 a uu ooc�_0 w w v m `o p `o `o LV i Ll u D O D D 0 x a > v > v v v v v v v v w XX wV vOi w a w a 90 O Oo E v o v O O L i L O O L > > O = o E ° 2o w - No oro o o m w v LD ¢ u a o v w v w v m �j N c o m mv ° o Y -° m o V m° m ° 2 m Y z V w w w m a .n l7 l7 a l7 vi E O v v v > a 0 3 � a r Y 0 0 0 ov m m umi v N v o1Oo T r r m r m m o ° w m m ° o 0 Oi Oi W Oi Oi Oi Oi Oi W Oi Oi Oi Oi O Q� Q�Q m W W U Oi W W Oi Oi W Oi > Q Ol Ol NO Q Q l0 Q Q Q Q Q Q O U U Q U UV V V V V U V V V v m N U U U N 01 U vi V V N E d d g °' g v 16 1 '° ov `L' tg tg 5 t0 g g g a v d N a v o a a v a '- Q` Q` " m o o .L � � v c a o Z 2 V - H H 2i .n H O V .n .n - O .n V 0 0 m 0o v o v UI UI Y Y O ^ V Ll v N a s Y v"vi ai o Q > m > v w v Q m Q Q > m° v v v '^ v > a } > v > 3 Q v o d a Q ro D Q O Q Q 3 �n Q ° a - - n ^ > o V' - ° .n .n .n .n '^ Q o 3 o N D a o m m v v $ `� c c m 0 3 m 0 c c L v o L L L L o - v �7 L o 3 ° v V v c °- v v N m LL LL v .^Yi ,� ~ v v v v - `^ Y m v O r"a V v `0 ° u 3 z° z° z m° m° 3 3 w Y w w w m` a a ° E o o z z w 3 j 3 oo w w 0o m m 0 �'' 0 0 o w o .. o m o o �" o m w > �'' .. v -° .n .n .n m n n o m m o o v o m .N. 5 v'^i oo J v - � u > V N H 3 V O F Om >' u o v O O > - c O u O V L ziip o o N a N 0 J C w N N N V m V - E -O } V O O O LL V V ° >' >' m o m:E sm V E o v o o mw Tm vi o 2 o o m m v ° u u v O v x 3 0 Y o - v > v o o v x N ° `° a '" o O O o o N ra o >. '^ v E - v `0 v ro `° m v o V o n .-> c 0 0 o o. ° a 3 a c o E v O u a ° o ° .� w .� °' 'o d - = m mo 0 0 - O ° v v v -° w `�°, V u o E - V ._ v o V > 3 3 v O - `0 a ¢ 0 0 o LL o v V = ° a Q a - O w v o 0 0 0 E E °o °o E v O O .� �.i > > > V u °u > v °1 .� n c .n > > Y w - _ m t7 t7 t7 = z z O o o O O O a vv, o vv, > > v v, o v v O v 0 > o z - ¢ o `o v 0 o n o v o p v v " o c c o 'o _ O > oo=o a` J Vo m v w v E u uin v min v L a > a c a Y u ° a v o v v = E v V Y Y } m Q D Q Z D V V m d 0 - W Y Y W N N Index of Interested Parties Adjacent Jurisdictions, Utilities, and College Districts List E L O w- U U N v 'C N N O C O 0 N C O Z V01 >i N OU O 4 } Y T N J J6 m m O T C m O m "O C C N m m 3 m L m L +@' L L C U L m M "O N m +' v � N U Q Y U Y V1 Q Q V1 0 K r V1 U Y Q U U U O E v >O E L O m O U E U 0 0 O O j j C v 0 u w "JO v 3 O t O m0 O u m -° o > 0 u y u °1 L O o c `° 0 0 0 Y m u O c o f Ou o O E u u o u 3 u u Y 0 U m - c `o $ .. L > o L u u v - Oi o O O p E O-Oo O m °Lou E c Y NE L W m Y vii m E oo oo N a U m Y O bmp N O N to O m O < N N Q Q Ol N C p p U �o Q Ol N Q m N op m p U l0 �p C U O V1 p � V N N oo N O ` 'E O I� M o m oo O V/ N Q N - N U Ol U c-1 V O O v o Q o o m U u m o U N r C O C Ol C V O N Q I� E oo oo l0 V V O N N N Q O 0 N 12 Q Q p r C N C Q O m 0 o) N ry ry U O o)j O Q m U O O m u m Np Q o^0 U x U N Q U w C r-, M 0 0 0 0 N O m N LL C op V1 = I- U N m N Ol Qr U N N N m U m O C C N V1 V '12 O j Ol m N V1 bA Uc C "O m Ol Ol Ol C C N M m N O p X C N ` U bmp C U N N 6 m "O >i `""� N V1 > m m O J C C C O M -O ~ > 3 L U c > O m m m N m0 2 m C N "00 Index of Interested Parties Orange County Housing Developers List 0 O E 0 $ v E v o g ° o r o v E 0 oo a " E U N U i m t O0 p C ; }+ O m y v 0 L a>' 0@0 , 3 u r c +t Nmu c .o Y°o v v 3 0 v Y $ v o 3 v = c m c m E c v Y 0 0 0 o o v o 3 0 E o o c W c c c -E c w v c c c c o 3 m m oo 0 ll1 , O N .--I O oo 0�0 O m r r 2 - m V . � m M 0 lco 00 l00 N l00 l00 l00 N l00 l00 T l0 T M r M l0 l0 `""� T Ol N T T V V N N ry N V oo op Ol Ol I� m N N N Ol Ol .y ry m 0) U M M 0) 0) 'C V1 l0 l0 V N U U op oo N � U U r Q `� U v O O D U ° O1 01 m N m m m l0 m I� Ol w m m 0 L m c-I c-I L L m Ol N C Ol C ry m m ry Ol N ry m m ry O ry m m ry ry U m m 0) m m O1 Q 0) f6 O) N m m 0) v 0) m c 0) 0) t m m m U o o a aUa ma U p p U v U U m �o �o U c U o w U U am o o J a v v 5 3 3 5 12 -5 o > Q 3 3 > _o 3 c > > m 3 3 0 m '> N N ` o � p N N ` '` N 7 '` '` N N p m > C z z _ O U _ z z _ _ z x _ _ �n z z >- vi L Q Oo O O N O OO N O O w 0 ON 0N N N N 0 O O O 0 �N c-I jaj O O m j C c > ` N M r > > 0 OO N aj ? N V1 N > N > 0mo 3 U m ° 3 c c c Yn Yn > u j u o u v v v m v v m . = a o a m > u > 3 u v a t U v o21 m 0 v U U v o 0 5; a; t 'E u a t c Q ova o m a aD a m •cCc .mV.�-1I l0Z3 ov oo --� (o r o n 12 > U 0 o o z . m O 0) m oO O0 @ ym 0) 0 moO O O O0) 0) O0) V V oo oo MO vNnri N V V m C _O = N m E = N m m OI C = L J ra U � Y C N O E C ° Y O D ECL c x t! p u N C U x C O N u U Q U C C C ob N C O! u w =uE va = cm Od m uDuD ' ? c-Di E E EE Eo aio nmi O ° ° ° ^ � 0 Q o ° = x =ouao o u E E oO Cm ° 0 - z u ' o - Iz o : c Eu ¢ta m u mr U° m > Index of Interested Parties Tustin Home Owners Association/Property Management Companies List c n! C m J T 0 m T c on O -E T m m N O fa E N O O E = E y m c v c w m 3 c m E c v m c LL u °i c m v c r m m c m m o m o m a v o a U ° ° m v m C1 t c c c > LL o m O > ^ = O m o = m° T m° = t c T E m c v m a v _ N t m N N Y } E T U N U L m 0 m 01 �' c C 01 m r 01 t bD C m ° m J J O LL N t m m m m a m a O m p O m m m m _N N m O a a Y V1 V1 Y x Q Q Y Q V1 U Q U } p V1 U Q V1 � > r O O 0 M 0 M p M ap M M N V/ NrnU NON N N Ol O O O Om m0 0 0omrn � � mmaUmmOrnmmmaoOmrn ArnN QmOmNma ° �° amOOmOmU O �0 ° U wM = W N m N U U a ( N N N a > E m o nj C p � m C C nj C C L C C m C C C C C p C m c m nj C C C C nj nj C C C C C �a Q C nj nj o > j s o m o > > j °�° 'o Y Y Y Y Y Y c Y v c o :c :c c c m Y Y Y O 3 :c c c a r U m n U r r �° ° Q, E c E v E v E °' a o ° a E w W W c m c m °�° v E E T o c v m aci ' c v c c E m " c `c w E m J m o' a m E a E m V c v v m m u o T c v m m E > a m m °' `° c m o a v m a c m aci 3 c E m C u c w c u atv u O E a m c omn w : 'u c O m v — v Q m c m v E � c E a � O v a 3 E p m n a O m o v E > YQl m y m y aci g m m o. f6 m m \ a a p o c c u o E m O cc o 3 u : v m T m_0 Q.'- -P c m O` to T m U T U d V�1 m U U T.0 O "p Q T c Q m m U U bvU - c � N m U O W c t c o m v u c Cw c at o c m m e u c m e ° o = v O C Q 2 o „ c c S ° a° a m o > ° v E w o a ° o c ovn a :� m c ° o .m > o o T a a T c c� ai7 m m N u 2 u p_Y c m '^ in 'u 'E E 2 0 12tuna m v u N Q Q a o mo->m u p O u 3 v uYO a o a a E u > o LL a o a m a 0. m u a 'o -` o ° a T T m v E u a m v a o r O T a� v "' 'c ° o O u v ° p D u J a t u a > .�Q ° O O ° = = ° O p . E m O E U Q u m v u O u v m u u m E u ° o u u 'c O w u E ' v ` v m a o Q Q v 0 3 QO O 'c o ° E E o 'u c a o m Q O c O m E O E m c o c O O O aci " x0 m O c o x w p E x p E v u o QO Q °'z v Q Q c c E O E a c 6 x o p "O Q m O Q x b u r N E u EO c U 0 c x O m O m x E o " x U - v > U` in u ., u O = O -p in m v > E U m N U Q a Q " m O m - 0 Y v1 m x a x x O — c O O O m O T T m -O Y a \ a > = O! fa U r Q C yj w C ° Q J J = v c U m x O C T O N Y O U U U '? a= C v L O y N U 0 m m m o - o E m � > U o m .2 m a Y 3 m c 3 3 v m N o 6 ° v v v o m 4 v v E v a m 3 v E E v c m c m O v a m-p ` E p 3 > r v a s m a) s o m x v m m m > > °i ° m +m' E N o m = u v m c m c c c E E E � a m m ° m o 0 0 w e ° v O m m m m m m o 0 o v c v 0 0 Q Q Q a` Q m m m m m` m` m U U U U w w w w C7 C7 (D � �° �° � : � r a a a a a a a C � C T o O a O N 3 a o m o E c t E 6 ° T ° °U T ° L C U 6 t "O N N C E N L YO ° E m° E n m r o x i r r m o v o v `c c m o v �_ o c m y Ca v v u = N T w C m C in T to C m m t6 T t6 N t6 C O`a Y U O`a u m C m O c != N m o m C O m C O m m J "O O N C O m ro N E .m N t m N FC 0 m m Z V1 m X m U 0 Y Y Q D U Q m m m O r Y V1 Y V1 x m m N N N O00 N M M M Ol M Ol O N ONO U u m mU m U m Q ^ l0 Q ^ l0 Q N U mw Q ^ M m M mm mQ ry m m r O 0 mrnm M m M M M M 0) 0) 0) 0) 0) 0) 0) l0 rn - rn U rn " rn v U u U a 0) 0)a a Q Q a a v U a a a = a Q a = a Q c 'i a = a c Q a c Q Q > U Q Q Q o U o U U o U U U o m E Q U U m a m a a C a a U N N Y C t N to C m N C ba N C N C N t6 C N t6 C N O m t t6 C N C N j > > > > -m O > > > N m C > t6 J m > m12 > J > m> m J > t6 JS V > m C �Ca O > J > Q z r z r r r U — z Q �n r a O r — �n r �n r �n Q �n U r T c m a i, O v 3' at +� c r oa c m c u p U E c c m m m v c c - v o a E cm E ar p ar o U c E c E v m m� v c m 01 E w ° a o >, a c E E �,c�7 °m° v p m 0 v °m° c v c �n m U c g m c a' Ewcw T oa v, c _ ° Q a .� o m e a T ¢ a m 01 > E m c E aT C >, O. N t6 N bva C m m C C E E T m m O >,to O ° \ U T m N N C C w a! p c Q E Q v a m T c m o� E >' O m U 3 Q o >, T om, o v o " " 'u v u m c E c v c o m v o °- E c v f6 a T m v m ° m c T a O m .� a o.m c c c a p C m o 'a — a a a o` � a u —u O w 'u v °i 'u >, r O O O 4 m m v c 'U o Q 2 m a T E N Q o o U N O a o a °- m an d 'U c 2 ° U ai a E u E o v a c '.' o u >. O 2 a 3 C o m ,m m m o u = 0 `° m` p E > c Q o r°pa a C Q a Y c o ° E 'm o a, O ° a c Em u o o o a a o E ° w0a �_ o u m > m O o 'u c = a cw m a" a" a" Y a a E c v a o o_u 'E EJ O! u YO"° C �, 2 x j \ E U E o C O u 3 o" m Y O u N m Y Y Y U 'E 2 bO p c U 2 O a Y Q o u T.o c° m C E a .Q v a "°O O a QO O 3 ` 'p \u Q m0 � � u Q m a o 'v°` E m v O O c O u Q 0 � E E E v O E O v E o > w ¢ u a E a x E o c o x ° a r O x u t x o v m U ` m aLL ° o E o C u m c m 3 c c E > O x 3 - o 0 0 o a ° u - a c o > E o ov v u O ma m o E u v x m — U U U w v o-¢ O Q O — u u — O a O C m N N u U O \ U Q U >'p Q m C O U E O — = Y C N ° > U L L L L v m 0 O m ° m m N c N x U O Q m O Y C7 C7 'm c 0 E C "O "O 'O p Q '° c c c c c 3 r—ma r—ma m ry m > > u v u = O U , u. v v > x u 0 o v v o v m — = v 0 0 0 o m m °p ° ° m ° x 3 3 > o o m m o a a U U LL LL 0 0 0 a a r > > > m c [2 ` m = u u u u 0 o = v 0 m E E - x '^ c c c c c c c c c c c c c c c c c c c c c c m > > m m m m t6 t6 t6 t6 t6 N N N L L N T TJ J J J J J J J J J J J J J J J J J J J J m N N 7n r r r r r r r r r r r r r r r r r r r r r r r r > > > >> > T m L m bmU p E m U m > O m x > m ._ m � o � O o ol N 00 N O O O O O O 0 0 mm mmmm x m `p U U a U U U U U U LL C N N m c c c c c c by Y C +' a+ 'a+ 'a+ 'a+ 'Z- 3 3 +> > N m C 2 E m T m by � m m m C C O U 3 c v c c ox m m E E E E Y O" N m v N N N d U O` >— 'UOC bm m m bm m 2 m N bA cm m 0 U O m " " " O .p U O t m v N v N C c u u 0 0 0 0 0 .? c 0 O \a` a aa c F m u a u U 0 0 m v O , N p Ea QO v p ., u v 3 x c_ = v c 0 '- o E > _�U m -6 mu m x x o a O t v C7 H -O O m m c E c r°no c c f0 v O Ul j j t > > � � � U x H H in H APPENDIX F REFERENCES This page intentionally left blank. F-2 REFERENCES The data used for the completion of this Housing Element comes from a variety of sources. These include,but are not limited to: 1. 2010,2014,and 2020 Census 2. American Community Survey 3. Regional Analysis of Impediments to Fair Housing(AI) 4. California Department of Housing and Community Development(HCD) 5. California Department of Finance (DOF) 6. California Employment Development Department (EDD); 7. Point-in-Time Homeless Census by the Regional Task Force on the Homeless,2019 8. California Employment Development Division Occupational Wage data, 2020 9. Department of Housing and Urban Development, Comprehensive Housing Affordability Strategy (CHAS),2013-2017 10. City of Tustin,Zoning Ordinance 11. City of Tustin,General Plan,as amended 12. Tustin Legacy Specific Plan 13. City of Tustin Consolidated Plan 14. City of Tustin Consolidated Annual Performance and Evaluation Report, The data sources represent the best data available at the time this Housing Element Update was prepared. The original source documents contain the assumptions and methods used to compile the data. A. Documents 1. 2010 Census Report. U.S. Department of Commerce,Bureau of the Census. 2. 2014 Census Report. U.S. Department of Commerce,Bureau of the Census. 3. U.S. Census Bureau,American Community Survey,2014-2018 Five-Year Estimates 4. Comprehensive Housing Affordability Strategy for Fiscal Years 2007-2008 to 2017-2018,David Paul Rosen&Associates (DRA). CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 F-3 5. Tustin Legacy Specific Plan,Adopted February 2003,Amendments through November 2014. 6. Downtown Commercial Core Specific Plan,Adopted July 2018. 7. East Tustin Specific Plan,Adopted March 1986,Amendments through November 1997. 8. Pacific Center East Specific Plan,Adopted December 1990,Amendments through April 2011. 9. Red Hill Avenue Specific Plan,Adopted November 2018. 10. California State Department of Finance,2021,E-5 Population and Housing Estimates. 11. Orange County Projections 2018 Modified, Center for Demographic Research at California State University,Fullerton. 12. Southern California Association of Governments, Regional Housing Needs Assessment,2021. 13. Southern California Association of Governments,Local Profile for the City of Tustin,2019. 14. U.S. Department of Housing, Comprehensive Housing Affordability Strategy (CHAS),2013-2017 15. City of Tustin,Zoning Ordinance. 16. City of Tustin,General Plan,as amended through November 2018. 17. City of Tustin 2020-2025 Consolidated Plan. 18. City of Tustin Comprehensive Annual Financial Report For the Year Ended June 30,2020. 19. City of Tustin 2020-2045 Five Year Consolidated Plan,2020-2021 Annual Action Plan. 20. Fourth Five-Year Implementation Plan for The Town Center and South Central Redevelopment Project Areas (FY 2010-2011 to 2014-2015),Tustin Community Redevelopment Agency,October 2010. 21. State of California,Department of Housing and Community Development, Website. 22. Orange County Department of Education,Division or School and Community Services,McKinney-Vento Homeless Education Assistance Act, 2006-07. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 F-4 23. 2021 State Income Limits,State Department of Housing and Community Development. 24. Marshall&Swift 25. State of California Government Code Sections 65580 et seq. 26. California Department of Housing and Community Development, Affirmatively Furthering Fair Housing in California 27. 2020 Orange County Analysis of Impediments CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2021 F-5